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Protection of Personal Data
CONDITIONS FOR PROCESSING PERSONAL DATA
These conditions for the processing of personal data (hereinafter referred to as the “Conditions”) describe the way in which the company Accencis s. r. o., Registration ID: 53 241 967, with its registered office at Na Bráne 8665/4, 010 01 Žilina, Slovak Republic, registered in the Commercial Register of the District Court Žilina, Section: Sro, Insert No.: 85459/L (hereinafter referred to as the “Company” or “we”) processes your personal data for the purpose of providing our services, which mainly consist of providing marketing consultancy, strategic planning, and setting up marketing campaigns during the “Initial Session,” “Workshop,” and/or “Consulting,” in person, by phone, or via video conference (hereinafter referred to as the “Services”) on the website www.adrianfric.com/ (hereinafter referred to as the “Website”) as well as through other means of remote communication, especially social networks Instagram, X, and LinkedIn (hereinafter referred to as the “Social Networks”).
The Company is responsible for the processing of personal data in accordance with 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, and repealing Directive 95/46/EC (hereinafter referred to as the “GDPR”) and Act No. 18/2018 Coll. on the protection of personal data and on the amendment and supplementation of certain laws as amended (hereinafter referred to as the “Act”).
The Company has taken all appropriate technical and organizational measures to ensure the protection of personal data. Through these Conditions, the Company fulfills its information obligation under Articles 13 and 14 of the GDPR. We regularly update and publish the Conditions on the Website.
If you have any questions regarding these Conditions, the processing of your personal data, or the exercise of your rights under the GDPR and the Act, you can contact us by email: hello@adrianfric.com or by post at our registered office address.
WHAT ARE PERSONAL DATA AND WHY DO WE PROCESS THEM?
Personal data is any information by which you can be identified as a natural person or that is specific to you. Processing of personal data is any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.
The processing of personal data is necessary for us to provide the Services and fulfill various legal and contractual obligations.
WHAT INFORMATION DO WE COLLECT AND FOR WHAT PURPOSE?
We collect the following personal data (hereinafter referred to as “Personal Data”) about you, depending on how and to what extent you use our Website and/or Services:
| Purpose of Processing | Legal Basis for Processing | Processed Personal Data | Obligation/Voluntariness of Providing Personal Data | Retention Period |
|---|---|---|---|---|
| Online Sale of Services (Initial Session, Workshop, Consulting) | Article 6(1)(b) GDPR (contract performance with the data subject) | common personal data (e.g., title, name, surname, email) | provision of personal data is voluntary | 4 years from the end of the contractual relationship |
| Provision of Services | Article 6(1)(b) GDPR (contract performance with the data subject) | common personal data (e.g., title, name, surname, email, position, phone number, Teams/Skype/Zoom ID) | provision of personal data is voluntary | 4 years from the end of the contractual relationship |
| Company Presentation in the Online Environment (i.e., Website, Social Networks, conferences, taking photographs, and audiovisual recordings) including publishing your testimonials about Services | Article 6(1)(a) GDPR (consent of the data subject) and Article 6(1)(f) GDPR (legitimate interest of the Controller) | various types of common personal data provided by you in the online environment (e.g., photo, audiovisual recording, title, name, surname, position, email, phone number) | provision of personal data is voluntary | according to the type of legal basis for processing, either the duration of the consent or until a legitimate objection to processing is filed |
| Sending marketing communications and promotional newsletters | Article 6(1)(a) GDPR (consent of the data subject) and Article 6(1)(f) GDPR (legitimate interest) | common personal data (e.g., title, name, surname, email, position) | provision of personal data is voluntary | according to Article 6(1)(a) GDPR – duration of consent. According to Article 6(1)(f) GDPR – 4 years from the end of the contractual relationship or until the right to object to marketing information is exercised |
| Communication with a person who filled out the contact form on the Website or sent a message on Social Networks | Article 6(1)(a) GDPR (consent of the data subject) | common personal data (e.g., title, name, surname, email, phone number, position, communication content, any other necessary data you choose to provide in communication) | provision of personal data is voluntary | 90 days from the day the respective inquiry is handled |
| Handling complaints | Article 6(1)(c) GDPR (compliance with a legal obligation, especially under Act No. 250/2007 Coll. on consumer protection as amended and Act No. 40/1964 Coll. Civil Code) | common personal data (e.g., title, name, surname, email, phone number, address, and IBAN) | provision of personal data is mandatory – it is a legal requirement under the relevant legal regulations | during the archival period required by specific legal regulations and supervisory authorities |
| Processing cookies on the Website | Article 6(1)(a) GDPR (consent of the data subject) and Article 6(1)(f) GDPR (legitimate interest of the Controller) | common personal data | provision of personal data is voluntary | depending on the category of cookies |
| Protection of Company’s legal claims | Article 6(1)(f) GDPR (legitimate interest) | common personal data (e.g., title, name, surname, address, contact email and phone number, existence of employment or other relationship with the person making a legal claim against the Company and work position) | provision of personal data is voluntary | until the out-of-court settlement of the dispute or until the final decision of the court or other authority in the case |
| Managing own corporate agenda | Article 6(1)(a) GDPR (consent of the data subject) | common personal data mentioned in corporate documents (i.e., personal data of statutory bodies, persons authorized to act on behalf of the company) | this is further processing of personal data originally provided for another purpose that is compatible with the original purpose of processing | during the duration of the Company |
| Accounting | Article 6(1)(c) GDPR (compliance with a legal obligation) | common personal data (e.g., business name, place of business, ID, VAT number, bank account number of a sole trader, and the name and surname of the statutory representative of a legal entity) | provision of personal data is mandatory – it is a legal requirement under the relevant legal regulations governing taxes and accounting (e.g., VAT Act, Accounting Act) | 10 years following the year to which they relate |
| Archiving (record-keeping) | Article 6(1)(c) GDPR (compliance with a legal obligation) | common personal data mentioned in record-keeping documents | this is further processing of personal data originally provided for another purpose that is compatible with the original purpose of processing | 10 years following the year to which they relate |
Table 1
Your Personal Data will be processed in accordance with applicable legal regulations and we will protect your Personal Data against misuse and/or unlawful disclosure.
HOW LONG WILL WE PROCESS YOUR PERSONAL DATA?
Unless otherwise provided by applicable legal regulations, we have the right to process your Personal Data in a form that allows your identification for the time necessary to achieve the purpose for which the Personal Data was provided (this may include the period during which you visit our Website or use our Services and/or for the entire duration of the purpose of processing Personal Data), unless otherwise stated and for the length stated in Table 1, specifically according to the purpose of processing Personal Data.
We also have the right to process your Personal Data for a period longer than stated in Table 1 if necessary to fulfill our legal obligations, to demonstrate, exercise, or defend our legal rights (including providing information to third parties to prevent fraud and minimize payment risks).
WHERE DO WE GET YOUR PERSONAL DATA?
When processing Personal Data, we obtain your Personal Data directly from you if you provide it to us (e.g., by sending an email through the contact form on the Website, subscribing to the newsletter, ordering Services on the Website, or directly during your visit to the Website (online identifiers)).
If the Services on the Website are ordered by a company of which you are a representative or contact person, the source of your Personal Data is precisely this company.
HOW DO WE SHARE YOUR PERSONAL DATA?
For the purpose of providing our Website and/or Services (and if necessary given the circumstances), we have the right to provide your Personal Data (and you agree to such provision) in accordance with the principle of data minimization only to a limited circle of persons, namely our employees, subcontractors, officials, advisors, business representatives, suppliers, or affiliated persons of the Company to the extent necessary to achieve the purpose stated in these Conditions, particularly to the following service providers:
| Area | Service Provider | Transfer Outside EEA |
|---|---|---|
| IT Services | IT Service Provider | No |
| Domain and Web Hosting | Domain Registrar and Web Hosting Provider (Websupport s. r. o.) | No |
| Subcontractors | Contractual providers of legal, accounting, and tax services | No |
| Newsletter Distribution | Newsletter platform operator Mailjet (applies only if you have consented to receiving the newsletter) | Yes (USA) |
| Accounting and Taxes | Accounting platform provider (SuperFaktúra) | No |
| Marketing | Providers of marketing tools and platforms (LinkedIn, Instagram, Google) | Yes (USA) |
| Office (email cloud) | Google LLC (Google Mail and Google Cloud) | Yes (USA) |
| Compliance with Legal Obligations | Public authorities | No |
| Online Meeting Scheduling | Online meeting scheduling platform provider Calendly | Yes (USA) |
| Online Payments | Payment processor (Stripe) | Yes (USA) |
Table 2
Furthermore, we may provide your Personal Data:
- to the extent required by applicable legal regulations
- in connection with any ongoing or future legal proceedings, or
- to demonstrate, exercise, or defend our legal rights (including providing your Personal Data to third parties to prevent fraud and minimize payment risks).
Other recipients of your Personal Data include companies operating Social Networks, especially if you contact us via a message on a Social Network, give us consent to publish your testimonial about our Services, or your photograph (companies Meta Platforms Ireland, Twitter International Unlimited Company / X Corp., and LinkedIn Ireland Unlimited Company).
If you visit our Website and give consent to the use of analytical and marketing online tools (so-called “cookies”), your Personal Data will be transferred to the USA to companies Google LLC, Meta Platforms, and LinkedIn Corporation as parent companies of the European service providers we use to measure Website traffic and activity.
For completeness, we state that we use the Google Analytics, Google Ads Remarketing Tag, and Meta Pixel tools on the Website. The Google Analytics and Google Ads Remarketing Tag tools are provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, and the Meta Pixel tool is provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. These tools use cookies to enable analysis of Website use, especially to process information generated by your device about the use of our Website, interactions with our Website, and advertising activities, as well as your IP address, browser information, previously visited websites, and date and time of access, for the purpose of analyzing and graphically displaying the reach of our ads and displaying personalized ads. This may also involve determining whether different end devices belong to you or your household. Through “remarketing,” users of our Website can be re-identified and recognized on other sites within the Google and Meta advertising network (e.g., in Google search or when using Facebook, YouTube, and Instagram). Subsequently, they may be shown ads tailored to their interests. Information generated by cookies (e.g., IP address; time, place, and frequency of Website visits) is transmitted to the USA. You can prevent cookies from being downloaded to your computer by adjusting your internet browser settings. However, this may affect the proper functioning of some Website functions. If any function is not working, it is advisable to check the cookie settings in your web browser. The conditions for processing personal data by Google Inc. can be found here: https://policies.google.com/privacy, and the conditions for processing personal data by Meta Platforms Ireland Limited can be found here: https://www.facebook.com/privacy/policy.
We do not share your Personal Data, which allows your identification or localization, with third parties for direct marketing purposes.
HOW DO WE PROCESS SERVICE ORDERS AND FINANCIAL TRANSACTIONS?
In case of ordering the Service “Initial Session,” “Workshop,” and/or “Consulting,” the scheduling of the meeting at which the ordered Service is to be provided takes place through the “Calendly” platform of Calendly LLC for online meeting scheduling. The conditions for processing personal data by this provider can be found here: https://calendly.com/legal/privacy-notice.
In case of ordering the Service “Workshop” and/or “Consulting,” with the scheduling of the meeting through the “Calendly” platform, the Company’s fee for providing the ordered Service is also paid. All financial operations and transactions for the Services electronically performed through the “Calendly” platform will be processed through the online payment service provider Stripe Technology Europe Limited. The conditions for processing personal data by this provider can be found here: https://stripe.com/en-sk/privacy.
We will provide your Personal Data to online meeting scheduling platform providers and online payment service providers only to the extent necessary to arrange a meeting and process payments for the ordered Services that you perform through our Website, the “Calendly” platform, and payment services of Stripe Technology Europe Limited, for the refund of such payments and handling complaints and inquiries related to such payments and refunds.
WHO PROCESSES PERSONAL DATA ON SOCIAL NETWORKS?
As part of marketing and advertising support, you can find links to Social Networks on the Website. Please note that after clicking on the plugin on the Website and moving to the Social Network, the privacy rules of the social network operator apply, except when you contact us via a message on a Social Network (in which case, the processing of your Personal Data is also governed by these Conditions and we will process your Personal Data in accordance with the information provided above).
Further information on the processing of your Personal Data by Social Network operators can be found at the following links:
- LinkedIn: https://www.linkedin.com/legal/privacy-policy
- Instagram: https://sk-sk.facebook.com/help/instagram/155833707900388/
- X: https://x.com/sk/privacy
We have no control over and bear no responsibility for the terms of processing and procedures of third parties in the field of personal data protection.
DO WE TRANSFER YOUR PERSONAL DATA TO THIRD COUNTRIES?
When processing your Personal Data, we strive to minimize any transfer of Personal Data outside the European Economic Area (hereinafter referred to as the “EEA”). However, in the course of our business activities, we also use global service providers who may transfer Personal Data outside the EEA (as listed in Table 2). In these cases, the Company ensures that the conditions of the GDPR for such processing are met, and the transfer is carried out only based on the existence of a European Commission decision on adequacy according to Article 45 of the GDPR or based on standard contractual clauses according to Article 46(2) of the GDPR (e.g., transfers to the USA).
HOW CAN YOU WITHDRAW YOUR CONSENT?
If we process your Personal Data based on your consent, you can withdraw your consent at any time at your own discretion by email at hello@adrianfric.com or by post at our registered office address.
Withdrawal of consent does not affect the legality of processing based on consent before its withdrawal. Regardless, you have the right to object at any time to the processing of personal data based on legitimate or public interest as well as for direct marketing purposes, including profiling.
WHAT ARE YOUR RIGHTS AND OBLIGATIONS?
You have the right to:
- Access your Personal Data, in particular, to request information about:
- the purpose of processing Personal Data
- categories of processed Personal Data
- recipients to whom Personal Data is provided
- the retention period of your Personal Data
- the right to request from us the correction of Personal Data relating to you, their deletion, or restriction of their processing or the right to object to the processing of Personal Data
- the right to submit a proposal for the initiation of proceedings for the protection of personal data before the Office for Personal Data Protection
- the source of Personal Data if Personal Data were not obtained from you.
The Company will promptly provide you with your Personal Data that it processes in a manner according to your requests. For repeated provision of Personal Data that you request, we may charge a reasonable fee corresponding to the administrative costs.
- Correction of Personal Data If you learn that we are processing your incorrect Personal Data, please inform us of this fact, and we will correct such incorrect data without undue delay. You also have the right to request the completion of incomplete Personal Data.
- Deletion of Personal Data (Right to be Forgotten) We will delete your Personal Data, especially if: (i) the Personal Data are no longer necessary for the purpose for which they were obtained, (ii) you withdraw your consent to the processing of personal data under the conditions stated in these Conditions, (iii) you object to the processing of Personal Data, (iv) we have obtained your Personal Data unlawfully, or (v) we have a legal obligation to delete your Personal Data.In case of deletion of Personal Data at your request, we will also take appropriate security measures to inform other controllers who process your Personal Data of this request, so that these controllers delete references to these Personal Data and their copies or extracts.
- Restriction of Processing of Personal Data You have the right to restrict the processing of your Personal Data if: (i) you dispute the accuracy of the Personal Data for a period that allows us to verify their accuracy, (ii) the processing of your Personal Data is unlawful, and you object to the deletion of Personal Data instead of restricting their use, (iii) we no longer need your Personal Data for processing purposes, but you need them for the establishment, exercise, or defense of legal claims, or (iv) you object to the processing of Personal Data until we verify whether our legitimate reasons outweigh your legitimate interests.If the processing of Personal Data is restricted, except for storage, we process Personal Data only with your explicit consent or for the establishment, exercise, or defense of legal claims, for the protection of persons, or for reasons of public interest.
- Data Portability You have the right to receive from us your Personal Data that we process in a structured, commonly used, and machine-readable format for the purpose of transferring these Personal Data to another controller.
- Object to Processing of Personal Data You have the right to object to the processing of Personal Data for direct marketing purposes, including profiling, to the extent that it is related to direct marketing.
- Initiate Proceedings Before a Supervisory Authority If you suspect that your rights related to the protection of your Personal Data have been violated, you have the right to submit a proposal for the initiation of proceedings before the supervisory authority – the Office for Personal Data Protection, Hraničná 12, 820 07 Bratislava 27, Slovak Republic, https://dataprotection.gov.sk/uoou/sk according to § 100 et seq. of the Act.
DO WE USE AUTOMATED DECISION-MAKING AND PROFILING?
We do not use automated individual decision-making, including profiling, for providing our Services.
DO WE PROCESS PERSONAL DATA OF CHILDREN?
We consider the protection of your children’s privacy to be particularly important. For this purpose, we do not knowingly collect any personal data of persons under the age of 18. If you are under 18, please do not send us any of your Personal Data, including your name, permanent address, phone number, or email address. No person under the age of 18 is authorized to provide their Personal Data on the Website or place an order for Services. If we find that any Personal Data we process relates to a person under the age of 18, and we have not been given the consent of the legal representative of such a person, we will delete such Personal Data without delay. If you suspect that we may be processing information from or about persons under the age of 18, please contact us by email at hello@adrianfric.com, by phone at +421 907 188 008, or by post at our registered office address.
HOW DO WE UPDATE OUR CONDITIONS FOR PROCESSING PERSONAL DATA?
We reserve the right to change these Conditions. If we change the Conditions or processes, we will publish these changes on the Website so that you are always aware of what information we collect, how we use it, and under what circumstances we may disclose it to a third party. It is important that you regularly check these Conditions to ensure that you are aware of any changes.
Last update: 10.07.2024