Information on the processing of personal data of the person concerned
This document contains information on the processing of personal data of data subjects who are clients of the company Promiseo s.r.o. or other persons using the company’s website (hereinafter the “Data Subject”).
1. Controller
1.1 The controller is the company Promiseo s.r.o., registered seat: Jesenského 1601/25, 040 01 Košice – Staré Mesto borough, Company ID No.: 44 930 747, registered in the Commercial Register of the Municipal Court Košice, Section Sro, Insert No. 24315/V (hereinafter the “Promiseo”). The contact person of Promiseo is Ivana Mirossayová, phone: +421 905 686 721, e-mail: ivana.mirossayova@promiseo.com.
2. Purpose of Personal Data Processing
2.1 The purpose of processing personal data of the Data Subject is:
2.1.1 newsletter subscription – 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 opening a training session or a job vacancy (hereinafter the “Newsletter”).
2.1.2 contact form – communication of the request addressed by the Data Subject to Promiseo (hereinafter the “Contact Form”).
2.1.3 Registration in the applicant database – the applicant grants consent for inclusion in the database of job applicants at PROMISEO for a period of 3 months or 2 years.
3. Scope of Processed Personal Data
3.1 The scope of personal data processed by Promiseo relating to the Data Subject is specific depending on the particular purpose of personal data processing defined in Article 2 of this document.
3.2 For the Newsletter purpose, Promiseo processes the Data Subject’s personal data in the scope of: e-mail address.
3.3 For the Contact Form purpose, Promiseo processes the Data Subject’s personal data in the scope of: name, e-mail address, possibly telephone number and the business name of the company on whose behalf the Data Subject contacts Promiseo.
4. Legal Basis for Personal Data Processing
4.1 The legal basis for the processing of personal data of the Data Subject by Promiseo is specific depending on the particular purpose of personal data processing defined in Article 2 of this document.
4.2 For the Newsletter purpose, Promiseo processes the personal data of the Data Subject on the legal basis of the Data Subject’s consent pursuant to Art. 6(1)(a) GDPR. The Data Subject expressed their consent by entering and submitting their e-mail address in the designated section on the Promiseo website.
4.3 For the Contact Form purpose, Promiseo processes the personal data of the Data Subject on the legal basis of the Data Subject’s consent pursuant to Art. 6(1)(a) GDPR. The Data Subject expressed their consent by entering and submitting their personal data in the designated section on the Promiseo website.
5. Recipients or Categories of Recipients of Personal Data
5.1 In processing personal data, Promiseo uses the services of other companies (processors) that process personal data on behalf of Promiseo. Promiseo does so in compliance with the conditions under Art. 28 GDPR, solely on the basis of a written contract and only after ensuring that the processor meets all technical and organizational requirements for personal data processing.
5.2 Promiseo processes e-mail addresses via a tool provided by 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 disclose the Data Subject’s personal data to any other third parties.
5.4 Promiseo does not publish the Data Subject’s personal data.
6. Transfer of Personal Data to Third Countries
6.1 As part of personal data processing by Promiseo’s processors, the transfer of the Data Subject’s personal data to third countries may occur, but always only under conditions ensuring secure transfers of personal data to third countries in accordance with GDPR, in a way that does not compromise the level of personal data protection of the Data Subject.
7. Personal Data Retention Period
7.1 The retention period for personal data of the Data Subject by Promiseo depends on the particular purpose of personal data processing defined in Article 2 of this document.
7.2 For the Newsletter purpose, Promiseo processes the Data Subject’s personal data for the period until the Data Subject unsubscribes from the Newsletter.
7.3 For the Contact Form purpose, Promiseo processes the Data Subject’s personal data for the period necessary to resolve the request of the Data Subject.
8. Automated Processing of Personal Data
8.1 The personal data of the Data Subject are not subject to automated decision-making, including profiling.
9. Additional Information on Personal Data Processing
9.1 Promiseo processes personal data of Data Subjects in accordance with GDPR, Act No. 18/2018 Coll. on Personal Data Protection and on amendments of certain acts, as amended and effective, as well as other relevant personal data protection legislation.
9.2 Promiseo processes the personal data of the Data Subject while maintaining a high standard of personal data protection. For this purpose, Promiseo has implemented technical, organizational, personnel and other security measures in accordance with Art. 32 GDPR.
10. Rights of the Data Subject
10.1 The Data Subject has the following rights under Art. 15 to Art. 21 and Art. 34 GDPR:
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 them are being processed. The Data Subject has the right to access these personal data. In particular, the Data Subject has the right to information about the purpose of processing, the retention period, to whom the data were provided, whether data were transferred to another country, etc.
10.1.2 Right to rectification of personal data: The Data Subject has the right to have Promiseo correct inaccurate personal data concerning them without undue delay. Considering the purpose of processing, the Data Subject has the right to have incomplete personal data completed.
10.1.3 Right to erasure (“right to be forgotten”): The Data Subject also has the right to obtain from Promiseo the erasure of personal data concerning them without undue delay, and Promiseo is obliged to erase such personal data without undue delay if one of the following reasons applies:
– the personal data are no longer necessary for the purpose for which they were collected or otherwise processed;
– the Data Subject withdraws the consent on which the processing is based and there is no other legal basis for processing;
– the Data Subject objects to the processing of personal data and there are no overriding legitimate grounds for the processing, or the Data Subject objects to processing for direct marketing purposes;
– the personal data have been processed unlawfully;
– the personal data must be erased to comply with a legal obligation under a legal regulation or an international treaty binding on the Slovak Republic; or
– the personal data were collected in relation to the offer of information society services.
10.1.4 Right to restriction of processing: The Data Subject has the right to have Promiseo restrict processing of personal data if:
– the Data Subject contests the accuracy of the personal data, for a period enabling Promiseo to verify the accuracy of the personal data;
– the processing is unlawful and the Data Subject opposes the erasure of the personal data and requests the restriction of their use instead;
– Promiseo no longer needs the personal data for the purpose of processing, but they are required by the Data Subject for the establishment, exercise or defence of legal claims; or
– the Data Subject has objected to processing pending verification of whether the legitimate grounds of Promiseo override those of the Data Subject.
The Data Subject whose data processing is restricted must be informed by Promiseo before the restriction is lifted.
10.1.5 Notification obligation regarding rectification or erasure of personal data or restriction of processing: Based on Art. 19 GDPR, Promiseo is obliged, if the Data Subject requests it, to inform the Data Subject about the recipients to whom Promiseo has notified rectification, erasure or restriction of personal data.
10.1.6 Right to data portability: The Data Subject has the right to receive the personal data concerning them, which they have provided to Promiseo, in a structured, commonly used and machine-readable format, and has the right to transmit those data to another controller.
10.1.7 Right to object to personal data processing: The Data Subject has the right to object, on grounds relating to their particular situation, to the processing of personal data concerning them where the processing is based on the necessity to perform a task carried out in the public interest or on the necessity for the purposes of legitimate interests of Promiseo or a third party, including profiling based on those provisions. Promiseo may no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing that override the interests, rights and freedoms of the Data Subject or for the establishment, exercise or defence of legal claims. The Data Subject has the right to object to the processing of personal data for direct marketing purposes, including profiling to the extent that it is related to direct marketing.
10.1.8 Right not to be subject to automated individual decision-making: The Data Subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.
10.1.9 Right to notification of a personal data breach: In the case of a personal data breach likely to result in a high risk to the rights and freedoms of natural persons, Promiseo shall notify the Data Subject of the personal data breach without undue delay.
10.1.10 Right to lodge a complaint: The Data Subject has the right to lodge a complaint or initiate proceedings with the supervisory authority, which is the Office for Personal Data Protection of the Slovak Republic, if the person is directly affected in their rights.
10.2 Provision of information to the Data Subject:
– Promiseo shall provide the Data Subject, upon request, with information under Art. 13, Art. 15 to Art. 21 and Art. 34 GDPR regarding the processing of their personal data. The information shall be provided in written or electronic form, usually in the same form in which the request was submitted. If requested by the Data Subject, Promiseo may also provide the information orally, provided the Data Subject proves their identity in another way. Promiseo shall provide cooperation to the Data Subject when exercising rights under Art. 15 to Art. 21 GDPR.
– Promiseo shall provide the information to the Data Subject within one month of receiving the request. Promiseo may extend this period by a further two months where necessary, taking into account the complexity and number of requests, even repeatedly. Promiseo shall inform the Data Subject of any such extension within one month of receiving the request, together with the reasons for the delay.
– Promiseo provides the information free of charge.
– If the Data Subject’s request is manifestly unfounded or excessive, in particular because of its repetitive nature, Promiseo may charge a reasonable fee considering the administrative costs of providing the information, notification, or taking the requested action, or may refuse to act on the request.
10.3 In exercising their rights or requesting any other information, the Data Subject may contact the Promiseo contact person listed in section 1.1 of this document.
Cookies
To ensure proper functioning of our website, we sometimes store small data files on your device, so-called cookies. This is common practice for most websites.
What are cookies?
A cookie is a small text file that a website stores on your computer or mobile device when you browse it. Thanks to this file, the website retains information about your actions and preferences (such as login name, language, font size and other display settings) for a certain period so that you do not have to re-enter them during your next visit or while browsing the site. Cookies do not contain harmful programs, malware or spyware.
How do we use cookies?
We use cookies to collect anonymous statistical information about visitors, store user settings, better tailor advertisements to visitor interests, and for essential website functionalities.
The website also uses persistent cookies stored in the end device for the purpose of ensuring information needed for web analytics and statistics (which pages were visited, how long they were viewed, date of individual visits, number of visits, usage intervals, etc.).
We provide cookie data to third parties (Facebook, Google) for web analytics and statistics and to create specific audiences for remarketing and personalized advertising.
Cookies are processed on the legal basis of the Data Subject’s consent in accordance with Art. 6(1)(a) GDPR. The Data Subject expressed their consent by clicking consent in the Promiseo pop-up window or by adjusting cookie settings on the Promiseo website.
The Data Subject may withdraw their consent for non-essential cookies through the cookie settings on the Promiseo website.
Information obtained from cookies is used by Promiseo through other companies (processors): Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, and Google Ireland Ltd., Gordon House, Barrow Street, Dublin, D04 E5W5, Dublin, Ireland. As part of personal data processing by Promiseo’s processors, the transfer of personal data of the Data Subject to third countries may occur, but always under the conditions of secure personal data transfer to third countries under GDPR, in a way that does not compromise the level of personal data protection of the Data Subject.
Additional information on personal data processing can be found in section 9 of this document. Information on the rights of the Data Subject can be found in section 10 of this document.
How to control cookies
You can control and/or delete cookies at your discretion – see details at aboutcookies.org. You can delete all cookies stored on your computer, and most browsers can be set to prevent cookies from being stored. However, in such a case, you may have to manually adjust some settings every time you visit a website, and some services and functionalities may not work properly.
Košice, 21 April 2020