STATEMENT OF THE OPERATOR ON THE PROCESSING OF PERSONAL DATA

In this section, we provide information on the processing and protection of personal data in accordance with Regulation of the EP and Council of the EU No. 2016/679 on the protection of natural persons in the processing of personal data and on the free movement of such data, which repeals Directive 95/46/EC (general regulation on data protection) and Act of the Slovak Republic no. 18/2018 Coll. on Personal Data Protection and Amendments to Certain Acts (hereinafter referred to as the “Personal Data Protection Act”).

The operator of Moje Apps s. r. o. with registered office at Ulica Titusa Zemana 9418/33 Trnava, 917 01, ID: 55862543 (hereinafter referred to as the “operator”), has taken adequate technical and organizational measures to ensure the protection of the rights of the affected persons, which declare the legal processing of personal data. Furthermore, the operator has implemented a transparent system for recording security incidents and any questions from the affected person as well as other persons.

If necessary, the person concerned can also obtain individual information by e-mail: support@mojeapps.sk.

1. Operator

Moje Apps s. r. o.

Ulica Titusa Zemana 9418/33

917 01 Trnava

ID: 55862543

We process your data for our own purposes as an Operator. This means that we determine the purpose for which we collect your personal data, determine the means of processing and are responsible for their proper execution.

2. Intermediaries

In certain cases, the operator may also process the personal data of the affected persons through intermediaries who are authorized to process personal data in accordance with Article 28 of the GDPR Regulation.

Intermediaries process the personal data of the affected persons on behalf of the Operator. The processing of personal data through an intermediary does not have a negative impact on the exercise and application of the rights of the person concerned. The operator only uses intermediaries providing adequate technical, organizational and other measures so that the processing meets the requirements of the GDPR and that the rights of the data subject are fully protected.

The operator uses the following categories of intermediaries when processing the personal data of the persons concerned:

• a supplier providing technical solutions, web hosting services, maintenance and support of IT systems used by the Operator
• a supplier providing services in the field of accounting and tax obligations of the Operator

Categories of recipients of personal data: persons acting on the authority of the operator, legal representative, auditor, bodies of state administration and public authority for the exercise of control and supervision.

3. Purpose of personal data processing

As an operator, we exclusively process personal data that we can substantiate with a legitimate legal basis and defined purposes:

• when responding to an inquiry, initiative or question submitted physically, by telephone or in the form of electronic/paper mail, for the purpose of a feedback directed to the satisfaction of the person concerned, we apply the legal basis of processing Art. 6 par. 1 letter f) GDPR regulations – legitimate interest of the operator. As a data subject, you have the right to object to such processing at any time.
• when showing interest in our services or products, when establishing cooperation, the legal basis for data processing is Art. 6 par. 1 letter b) GDPR regulations – when data processing is necessary for the implementation of the necessary measures before the conclusion of the contract, i.e. during the pre-contractual relationship process.
• after the establishment of a contractual relationship between the operator and the affected person, with the necessary cooperative communication, data processing takes place again in accordance with Art. 6 par. 1 letter b) Regulations of the GDPR, which is necessary for the fulfillment of the contractual relationship.
• in the event that you are looking for a job and would like to work for our company, you can leave us your CV with a motivation letter based on your consent to the processing of personal data in accordance with Art. 6 par. 1 letter a) GDPR regulations. We include the data received in this way in the register of job applicants. You can revoke your consent at any time.

4. Time of processing and storage of your personal data

Your personal data that we have processed or are processing in accordance with Art. 6 par. 1 letter b) GDPR regulations – as part of fulfilling the obligations of the operator, we further process for the purpose of fulfilling our legal obligations in the area of taxes and accounting, which result from generally binding legal regulations (e.g. keeping individual accounting records and invoicing in accordance with Act No. 431/ 2002 Coll. on accounting as amended, for cases of proof of compliance with tax obligations in accordance with tax legislation Act No. 595/2003 Coll. on income tax, Act No. 563/2009 Coll. tax administration, etc.), we must keep it for the period specified by the relevant legal regulations. In any case, we follow the principle of minimizing the storage of personal data in accordance with Art. 5 par. 1 letter e) GDPR regulations and therefore your personal data, which are not subject to archiving according to special legal regulations, will be deleted or anonymized.

Personal data processed in accordance with Art. 6 par. 1 letter a) GDPR regulations – on the basis of consent granted, e.g. with the inclusion of the affected person in the register of job applicants, or for the purpose of sending current marketing news, we process for a period of 3 years, or until it is revoked. In the case of the end of the data processing period, we will contact the affected person, when consent to the processing of personal data for a defined purpose can be renewed and extended for the next processing period. If the person concerned does not give consent for the following period, or does not respond to the contact made, we will no longer process the personal data of the person concerned – i.e. we automatically remove the data from the records, technically delete the electronic data from the systems and shred the physical data.

Personal data processed in accordance with Art. 6 par. 1 letter f) Regulations of the GDPR – on the basis of legitimate interest, which were obtained in response to a submitted inquiry/suggestion or question for the purpose of a feedback aimed at satisfying the person concerned and were not subsequently transferred to a pre-contractual or contractual relationship after processing, are deleted without delay.

As the Operator, we will ensure the deletion of personal data without undue delay after: all contractual relations between you and us as the operator have been terminated; and/or

• all your obligations towards the operator have ceased; and/or
• all your complaints and requests have been dealt with; and/or
• all other rights and obligations between you and us as the operator have been settled; and/or
• all the purposes of processing established by legal regulations or the purposes of processing for which you have given us your consent have been fulfilled, if the processing took place on the basis of the consent of the person concerned; and/or
• the period for which the consent was granted has passed or the person concerned has withdrawn his consent; and/or
• the request of the affected person for erasure of personal data was granted and one of the reasons justifying the granting of this request was fulfilled; and/or
• a decisive legal fact has occurred for the termination of the purpose of processing and at the same time the protective retention period defined with regard to the principle of minimizing the period of storage of personal data has expired;
• and at the same time the legitimate interest of the operator does not exist, all obligations established by generally binding legal regulations that require the storage of the personal data of the person concerned (especially for the purposes of archiving, performing tax audits, etc.) or which would not be able to be fulfilled without their storage have ceased to exist.

In no case do we systematically process any randomly obtained personal data further for any purpose defined by us. If possible, we will inform the affected person to whom the accidentally obtained personal data belong about their accidental acquisition and, depending on the nature of the case, we will provide him with the necessary cooperation leading to the restoration of control over his personal data. Immediately after these necessary actions aimed at resolving the situation, we will immediately dispose of all accidentally obtained personal data in a secure manner.

If you are interested in further information about the specific storage period of your personal data, please contact us using the contact details provided.

5. Disclosure of Data

Our company does not publish the obtained data under any circumstances.

6. Cross-border transfer of personal data

Cross-border transfer is not implemented.

7. Rights and obligations of the person concerned

• The person concerned is obliged to provide only complete and true data.
• The affected person undertakes to update his/her data in the event of a change, at the latest before the first order following the change is made.
• The person concerned undertakes that if he provides personal data of a third person (name, surname, telephone number), he does so only with his consent and that the person concerned is familiar with the procedures, rights and obligations listed on this page.
• As a data subject, you have the right to decide on the handling of your personal data within the specified scope. You can exercise the aforementioned rights in person at the Operator’s headquarters or by phone – in writing (by mail / e-mail).

We will try to answer you as soon as possible, but we will always answer you no later than 30 days after receiving your request. Applicable legal regulations and the GDPR Regulation, or The law ensures you in particular:

Right of access  – You have the right to request confirmation from us as to whether your personal data is being processed and, if so, to obtain a copy of this data and additional information pursuant to Art. 15 Regulations, or § 21 of the Act. In the event that we obtain a large amount of data about you, we may require you to specify your request for the range of specific data that we process about you.

Right to rectification – In order for us to continuously process only up-to-date personal data about you, we need you to notify us of any changes as soon as possible. If we process incorrect data about you, you have the right to request their correction.

Right to erasure – If the conditions of Article 14 of the Regulation are met, or § 23 of the Act, you can request deletion of your personal data. You can therefore request deletion, for example, if you have revoked your consent to the processing of personal data and there is no other legal basis for processing, or in the event that we process your personal data illegally, or the purpose for which we processed your personal data has expired and we do not process it for another compatible purpose. However, we will not delete your data if it is necessary to demonstrate, exercise or defend legal claims.

The right to limit processing – If the conditions of Article 18 of the Regulation are met, or § 24 of the Act, you can request us to limit the processing of your personal data. You can therefore request a restriction, for example, when you dispute the correctness of the processed data or in the event that the processing is illegal and you do not want us to delete the data, but you need their processing to be limited while you exercise your rights. We continue to process your data if there are reasons to prove, exercise or defend legal claims.

Right to portability – If the processing is based on your consent or carried out for the purpose of fulfilling a contract concluded with you and at the same time carried out by automated means, you have the right to receive from us your personal data, which we have obtained from you in a commonly used machine-readable format. If you are interested in this and it is technically possible, we will transfer your personal data directly to another operator. This right will not be applicable to processing carried out for the purpose of fulfilling a task carried out in the public interest or in the exercise of public authority.

The right to object to processing – If we process your personal data for the purpose of fulfilling a task carried out in the public interest or in the exercise of public authority entrusted to us, or if the processing is carried out on the basis of our legitimate interests or the legitimate interests of a third party, you have the right to object to such processing. Based on your objection, we will limit the processing of personal data and unless we demonstrate serious legitimate reasons for processing that outweigh your interests, rights and freedoms or reasons for proving, exercising or defending legal claims, we will not continue to process personal data and we will delete your personal data. You have the right to object at any time to the processing of personal data for direct marketing purposes, including profiling to the extent that it is related to such direct marketing. After raising an objection, we will no longer process your personal data for this purpose.

The right to file a complaint – If you believe that the processing of your personal data is contrary to the Regulation, or By law, you have the right to file a complaint with one of the relevant supervisory authorities, especially in the member state of your habitual residence, place of work or in the place of the alleged violation. For the territory of the Slovak Republic, the supervisory authority is the Office for the Protection of Personal Data, with registered office: Hraničná 4826/12, 820 07 Bratislava, Slovak Republic, website: www.dataprotection.gov.sk, phone: +421 /2/ 3231 3220.

Right to withdraw consent – If the processing of your personal data is based on consent, you have the right to withdraw this consent at any time. Withdrawal of consent does not affect processing already carried out. If at any time later you decide that you are interested in receiving business and marketing offers about our products and services from us again, you can re-grant your revoked consent (or objection) at any time, using any of the above-mentioned forms of contact.

8 . Contact details of the Office and the responsible person

Personal Data Protection Office of the Slovak Republic

Address:

Hraničná 12

820 07, Bratislava 27

Slovak republic

ID: 36 064 220

Registration office:

Monday – Thursday: 8:00 – 15:00

Friday: 8:00 – 14:00

Telephone consultations in the field of personal data protection:

Tuesday and Thursday from 8:00 a.m. to 12:00 p.m. +421 2 323 132 20

Secretariat of the head of the office +421 2 323 132 11

Secretariat of the office +421 2 323 132 14

Fax: +421 2 323 132 34

Spokesperson:

mobile: 0910 985 794

e-mail: hovorca@pdp.gov.sk

E-mail :

1. a) generally: dozor@pdp.gov.sk
2. b) for providing information according to Act no. 211/2000 Coll.: info@pdp.gov.sk
3. c) website: webmaster@pdp.gov.sk
4. d) for submitting requests for the provision of information pursuant to Act no. 211/2000 Coll. about free access to information, use the online form.
5. e) email address through which the Office will provide you with advice in the field of personal data protection. It is intended for children, youth, students, teachers, parents who suspect that their personal data has been misused: ochrana@pdp.gov.sk

You can find a sample proposal for the initiation of personal data protection proceedings on the website of the Office (https://dataprotection.gov.sk/uoou/sk/content/konanie-o-ochrane-osobnych-udajov).