Personal data protection

Principles of personal data processing for customers of Aledo.sk s.r.o. according to the GDPR

The aim of these Personal Data Processing Principles for customers of Aledo.sk s.r.o., ID:

is to provide customers with information about

• what personal data does Aledo.sk, as an administrator, process about natural persons when providing services and when visiting websites operated by Aledo.sk
  and contacts with potential customers

• for what purposes and for how long does Aledo.sk process these personal data in accordance with applicable legal regulations

• to whom and for what reason it can transfer them, and also inform about what rights natural persons have in connection with the processing of their personal data

These Principles relate to the processing of personal data of Aledo.sk customers and, as appropriate, their representatives or contact persons, users of Aledo.sk services, those interested in Aledo.sk services and visitors to websites operated by Aledo.sk, always within the scope of personal data corresponding to their position in relation to Aledo.sk

These Principles are effective from 08.06.2018 and are issued in accordance with Regulation (EU) 2016/679 on the protection of natural persons in the processing of personal data (“regulation” or “GDPR”) for the purpose of ensuring the information obligation of Aledo.sk as the administrator according to Art. 13 GDPR.

A. Category of personal data

Personal data is any information that relates to a natural person that Aledo.sk is able to identify. In connection with the provision of services, Aledo.sk may process the following categories of personal data

1. Basic personal identification data and address data

Such data are necessary for the conclusion and performance of the contract. It is mainly about:

• academic degree

• name and surname

• business name

• ID number, TIN

• address of registered office or place of business

• invoicing address

Aledo.sk s.r.o. with registered office at Za plavárňou 8955/17 , Žilina 010 08, Slovak Republic, ID number: 50 783 572, registered in the commercial register of the Žilina District Court, Department: Sro, Insert number: 67376/L 1

• identification data of the bill payer

• bank connection

2. Contact information

• contact phone number

• contact e-mail

• addresses for social networks (if logging in via Facebook or Gmail)

3. Data processed based on your consent

The processing of this data is necessary for the fulfillment of the contract or legal obligations or protection the processing of this data is necessary for the fulfillment of the contract or legal obligations or protection of the legitimate interests of Aledo.sk, as well as their processing, will enable Aledo.sk to improve services, focus on what customers are really interested in, and possibly inform customers about offers that are suitable for them. These data are processed only in case of consent and may be processed during the validity of this consent.

It is mainly about:

• data obtained through marketing surveys (they are processed by customers of Aledo.sk services on the basis of consent to the processing of personal data for business purposes)

• records of behavior on websites managed by Aledo.sk obtained from cookies if cookies are enabled in the web browser (they are processed to improve the operation of websites operated by Aledo.sk, internet advertising and in case of consent to the processing of personal data for business purposes, these data processed together with other personal data for this purpose).

B. Purposes, legal reasons and periods of personal data processing

The scope of processed data depends on the purpose of processing. For some purposes, it is possible to process data directly on the basis of the contract, the legitimate interest of Aledo.sk or on the basis of the law (without consent), for others only on the basis of consent.

1. Processing due to the fulfillment of the contract, fulfillment of legal obligations and due to the legitimate interests of Aledo.sk

The provision of personal data necessary for the performance of the contract, the fulfillment of Aledo.sk’s legal obligations and the protection of Aledo.sk’s legitimate interests is mandatory. Without providing personal data for these purposes, it would not be possible to provide services. The processing of personal data for these purposes does not require the consent of the person concerned by law. Processing for the purpose of fulfilling the contract and fulfilling legal obligations cannot be refused.

These are mainly the following basic sub-purposes:

• ensuring the operation and protection of electronic communication networks (fulfilment of the contract),

• provision of electronic communication services, payment transactions, provision of other services (contract performance),

• invoicing for services (performance of the contract),

– fulfillment of legal tax obligations (fulfilment of legal obligations),

Aledo.sk s.r.o. with registered office at Za plavárňou 8955/17 , Žilina 010 08, Slovak Republic, ID number: 50 783 572, registered in the commercial register of the District Court of Žilina, Department: Sro, Insert number: 67376/L 1

• purposes established by special laws for the needs of criminal proceedings and for the fulfillment of the obligation to cooperate with the Police of the Slovak Republic and other state authorities (fulfilment of legal obligations),

• data exchange between website operators and providers of electronic communications services to ensure connection and access to the website, for mutual invoicing (fulfilment of the contract),

• operation of camera and monitoring systems on the premises of Aledo.sk to prevent damages (legitimate interest of Aledo.sk),

• evaluation of the customer’s behavior when using the services and his payment ethics for the purpose of preventing claims arising, which may have an impact on Aledo.sk’s decisions on the terms of concluding further contracts with the customer, while the decision on whether or not to conclude further contracts does not take place automatically (the legitimate interest of the company Aledo.sk),

• collection of receivables from the customer and other customer disputes (legitimate interest),

• processes associated with customer identification (fulfilment of the contract),

• provision of evidence in the event of the need to defend the rights of Aledo.sk (legitimate interest of Aledo.sk),

• records of debtors (legitimate interest of Aledo.sk),

• records of misuse of the website and electronic communication services (legitimate interest of Aledo.sk).

Personal data for these activities are processed to the extent necessary for the fulfillment of these activities and for the time necessary to achieve them or for the time directly stipulated by legal regulations. After that, the personal data is deleted or anonymized. Basic periods for processing personal data are available below.

For customers of Aledo.sk’s services, Aledo.sk is authorized to process their basic personal, identification, contact data, service data and data from their communication with Aledo in the customer database if they have fulfilled all their obligations towards it. sk for a period of 10 years from the date of termination of the last contract with Aledo.sk.

In the case of negotiations between the company Aledo.sk and a potential customer on the conclusion of a contract, which was not completed by the conclusion of the contract, the company Aledo.sk is authorized to process the provided personal data for a period of 3 months from the relevant negotiation.

According to §76, the invoices issued by Aledo.sk are in accordance with Act no. 222/2004 Coll. about value added tax archived for 10 years from their issue. Due to the need to document the legal reason for issuing invoices, customer contracts are also archived for 10 years from the date of termination of the contract. The identification data required for the provision of the service from the customer’s identity card are processed by Aledo.sk in accordance with §19 of Act no. 297/2008 Coll. on certain measures serving to protect against the legalization of income from criminal activity and the financing of terrorism for a period of 10 years from the date of termination of the customer’s contract with Aledo.sk.

In order to fulfill this legal obligation, the company Aledo.sk keeps for a period of 10 years from the date of termination of the last service for the customer a copy of the identity cards with the information necessary for the provision of the service by the company Aledo.sk, while other data that are not necessary for the provision of the service are on copy of the license blacked out.

Camera recordings from stores and the premises of Aledo.sk and around the buildings of Aledo.sk are processed for a maximum period of 90 days from the date of acquisition of the camera recording.

2. Processing the data of customers of Aledo.sk services with the consent of Aledo.sk s.r.o. for business purposes.

Aledo.sk s.r.o. with registered office at Za plavárňou 8955/17, Žilina 010 08, Slovak Republic, ID number: 50 783 572, registered in the commercial register of the District Court of Žilina, Department: Sro, Insert number: 67376/L 1. We process the personal data of customers of Aledo.sk with with his consent for business purposes

With the consent for business purposes, the company Aledo.sk will, from the effective date of this Policy, process the customer’s personal data primarily for the creation of a suitable offer of products and services of the company Aledo.sk or third parties and in connection with addressing the customer, namely by phone, in writing, through any means of the Internet advertisements and in the form of electronic communication through contact data or service numbers. Therefore, Aledo.sk will also store data on customers who give this consent about their type of behavior when using the services of Aledo.sk and create and store anonymized behavioral analyses. All these activities are absolutely necessary to address customers with appropriate marketing offers.

The provision of consent for business purposes is voluntary and can be revoked by the customer at any time. This consent remains valid during the use of Aledo.sk services and for the next 3 years thereafter or until the customer revokes it. For business purposes, based on consent, all categories of data listed in section A of this document (except for signatures and copies of identification documents) may be processed, for the period during which the company Aledo.sk is authorized to record these data for the purpose of providing services, fulfilling legal obligations and the protection of their legitimate interests, but at the latest until the withdrawal of consent or until the expiration of a period of 3 years from the date of termination of the contract for the provision of services with the company Aledo.sk, unless the customer withdraws the consent earlier.

If the data subject withdraws his consent, this does not affect the processing of his personal data by Aledo.sk for other purposes and on the basis of other legal titles, in accordance with these personal data processing principles.

The customer of Aledo.sk, in the event that he allows the use of this service by users, confirms as part of granting consent to the processing of personal data for business purposes that he is authorized to grant consent regarding data relating to users of the service other than the customer.

3. Data processing of data subjects who have given consent to marketing contact via electronic contact or in personal contact with an employee of Aledo.sk

For entities that have given their consent to marketing outreach through electronic contact, the company Aledo.sk, with their consent, processes the contacts that the entity makes available to it for the purposes of marketing outreach with the Aledo.sk service offer for the period specified in the consent.

If this consent is granted through websites operated by Aledo.sk, together with these contacts, data from Aledo.sk cookies, which are placed on the websites on which this consent was granted, are processed together with these contacts, only if the subject has cookies enabled in the web browser.

4. Processing cookies from websites operated by Aledo.sk

If the subject has cookies enabled in his web browser, we process behavioral records about him from cookies placed on websites operated by Aledo.sk, for the purpose of ensuring better operation of Aledo.sk websites and for the purposes of Aledo.sk´s internet advertising.

C. Sharing of Personal Data with Other Administrators

The company Aledo.sk is, according to Act no. 250/2007 Coll. On consumer protection, for the purposes of protecting the rights and legally protected interests of sellers and consumers, authorized without consent to transfer identification data, data indicating the creditworthiness, payment morals and trustworthiness of the data subject to registers that serve to inform each other of sellers about the ability and willingness of consumers to fulfill their obligations.

This transfer also applies to relationships established as part of the data subject’s business or other self-employed activity. The company Aledo.sk is authorized to transfer personal data or allow access to it to the company ALIS Tech s.r.o., ID: 06728103, registered office at Purkyňova 649/127, Medlánky, 612 00 Brno, Czech Republic. The data subject hereby consents to the transfer of personal data to this company.

D. Categories of recipients of personal data

Aledo.sk uses the professional and specialized services of other entities to fulfill its contractual obligations. If these suppliers process personal data transferred by Aledo.sk, they have the status of personal data processors and process personal data only within the framework of instructions from Aledo.sk and may not use them otherwise.

This is mainly a provider of postal and transport delivery, debt collection, activities of experts, lawyers, auditors, IT system management, internet advertising or sales agency. Transfer and processing of personal data always takes place in accordance with applicable legislation.

The company Aledo.sk also transfers personal data to administrative bodies and offices designated by applicable legislation as part of the fulfillment of its legal obligations.

E. Method of personal data processing

Aledo.sk processes personal data manually and automatically. The Aledo.sk company keeps records of all activities, both manual and automated, that involve the processing of personal data.

F. Information on the rights of data subjects in connection with the processing of personal data

According to the regulation, if the data subject is an identifiable natural person for Aledo.sk and proves his identity to Aledo.sk, he has the following rights:

1, Right of access to personal data                                                                            

According to Art. 15 GDPR, the data subject will have the right to access personal data, which includes, on the one hand, the right to obtain from Aledo.sk:

• confirmation as to whether it processes personal data,

• information on the purposes of processing, categories of personal data concerned, recipients to whom personal data have been or will be made available, planned processing time, on the existence of the right to request from the administrator the correction or deletion of personal data relating to the data subject or to limit their processing or to raise an objection to this processing, about the right to file a complaint with the supervisory authority, about all available information about the source of personal data, unless it is obtained from the data subject, about the fact that automated decision-making takes place, including profiling, about suitable guarantees when transferring data outside the EU,

• in case the rights and freedoms of other persons of personal data are not adversely affected.

In the event of a repeated request, Aledo.sk will be entitled to charge a reasonable fee for a copy of personal data. The right to confirmation of the processing of personal data and to information can be exercised in writing to the address of the registered office of Aledo.sk

The right to a copy of personal data can be exercised at the head office of Aledo.sk at the address Za plavárňou 8955/17, 010 08, Žilina, under the condition of proving the eligibility of the above request.

2. The right to correct incorrect data

According to Art. 16 GDPR, the affected person has the right to correct inaccurate personal data processed by Aledo.sk. The customer of Aledo.sk is obliged to report changes to his personal data and to document that such a change has occurred.

At the same time, he is obliged to cooperate with Aledo.sk if it is found that the personal data it processes about him is not accurate. The repair will be carried out by Aledo.sk without unnecessary delay, but always taking into account the given technical possibilities. A request for the correction of personal data can be made at the head office of Aledo.sk at the address Za plavárňou 8955/17, 010 08, Žilina, on the condition that the eligibility of the said request is documented.

3. Right to erasure

According to Art. 17 GDPR, the affected person has the right to delete personal data concerning him, if the company Aledo.sk does not prove legitimate reasons for the processing of this personal data. If the data subject believes that his personal data has not been deleted, he can contact Aledo.sk in writing.

4. Right to restriction of processing

According to Art. 18 GDPR, the data subject has the right to limit processing until the complaint is resolved, if he denies the accuracy of personal data, the reasons for their processing or if he files an objection against their processing, in writing to the address of the registered office of Aledo.sk.

5. Right to notification of correction, deletion or restriction of processing

According to Art. 19 GDPR, the affected person has the right to be notified by Aledo.sk in case of correction, deletion or restriction of processing of personal data. If personal data is corrected or deleted, we will notify individual recipients, except where this proves impossible or requires disproportionate effort. Based on the data subject’s request, we can provide information about these recipients.

6. Right to portability of personal data

According to Art. 20 GDPR, the data subject has the right to the portability of data concerning him and which he has provided to the administrator, in a structured, commonly used and machine-readable format, and the right to request Aledo.sk to provide this data to another administrator.

If a data subject provides us with personal data as part of a service contract or on the basis of consent and their processing is carried out automatically, he has the right to receive such data from us in a structured, commonly used and machine-readable format. If it is technically possible, the data can also be transferred to the administrator designated by you, if the person acting for the relevant administrator is properly designated and can be authorized. If the exercise of this right could adversely affect the rights and freedoms of third parties, your request cannot be granted. The application can be made at the headquarters of Aledo.sk after delivery of a justified application.

7. The right to object to the processing of personal data

According to Art. 21 GDPR, the data subject will have the right to object to the processing of his personal data due to the legitimate interest of Aledo.sk. In the event that the Aledo.sk company does not prove that there is a serious legitimate reason for the processing that prevails over the interests or rights and freedoms of the person concerned, the Aledo.sk company will terminate the processing based on the objection without unnecessary delay. The objection can be sent in writing to the address of the registered office of Aledo.sk.

8. The right to withdraw consent to the processing of personal data

Consent to the processing of personal data for business purposes can be revoked at any time. The appeal must be made explicitly, comprehensibly and with a certain expression of will, either electronically to the email aledo@aledo.sk or at the head office of the Aledo.sk company at the address Za plavárňou 8955/17, 010 08, Žilina.

Consent to marketing communications granted for a specific electronic contact can be revoked at any time by email at aledo@aledo.sk or at the head office of Aledo.sk at Za plavárňou 8907/15, 010 08, Žilina. The processing of data from cookies can be prevented by setting the web browser.

9. Automated individual decision-making, including profiling

The person concerned has the right not to be the subject of any decision based exclusively on automated processing, including profiling, which would have legal effects for him or significantly affect him in a similar way. Aledo.sk states that it does not make automated decisions without the influence of human assessment with legal effects for data subjects.

10. The right to contact the The Office for Personal Data Protection of the Slovak Republic

Without prejudice to any other means of administrative or judicial protection, you have the right to file a complaint with a supervisory authority, in particular in the state of your habitual residence, place of employment or the place where the alleged violation occurred, if you believe that the processing of your personal data the GDPR is violated.

In the Slovak Republic, this supervisory authority is the The Office for Personal Data Protection of the Slovak Republic (https://dataprotection.gov.sk/uoou/). The supervisory authority where you file the complaint will inform you about the progress in resolving the complaint and its outcome.

11. Notification of personal data security breaches

The protection of your personal data is also ensured by the obligation of each administrator to notify you without undue delay of a breach of the security of your personal data, if it is likely that a certain case of breach will result in a high risk to your rights and freedoms. This information obligation is not required for the implementation of specified protective measures, or its fulfillment would require a disproportionate effort.