Personal data processing principles of RXD, s.r.o.
Based: Nam. Hraničiarov 1, 851 03 Bratislava
identification number: 36692000
registered in the Commercial Register maintained by the OS in Bratislava, Section Sro, Insert 42911/B(hereinafter referred to as „Administrator").
Address. Nam. Hraničiarov 1, 851 03 Bratislava
The processing of personal data is carried out 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 „GDPR"), the Personal Data Processing Act and Act No. 480/2004 Coll., on certain services of the information society, as amended.
1. DEFINITION OF TERMS
1.1. Data subject: The natural person (both consumer and self-employed person) to whom the personal data relates (hereinafter also „you“ or „customer“);
1.2. Personal Information: Any information about an identified or identifiable customer; An identifiable customer is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, a network identifier or to one or more specific elements of that natural person's physical, physiological, genetic, psychological, economic, cultural or social identity (hereinafter referred to as „data“);
1.3. Controller: The entity that determines the purpose and means for the processing of personal data, carries out the processing and is responsible for that processing. The controller of personal data is the company RXD, s.r.o., ID No.: 36692000 (hereinafter referred to as „Controller“);
1.4. Processor: The Entity that processes personal data for the controller on the basis of the law or on behalf of the controller, on the basis of the personal data processing agreement (hereinafter referred to as „processor" or „business partner");
1.5. Website:Website available at www.thestreets.eu
1.6. Purpose of personal data processing: The reason of personal data processing. Such reason may be, for example, to perform a contract, manage user accounts, handle complaints, send commercial communications or display advertisements based on customer interests;
1.7. Scopeof personal dataprosessing: Enumeration of specific categories of customer personal data processed for a specific purpose;
1.8. Cookies: Short text files stored by your web or mobile browser. Most cookies contain a unique identifier, called a cookie ID. This is a string of characters assigned by websites and servers to the browser that stored the cookie. This allows websites and servers to distinguish and identify individual browsers. Cookies are used to improve the performance of websites, to evaluate their traffic and to better target marketing activities. If you browse our website, we assume that you consent to the use of these cookies.
2. WHAT PERSONAL DATA IS PROCESSED?
2.1 The Controller and its contract processors process the following personal data or categories of personal data in relation to the relevant legal title and purpose of processing:
a) identification and address data: e.g. name, surname, delivery or other contact address, address of the collection place, registered office, business registration number, VAT number;
b) electronic contact data: e.g. telephone number, e-mail address;
c) other electronic data: IP address processed by means of the so-called cookies;
d) other personal data related to the contractual relationship: bank account number, order history;
e) other personal data: typically the data provided by the customer in the order form or in other documents and when communicating with us, including subsequent updates.
3. WHAT IS THE SOURCE OF PERSONAL DATA?
3.1 We process the data you provide to us, e.g. when ordering our services, registering a user account, communicating with us. Usually this includes:
a) identification and address data;
b) electronic contact details;
c) other personal data related to the contractual relationship.
3.2. And further, data that we collect automatically based on your browsing of our website. Usually this includes:
other electronic data:
• the website from which you came to our website;
• IP address;
• date of access and time of access;
• search queries;
• http and https response code;
• transmitted data groups;
• information about the browser and operating system of the computer.
4. WHY IS PERSONAL DATA SHARED?
4.1 Your personal data may be processed for the following purposes:
a) Contract conclusion and performance of the contractual relationship
Purpose: You are entitled to the goods you have ordered under your contract with us. In return, we are entitled to payment of the agreed price. In order for us to fulfill our part and check that your part of the commitment has been fulfilled, we need to process your identification and address data, contact details and other personal data associated with the contractual relationship (e.g. account number).
Legal basis: The processing of personal data for the purpose of fulfilling the contractual relationship is justified by the contractual relationship between you and us. The provision of personal data in this case is a contractual requirement without which the contract cannot be concluded.
Storage period: The storage period is determined by the duration of the customer's contractual relationship with us.
b) Management of customer accounts
Purpose: Customers can register and manage their personal settings on our website. For this purpose, we need to process your email address, first name, last name and user name. These data are then used to facilitate the ordering of our products.
Legal basis: The processing of personal data for the purpose of managing customer accounts is justified by the performance of a pre-contractual measure. In this case, the provision of personal data is voluntary, but it would not be possible to register without it.
Storage period: The data storage period is determined by the duration of the legal scope of the Data Controller. The eventual deletion will take place after not logging into the customer account for more than 3 years.
c) Customer communication, satisfaction evaluation, publication of reviews, handling of complaints.
Purpose: We use your data to manage your enquiries, make product range recommendations, handle suggestions, complaints with our customer support. We may also contact you by requesting you to fill out a satisfaction questionnaire.
We also use your data to notify you of the status of your order and to alert you to any changes to your order (non-payment of the agreed amount, change of delivery, etc.). If you do not complete your order, we may send you an email or SMS reminding you that you have not completed this order. We believe this is a useful service because it allows you to continue with the order you have started and you do not have to re-enter the whole order from the beginning.
We also process your data in cases of exercising your rights from defective performance and in exercising your rights in relation to the processing of your personal data.
Legal Basis: The processing of personal data for the purpose of communicating with customers, evaluating satisfaction, dealing with reports and complaints is justified by our legitimate interest in being able to communicate with customers. The provision of personal data in this case is not a legal or contractual requirement. Thus, you are under no obligation to provide us with your personal data for this purpose.
Storage period: The storage period is determined by the duration of the customer's contractual relationship with us and thereafter for a period of 4 years from its termination.
d) Sending commercial communications and offering our goods
Purpose: We regularly send news about our goods via email to our customers and those who have consented. You can quickly and easily unsubscribe from these commercial communications at any time by using the unsubscribe link included in each communication.
Otherwise, we ask for your consent to receive commercial communications about our goods, promotions and company campaigns. We may use the information you provide to us, as well as information otherwise obtained in connection with our goods – such as information about how you use the website, information about orders you have made or information about your participation in promotions and contests, to personalize our commercial communications. We will ask for your consent to receive commercial communications whenever consent is required by applicable law.
Legal basis: The processing of personal data for the purpose of sending you commercial communications and offering you our goods is justified by your consent or our legitimate interest in direct marketing. The provision of personal data on the basis of your consent is voluntary in this case, but without it it would not be possible to send you commercial communications. You can withdraw your consent at any time. The provision of personal data in this case is not a legal or contractual requirement. You are therefore under no obligation to provide us with your personal data for this purpose.
Storage period: The storage period is determined by the duration of your consent. We will consider your consent withdrawn or your legitimate interest terminated if you do not open our business communications for a period of 5 years.
e) Direct marketing and the creation of personalised content and advertising
Purpose: Personalized content creation and advertising technologies allow us to display to visitors who have already expressed interest in our website or services. We strive to ensure that you are only shown advertising that you are genuinely interested in, and not advertising without any connection to your person and interests. Based on your order history, interests and website behaviour, you may be shown personalised content and offers on our website and on third party websites and applications (including social media). In addition, we are entitled to store other personal data about you for compliance with legal provisions for our own marketing purposes. Furthermore, we would like to assure you that there is no transfer of the stored data to third parties. All data is anonymised and pseudonymised for these partners who help us with this way of advertising. These are mainly cookies. You can read more about managing your preferences regarding the processing of cookies in the Cookies section.
Legal basis: The processing of personal data for the purpose of direct marketing and the creation of personalised content and advertising is justified by your consent or our legitimate interest in direct marketing. The provision of personal data on the basis of your consent is voluntary in this case, but without it it would not be possible to provide you with personalised content and advertising. You can withdraw your consent at any time. The provision of personal data in this case is not a legal or contractual requirement. You are therefore under no obligation to provide us with your personal data for this purpose.
Storage period: The storage period is determined by the duration of your consent. The storage period of cookies may vary, depending on the type of cookie. Some cookies are limited by the duration of the session (so-called session or session cookies). These are processed while the browser is running and are automatically deleted when the browser is switched off. Other cookies are permanent (called persistent cookies). These cookies remain in the browser after it has been switched off until a set date, or until they are manually deleted by the user. These cookies can be used to identify the user's computer when the web browser is restarted and the internet is browsed again. You can find out more about the storage time of cookies in the Cookies section.
f) Improving the quality of our goods and services, analysing traffic to our website and your behaviour on the website
Purpose: We are always striving to improve the quality of our goods and services and your experience. The development of new services and goods and the improvement of existing ones is done by identifying the needs and wants of users through phone calls, questionnaires, website analysis, interest in certain services and texts, etc.
In connection with browsing our website, we further process information about traffic, readership, number of viewed pages, the device from which you come to our website, time spent on the site. This data helps us to identify less accessible or less understandable areas of our website. We collect this data so that we are able to offer quality content that is user-friendly for you and to develop services in which you have an obvious interest. We regularly improve our website based on this information.
If you do not want data to be collected using these technologies, there is a simple process you can follow: most browsers offer you the option to automatically reject many of these technologies, or give you the choice to accept or reject them. You can read more about managing your preferences regarding the processing of cookies in the Cookies section.
g) Protection of our rights, property or safety or the rights, property or safety of others
Purpose: We may use information about your use of our website or information about your orders to prevent or detect fraud, abuse, misuse, unlawful use, and violations of our terms and conditions, and to comply with court or other law enforcement, governmental authorities, or conditions imposed by applicable law.
Legal Basis: The processing of personal data for the purpose of protecting our rights, property or safety or the rights, property or safety of others is justified by the performance of legal obligations or our legitimate interest in protecting our rights, property or safety or the rights, property or safety of others. The provision of personal data in this case is not a legal or contractual requirement. You are therefore under no obligation to provide us with your personal data for this purpose.
Storage period: The storage period is 10 years from the end of our contractual relationship, or 4 years from the date of acquisition.
h) Accounting and tax purposes
Purpose: We also need to process your personal data because we are required to do so by the relevant accounting and tax legislation.
Legal Basis: We handle this personal data mainly for the purpose of fulfilling the concluded contract. The fulfilment of contractual obligations typically occurs when, on the basis of the concluded contract, we are required to record invoices or other tax documents in the accounting system in accordance with Act No. 563/1991 Coll. on Accounting.
Storage period: For the period prescribed by law, in particular Accounting data are processed for 5 years starting from the end of the accounting period to which they relate, tax documents for 10 years from the end of the tax period in which the performance took place.
5. WHO IS PERSONAL DATA SHARED TO?
5.1 Your personal data is disclosed primarily to our employees who need the data in order for us to provide our services to you.
5.2 In addition to our employees, we need to sell your personal data to various business partners who enable the Administrator to operate and help us provide you with higher quality, more accurate and overall more specific content and services. We select the processors to whom we entrust your personal data very carefully. We only work with those who are able to ensure that technical and organisational security measures are in place to prevent unauthorised or accidental access to or other misuse of your data. All such partners are only authorised to process your data on the basis of a personal data processing addendum in which they undertake a duty of confidentiality. They can not use the data provided for any purposes other than those for which we have made it available to them.
5.3 The following categories of our partners (recipients) may have access to your personal data:
a) Partners who arrange for us transport of our goods
b) Partners to whom we provide data for the purpose of analysing traffic to our website, your behaviour on the website and business conversions
We strive to make your experience of using our website as pleasant as possible. That's why we work with partners who conduct analyses of traffic and your behaviour on our website. Thanks to these partners, we have information about which parts of our website are not understandable, where you may be looking for the information you want and whether you are finding it, which offers on our website you clicked on, etc. We regularly improve our website based on this information.
c) Partners who provide their services to us, who provide the technical operation of a particular service for us, and the operators of the technologies we use for our services.
In order for the Administrator to function properly and to provide our services to you, we must work with a number of partners who provide their services to us, provide the technical operation of a particular service, or operate the technologies we use for our services. Typically, these categories of partners are:
● providers of accounting and tax advice,
● providers of IT services and hosting, including cloud storage,
● providers of security and integrity of our services and websites,
● providers of payment gateways (payment card providers),
● providers of legal services, attorneys,
● providers of printing and mailing services,
● partners cooperating with us in loyalty programs, in organizing social events, seminars, etc.
● partners cooperating with us in organizing social events, seminars, etc.
d) Government organs
● We disclose personal data in the case of law enforcement, if required by law or necessary for the prevention, detection and prosecution of crime and fraud, or if we are otherwise legally obliged to do so.
● This may be a law enforcement agency (the Police, prosecutor's office and courts) or financial authorities.
● The transfer of personal data to these recipients does not take place on a regular basis, but only on an occasional basis, especially if required by law.
6. HOW IS PERSONAL DATA PROCESSED?
Personal data is processed both manually and automatically. We keep proper records of all processing activities in accordance with the relevant legislation – in particular Article 30, Records of processing activities.
7. WHAT ARE THE RIGHTS OF DATA SUBJECTS?
7.1 To exercise your rights, please contact us using our contact details set out in the introduction to this policy. We reserve the right to reasonably verify the identity of the applicant for the rights in question. If requests are repeated and manifestly unfounded or unreasonable, we may impose a reasonable fee or refuse to comply with the request.
a) Right of access to personal data
If you want to know whether we are processing your personal data, you have the right to obtain information from us about whether your personal data is being processed and, if so, you also have the right to access your personal data. In the event of a repeated request, we are entitled to charge a reasonable fee based on our administrative costs for a copy of the personal data provided.
b) Right to rectification of inaccurate and completion of incomplete personal data
If you believe that we are processing inaccurate or false data about you, you have the right to request its correction. You also have the right to have incomplete data completed. We will carry out the correction or completion without undue delay, but always within our technical capabilities.
c) Right to erasure
In the event that your personal data is no longer necessary for the purposes (in particular due to necessary legislative provisions) for which it was collected or otherwise processed, or if you become aware that it has been unlawfully processed, you have the right to request its erasure.
d) Right to restrict the processing of personal data
If you are not interested in a complete erasure, but only in temporary restrictions on the processing of your personal data, you may request us to restrict the processing of your personal data in certain cases.
e) Right to data portability
If you want us to transfer your personal data to a third party, you can exercise your right to data portability if you have previously given your consent. In the event that the exercise of this right could adversely affect the rights and freedoms of third parties, we will not be able to comply with your request.
f) Right to object
You have the right to object at any time to the processing of personal data which is processed for the performance of a task carried out in the public interest or in the exercise of official authority or for the protection of our legitimate interests. If it is not proven that there is a compelling legitimate reason for the processing which outweighs your interests or rights and freedoms, we will terminate the processing without undue delay on the basis of your objection.
g) Right to withdraw consent at any time
If the processing of your data is based on your consent, you have the right to withdraw your consent at any time.
h) Right to information about automated decision-making, including profiling
You are not subject to any decision based solely on automated processing, including profiling, which would have legal effects on you or similarly affect you in a significant way
i) Right to lodge a complaint with the Supervisory Authority
Last but not least, you also have the right to lodge a complaint with the supervisory authority.
a) ensuring the basic functions of the Site work,
b) storing your preferred language,
c) analyzing traffic to improve the Site,
d) marketing purposes, in particular displaying advertisements on the Site.
For more information about cookies, please see here.
9. IS CHILD DATA ALSO PROCESSED?
9.1 Our website is not intended for children under the age of 16. We therefore do not intentionally collect their personal data. If we become aware that we have inadvertently collected personal data about children under the age of 16, we will take steps to delete that data as soon as possible, except where we are bound by relevant law to retain it.
10.1 The Personal Data Processing Policy was drawn up and approved by the Managing Director of the Company on 1 September 2021.
10.2 Our business strategy and related ways of processing your personal data are subject to change. If we decide to update this policy, we will place the changes on our website and inform you of these changes not only on the aforementioned website but also on social media. We ask that you read this policy carefully and check this policy regularly when you next communicate with us or use our website.