To whom it may concern,
I. WHO ARE WE?
The operator is the company NGCC s. r. o., with registered office at Klincová 37, 821 08 Bratislava, registered in the Commercial Register maintained by the District Court of Bratislava I, Department: Sro, Insert number: 58515/B, ID: 44746920, VAT number: 2022827961 (hereinafter also referred to as "NGCC" or "operator ").
II. WHAT ARE OUR CONTACTS?
III. WHERE DO WE COLLECT YOUR PERSONAL DATA?
In general, you can visit the website without providing us with information about your identity or without revealing any information about yourself. Our Internet servers collect IP addresses for IT reasons that allow you to connect to our platform and provide you with our services.
IV. WHAT DO WE USE THIS INFORMATION ABOUT YOU FOR (PURPOSES) AND ON WHAT LEGAL BASIS?
Data subject, collected data, purposes of collection, legal basis, retention period
Website visitor, IP address, domain name, version of your browser and operating system, operational data, web protocols, identification of web sessions, information about the default language in which the user uses service management tools, legitimate interest in measuring use and improving the content of the website (Art. 6 paragraph 1 letter f) GDPR) after logging out of the website, the data is deleted
Contact person, statutory body, representative of the service customer, common contact and identification data in the scope of title, first name, last name, job position, employer identification data, telephone number, e-mail address, Information resulting from the commercial register or other publicly available register in the case of members of statutory bodies and control bodies in the scope, data of the authorized person and the person signed on the power of attorney in the scope of name, surname, date of birth, residence address, type of identification document of the signed persons (in the case of an official certificate of power of attorney) in the case of representing the supplier on the basis of a power of attorney, any other personal data, as long as their processing is necessary for the realization of rights and obligations arising from supply contracts and for other purposes according to these protection conditions. Fulfillment of the contract. This is the exercise of rights and obligations from the contractual relationship between NGCC and customers. Fulfillment of our obligations arising from valid legal regulations. It may happen that we process your personal data in order to fulfill our legal obligation, or to comply with the decision of the relevant public authority or court (i.e. keeping registry records during retention periods, etc.). Effective communication and ensuring contractual activities. Marketing purposes. We may also process your personal data for the purpose of sending newsletters and alerts, surveys or other direct marketing communications regarding various NGCC services and products. Dealing with the agenda of the rights of affected persons. We will process your personal data if you contact us as a data subject and exercise your rights against us arising from regulations on the protection of personal data. Exercise and defense of legal claims. We process your personal data even if we are a party to a dispute led by us or against us. pre-contractual relations and performance of the contract (Article 6 paragraph 1 letter b) GDPR) fulfillment of legal obligations according to special regulations and legitimate interest of the operator (Article 6 paragraph 1 letter f) GDPR). legitimate interest in ensuring effective communication and fulfillment of contractual obligations (Article 6(1)(f) GDPR). your consent to the processing of personal data (Article 6(1)(a) GDPR). fulfillment of the legal obligation of the operator (Article 6 paragraph 1 letter b) GDPR). the legitimate interest of NGCC, namely to protect the good name, property interests or financial stability of NGCC (Article 6(1)(f) GDPR). As a rule, 10 years from the date of expiry of the obligation-legal relationship, if a special regulation does not require the retention of data for a longer period.
V. COOKIES POLICY
Microsoft Internet Explorer:
VI. INSTRUCTION ON OBLIGATION OR VOLUNTARINESS TO PROVIDE REQUIRED PERSONAL DATA:
In the event that the legal basis for the processing of your personal data is the fulfillment of our legal obligation pursuant to Article 6 par. 1 letter c) GDPR and you refuse to provide us with your personal data, this may lead to damage for which we can claim compensation from you (e.g. if a sanction were imposed on us in causal connection with the failure to fulfill our obligation). In the event that the legal basis is for the processing of your personal data, entering into or fulfilling a contractual relationship and you refuse to provide us with your personal data, this may lead to the failure of the possibility to enter into a binding contractual legal relationship with NGCC. In the event that the legal basis for the processing of your personal data is consent to the processing according of article 6 par. 1 letter a) GDPR, you can revoke it at any time, while you are entitled to use the same method in which you gave us your consent. We never condition the granting of consent to the processing of personal data for the required purposes on the possibility of entering into a contractual relationship with us. In the event that the legal basis for processing your personal data is the preponderance of our legitimate interests and we use the legal basis for processing your personal data according to Article 6 par. 1 letter f) GDPR, you are obliged to tolerate this processing, but you have the right to object to it. You will learn more about this right in the special section below. In the event that the legal basis for the processing of your personal data is the performance of a task carried out in the public interest according to Art. 6 par. 1 letter e) GDPR, we are authorized to process your personal data under the conditions specified in this document.
VII. RECIPIENTS OF PERSONAL DATA:
Beneficiaries mainly include (i) external companies providing services for the development and support of internal systems, hosting providers, data center service providers, cloud service providers, (ii) delivery companies and companies providing courier services, (iv) law firms, courts and enforcement agencies involved in the process of enforcing our claim against you in the event that you do not fulfill your monetary obligations due to NGCC and do not respond positively to our offer of an out-of-court settlement. Other persons who come into contact with your personal data are NGCC employees who are regularly trained on procedures for legal and secure processing of your personal data. All NGCC employees are legally bound to maintain the confidentiality of your personal data. Our personal data protection coordinator will provide you with more detailed information about our current recipients (including intermediaries) at any time upon request. In the case of intermediaries, NGCC ensured an increase in legal guarantees for the protection of your personal data by concluding a personal data processing agreement (DPA) in accordance with Art. 28 par. 3 GDPR. We are also obliged to provide your personal data to authorized public authorities in the event of the exercise of their legal authorizations according to relevant special laws (e.g. police investigations, the Office for Personal Data Protection, courts, etc.), which, however, do not have the status of recipients in the sense of the GDPR.
VIII. WEBSITE USERS 16 YEARS OF AGE AND UNDER
If you are under 16 years of age, please ask your parents or other legal representatives for consent before providing us with any personal data. Without granting such consent, you are not authorized to provide us with your personal data.
IX. TRANSFER TO THIRD COUNTRIES:
We do not transfer your personal data to any third country outside the EU/EEA. However, in the event of any possible transfer to a third country outside the EU/EEA, we guarantee that we have ensured that adequate guarantees in Art. 44 and seq. GDPR. Some non-EEA countries have been approved by the European Commission as providing substantially equivalent protection under EU personal data protection legislation, and therefore no additional safeguards are required for the transfer of personal data to these jurisdictions (see the full list here http://ec .europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm).In countries that have not obtained this approval (e.g. Russia), we will, if necessary, require either your consent to the transfer or the transfer will take place in accordance with standard terms and conditions approved by the European Commission, which impose the same data protection obligations directly on the recipient, unless the relevant data protection legislation allows this transfer to take place without such formalities.
X. PROFILING AND AUTOMATIC DECISION-MAKING:
No, there is no profiling or automated decision making at NGCC or any of its intermediaries.
XI. RIGHTS OF THE PERSONS CONCERNED:
According to applicable data protection legislation, you have the following rights as a data subject:
- a) Right of access – you have the right to be provided with a copy of the personal data we hold about you, as well as information on how we use your personal data. In most cases, your personal data will be provided to you in written document form, unless otherwise requested by you. If you have requested the provision of this information by electronic means, it will be provided to you electronically if technically possible.
- b) Right to rectification – we take reasonable measures to ensure the accuracy, completeness and timeliness of the information we have about you. If you believe that the data we hold is inaccurate, incomplete or out of date, please do not hesitate to ask us to correct, update or supplement this information.
- c) The right to erasure - in certain circumstances you have the right to ask us to erase your personal data, for example, if the personal data we have collected about you is no longer necessary to fulfill the original purpose of processing or if you revoke your consent to processing. However, your right must be assessed in light of all the relevant circumstances. For example, we may have certain legal and regulatory obligations which mean that we will not be able to comply with your request.
- d) The right to restrict processing – under certain circumstances, you are entitled to ask us to stop using your personal information. These are, for example, cases when you think that the personal information we have about you may be inaccurate or when you think that we no longer need to use your personal data.
- e) The right to data portability - in certain circumstances, you have the right to ask us to transfer the personal data you have provided to us to another third party of your choice.
- f) Right to object – you have the right to object to data processing based on our legitimate interests. If we do not have a compelling legitimate reason for processing and you file an objection, we will not process your personal data further.
- g) Rights related to automated decision-making – you have the right to refuse automated decision-making, including profiling, which results in a legal or similar significant consequence for you.
- h) The right to withdraw consent – in cases where your consent to the processing of personal data has been granted, you have the right to withdraw your consent to the further use of your personal data.
- i) The right to file a complaint with the supervisory authority or seek legal protection - as a data subject, you also have the right to file a complaint with the supervisory authority, which is the Personal Data Protection Office of the Slovak Republic, at any time (more information can be found on the website (gov.sk) or file a claim with the competent court.
How and where to submit your request? Each request for the exercise of the right of the data subject under the GDPR can be made (i) on the basis of a written and hand-signed request sent to the address of the headquarters of NGCC to the personal data protection coordinator, (ii) by e-mail to e- to NGCC's email address with a trusted electronic signature, (iii) in person at NGCC's headquarters or (iv) in any other way. This procedure does not affect your right to revoke your consent to the processing of personal data, which you can always revoke as easily as you granted it (e.g. if you granted consent electronically, you can always revoke it by e-mail or application without the need to send a written request to the address of the NGCC headquarters). Identification data (for identity verification) or what purposes and data the request relates to. In the case of overly general requests, we have to ask for clarification. We would like to inform you that when processing your request for the exercise of the right of the data subject according to the GDPR and other relevant legal regulations for the protection of personal data, we may ask you for a reliable verification of your identity, especially if you will request the exercise of your right in a way other than a written letter with a handwritten signature, an electronic mail with a trusted electronic signature, or in person at the NGCC headquarters (i.e., for example, in cases of ordinary e-mail requests or phone calls). How and when will your request be processed? Each of your requests for the exercise of the rights of the affected person delivered to the NGCC will be individually and competently assessed, while we will always inform you of the result no later than one (1) month after receiving the request. The processing of a request connected with the exercise of the data subject's right under the GDPR and other relevant legislation on the protection of personal data is free of charge. If your request is clearly unfounded or disproportionate, especially because it is repeated, we are entitled to charge a reasonable fee that takes into account administrative costs associated with providing the required information. In the case of repeated requests to provide copies of processed personal data, we reserve the right to charge a reasonable fee for administrative costs for this reason. The GDPR establishes general conditions for the exercise of your individual rights. However, their existence does not automatically mean that we will comply with them when exercising individual rights, as exceptions may also apply in a specific case, or some rights are linked to specific conditions that may not be met in every case. We will always deal with and examine your request regarding a specific right from the point of view of legislation and our internal policy for handling data subject complaints. In the event that we do not handle your request for the exercise of the data subject's right according to your opinion in accordance with the GDPR, you have the option to submit complaint to the supervisory authority or apply a judicial remedy directly to the relevant court. If the NGCC is not competent to assess your request for the exercise of the right of the person concerned, your request will be forwarded to the relevant operator without delay.
XII. CHANGE OF TERMS:
The information that we are obliged to provide you with regard to our processing of personal data may change or cease to be up-to-date. NGCC therefore regularly revises and updates this document. The current version is always available on the website.
This version was issued on 18/04/2022.