Privacy Policy

GENERAL INFORMATION

These Terms of Use of the Personal Data (hereinafter as „Privacy Policy“) become valid and effective as of 25 May, 2018 and they regulate your private information and data. We kindly ask you to get acquainted with the Privacy Policy.
This Privacy Policy systematically describes principles and rules for processing of the personal data by a limited liability company Nuatri s.r.o., with its seat at A. Jiráska 39, 984 01 Lučenec, Slovak Republic, Identification No.: 51 280 779, registered in the Commercial Registry maintained with the District Court Banská Bystrica, Section: Sro, File No.: 33376/S (hereinafter as the „Operator“) related to the provision of Operator´s services on the portal www.locals4friends.com (hereinafter referred to as the „Website“).
The Operator shall process the Personal Data in accordance with the 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 (General Data Protection Regulation) as of 27 April 2016 (hereinafter as „Regulation“) and other relevant generally binding legal regulation on protection of basic rights and fundamental freedoms to which all human beings are entitled, mostly on protection of their personal data and privacy.
Personal Data means any information related to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
The Data Subject means a natural person, personal data of whom are processed by the Operator in connection to the services provided by the Operator on Website.
The Controller means the Operator as a subject that determines the purposes and means of the processing of personal data and as a subject that processes personal data of a data subject on its behalf.
Privacy Policy is considered as fulfillment of the information duty of the Operator in respect to the relevant data subjects in accordance with Article 13 of the Regulation. The Privacy Policy is also published and accessible without any limitation on the Portal.

WHAT IS A LEGAL GROUND AND PURPOSE OF PERSONAL DATA PROCESSING?

8. An active confirmation/approval of the Privacy Policy and following submission of the registration or any other request for provision of services on the Portal is considered as:

An approval of the personal data processing for the purposes as defined herein and in accordance with the Regulation,
A confirmation of the full acknowledgement of this Privacy Policy,
A confirmation that the provided Personal Data are accurate and actual,
A confirmation that the Data Subject is at least 16 years old.

9.The purpose of personal data processing is providing of the Operator´s services on the Portal, including the execution of a relevant agreement for provision of such services by the Operator. The services of the Operator consist mainly of providing the contact information and the communication channel between the Traveler, the Local and the Provider. As to the scope of the services provided by the Operator, the detailed information on scope, nature and terms are provided in the documents published on the Portal, including the Pre-contractual information, General Terms and Conditions for Locals, General Terms and Conditions for Travelers, Services’ Description for Locals and Services’ Description for Travelers.

10. The e-mailing of news or any other notifications related to the services of the Operator to the e-mail address provided by the data subjects is also understood as a purpose connected to provision of the Operator´s services.

11. The analysis and statistics of provided services, executed for the purpose of improving the provided services and the Portal, is also understood as a purpose connected to the provision of Operator´s services.

12. Personal data processing is necessary for the following purposes:

Direct marketing, including the profiling in the scope as it is necessary in connection to the direct marketing, which is in accordance with Recital 7 of the Regulation understood as a legitimate interest of the Operator. This means that the Operator (as a controller) is entitled to process the personal data provided also for the purpose of the direct marketing. The Operator may therefore send e-mails of the commercial nature related to the services provided on the Portal to the data subjects.
Effective marketing communication, including the profiling in the scope as it is related to such purpose means that the Operator (as a controller) is entitled to display advertisement related to the services provided on the Portal to the data subjects that is relevant and that corresponds with the preferences of the data subjects presumed by their online activities.

13. Personal data processing may be necessary also for the purpose of fulfilling the obligations imposed by the Regulation and/or other generally binding legal regulations.

14. Personal data processing may be necessary also for the following legitimate interests of the Operator:

Judicial and extra-judicial claims and proceedings of the Operator,
A prevention of criminal offences and illegal activities, notification and evidencing thereof, cooperation with the criminal and administrative offences investigation bodies, courts and other public bodies,
Protection of the Portal and the information infrastructure of the Operator and prevention of abuse of the services provided by the Operator,
Any other legitimate interest of the Operator or third party as defined in the Regulation.

15. The Operator (as a controller) may process your personal data for a purpose other than described in this Privacy Policy only if you as a data subject expressly agree with such personal data processing, or if such personal data processing for other purposes is in compliance with the original purpose of personal data processing. Personal data processing for archiving or statistics purposes in accordance with the Regulation and act No. 18/2018 Coll. on personal data protection as amended is understood as a personal data processing compliant with the original purpose. When processing the personal data for archiving and statistic purposes, the Operator applies adequate and effective operating and organizational measures that guarantee minimization (and if possible also) pseudonymisation (personal data shall not be attributed to a natural person without use of the additional information maintained separately) or anonymisation (personal data may not be attributed to a natural person, and therefore your identification shall not be possible).

WHAT IS THE SCOPE OF THE PROCESSED PERSONAL DATA

16. The Operator processes your personal data only in the scope necessary for purpose of their processing, as follows:

a. If you register as Traveler:

E-mail address,
Password,
Name and surname,
Gender,
Localization data,
Data on log-in to the registered profile,
Data on visits and activities on the Portal,
IP address,
Data from Cookies files;

b. If you register as Local:

E-mail address,
Password,
Name and surname,
Gender,
Localization data,
Profile photograph,
Phone number,
Data on log-in to the registered profile,
Data on visits and activities on the Portal,
IP address,
Data from Cookies files,
Any other personal data on your social, cultural or other identity (e.g. data on your interests, hobbies, skills, etc.), provided as part of your offer in your profile on the Profile.

17. By accepting this Privacy Policy and by registration as a Local, you also agree with the publication of your first name (but not your surname), photograph and other personal data included in your profile and your offer on the Portal to the third persons. By accepting this Privacy Policy you also confirm that you provide the information included in your offer voluntarily, on your own behalf and at your own liability. In case your offer includes any personal data of a third person, you expressly confirm that the concerned third person provided you his/her approval for use and publication of his/her personal data.

18. Cookie files. The Operator uses cookie files on the Portal. You can accept the cookie files on the Website by clicking „OK” in the window shown automatically on the screen on the Portal.

What are the cookies and how are they used by the Operator?

A cookie is a small piece of data sent from a Website and stored on your computer, mobile phone or other device. Cookies used by the Operator enable the Website to recognize you and to access the requested services. By using the cookies, the Website may also remember your internet browser setting, your password, communication language etc. Your next visit on the Website may be therefore faster and more comfortable. Website browsing without the cookie files is less comfortable (permanent cookies). Cookies also help the Operator to improve its services and modify them to your preferences and needs. Cookies also enable the Operator to analyze and statistically evaluate use of services on Website and consequently to improve design, functions and content of the Website (operational cookies).

How to manage and erase the cookies?

Internet browsers generally automatically accept the cookies in the pre-defined setting. In the settings of your internet browser, you can either fully block the cookies or you can select the cookies that may be used. You can also erase already remembered cookies on your device. If you wish to block the Operator from using its cookies on your device, you can manage its settings so that it refuses the cookie used by the Operator or that it informs you when the Website tries to remember cookies on your device. However, if you fully refuse the use of cookies, the Website may be visited, but some of its features may not operate correctly. Therefore the Operator advices you to keep the cookies activated. Information on internet browsers and management of cookies therein is provided here:

Chrome: https://support.google.com

Firefox: https://support.mozilla.org

Internet Explorer: https://support.microsoft.com

Safari: https://www.apple.com

HOW LONG ARE THE PERSONAL DATA STORED?

19. The processed personal data are stored in the necessary scope and in the form that enables your identification no later than until the purpose of the processing is met in accordance with this Privacy Policy. Consequently, the Operator shall enable a removal of your personal data in accordance with the Regulation (by erasing or by anonymization).

ARE THE PROCESSED PERSONAL DATA PROTECTED? WHO CAN RECEIVE THEM?

20. Your personal data are secure because they are processed automatically in the information system of the Operator, while using the adequate technical and organizational measures that guarantee security of personal data, including their protection against unauthorized or illegal processing, accidental loss of personal data, erasure or damage of personal data. The Operator is entitled to charge a third person as a processor of the personal data by a conclusion of a separate written agreement; such processor shall have adequate personal, technical, organizational and professional measures and skills that guarantee the personal data processing on behalf of the Operator is in accordance with the Regulation.

21. The Operator is entitled to provide your personal data in the necessary scope to the following recipients:

Persons (entities) that advice on judicial and non-judicial establishment, exercise or defense of claims of the Operator, in the scope necessary for submission and application of such claims;
Courts and other judicial authorities, executors, criminal offence authorities or any other public authorities, for the purpose of establishment, exercise or defense of Operator´s claims, or for the purpose of obliging to the obligations of the Operator imposed by the valid legal regulations;
Persons included in the corporate structure of the Operator;
Persons providing the technical support to the Operator in connection to the Portal, services provided thereon, and its information system structure;
Persons providing protection and security services to the Operator in connection to the Portal, services provided thereon and its information system structure, including its monitoring and testing;
Persons providing analytic and statistic services to the Operator, with the aim of improving the provided services and the Portal;
Persons providing marketing services to the Operator, with the aim of improving the marketing communication of the Operator (for the purpose of clarification, the Operator hereby declares that this category of recipients may not use the personal data for its own marketing purposes or for marketing purposes of third persons).

WHAT ARE YOUR RIGHTS RELATED TO THE PERSONAL DATA PROCESSING?

22. We would like to inform you on your rights and legally relevant facts in respect to the protection of your personal data, as incorporated in the relevant provisions of the Regulation:

The right of access to the personal data (Article 15 of the Regulation),
The right to rectify your personal data by the Operator (Article 16 of the Regulation),
The right to erasure (right to be “forgotten”) of your personal data by the Operator (Article 17 of the Regulation),
The right to restrict processing of your personal data by the Operator (Article 18 of the Regulation),
The right of personal data portability to another controller (Article 20 of the Regulation),
The right to object the personal data processing by the Operator (Article 21 of the Regulation),
The right to complain to the independent supervisory authority, which is for the Slovak Republic: Úrad na ochranu osobných údajov SR (Office for Personal Data Protection of the Slovak Republic), Hraničná 12, 820 07, Bratislava 27 (Section 100 to 103 of the act No. 18/2018 Coll. on Personal Data Protection as amended),
The right to withdraw consent with the personal data processing at any time,
Provision of the personal data – e-mail address, password, name and surname, gender and localization data is necessary for execution of a contract, on grounds of which the services are provided on the Portal to the Traveler. If given personal data are not provided, the contract may not be concluded and the services may not be provided to the Traveler,
Provision of the personal data – email address, password, name and surname, gender, localization data, profile photograph and phone number is necessary for execution of a contract, on grounds of which the services are provided on the Portal to the Local. If the given personal data are not provided, the contract may not be concluded and the services may not be provided to the Local.

23. We expressly inform you about your right to object to processing the personal data, as incorporated in Article 21 of the Regulation, pursuant to which you may:

Object to processing of personal data for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller or third party, including the profiling connected thereof,
Object to processing the personal data for direct marketing on the grounds of a legitimate interest of the Operator, including the profiling in the scope necessary for direct marketing, while personal data may no longer be processed for the purpose of direct marketing upon submission of such objection.

24. We equally expressly inform you that you have the right to withdraw your consent with the personal data processing. Cancellation of your registration on the Portal is also considered as a withdrawal of your consent with the personal data processing. Withdrawal of the consent with the personal data processing has no effect on validity and legality of personal data processing upon previously provided consent. If the consent with personal data processing is withdrawn and no other legal grounds for personal data processing exists (e.g. fulfillment of the contractual obligations, obligations imposed by the generally binding legal provisions or legitimate interest of the Operator), the Operator shall secure the removal (erase or anonymization) of your personal data without undue delay in accordance with the Regulation.

HOW TO CLAIM RIGHTS RELATED TO THE PERSONAL DATA PROCESSING?

25. You can claim your rights or submit questions related to the personal data processing directly with the Operator, or you can contact a person authorized by the Operator to manage the personal data processing. The contact information is as follows:

	Operator	Authorized Representative
Mailing address:	Nuatri, s.r.o., A. Jiráska 39, 984 01 Lučenec, Slovak Republic	Martina Balázsová, A. Jiráska 39, 984 01 Lučenec, Slovak Republic
Email address:	contact@locals4friends.com	contact@locals4friends.com
Phone Number:	421 915 041 200	421 915 041 200

26. By giving consent to the personal data processing as described in this Privacy Policy, you are aware that if your request is manifestly unfounded or excessive, in particular because of its repetitive character, the Operator may (in consideration of the request´s content):

Charge a reasonable fee based on administrative costs for providing such information, or reasonable fee based on administrative costs for execution of the requested measure, or
Refuse to react to such request.

27. By giving consent to the personal data processing as described in this Privacy Policy, you are aware that prior to administration of such request, the Operator shall adequately verify your identity in order to prevent the abuse of your rights. Therefore the Operator may ask you to provide additional information or evidence necessary for such verification of your identity. In case that even such additional verification does not allow the Operator to identify you as a data subject, the Operator shall inform you thereof and it may refuse to process your request.

28. If the Operator does not process your request or processes it inadequately, you may address an independent supervisory authority competent to supervise compliance with the Regulation; such authority competent for the Slovak Republic being: Úrad na ochranu osobných údajov SR (Office for Personal Data Protection of the Slovak Republic), Hraničná 12, 820 07, Bratislava 27. You can address such supervisory authority directly in accordance with relevant provisions of the Regulation.

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