Privacy Policy Information
prepared 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 (hereinafter referred to as "GDPR") and Act No. 18/2018 Coll. on Personal Data Protection (hereinafter referred to as the "Personal Data Protection Act")
Introductory Provisions
The company New School Communications s.r.o., with its registered office at Továrenská 12, Bratislava - Staré Mesto 811 09, ID No. (IČO): 52 348 521, registered in the Commercial Register of the District Court Bratislava I, Section: Sro, Insert No.: 136918/B (hereinafter referred to as "NEW SCHOOL COMMUNICATIONS" or "our company") respects the privacy of all data subjects with whom it comes into contact; regardless of whether it processes personal data itself or through third parties. It is extremely important for our company that every natural person affected understands which personal data we process about them, why we do so, and what their rights are. Personal data of data subjects may be processed in various ways and situations depending on the type of data subject. Below in this document, you will find general information such as:
- identification and contact details of our company (Section 1 of this document),
- your rights in connection with the processing of your personal data (Section 2 of this document),
- information on automated individual decision-making, including profiling (Section 3 of this document); while more information about the processing of personal data in your specific case can be found in Section 4 of this document depending on whether you are:
- a website visitor (Section 4.1 of this document) (cookie processing)
- a newsletter subscriber (Section 4.2 of this document)
- a client or prospective product customer (Section 4.3 of this document)
We would also like to ask you on behalf of NEW SCHOOL COMMUNICATIONS to always provide us only with up-to-date and accurate personal data, which our company will subsequently process. In the event of a change in your personal data, we kindly ask you to notify us of this fact without undue delay.
To protect your personal data from unauthorized persons and against unlawful processing, unforeseen loss, destruction, and damage, in both online and offline environments, we use physical, electronic, and organizational measures to prevent such situations in accordance with our internal data protection rules.
1. Identification and Contact Details of NEW SCHOOL COMMUNICATIONS
Identification and contact details of NEW SCHOOL COMMUNICATIONS are:
Company name: NEW SCHOOL COMMUNICATIONS, s.r.o.
Registered office: Továrenská 12, Bratislava - Staré Mesto 811 09
ID No. (IČO): 52 348 521
Registration: Commercial Register of the District Court Bratislava I, Section: Sro, Insert No.: 136918/B
Correspondence address: Továrenská 12, Bratislava - Staré Mesto 811 09
email: ochranaudajov@katedrakomunikacie.sk
Phone: +421 908 169 879
NEW SCHOOL COMMUNICATIONS has not appointed a Data Protection Officer (our company is not required to appoint a Data Protection Officer under the GDPR and the Personal Data Protection Act).
2. Rights of the Data Subject
If our company processes your personal data, you, as a data subject, have the following rights:
Right to withdraw consent - in cases where we process your personal data based on your consent, you have the right to withdraw this consent at any time. You can withdraw your consent electronically at the address specified in Section 1 of this document, in writing, by notice of withdrawal of consent (or in another appropriate manner). The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right of access - you have the right to be provided with a copy of the personal data we hold about you, as well as information about how we use your personal data. In most cases, your personal data will be provided to you in electronic form where technically feasible.
Right to rectification - we take reasonable measures to ensure the accuracy, completeness, and timeliness of the information we hold about you. If you believe that the data we hold is inaccurate, incomplete, or out of date, please do not hesitate to ask us to modify, update, or supplement this information.
Right to erasure (to be forgotten) - you have the right to ask us to delete your personal data, for example, if the personal data we collected about you is no longer necessary to fulfill the original purpose of processing. However, your right must be assessed in light of all relevant circumstances. For example, we may have certain legal obligations, which means we will not be able to comply with your request.
Right to restriction of processing - under certain circumstances, you are entitled to ask us to stop using your personal data. This includes, for example, cases where you think that the personal data we hold about you may be inaccurate or when you think that we no longer need to use your personal data.
Right to data portability - under certain circumstances, you have the right to ask us to transfer the personal data you provided to us to another third party of your choice. However, the right to portability applies only to personal data that we obtained from you based on consent or based on a contract to which you are a party.
Right to object - you have the right to object to the processing of data that is based on our legitimate interests. In the event that we do not have a compelling legitimate ground for processing and you submit an objection, we will no longer process your personal data.
Right to lodge a complaint - if you believe that your personal data is being processed unfairly or unlawfully, you can lodge a complaint with the supervisory authority, which is the Office for Personal Data Protection of the Slovak Republic, Hraničná 12, 820 07 Bratislava 27; Phone: +421 /2/ 3231 3214; Email: statny.dozor@pdp.gov.sk, https://dataprotection.gov.sk. In the case of submitting a proposal in electronic form, it is necessary that it meets the requirements pursuant to § 19 par. 1 of Act No. 71/1967 Coll. on Administrative Proceedings (Administrative Procedure Code).
3. Automated Decision-Making and Profiling
Your personal data will not be used for automated individual decision-making, including profiling.
4. Information on Personal Data Processing by Categories of Data Subjects
The provisions of this Section 4 do not apply to data subjects who have been separately instructed in writing by NEW SCHOOL COMMUNICATIONS in accordance with Sections 19 and 20 of the Personal Data Protection Act, provided that the data subject personally signed such instruction, from the moment of such personal signature.
4.1. Website Visitor and Cookie Processing
The company NEW SCHOOL COMMUNICATIONS is the operator of the website located at www.newschool.sk and www.elfovia.newschool.sk (hereinafter collectively referred to as the "website").
4.1.1. What are Cookies?
If you visit a site (including our company's website) that writes cookies, a small text cookie file is created on your computer. A cookie file is a short text file that a website stores in the browser of your computer or mobile device (including a tablet) when browsing it. If you visit the same site repeatedly in the future, thanks to it, for example, you will connect faster or the website will remember certain information regarding your browsing preferences, browser type, selected website settings, etc. You can control or delete cookies as you see fit. You can delete all cookies stored on your computer and set most browsers to prevent them from being stored. Instructions for deleting or blocking all cookies, including incorrectly stored ones, can be found on the websites of web browsers.
4.1.2 Types of Cookies and Purpose of Use
We process cookies for various purposes (listed below), but primarily we use them to be able to display our website to you in an optimal way and ensure proper functionality of our website in accordance with your preferences. For purposes other than those stated, your cookies will be stored only with your consent.
a) Functional (strictly necessary) cookies Functional (necessary) cookies guarantee functions without which you could not use the website and ensure, among other things, that when you invoke website functions, a version is displayed that has a data volume corresponding to the internet connection you use. In addition, cookies of this type store your decision regarding the use of cookies on our website. These cookies do not collect information and data based on which we could individually identify you as a user of our website. The strictly necessary cookies we use are (processed for the following purpose):
- cookies used to ensure the transmission of data over the internet;
- cookies that are strictly necessary for us to provide you with a service you have explicitly requested;
- cookies that allow our website to remember choices made on your device while browsing the website and provide enhanced, personal features.
b) Analytical cookies These cookies serve to provide statistical information on the performance of our website (e.g., number of visits, sources of traffic, etc.). Analytical cookies can, for example, recognize a repeat visit to our website from the same device and track your activity. The information obtained helps us especially to determine the effectiveness of individual parts of our website, based on which we subsequently refine the website itself.
On our website, we use third-party analytical cookies that are not created or managed by our website, but by a third party. We use cookies within the Google Analytics platform, which uses cookies to analyze visits to our site; more information can be obtained at this link: ( https://support.google.com/analytics/answer/6004245?hl=en )
By granting consent to the use of analytical cookies through the Google Analytics platform, you agree that we may store cookies on your computer through our website.
Consent to the use of analytical cookies via Google Analytics can be withdrawn at any time, either through settings directly in your web browser or through this link: ( http://www.aboutads.info/choices or http://www.youronlinechoices.eu )
4.1.3. Consent to the Use (Processing) of Cookies
When you visit our website for the first time, a pop-up window (banner) will be displayed with an explanation about cookies. Within this banner, you can select consent or disagreement with the processing of individual types of cookies through the website (with the exception of functional or necessary cookies for which your consent is not required).
You can disable the use of cookies at any time directly through your browser (more information can be found directly in your browser settings). If you refuse or disable the use of cookies, you will still be able to use our website, but some features may not function properly.
We also point out that in connection with cookies you have rights as stated in Section 2 of this document (above).
4.1.4. Processing Period
Browsing data stored according to cookie settings will be kept for the time necessary for the purpose for which it was collected, but for a maximum of 2 years.
4.2. Newsletter Subscriber
Browsing data stored according to cookie settings will be kept for the time necessary for the purpose for which it was collected, but for a maximum of 2 years.
4.2.1. Purpose of Personal Data Processing
Newsletter subscription - marketing purposes and the execution of our marketing activities, which include providing information about our activities, sending newsletters, and displaying targeted advertising.
Source of personal data - Personal data is provided to our company voluntarily by the interested party by filling out the contact form for newsletter subscription purposes located on the website.
4.2.2. Legal Basis
Our company processes your personal data based on your consent, which you express by checking the consent checkbox located next to the contact form for newsletter subscription purposes on the website.
4.2.3. Scope of Personal Data Processing
If you are interested in the newsletter, we obtain and process the following data from you: email address.
4.2.4. Categories of Recipients
Personal data is processed directly by our company in electronic form. Our company may share your data with third parties under the following circumstances:
If required by law or a court order, we may share your personal data, for example, with law enforcement agencies or other authorized authorities of the Slovak Republic.
Likewise, in the case of a legitimate interest of our company, we may provide your personal data to companies with economic or personnel ties to our company.
Certain activities for our company are carried out by subcontractors. For the purpose of performing these activities, it is required that personal data of the data subject be provided to such a subcontractor to the necessary extent for fulfilling the subcontractor's tasks. Such external subcontractors are mainly external marketing agencies, other consulting companies, administrative service providers, and companies operating data storage and server management. Specific companies and activities may be subject to change according to the current needs of our company. In case of sharing personal data, our company will ensure the highest level of protection for your personal data and its processing in accordance with the Personal Data Protection Act.
4.2.5. Transfer of Personal Data
Our company may also process certain personal data through electronic systems and data storage facilities operated by persons (processors) outside the European Union. Our company will always verify that they ensure the highest possible protection of personal data within the meaning of relevant legal regulations (i.e. they are part of an adequacy decision of the European Commission, e.g. part of the EU-US Privacy Shield framework if located in the US, etc.).
4.2.6. Personal Data Processing Period
In accordance with the principle of proportionality and data minimization under the GDPR, we store your personal data for a period of 3 years from the granting of your consent. After this period, your personal data will be deleted and destroyed. If you wish to continue receiving our newsletter, you can grant your consent again for this purpose via the website.
You have the option to withdraw your consent to receive the newsletter at any time and unsubscribe. You can do so by clicking the "Unsubscribe from newsletter" link in the email message received from us, or by writing to us at our contact email address specified above in this document.
4.3. Client (or Prospective Customer)
A product of NEW SCHOOL COMMUNICATIONS means any service provided by NEW SCHOOL COMMUNICATIONS and/or any goods sold by NEW SCHOOL COMMUNICATIONS.
4.3.1. Purpose of Personal Data Processing
In order to conclude and perform a contract with you or with the company you represent, or so that you can use the product we offer, it is necessary to process your personal data.
The purpose in specific cases is mainly the processing of personal data in connection with the following activities: (i) conclusion of contract or other agreements and processing of related documents, their recording or control and amendments, including ensuring performance under these contracts, (ii) company bookkeeping.
Source of personal data - Contact personal data is provided to our company voluntarily by the prospective customer (e.g. by reaching out via website or email), or our company obtains it from publicly available sources (registers and databases of prospective customers of products similar to ours) or from cooperating persons (if such handling of personal data complies with the law, provided that confidentiality of personal data is always secured by contract).
4.3.2. Legal Basis
We process your personal data only when we have a legal basis to do so.
This means that processing must be necessary for the performance of a contract to which you or the company you represent is a party, or to take steps at your request prior to entering into a contract (the legal basis is therefore the contract, including pre-contractual relations and fulfillment of rights and obligations arising from such contract and related documentation).
In accordance with our legitimate interest, we may also use your data for the proper conduct of our company's business activity, to provide you with information about our products, prospects, analyses that might be in your best interest, or to perform necessary tasks resulting from a business relationship (the legal basis is therefore our company's legitimate interest).
We have a legal obligation to provide your personal data during audits by authorized institutions and in the prevention, monitoring, and proving of fraud and other criminal activity (the legal basis in selected cases is therefore statutory law).
4.3.3. Scope of Personal Data Processing
NEW SCHOOL COMMUNICATIONS processes "ordinary personal data" to the extent necessary to fulfill the purposes specified in Section 4.2.1 of this document, primarily in the following scope:
- first name, last name,
- permanent residence address, correspondence address
- Company ID (IČO), Tax ID (DIČ), VAT ID (IČ DPH), place of business, registered office or establishment (which may match the residence); for self-employed clients
- phone number, email
- bank account numbers (for contractual payment settlements)
- signature
4.3.4. Categories of Recipients
Personal data is processed directly by our company in written and electronic form. Personal data may be disclosed to entities authorized under special regulations, which are mainly: law enforcement agencies, courts, executor offices, etc.
Certain activities for our company are carried out by subcontractors. For the purpose of performing these activities, it is required that your personal data be provided to such a subcontractor to the necessary extent for fulfilling the subcontractor's tasks. Such external subcontractors are mainly external accounting, tax, marketing, legal and other consulting companies, web hosting providers, and server/data storage management companies, etc. Specific companies and activities may be subject to change based on the current needs of NEW SCHOOL COMMUNICATIONS.
In case of sharing personal data, our company will ensure the highest level of protection for your personal data and its processing in accordance with the Personal Data Protection Act.
4.3.5. Transfer of Personal Data
Our company may process certain personal data (e.g. first name, last name, and email) through electronic systems and data storage facilities operated by persons (processors) outside the European Union. Our company will always verify that they ensure the highest possible protection of personal data within the meaning of relevant legal regulations (i.e. they are part of an adequacy decision of the European Commission, e.g. part of the EU-US Privacy Shield framework if located in the US, etc.).
4.3.6. Personal Data Processing Period
Your data is stored by our company as long as necessary to fulfill the purpose of processing under special regulations, and the purpose for which it was collected (see Section 4.2.1 above), if we have a legitimate interest in retaining it, e.g., until the end of a contractual relationship. After termination of the contractual relationship and settlement of all obligations arising from or related to such contractual relationship, our company stores your personal data for the time strictly necessary required by applicable legal regulations. Where such period is not specified by law, our company is entitled to retain your personal data for at least three years from the date of termination of the contractual relationship (maximum up to ten years, unless applicable legal regulations specify a longer retention period). In the event of a court dispute with you (as a data subject), at least three years from the date of final resolution of the court dispute.