1. IDENTIFICATION OF CONTROLLER AND GENERAL INFORMATION
The Controller processes your personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter as “Regulation“), with Act No. 502 of 23 May 2018 on supplementary provisions to the regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the Data Protection Act) (hereinafter as “Act“), in accordance with Swiss Federal Act on Data Privacy (FADP) of 19 June 1992 (Status as of 1 March 2019) and other legislation in relation to personal data protection (hereinafter as “Personal data protection legislation“).
In matters related to personal data processing and protection, you may contact the Controller at the address Debex Suisse AG, Rainstrasse 1, CH-6052 Hergiswill NW, Switzerland or via e-mail to e-mail address email@example.com. The Controller has not designated a data protection officer in the area of personal data processing and protection.
2. PURPOSES, LEGAL BASIS, STORAGE PERIOD and CATEGORIES OF PERSONAL DATA
The Controller processes your personal data only for justified purposes, for a limited time and with the use of the maximum possible level of security. The Controller processes personal data only if there is a legal basis for their processing (in accordance with the principle of legality). The Controller always keeps personal data in accordance with the principle of minimization only during the period during which it is necessary to keep personal data. After this period, the Controller will delete the personal data, unless otherwise provided by respective legislation.
Specific information on the purposes of the processing, the legal bases for their processing, the categories of personal data processed and the specified retention period can be found in the table below.
|Purpose of the processing||Responding to messages and handling inquiries / requests from messages delivered via the contact form on the website, the Controller's profile on the social network and via e-mail communication or by telephone|
|Legal basis||Art. 6 (1) letter f) of the Regulation - processing of personal data is performed on the basis of the legitimate interest of the Controller, which is the response to received messages and requests for proper management of business communication and the provision of information on the activities of the Controller|
|Personal data or categories of personal data||Name, surname, e-mail, tel. no., other data stated in the message|
|Retention period||30 days from the date of receipt of the request or until the request is processed (fulfillment of purpose), whichever occurs first|
|Purpose of the processing||Making of photographs and audio-visual recordings of the data subjects and their publication together with other personal data on the Controller's website and on other promotional materials and online communication channels during the Controller's presentation and business activities|
|Legal basis||Art. 6 (1) letter a) of the Regulation - the carried out processing of personal data is based on the consent of the data subject|
|Personal data or categories of personal data||Photo, title, name, surname, job title|
|Retention period||5 years from the date of the consent or until its revocation, whichever occurs first|
|Purpose of the processing||Processing the exercised rights of the data subjects|
|Legal basis||Art. 6 (1) letter c) of the Regulation - the processing of personal data is carried out in order to comply with the legal obligations|
|Personal data or categories of personal data||Ordinary personal data that is part of the application|
|Retention period||Until the exercised rights are handled with|
|Purpose of the processing||Records of the exercised rights of the data subjects|
|Legal basis||Art. 6 (1) letter f) of the Regulation - processing of personal data is performed on the basis of the legitimate interest of the Controller, which lays in the need to keep records of the exercised rights of the data subjects, in order to prove to the respective authority the fulfillment of obligations arising from legal regulations|
|Personal data or categories of personal data||Ordinary personal data that is part of the application|
|Retention period||5 years from the date of exercise of rights|
|Purpose of the processing||Sending information about the Controller's activities and its own services (direct marketing to existing and former clients)|
|Legal basis||Article 6 (1) letter f) of the Regulation - processing of personal data is performed on the basis of the legitimate interest of the Controller, which is the interest in maintaining the existing clientele and its information and current services of the Controller|
|Personal data or categories of personal data||Name, surname, position in the company of the business partner / customer, e-mail address|
|Retention period||3 years from the date of provision of services / sale of goods or until the subscription to the newsletter is cancelled, whichever occurs first|
|Purpose of the processing||Website traffic measurements, website activity and targeting of the Controller's online advertising (via an online tool - cookies)|
|Legal basis||Article 6 (1) letter a) of the Regulation - the carried out processing of personal data is based on the consent of the data subject|
|Personal data or categories of personal data||IP address and other information about the activity on the Controller's website and its preferences in the online environment|
|Retention period||For a maximum of 2 years from the date of the consent was granted or until its withdrawal, whichever is the earlier|
In relation to securing the personal data, the Controller has adopted internal documentation, in which adequate security measures are further specified. Security measures have been adopted in order to secure the processing of your personal data.
3. SOURCE OF THE PERSONAL DATA
The Controller obtains your personal data directly from you as a data subject, in case you provide the Controller with your personal data (when you contact us via message sent through contact form on the websites, social network, or when you visit one of the websites of the Controller).
In some cases, especially if a service is ordered from the Controller by a business company or other entity of which you are a representative or contact person, the source of your personal data is this entity.
If you do not provide the Controller with your personal data in some cases, the Controller would not be able to respond to your message or to provide you with newsletter.
4. TO WHOM THE CONTROLLER PROVIDES YOUR PERSONAL DATA?
Your personal data may be in some cases provided to public authorities, which are entitled to process your personal data, e.g. to courts, law enforcement authorities or other inspection authorities.
The Controller provides your personal data also to its processors, i.e. external subjects which process your personal data on behalf of the Controller. Processors process personal data based on the agreement with the Controller, in which they committed to adopt adequate technical and organisational measures in order to secure the processing of your personal data. The Controller currently uses as a processor:
In the case of the processing of personal data via social media profiles, the recipients of your personal data include also the operators of these social networks (European branches of Facebook, Inc. and Google, LLC) in the position of joint controller together with the Controller. In accordance with the concluded agreement of the joint controllers, the contact point for the data subjects regarding the processing of personal data in these cases is the Controller. When using analytical and marketing cookies on the website of the Controller, your personal data may be disclosed to the providers of these services (in particular Google, LLC) if the Operator uses them based on your consent.
5. TRANSFER TO THIRD COUNTRIES AND INTERNATIONAL ORGANISATIONS AND PROFILING
In some cases, your personal data may be transferred to third countries, to the USA:
The transfer is always carried out in accordance with the Personal data protection legislation. In relation to the Switzerland based on adequacy decision. In relation to the USA on the basis of standard contractual clauses (which are part of the contractual terms of the above specified services) and the Controller fulfils all obligations related to the transfer.
The Controller does not use profiling when processing your personal data and does not process personal data in any form of automated individual decision-making, via which your personal aspects would be evaluated.
6. SOCIAL MEDIA AND LINKS TO OTHER WEBSITES
As part of marketing and advertising support, you will find links to various social networks on the Controller's website, such as Facebook. The Controller hereby informs you that after clicking on the add-on on the website and going to the social network, the rules of personal data protection of the social network controller will apply, except in cases where you contact the Controller via a message on the social network (in which case the processing of your personal data also governs this policy and your personal data processed by the Controller in accordance with the information provided above).
You can find more information about the processing of your personal data by social network controllers at the following links: Facebook: https://sk-sk.facebook.com/policy.php, (ii) Pinterest: https://policy.pinterest.com/sk/terms-of-service.
7. WHAT ARE YOUR RIGHTS IN RELATION TO PERSONAL DATA PROCESSING?
As the data subject, your rights regarding the processing of your personal data are as follows:
|Right of access - You have the right to obtain a copy of the personal data which we hold about you, as well as the information on how we use your personal data. In most cases, your personal data will be provided to you by electronic means of communication, unless otherwise requested by you.||Right to rectification - We take reasonable measures in order to ensure that the data which we hold about you are accurate, complete and up-to-date. In case the personal data we hold are inaccurate, incomplete or outdated, we will modify, update or complete such personal data on basis of your request.|
|RIGHT TO OBJECT You have the right to object to processing of your personal data, for example if we process your personal data based on the legitimate interest or to processing in which profiling occurs. If you object to such personal data processing, we will not further process your personal data unless we demonstrate compelling legitimate grounds for such processing|
|Right to erasure - Under certain circumstances, you have the right to ask us to erase your personal data, for example, if the personal data we have obtained about you, are no longer necessary to fulfil the original purpose of processing or if you withdraw your consent to the personal data processing. We assess exercising your right to erasure (right to be forgotten) on the basis of individual circumstances of each particular case of processing. However, your right has to be assessed in the light of all relevant circumstances. For example, there may be certain circumstances or cases arising for us from applicable legislation when your personal data cannot be erased. In such case, we will not be able to accept your request.||Right to data portability - Under certain circumstances, you have right to transmit the personal data to another subject according to your choice. However, the right to portability applies only to personal data that we process under the contract to which you are one of the parties or on the basis of the consent which you have granted us.|
|RIGHT TO WITHDRAW CONSENT If we process your personal data on the basis of your consent, you have the right to withdraw such consent for further processing of your personal data. You may withdraw your consent at any time in writing, by e-mail or orally (in person).|
|Right to restriction of processing - You have also the right to ask us not to process your personal data. If you believe that the personal data we process about you are not accurate, that the processing is unlawful and you request the restriction of their processing, that we no longer need your personal data, but they are required by you as the Data subject for the exercise of legal claims or if you believe that we as the controller are not entitled to further process your personal data, we will not further process your personal data on the basis of your request.||Right to lodge a complaint or request - If you believe that we breach Personal data protection legislation when processing your personal data or that we have not handled your request in accordance with such legislation, you can lodge a complaint with the supervisory authority for the EU: Úrad na ochranu osobných údajov SR, Hraničná 12, 820 07 Bratislava 27, Slovak republic, website: dataprotection.gov.sk, tel. No.: 02 3231 3214; e-mail: firstname.lastname@example.org.|
You may exercise your rights specified in the table above at the contact addresses of the Controller listed at the beginning of this document.
The Controller will provide you with the answer to the exercise of your rights free of charge. In the event of a repeated, unreasonable or inappropriate request for the exercise of your rights, the Controller is entitled to charge a reasonable fee for the provision of information. The Controller will provide you with an answer within 1 month from the day when you exercised your rights. In certain cases, the Controller is entitled to extend this period, in the case of a high number and complexity of applications of the data subjects, maximally by 2 months. The Controller will always inform you about the extension of the deadline in advance.