PROTECTION OF PERSONAL DATA

TERMS OF PERSONAL DATA PROCESSING

These terms of personal data processing (hereinafter referred to as the “Terms”) describe the way in which Accencis s. r. o., Company 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, consisting mainly of marketing consulting, strategic planning, and setting up marketing campaigns as part of the “Initial Session” (in Slovak: “Úvodné stretnutie”), “Workshop” (in Slovak: “Workshop”), and/or “Consulting” (in Slovak: “Konzultácia”), conducted in person, by phone, or in the form of video conferencing (hereinafter referred to as “Services”), on the website www.adrianfric.com/ (hereinafter referred to as the “Website”), as well as through other remote communication channels, particularly social networks Instagram, X, and LinkedIn (hereinafter referred to as “Social Media”).

The Company is responsible for the processing of personal data under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (hereinafter referred to as “GDPR”), and Act No. 18/2018 Coll. on Personal Data Protection and on amendments to certain laws in its currently effective wording (hereinafter referred to as the “Act”).

The Company has implemented all appropriate technical and organizational measures to ensure the protection of personal data. Through these Terms, the Company fulfills its information obligation under Articles 13 and 14 GDPR. The Terms are regularly updated and published on the Website.

If you have any questions related to these Terms, the processing of your personal data, or concerning the exercise of your rights under GDPR and the Act, you can contact us by email at: hello@adrianfric.com or by post at our registered office.

WHAT IS PERSONAL DATA AND WHY DO WE PROCESS IT?

Personal data is any information that can identify you as a natural person or is specific to you.

Processing of personal data is any processing operation or set of processing operations performed on personal data or sets of personal data, particularly collection, recording, organization, structuring, storage, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, regardless of whether it is carried out by automated or non-automated means.

The processing of personal data is necessary on our part mainly to be able 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”), 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 Sales of Services (Initial Session, Workshop, Consulting)	Article 6(1)(b) GDPR (performance of a contract with the data subject)	Basic personal data (e.g., title, name, surname, email)	Voluntary	4 years from the end of the contractual relationship
Provision of Services	Article 6(1)(b) GDPR (performance of a contract with the data subject)	Basic personal data (e.g., title, name, surname, email, position, phone number, Teams/Skype/Zoom ID)	Voluntary	4 years from the end of the contractual relationship
Company Presentation in Online Environments (Website, Social Media, conferences, photographs, audiovisual recordings)	Article 6(1)(a) GDPR (data subject’s consent) & Article 6(1)(f) GDPR (legitimate interest of the Controller)	Various types of personal data provided by you online (e.g., photograph, audiovisual recording, title, name, surname, position, email, phone number)	Voluntary	Based on legal basis: duration of consent or until a legitimate objection is raised
Sending Marketing Communications and Newsletters	Article 6(1)(a) GDPR (data subject’s consent) & Article 6(1)(f) GDPR (legitimate interest)	Basic personal data (e.g., title, name, surname, email, position)	Voluntary	Duration of consent or 4 years from the end of the contractual relationship
Communication via Contact Form or Social Media	Article 6(1)(a) GDPR (data subject’s consent)	Basic personal data (e.g., title, name, surname, email, phone number, position, message content)	Voluntary	90 days from responding to the inquiry
Complaint Handling	Article 6(1)(c) GDPR (compliance with legal obligations)	Basic personal data (e.g., title, name, surname, email, phone number, address, IBAN)	Mandatory	Retention period as required by specific legal regulations
Processing Cookies on the Website	Article 6(1)(a) GDPR (data subject’s consent) & Article 6(1)(f) GDPR (legitimate interest of the Controller)	Basic personal data	Voluntary	Depends on the category of cookies
Protection of the Company’s Legal Claims	Article 6(1)(f) GDPR (legitimate interest)	Basic personal data (e.g., title, name, surname, address, contact email and phone number)	Voluntary	Until an out-of-court settlement is reached or a final legal decision is made
Management of the Company’s Corporate Records	Article 6(1)(a) GDPR (data subject’s consent)	Basic personal data in corporate documents (e.g., personal data of statutory representatives)	Compatible with the original purpose of processing	For the duration of the Company’s existence
Accounting	Article 6(1)(c) GDPR (compliance with legal obligations)	Basic personal data (e.g., business name, Company ID, VAT ID, bank account number)	Mandatory	10 years following the year to which they relate
Archiving (Records Management)	Article 6(1)(c) GDPR (compliance with legal obligations)	Basic personal data in archival records	Compatible with the original purpose of processing	10 years following the year to which they relate

Table No. 1

We will process your Personal Data in compliance with applicable legal regulations and will protect your Personal Data against misuse and/or unlawful disclosure.

HOW LONG WILL WE PROCESS YOUR PERSONAL DATA?

Unless otherwise specified in applicable legal regulations, we have the right to process your personal data in a form that allows your identification for the period necessary to achieve the purpose for which the personal data was provided. This may include the time during which you visit our Website or use our Services and/or for the entire duration of the purpose of processing personal data, unless stated otherwise, for the period specified in Table No. 1, separately according to the purpose of processing personal data.

We also have the right to process your personal data for a longer period than specified in Table No. 1, if necessary, to fulfill our legal obligations, to establish, exercise, or defend our legal rights (including providing information to third parties to prevent fraud and minimize payment risks).

WHERE DO WE OBTAIN 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 via the contact form on the Website, subscribing to the newsletter, ordering a Service on the Website, or directly by visiting our Website (online identifiers)).

If a business entity orders Services on the Website and you are its representative or contact person, the source of your personal data is that company.

HOW DO WE SHARE YOUR PERSONAL DATA?

To enable access to our Website and/or Services, we have the right to provide your Personal Data (and you agree to such provision) in accordance with the principle of minimization only to a limited circle of persons, namely our employees, subcontractors, officers, consultants, business representatives, suppliers, or affiliated entities of the Company, to the extent reasonable and necessary to achieve the purpose stated in these Terms, specifically to the following service providers:

 

Area	Service Provider	Transfer Outside EEA
IT Services	IT service provider	No
Domain & Web Hosting	Domain registrar and web hosting provider (Websupport s. r. o.)	No
Subcontractors	Contracted providers of legal, accounting, and tax services	No
Newsletter Distribution	Newsletter distribution platform provider Mailjet (applies only if you have consented to receiving newsletters)	Yes (USA)
Accounting & 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 Appointment Scheduling	Online scheduling platform provider Cal.com	Yes (USA)
Online Payments	Payment processor (Stripe)	Yes (USA)

Table No. 2

Additionally, we may provide your Personal Data:

a) To the extent required by applicable legal regulations,

b) In connection with any ongoing or future legal proceedings, or

c) To establish, 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 social media platform providers, particularly if you contact us via Social Media, grant us consent to publish your testimonial about our Services, or share a photograph with us (Meta Platforms Ireland, Twitter International Unlimited Company / X Corp., and LinkedIn Ireland Unlimited Company).

If you visit our Website and consent to the use of analytical and marketing online tools (so-called “cookies”), your Personal Data will be transferred to the USA to the companies Google LLC, Meta Platforms, and LinkedIn Corporation, as the parent companies of European service providers we use for measuring traffic and activity on the Website.

For completeness, we note that our Website uses Google Analytics, Google Ads Remarketing Tag, and Meta Pixel.

• Google Analytics and Google Ads Remarketing Tag are provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA.

• Meta Pixel is provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

These tools use cookies to enable the analysis of Website usage, particularly to process information generated by your device regarding:

• Use of our Website

• Interactions with our Website and advertisements

• Your IP address, browser information, previously visited websites, and access time

This data is used for analysis, measurement of ad reach, and displaying personalized ads. It may also determine whether various devices belong to you or your household.

Through remarketing, users of our Website can be re-identified and recognized on other pages within Google’s and Meta’s advertising networks (e.g., Google Search, Facebook, YouTube, and Instagram). Subsequently, personalized ads may be displayed based on your interests.

Information generated by cookies (e.g., IP address, time, location, and frequency of Website visits) is transferred to the USA. You can prevent the downloading of cookies to your computer by adjusting your browser settings. However, this may impact the functionality of certain Website features. If any function stops working, check your browser’s cookie settings.

Terms of Google Inc.’s personal data processing can be found here: Google Privacy Policy

Terms of Meta Platforms Ireland Limited’s personal data processing can be found here: Facebook Privacy Policy

We do not share your personal data that can identify or locate you with third parties for direct marketing purposes.

HOW DO WE PROCESS SERVICE ORDERS AND FINANCIAL TRANSACTIONS?

When ordering a Service such as “Initial Session” (in Slovak: “Úvodné stretnutie”), “Workshop” (in Slovak: “Workshop”), and/or “Consulting” (in Slovak: “Konzultácia”), the scheduling of the session where the ordered Service will be provided is conducted through the “Cal.com” platform, operated by Cal.com, Inc., a company specializing in online appointment scheduling. The terms of personal data processing by this provider can be found here: Cal.com Privacy Policy.

If you order the “Workshop” or “Consulting” service and schedule an appointment via Cal.com, the payment for the Service will be required. All financial transactions and payments for Services made electronically via “Cal.com” will be processed through the online payment service provider: Stripe Technology Europe, Limited. The terms of personal data processing by this provider can be found here: Stripe Privacy Policy.

We will provide your Personal Data to the online scheduling platform provider and online payment service provider only to the extent necessary for:

• Scheduling an appointment

• Processing payments for the ordered Services via our Website, Cal.com, and the Stripe payment system

• Refunding payments if necessary

• Handling complaints and queries related to these payments and refunds

WHO PROCESSES PERSONAL DATA ON SOCIAL MEDIA?

For marketing and advertising purposes, our Website contains links to Social Media platforms. Please note that upon clicking on a plugin on our Website and being redirected to a Social Media platform, the privacy policies of the social network provider apply—except in cases where you contact us via a direct message on Social Media. In such cases, your Personal Data processing is also governed by these Terms, and we process your Personal Data in accordance with the information provided above.

For more details on how Social Media providers process your Personal Data, please refer to the links below:

LinkedIn: LinkedIn Privacy Policy
Instagram: Instagram Privacy Policy
X (Twitter): X Privacy Policy

We have no control over and bear no responsibility for the personal data processing conditions and practices of third-party Social Media providers.

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 (EEA). However, in the course of our business operations, we utilize global service providers, who may transfer Personal Data outside the EEA (as listed in Table No. 2).

In such cases, the Company ensures that GDPR compliance is met for such processing and transfer, which takes place only based on:

• A decision of the European Commission on adequacy, in accordance with Article 45 GDPR, or

• Standard contractual clauses for data protection, in accordance with Article 46(2) GDPR (e.g., transfers to the USA).

HOW CAN YOU WITHDRAW YOUR CONSENT?

If we process your Personal Data based on your consent, you may withdraw your consent at any time at your own discretion by sending an email to: hello@adrianfric.com or by post to our registered office.

Withdrawal of consent does not affect the lawfulness of personal data processing based on consent before its withdrawal. Regardless, you have the right to object at any time to the processing of your Personal Data based on a legitimate or public interest, as well as for direct marketing purposes, including profiling.

WHAT RIGHTS AND OBLIGATIONS DO YOU HAVE?

You have the right to:

A. Access Your Personal Data

You may request information about:

a) The purpose of processing your Personal Data,

b) The categories of processed Personal Data,

c) The recipients to whom your Personal Data is provided,

d) The retention period of your Personal Data,

e) The right to request correction, deletion, or restriction of Personal Data processing, or the right to object to Personal Data processing,

f) The right to file a complaint with the Data Protection Authority,

g) The source of your Personal Data if it was not obtained directly from you.

The Company will promptly provide you with your Personal Data, which we process, in a manner according to your request. For repeated requests, we may charge a reasonable fee covering administrative costs.

B. Rectification of Personal Data

If you find that we process incorrect Personal Data, please inform us, and we will correct it without undue delay. You also have the right to request completion of incomplete Personal Data.

C. Erasure of Personal Data (Right to be Forgotten)

We will delete your Personal Data particularly if:

(i) The Personal Data is no longer needed for the purpose for which it was collected,

(ii) You withdraw your consent under the conditions stated in these Terms,

(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.

If we erase your Personal Data upon your request, we will also take reasonable security measures to inform other controllers processing your Personal Data about this request so that they can delete any links, copies, or replications of the Personal Data.

D. Restriction of Personal Data Processing

You have the right to request restriction of processing in the following cases:

(i) If you challenge the accuracy of the Personal Data, for a period allowing us to verify its accuracy,

(ii) If the processing is unlawful, but instead of deletion, you oppose the erasure of the Personal Data,

(iii) If we no longer need the Personal Data, but you require it for establishing, exercising, or defending legal claims,

(iv) If you object to the processing, until we determine whether our legitimate interests override your rights.

If Personal Data processing is restricted, we will only store the Personal Data and process it with your explicit consent, or for the purpose of legal claims, protecting individuals, or for public interest reasons.

E. Data Portability

You have the right to receive your Personal Data processed by us in a structured, commonly used, and machine-readable format, so you can transfer it to another data controller.

F. Object to Personal Data Processing

You have the right to object to the processing of Personal Data for direct marketing purposes, including profiling, to the extent that it relates to direct marketing.

G. File a Complaint with the Data Protection Authority

If you suspect that your rights related to the protection of your Personal Data have been violated, you have the right to file a complaint with the Data Protection Authority:

Office for Personal Data Protection
Hraničná 12, 820 07 Bratislava 27, Slovak Republic
Data Protection Authority Website

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, in providing our Services.

DO WE PROCESS CHILDREN’S PERSONAL DATA?

We consider the privacy protection of children to be especially important. Therefore, we do not knowingly collect any Personal Data from persons under the age of 18.

If you are under 18 years old, please do not send us any Personal Data, including:

• Your name

• Your permanent address

• Your phone number

• Your email address

No person under 18 years old is authorized to enter their Personal Data on the Website or place an order for Services.

If we discover that any Personal Data we process relates to a person under 18 years old and we have not received parental consent, we will delete the Personal Data without delay.

If you suspect that we may have processed information from or about a person under 18 years old, please contact us via:

Email: hello@adrianfric.com
Phone: +421 907 188 008
Postal Address: Our registered office

HOW DO WE UPDATE OUR TERMS OF PERSONAL DATA PROCESSING?

We reserve the right to modify these Terms. If we change the Terms or our processing procedures, these changes will be published on our Website, ensuring that you are always informed about:

• What information we collect

• How we use it

• Under what circumstances we may share it with third parties

It is important that you regularly review these Terms to stay informed about any updates.

Last updated: July 10, 2024