I. INTRODUCTORY PROVISIONS
For the purposes of this Policy, the following shall be understood:
The operator of Werbea, s.r.o., ID number: 50 007 343, with registered office at Jakubova 45, 821 04 Bratislava
Personal data: first and last name, e-mail address, phone number, billing address, delivery address, IP address, cookies, information about reaching the age of 16.
The operator of the e-shop www.werbea.com, as the controller of Personal Data, hereby informs about the manner and extent of processing of Personal Data, including the extent of the Participant’s rights (as defined below) related to the processing of his Personal Data.
When processing personal data, the operator proceeds in accordance with the following legal regulations:
Law no. 18/2018 Coll. on personal data protection;
Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter referred to as the “Regulation”);
The Participant is a natural person who purchases goods and services from the Operator.
The operator is a legal entity that operates this online store for the purpose of selling goods and services to the end customer. In connection with the above, Personal Data is processed:
to the extent that they were provided in connection with the order of products and / or services of the Operator, or as part of the negotiations on the conclusion of the contract with the Operator, as well as in connection with the concluded contract;
for the purpose / purposes listed below in Art. II.
The e-shop is not intended for children under the age of 16. A person under the age of 16 can use our e-shop only if their legal representative (parent or guardian) gives their consent. If consent is not granted, it is necessary to inform us about this fact at gdpr@werbea.com.
II. PURPOSES AND PERIODS OF PERSONAL DATA PROCESSING
The Operator processes Personal Data for the following purposes:
performance of a contract, or other obligation, and provision of services:
personal data will be processed during negotiations on the conclusion of the contract between the Operator and the Participant, for the purpose of concluding the contract, as well as during the duration of the contractual relationship;
sending satisfaction questionnaires: sending satisfaction questionnaires for the purpose of improving the quality of the services provided to customers in connection with the created order, reservation or direct sale, as well as the possible detection of statistical data on satisfaction with products.
marketing actions: for the purpose of fulfilling the marketing action, evaluation, termination, delivery of any winnings, etc. Processing time: for the duration of the marketing campaign.
compliance with legal obligations (especially accounting, tax and archiving, cooperation with administrative authorities, police, courts, etc.);
the tax document will be kept for 10 years from the end of the contract: In order to fulfill the legal obligation to archive accounting documents based on Act no. 563/1991 Coll., on accounting, as amended, Personal data will be further processed and stored for a period of 10 years from the year following the year in which the contract between the Operator and the Participant was concluded;
fulfillment of obligations in connection with the exercise of rights from faulty performance, provision of cooperation to administrative authorities, the police, the court: The operator is authorized to process basic personal, identification and contact data of the customer, data about the goods and data from communication between the customer for a period of 4 years from the date of expiry of the warranty period for the goods.
legitimate interests of the Operator, protection of rights and legally protected interests of the Operator:
effective defense in case of dispute. The processing time here is set at 4 years from the expiration of the warranty period for the goods and is extended by the time for which the dispute is being conducted;
the legitimate interest of the Operator is to send commercial announcements (general offers and individual offers) if the Operator has obtained electronic contact details in connection with the sale of goods and services to the Subscriber. Legitimate interest arises as a result of the created customer order on our e-shop.
marketing and business offers of the Operator’s services;
general sending of business offers of products and services: sending general advertising messages without targeting a specific group of recipients. The period of personal data processing in this case is 3 years;
individual offer: sending advertising messages after evaluating some personal aspects relating to a natural person. The operator does not perform profiling in accordance with Art. 22 Regulations, as it is not about automated processing, but manual creation of individual offers. The period of personal data processing in this case is 3 years;
Sending Heureka questionnaires – verified by customers: sending Heureka questionnaires in order to improve the quality of services provided to customers. As part of satisfaction evaluation and other surveys, the operator transfers personal data in the scope and e-mail address to a third party – another administrator – Heureka Shopping s.r.o. The period of personal data processing in this case is 3 years. (Here the express consent of the Participant is required);
cookies: short text files generated by the web server and stored on the computer via the browser. There are two types. First of all, they are cookies necessary to ensure the functioning and analysis of the website (transmission of electronic communication via an electronic communication network, the use of these cookies cannot be expressed). Furthermore, these are cookies that evaluate some personal aspects related to a specific natural person. With the use of the second type of cookies, the Participant must express his consent. In this case, the processing time is 3 years.
For the purposes of re-marketing, cookies are transferred to other processors only if they have given consent for this purpose, with an expiration period of a maximum of 540 days. If consent to advertising cookies is withdrawn, it is technically not possible to immediately remove cookies that have already been transferred to the processor. Cookies are automatically deleted by the processor after the expiry period. An immediate solution to prevent re-marketing activities by the processor is to delete cookies from the browser according to the instructions for individual types of browsers.
The operator is the administrator of Personal Data.
III. PROTECTION OF PERSONAL DATA AND INFORMATION ABOUT PROCESSING
If the Participant does not provide his Personal Data, it is not possible to conclude a contract with the Operator and/or provide him with the services resulting from it. In this context, personal data are necessary for the provision of a specific service or product of the Operator.
After the expiration of the periods specified in Article II. The Operator deletes or anonymizes Personal Data.
The Participant is obliged to provide only true and accurate Personal Data to the Operator. The Participant is responsible for the correctness, accuracy and truthfulness of the Personal Data provided. The operator is not responsible for the correctness of the data provided.
The operator will make every effort to prevent unauthorized processing.
The Operator is entitled to transfer the Participant’s personal data to third parties for the following purposes: completion of the order process, delivery of goods, sending of business announcements, evaluation of customer satisfaction, customer support services, processing of complaints, registration of a new customer.
Personal data are and will be processed in electronic form in a non-automated manner.
IV. RIGHTS OF THE PARTICIPANT RELATED TO PROCESSING
Rights of the Participant in connection with the protection of personal data:
request access to his Personal Data from the Operator;
to correct the Personal Data provided;
to delete the Personal Data provided;
to limit the processing of Personal Data;
file a complaint with the Office for Personal Data Protection;
the right to transfer personal data to another administrator;
the right to object to the processing of personal data;
right to withdraw consent.
The participant can exercise his rights under par. 1 of this article can be applied through the link provided in the footer of the e-mail sent by the Operator or the request at gdpr@werbea.com or, in the case of a registered customer, in the customer section of the e-shop website.
Rights according to par. 1 of this article letter c) and d) cannot be applied to the extent and for the purposes specified in Art. II paragraph 1 letter a), b) and c) with the exception of point ii) letter c) Art. II, when it is possible to exercise all the rights listed in par. 1.
In the event that the Participant believes that the Operator is processing his Personal Data, which is contrary to the protection of his private and personal life or contrary to the relevant legal regulations, especially if the Personal Data is inaccurate with regard to the purpose of their processing, he may:
ask the Operator for an explanation by e-mail to the address gdpr@werbea.com
to object to the processing and request by e-mail sent to the address gdpr@werbea.com that the Operator ensures the elimination of the resulting situation (e.g. by blocking, correcting, supplementing or liquidating Personal Data). The operator will immediately decide on the objection and inform the Participant. If the Operator does not comply with the objection, the Participant has the right to contact the Office for Personal Data Protection directly. This provision does not affect the right of the Participant to contact the Office for Personal Data Protection directly with their initiative.
If the Participant exercises the right according to this article, the Operator is obliged to respond within 30 days from the receipt of the request by the Operator.
Acceptance of a request to exercise the right from Article IV, Point 1 a) and f) is possible only through a data report or a letter with an officially verified signature to the address of the company’s registered office. The application must include an e-mail address, to which a verification e-mail will be sent to confirm the applicant’s identity.
If the Participant exercises any of the rights from Article IV, Paragraph 1, the Operator has the right to request proof of the Participant’s identity. The request for access to personal data must be sent from the applicant’s e-mail address. If the request is submitted in a different form or from a different e-mail address, the Operator has the right to request additional verification in the form of a reply to the verification e-mail. In the event that the applicant does not prove his identity within 14 days of sending the verification e-mail, his request to exercise the rights from Article IV, Paragraph 1 will not be accepted.The Operator is entitled to charge a reasonable fee for the administrative costs associated with a repeated and unjustified request for the provision of a physical copy of the processed Personal Data.
V. FINAL PROVISIONS
All legal relationships arising from the processing of Personal Data are governed by the legal order of the Slovak Republic, regardless of where they were accessed. Any disputes arising in connection with the protection of privacy between the Participant and the Operator are the competent Slovak courts.
The affected person has the right to contact the Office for the Protection of Personal Data (https://dataprotection.gov.sk/uoou/sk).
These Principles take effect on August 8, 2019.
The operator of this online store is also the operator of a brick-and-mortar store. If this store will be monitored by a camera system, the company Werbea, s.r.o. processes these camera records. The record retention period is set for 30 days. Camera recordings are made for security reasons in order to increase the protection of the operator’s property.
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