This document provides information on how Immocap, a.s., with registered office at Plynárenská 7/C, 821 09 01, Company ID: 35 944 536, registered in the Commercial Register of the District Court Bratislava I, Section Sa, Insert No.: 3633/B, as the Controller (hereinafter referred to as „we“ or „company“) processes personal data of natural persons (hereinafter also referred to as „Data Subject“), within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) (hereinafter referred to as “GDPR“).
The purpose of this personal data processing policy for Immocap (the “Policy“) is to inform you in particular about what personal data we collect, from what sources we collect it, for what purposes we process it, whom we are entitled to provide with your personal data, what your rights are and how you can exercise them.
The Controller of personal data is:
Immocap, a.s.
Plynárenská 7/C 821 09 Bratislava, Slovakia
The Controller’s contact details:
Phone no.: +421 221 026 136
Email: immocap@immocap.sk
If you have any questions regarding this Policy, the use of your personal data or wish to exercise your rights described in this Policy, you may contact our company by email as well as in writing at our company’s address.
The applicable legislation in force allows us to process your personal data on the basis of a number of legal bases and the processing of personal data may occur without the Data Subject’s consent. What personal data we process and for how long we keep it varies depending on the purpose of the processing and the nature of the specific processing activity:
| The purpose of processing: | Processing of a contact request sent via a web-based contact form and contacting the sender back |
| Legal basis: | Legitimate interest of the Company (Article 6(1)(f) of the GDPR). The processing of personal data is necessary to enable us to process your contact request sent via the contact form on our website www.immocap.com, and to enable us to contact you back and communicate with you on the matter in which you have contacted us. |
| Scope of personal data processed: | Name and surname, email address and, if applicable, telephone number (if provided). We also process the personal data that you choose to provide in the contact form message. |
| Retention period of personal data: | We will retain your personal data for as long as we communicate with you, however, not more than 24 months from the last communication with you. |
| The purpose of processing: | Presentation of the products and services of the Company |
| Legal basis: | In the case of marketing messages sent to our existing customers and business partners, the legal basis for the processing of personal data is the legitimate interest of the Company (Article 6(1)(f) of the GDPR). In other cases, the legal basis for the processing of personal data is the Data Subject’s consent to the processing of personal data (Article 6(1)(a) of the GDPR). |
| Scope of personal data processed: | Name and surname, email, phone number. |
| Retention period of personal data: | Personal data will be stored for 3 years after consent to the processing of personal data has been given, but at the latest until its revocation. Personal data will be kept for the period of legitimate interest of the Company. If you object to the processing of personal data for marketing purposes, we will no longer process your personal data for this purpose. |
| The purpose of processing: | Performance of contracts with our business partners, suppliers of goods and services to the Company or negotiations on the conclusion of such contracts. |
| Legal basis: | Performance of a contract to which the Data Subject is a party and implementation of pre-contractual measures (Article 6(1)(b) of the GDPR) |
| Scope of personal data processed: | identification data of the Data Subject (in particular name, surname, date of birth, residence, signature, etc.); contact data of the Data Subject (in particular email, phone number, etc.); payment data of the Data Subject (bank account number, banking institution); other data of the Data Subject, the processing of which is necessary for the achievement of the purpose. |
| Retention period of personal data: | Personal data will be kept for the duration of the contractual relationship. After the expiry of this period, we will continue to store the personal data for the purpose of fulfilling the obligations laid down by law (in particular, the archiving obligation) and for the protection of our company’s legitimate interests in the form of the protection of our rights and the exercise of our company’s claims. |
| The purpose of processing: | Making and publishing recordings from Company trainings. |
| Legal basis: | Consent to the processing of personal data (Article 6(1)(a) GDPR). For the purpose of publishing audio, audio-visual and video recordings of our trainings, we only process your personal data to the extent of your recorded voice and image with your consent. Such consent is requested from you separately when you register for the training or before the start of the training. |
| Scope of personal data processed: | The image and voice of the Data Subject recorded on a recording. |
| Retention period of personal data: | Personal data will be processed for the period specified in the consent to the processing of personal data. |
| The purpose of processing: | Establishing, exercising or defending our legal claims. |
| Legal basis: | Legitimate interest of the Company (Article 6(1)(f) of the GDPR). |
| Scope of personal data processed: | identification data of the Data Subject (in particular name, surname, date of birth, residence, signature, etc.); contact data of the Data Subject (in particular email, phone number, etc.); payment data of the Data Subject (bank account number, banking institution); other data of the Data Subject, the processing of which is necessary for the achievement of the purpose. |
| Retention period of personal data: | The personal data will be processed for the period necessary to settle the obligations to the Company arising from the legal relationship and after the legal relationship is terminated for the duration of the limitation periods, up to a maximum of 10 years, unless otherwise provided for by law or unless there is a justified need to store the personal data for a different period of time. |
In most cases, we obtain personal data directly from you as the Data Subject.
However, in some cases we have to complete the data with information obtained from public sources (e.g. trade register, cadastre, business journal, etc.), or provided to us by a third party (e.g. if before concluding a contract, the business partner provides personal data of members of the business partner’s bodies, employees and/or other contact persons).
Recipients of personal data most often include suppliers of services to the Company and external consultants, such as, in particular, providers of software systems, IT services, postal and courier services, translators, accounting and tax advisors, marketing agencies.
Where necessary, personal data may be disclosed to courts, state and other authorities for the purpose of complying with the Company’s obligations, to enable the exercise of control over the Company’s activities, to resolve disputes and to enforce decisions; and to our other external advisors and legal representatives bound by confidentiality obligations.
Personal data may be shared with any acquirer if transferred as part of a sale or other transfer of all or part of the Company’s assets to another company.
We do not actively transfer your personal data to third countries outside the EU.
In accordance with the requirements of applicable legislation, we have put in place, implement and maintain all necessary security, technical and organisational measures, internal controls and processes to protect your personal data, in accordance with best business practice appropriate to the potential risk to you as the Data Subject. In addition, we take into account the state of technological development in order to protect your personal data against accidental loss, destruction, alteration, unauthorised disclosure or access.
These measures may include, but are not limited to, taking reasonable steps to ensure the accountability of relevant employees who have access to your data and training of employees.
If you wish to receive more information about the security of your personal information, please contact us at immocap@immocap.sk.
We respect your rights as a Data Subject when processing your personal data. Any Data Subject whose personal data we process has rights relating to the adequate protection and lawfulness of the processing of his or her personal data. The Data Subject has the following rights:
Right to access: In the event that personal data is processed related to you, you have the right to be informed within the scope of this Policy and to access to your personal data. 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 a written paper form, unless you request a different method of disclosure. If you have requested this information by electronic means, it will be provided to you electronically, if technically feasible. If you repeatedly request the same amount of your personal information, our company may charge you a reasonable fee corresponding to the administrative costs.
Right to rectification: You have the right to have your personal data rectified if it is processed incorrectly or inaccurately. It is very important to us that we have the correct information about you. Therefore, if you find that the information which we hold about you is incorrect, inaccurate or incomplete, please let us know and ask for your data to be rectified.
Right to be forgotten: If we process personal data about you in an unlawful manner, e.g. for longer than necessary, or if we process it without justification, you have the right to have it erased (“right to be forgotten”).
Restriction of processing: If you request the rectification of your personal data or object to the erasure of your personal data, if the processing of your personal data is unlawful, or if we no longer need your personal data for the relevant purposes but you may need it to prove or defend your legal claims, or if you have objected to the processing of your personal data on other grounds, we will restrict the processing of your personal data for as long as it is possible to resolve the matter.
Right to object: If you believe that we do not have the right to process your personal data that we process on the basis of legitimate interest of the Company, you can object to the processing. In such cases, we may only continue to process it if we can demonstrate justified reasons that override your interests, rights and freedoms. However, we may always process your personal data if this is necessary for the establishment, exercise or defence of legal claims.
Right to data portability: You have the right to obtain and request from us the transfer of your personal data you have provided to us to another third party, in a structured, commonly used and machine-readable format. However, the right to obtain and portability of personal data applies only to personal data that we have obtained from you on the basis of your consent or on the basis of a contract which you are party to. The right to data portability does not apply to personal data we process about you on the basis of specific legislation.
Right to withdraw consent: You have the right to withdraw the consent you have given us at any time. Withdrawal of consent does not affect the lawfulness of the processing of the personal data obtained prior to the withdrawal.
Right to object to direct marketing: If you object to the processing of your personal data for the purposes of direct marketing, we will stop processing your personal data for this purpose.
Right to complain: If you believe that we are processing your personal data unfairly or unlawfully, you can lodge a complaint with the supervisory authority, which is the Office for Personal Data Protection of the Slovak Republic, https://dataprotection.gov.sk, Hraničná 12, 820 07 Bratislava 27; Phone no.: +421 /2/ 3231 3214; Email: statny.dozor@pdp.gov.sk.
In case of any questions regarding the processing of your personal data, please contact us at:
Via the post: Immocap, a.s., Plynárenská 7/C 821 09 Bratislava, Slovakia
Via email at: immocap@immocap.sk.
The information we are required to provide to you in respect of the personal data processing may change or cease to be up to date. For this reason, we reserve the right to modify this Policy. In the event that we change this Policy in a material way, we will bring that change to your attention. The up-to-date version of this Policy will always be available on our website at www.immocap.sk.