This document contains information about the processing of personal data of affected persons who are clients of the business company Promiseo s.r.o. or other persons who use the company’s website (hereinafter referred to as the “Data Subject”).

1. Operator

1.1 The operator is the commercial company Promiseo s.r.o., with its registered office at Jesenského 1601/25, 040 01 Košice – Staré Mesto district, ID number: 44 930 747, registered in the Commercial Register of the District Court of Košice I, section Sro, insert no. 24315/V (hereinafter referred to as “Promiseo”). The contact person for Promiseo is Veronika Ondirová, tel. no.: 0904 319 217, e-mail: veronika.ondirova@promiseo.com.

2. The purpose of personal data processing

2.1 The purpose of processing the Personal Data of the Data Subject is:

2.1.1 subscription to news (newsletter) – informing the Data Subject about new products/services or changes to products/services. The newsletter may also include direct marketing of products and services provided by Promiseo, such as the opening of a training or job position (hereinafter referred to as the “Newsletter“).

2.1.2 contact form – communication of the request that the Data Subject addressed to Promiseo (hereinafter referred to as the “Contact Form“).

3. Scope of processed personal data

3.1 The scope of processed personal data of the Data Subject by Promiseo is specific depending on the specific purpose of personal data processing specified in Article 2 of this document.

3.2 For the purpose of processing the Newsletter, Promiseo processes the Personal Data of the Affected Person in the scope of: e-mail address.

3.3 For the purpose of processing the Contact Form, Promiseo processes the Personal Data of the Affected Person in the scope of: name, e-mail address, or phone number and information on the trade name of the company on whose behalf the Affected Person contacts Promiseo.

4. Legal basis for personal data processing

4.1 The legal basis for processing the Personal Data of the Data Subject by Promiseo is specific depending on the specific purpose of the processing of personal data specified in Article 2 of this document.

4.2 For the purpose of processing the Newsletter, Promiseo processes the Personal Data of the Affected Person on the legal basis – the consent of the Affected Person in accordance with Art. 6 point 1, letter a) GDPR. The person concerned expressed his consent to the processing of his personal data by entering and sending his e-mail address in the reserved space on the Promiseo website.

4.3 For the purpose of processing the Contact Form, Promiseo processes the Personal Data of the Affected Person on the legal basis – the consent of the Affected Person in accordance with Art. 6 point 1, letter a) GDPR. The person concerned expressed his consent to the processing of his personal data by entering and sending his personal data in the reserved space on the Promiseo website.

5. Recipients or categories of recipients of personal data

5.1 When processing personal data, Promiseo uses the services of other companies (intermediaries) that process personal data on behalf of Promiseo. Promiseo does so in compliance with the conditions according to Art. 28 GDPR, only on the basis of a written contract and after making sure that the intermediary meets all technical and organizational requirements for processing personal data.

5.2 Promiseo processes e-mail addresses through Rocket Science Group LLC d/b/a Mailchimp, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, Georgia 30308.

5.3 Promiseo does not provide or make available the Personal Data of the Affected Person to any other third parties.

5.4 Promiseo does not disclose personal data of the Data Subject

6. Transfer of personal data to third countries

6.1 As part of the processing of personal data by Promiseo intermediaries, the Personal Data of the Affected Person may be transferred to third countries, but always only in compliance with the conditions for the safe transfer of personal data to third countries according to the GDPR, in such a way that the level of protection of the Personal Data of the Affected Person is not jeopardized.

7. Time of personal data processing

7.1 The period of processing of the Personal Data of the Affected Person by Promiseo is specific depending on the specific purpose of the processing of personal data specified in Article 2 of this document.

7.2 For the purpose of processing the Newsletter, Promiseo processes the Personal Data of the Affected Person until the Affected Person unsubscribes from the Newsletter.

7.3 For the purpose of processing the Contact Form, Promiseo processes the Personal Data of the Affected Person until the request of the Affected Person is resolved.

8. Automated processing of personal data

8.1 Personal data of the Data Subject are not subject to automated decision-making, including profiling.

9. Further information on the processing of personal data

9.1 Promiseo processes personal data of Affected Persons in accordance with the GDPR, in accordance with Act No. 18/2018 Coll. on the protection of personal data and on the amendment and supplementation of certain laws in the valid and effective wording, as well as with other relevant legal regulations on the protection of personal data.

9.2 Promiseo processes the personal data of the Affected Person in compliance with a high standard of personal data protection. For this purpose, Promiseo adopted technical, organizational, personnel and other security measures in accordance with Art. 32 GDPR.

10. Rights of the data subject

10.1 In accordance with the provisions of Art. 15 to Art. 21 and Art. 34 GDPR the following rights:

10.1.1 Right of access to personal data: The data subject has the right to obtain confirmation from Promiseo as to whether personal data concerning him or her are being processed. The data subject has the right to access this personal data. In particular, the affected person has the right to information about the purpose of processing, the period of processing, to whom the data was provided, whether it was transferred to another country, etc.

10.1.2 Right to rectification of personal data: The data subject has the right to have Promiseo correct incorrect personal data concerning him without undue delay. Taking into account the purpose of personal data processing, the Data Subject has the right to supplement incomplete personal data.

10.1.3 Right to erasure (right to be “forgotten”): The data subject also has the right to obtain
for Promiseo to delete personal data relating to it without undue delay, and it is obliged to delete personal data without undue delay if any of the following reasons are met:
– personal data are no longer necessary for the purpose for which they were obtained or otherwise processed;
– The person concerned revokes the consent on the basis of which the processing of personal data is carried out, and there is no other legal basis for the processing of personal data;
– The person concerned objects to the processing of personal data and there are no valid reasons for the processing of personal data or the person concerned objects to the processing of personal data for the purpose of direct marketing;
– personal data is processed illegally;
– personal data must be deleted in order to fulfill a legal obligation according to a legal regulation or an international treaty to which the Slovak Republic is bound; or
– and personal data obtained in connection with the offer of information society services.

10.1.4 Right to restriction of processing: The data subject has the right to have Promiseo restrict the processing of personal data if:
– The affected person objects to the correctness of the personal data, during the period allowing Promiseo to verify the correctness of the processed personal data;
– the processing of personal data is illegal and the Data Subject objects to the deletion of personal data and instead requests the restriction of their use;
– Promiseo no longer needs personal data for the purpose of processing personal data, but the data subject needs them to assert a legal claim; or
– The affected person objects to the processing of personal data, until it is verified whether the legitimate reasons on the part of Promiseo prevail over the legitimate reasons of the affected person.

Promiseo is obliged to inform the affected person whose processing of personal data will be restricted before the restriction of processing of personal data is cancelled.

10.1.5 Notification obligation in connection with the correction or deletion of personal data or restriction of processing: Based on the provisions of Art. 19 GDPR, if the Data Subject so requests, Promiseo is obliged to inform the Data Subject about recipients to whom Promiseo has notified the correction of personal data, deletion of personal data or limitation of processing of personal data.

10.1.6 Right to data portability: The data subject has the right to receive personal data relating to him and provided by Promiseo in a structured, commonly used and machine-readable format and has the right to transfer this personal data to another controller.

10.1.7 The right to object to the processing of personal data: The data subject has the right to object to the processing of his personal data for a reason relating to his specific situation carried out on a legal basis, on the grounds that the processing of personal data is necessary to fulfill a task carried out in the public interest or on the grounds that the processing is necessary for the purpose of the legitimate interests of Promiseo or a third party, including profiling based on these provisions. Promiseo may not further process personal data if it does not demonstrate the necessary legitimate interests for processing personal data that outweigh the rights or interests of the Data Subject, or grounds for asserting a legal claim. The person concerned has the right to object to the processing of personal data concerning him for the purpose of direct marketing, including profiling to the extent that it is related to direct marketing.

10.1.8 Right to object and automated individual decision-making: The data subject has the right not to be subject to a decision that is based solely on automated processing of personal data, including profiling, and which has legal effects that concern him or similarly significantly affect him.

10.1.9 The right to notify a breach of personal data protection: In the event of a breach of personal data protection that is likely to lead to a high risk for the rights and freedoms of natural persons, Promiseo will notify the Data Subject without undue delay of the breach of personal data protection.

10.1.10 The right to file a complaint: The affected person has the right to file a complaint or a proposal to initiate proceedings with the supervisory authority, which is the Office for Personal Data Protection, in the event that the person’s rights are directly affected.

10.2 Provision of information to the data subject:

– Promiseo will provide the Data Subject upon his/her request with information pursuant to Art. 13, Art. 15 to Art. 21 and Art. 34 GDPR, which relate to the processing of her personal data. Information will be provided in paper or electronic form, usually in the same form in which the application was submitted. If requested by the Affected Person, Promiseo can also provide information verbally, if the Affected Person proves his identity in another way. Promiseo when exercising rights under Art. 15 to Art. 21 GDPR will provide the Data Subject with cooperation.

– Promiseo will provide the Data Subject with information within one month of receiving the request. In justified cases, taking into account the complexity and number of requests, Promiseo can extend the stated deadline by another two months, even repeatedly. Promiseo informs the Data Subject of any such extension within one month of receiving the request, along with the reasons for the extension.

– Information is provided by Promiseo free of charge.

– If the request of the Affected Person is clearly unfounded or disproportionate, especially due to its recurring nature, Promiseo may demand a reasonable fee taking into account the administrative costs of providing information or a reasonable fee taking into account the administrative costs of notification or a reasonable fee taking into account the administrative costs of carrying out the requested action, or refuse to act based on request.

10.3 In the case of exercising their rights or requesting any other information, the Affected Person has the opportunity to contact the contact person of Promiseo, which is listed in point 1.1 of this document.

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