PRIVACY POLICY (GDPR)

(valid from 25 May 2018)

The Policy is drawn up in accordance with Act No. 18/2018 Coll. on the Protection of Personal Data (hereinafter referred to as the "Act") and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter referred to as the "GDPR").

The purpose of this policy is to provide you with information about who processes your personal data, why, how, to whom it is provided, what rights you have under the Act and the GDPR Regulation. 

Subject (controller):

1) We collect the following information about you:

In order to conclude a mutual business relationship, we need to process the following information:

• the name of the company (or the name or first and last name of the person),
• address of the registered office or residence, billing data (ID number, VAT number, VAT number, account number),
• the name and surname of the contact person, his/her job title,
• telephone number, e-mail address,
• or any other additional data provided by the buyer and necessary for the fulfilment of the business relationship.

2) Purpose of processing personal data:

The legal basis for the processing of your personal data is one of the following:

1. the processing is necessary for the performance of a contract, the fulfilment of your orders (Article 6(1)(b) of the Regulation);
2. the processing is necessary for compliance with a legal obligation of the subject (Article 6(1)(c) of the Regulation), e.g. compliance with the Civil Code, the Accountancy Act, etc.
3. processing is necessary for the purposes of legitimate interests (Article 6(1)(f)), e.g. sending you information about our promotions, new products related to your previous orders, i.e. based on a previous business relationship.
4. You have consented to the processing of your personal data for one or more specific purposes (Article 6(1)(a) of the Regulation). You are entitled to withdraw this consent at any time.

3) Recipient of your personal data:

In terms of the law, we have the status of a controller, in connection with our activities we make your data available to another entity - an intermediary (external accountant), on the basis of a concluded intermediary contract.

Your personal data will not be disclosed to any other entity, except in cases where the seller is obliged to provide such data to public authorities in accordance with generally applicable legislation.

4) Duration of processing of your personal data:

We do not retain your personal data for longer than is necessary for the purpose of processing.

1. If we process your data on a legal basis - performance of a contract, we process it for the entire duration of the contractual relationship between us. However, as we also have to comply with obligations arising for us from tax and accounting legislation, we are entitled to continue to process this data according to the time limits set by the relevant legislation.
2. If we process your data on a legal basis - our legitimate interest or the legitimate interest of third parties, we process your personal data for the duration of the legitimate interest.
3. If we process your data on a legal basis - your consent, we process your personal data for the period for which you have given us consent to process your personal data or for the duration of the purpose of the processing.

5) Your rights related to the processing of personal data:

a. Right of access to personal data - you are entitled to ask us to confirm whether we are processing your personal data. You have the right to be informed of this:

• why we are processing your personal data (purpose),
• what data we are processing about you (category),
• to whom we may disclose your personal data (data recipients),
• how long we will keep your personal data,
• you have the right to request the rectification of your personal data, its erasure as well as the restriction of its processing, you have the possibility to object to the processing of your personal data,
• you have the right to know where your personal data comes from (source information), unless you have provided us with the information,
• the right to file a petition for the initiation of personal data protection proceedings under the law or the right to file a complaint with the Office for Personal Data Protection of the Slovak Republic,
• the right to know whether we use automated individual decision-making, including profiling,
• you have the right to know whether we transfer your data to a third country or an international organisation.

The right of access also means the possibility for you to obtain the personal data we process about you. We may provide you with a copy of the personal data we process about you. However, we may charge you a reasonable administrative fee if you repeatedly request the provision of your personal data.

b. Right to rectification of personal data - you are entitled to ask us to rectify the personal data we hold about you, including to complete it.

c. the right to erasure of personal data (the so-called right to be forgotten) - you have the right to erasure of personal data relating to you if one of the following grounds is met:

• your personal data is no longer necessary for the purpose for which we collected or otherwise processed it,
• you have withdrawn your consent to the processing of the personal data on the basis of which we process it and there is no legal basis for further processing,
• you object to the processing of personal data which is carried out on the legal basis of public interest or legitimate interest and there are no overriding legitimate grounds for the processing,
• your personal data have been unlawfully processed,
• your personal data must be erased because it is necessary to comply with an obligation under Slovak or EU law

However, we may not comply with your request in light of the particular circumstances, if the processing of your personal data is necessary to:

• to comply with a legal obligation,
• to enforce our legal claim,
• archiving purposes, statistical purposes.

d. right to restriction of processing of personal data - you have the right to restrict the processing of personal data if any of the following grounds are met:

• during the period allowing us to verify the accuracy of your personal data, you challenge the accuracy of your personal data,
• the processing of your personal data is unlawful, you object to the erasure of your personal data and request restriction of the processing of your personal data instead of erasure,
• we no longer need your personal data for any of the processing purposes, or you need it to establish or exercise your legal claims,
• you object to the processing of your personal data until we have verified that our legitimate interests outweigh your legitimate interests.

e. right to data portability - you have the right to request the transfer of your personal data to another controller if we are processing your personal data for the performance of obligations under a contract between us or on the basis of your consent.

f. right to withdraw consent - where we process your personal data on the basis of your consent, you have the right to withdraw that consent at any time, including before the expiry of the period for which that consent was given

g. right to object - if you have grounds relating to your particular situation, you have the right to object to the processing of your personal data where the legal basis for such processing is our legitimate interest. However, if our legitimate interest overrides your personal interests, we may continue to process your personal data despite your objection. Furthermore, we are entitled to continue to process your personal data where this is necessary for the establishment, exercise or defence of our legal claims.

You have the opportunity to object to the processing of your personal data for direct marketing purposes. The objection also applies to the analysis of personal data (so-called profiling) that is carried out in connection with direct marketing. If you object to direct marketing, we will stop processing your personal data for this purpose as well as for the purpose of all types of direct marketing actions.

6) How to contact us:

If you have any questions about the processing of your personal data, you can contact us in relation to the processing of your personal data in writing or by email:

• to address: SADLON TECHNOLOGIES s.r.o., Nam. Dr. A. Schweitzera 171, 916 01 Stara Tura, Slovakia
• to e-mail: cfo@sadlon.tech

Thank you for your trust.

We treat the protection of your data responsibly and with respect.