Description of the conditions for the collection and processing of personal data

according to law no. 18/2018 Coll. on the protection of personal data and

on Amendments to Certain Acts, as amended (hereinafter referred to as “Act No. 18/2018 Coll.”)

This document contains information concerning the conditions for the acquisition, processing, disclosure and cross-border transfer of personal data of the persons concerned, which are the clients of GRAMS GMC s.r.o. identified in point 1, where the client is any client who is a natural person according to Act no. 40/1964 Coll. Of the Civil Code as amended or any affected person acting on behalf of the client (hereinafter referred to as the “Client”).

1. Operator

1.1. The operator is the business company GRAMS GMC s.r.o., with its registered office at A. Přídka 30, 080 01, ID number: 52099652, VAT number: 2120890090, registered in the Commercial Register of the Prešov District Court, department: Ltd., file no. 71315 / L (hereinafter “Chianna way”).

2. Broker

2.1. Chianna way may use intermediaries in connection with the collection and processing of personal data.

2.2. If Chianna way uses third parties to obtain and / or process personal data, i. intermediaries (or provides personal data to other operators in this regard), it does so only on the basis of a written contract with the intermediary and only after thorough assurance that the intermediary meets all requirements in the field of technical, organizational and personnel security in relation to personal data collection and processing. .

2.3. A list of Chianna way intermediaries is available at www.chiannaway.com. The list of third parties to whom personal data may be provided, as well as the list of countries to which the transfer of personal data may take place, follows from the content of this document and Annex no. 1 of this document. Chianna way will publish the change of lists according to the previous sentences on its website www.chiannaway.com by updating this document and its annexes.

3. Purpose of personal data processing

3.1. The purpose of processing personal data in relation to the Client is:

3.1.1. newsletter – informing the Client about new products / services or about changes in products / services;

3.1.2. direct marketing – contacting the Client or the Client’s authorized person by Chianna way (or intermediaries on behalf of Chianna way) for the purpose of direct marketing of products and services provided by Chianna way, by sending documents, electronic form, call, facsimile messages or SMS messages ;

3.1.3. download ebook – download an information document about new products / services, changes in products / services, news and interesting things from the world of online marketing;

3.1.4. registration for the event (webinar / beer after the fifth) – the Client’s interest in participating in a free event organized by Chianna way or a third party, while Chianna way organizes the preparation and course of the event;

3.1.5. purchase of participation in the event – the Client’s interest in participating in a revenge event organized by Chianna way or a third party, while Chianna way organizes the preparation and course of the event;

3.1.6. pre-contractual and contractual relations – the Client’s interest in Chianna way services in the form of e.g. requests for a price offer, analysis, order of services, direct performance from a contractual relationship;

3.1.7. proposing the theme of the event – the Client’s tip addressed to Chianna way to realize the event

3.2. Other purposes of personal data processing related to the above-mentioned purposes of personal data processing may be specified in individual contracts on transactions concluded between the Client and Chianna way, or in the current business conditions of Chianna way.

3.3. The purpose of personal data processing also follows from Annex no. 1 of this document.

4. List of personal data or scope of personal data

4.1. Chianna way obtains and processes personal data to the extent specified in the relevant legal regulations, in documents on transactions that the Client will conclude with Chianna way and to the extent that such personal data will be provided to Chianna way on documents, forms, letters and notices, or in telephone calls or electronic communication between Chianna way and the Client.

4.2. The list of processed personal data also follows from Annex no. 1 of this document.

5. Legal basis of personal data processing

5.1. Chianna way collects and processes personal data in accordance with Act no. 18/2018 Coll., Especially on the basis of the consent of the affected person according to § 14 of Act no. 18/2018 Coll.

5.2. The legal basis for the processing of personal data also follows from Annex no. 1 of this document.

5.3. Personal data is provided by the Chianna way Client voluntarily, namely:

5.3.1. with the consent of the relevant agreement concluded with Chianna way on the relevant transaction, or

5.3.2. by giving consent in the form of an audio, video or audio-visual recording, or

5.3.3. a solemn declaration that he has provided personal data to the Chianna way information system or

5.3.4. in another verifiable and credible manner.

6. Access, provision and cross-border transfer of personal data

6.1. Chianna way does not provide or make available personal data to third parties, with the exception of:

6.1.1. those third parties who have a legal right to do so under the relevant legislation,

6.1.2. if the provision or disclosure between the Client and Chianna way is contractually agreed,

6.1.3. if the provision or disclosure is necessary for the performance of the concluded contract between Chianna way and the Client.

Chianna way will provide or make available personal data, including documents on which personal data are recorded or on which Chianna way personal data has been provided:

6.1.4. other personal data controllers who process personal data on behalf of Chianna way,

6.1.5. other persons, in particular a representative or legal, tax or other adviser of Chianna way, a person entrusted by Chianna way with the fulfillment of its contractual or legal obligations, including the exercise of rights from contractual relations between Chianna way and the Client, third parties for the purpose of providing the required business or use of the additional services offered by Chianna way through third parties,

6.1.6. third parties, which are for Chianna way web service providers so-called cloud solutions and accounts (Google Drive) and online web tools (Raven Tools, MOZ, Optimizely, Google Adwords, Google Analytics, Google Webmaster Tools, GTM, Majestic, Activecampaign),

6.1.7. any person where disclosure is reasonably necessary to enable Chianna way to exercise its rights and fulfill its obligations arising from the business relationship between Chianna way and the Client,

6.1.8. to third parties for the purpose of protecting and claiming Chianna way rights from business out of court or in court, or assigning a claim on Chianna way or part and accessories thereof, including disclosure of confidential information in connection with negotiations concerning such assignments or the conclusion of a contract.

6.2. Chianna way does not disclose the personal data obtained to the persons concerned (only with prior consent).

6.3. Chianna way personal data obtained or processed may be subject to a cross-border flow of personal data to the Member States of the European Union as well as to third countries guaranteeing adequate protection of personal data, following point 6.1.6 above.

7. Other conditions for the processing of personal data and the rights of data subjects

7.1. Personal data will be processed:

7.1.1. using both partial and fully automated means of data processing,

7.1.2. within the Chianna way information systems,

7.1.3. in a secure and protected manner in accordance with the relevant security standards, Act no. 18/2018 Coll. and related regulations on personal data protection.

7.2. The rights of the data subject in the processing of personal data are specified in § 19 et seq. Act no. 18/2018 Coll. The person concerned has, under the conditions specified in Act no. 18/2018 Coll. upon written request addressed to Chianna way the following rights:

7.2.2. Right of access to personal data:

The right to obtain from Chianna way a confirmation as to whether personal data concerning her are being processed. If Chianna way processes such personal data, the data subject has the right to access this personal data and information on the purpose of its processing, to whom the data were provided, whether they have been transferred to another country or for how long Chianna way will keep them.

7.2.3. Right to correct personal data:

The right for Chianna way to correct incorrect personal data concerning her without undue delay. With regard to the purpose of the processing of personal data, the data subject has the right to supplement incomplete personal data.

7.2.4. Right to delete personal data:

The right for Chianna way to delete personal data concerning the data subject without undue delay, but with the exceptions specified in Act No. 18/2018 Coll.

7.2.5. Right to restrict the processing of personal data:

The right to ask Chianna way for a temporary restriction on the processing of personal data in the following cases:

the data subject objects to the accuracy of the personal data during the period allowing Chianna way to verify the accuracy of the personal data,
the processing of personal data is illegal and the data subject objects to the deletion of personal data and calls instead for restrictions on their use,
Chianna way no longer needs personal data for the purpose of processing personal data, but needs the data subject to exercise a legal claim, or
if it objects to the processing of its personal data, pending verification that the legitimate reasons for the processing of personal data by Chianna way outweigh the legitimate interests of the data subject.

7.2.6. Right to transfer personal data:

The right to obtain personal data concerning her provided by Chianna way in a structured, commonly used and machine-readable format and the right to transfer such personal data to another operator, if technically possible.

7.2.7. The right to object to the processing of personal data

The right to object to the processing of her personal data on grounds relating to her specific situation. The data subject has the right to object to the processing of personal data concerning him or her for the purpose of direct marketing, including profiling, to the extent that it relates to direct marketing.

7.3. The right to obtain personal data on behalf of Chianna way derives to the entitled persons from labor law regulations (eg Act No. 311/2001 Coll., The Labor Code, as amended) or from a contract concluded between an intermediary and Chianna way. The person concerned may request notification of the identity of the authorized person who obtains personal data on behalf of Chianna way by proving the card of a Chianna way employee, or another document issued by Chianna way.

7.4. Documents on Chianna way information systems are listed in Annex no. 1 of this document, and will be made available on request at the address of the registered office of Chianna way on working days from 09:00. until 16:00

7.5. If you have any questions about this document or the use of your personal information or wish to exercise your rights described in this document, you may contact us by email at mattey@chiannaway.com or in writing at Chianna way.

7.6. If you believe that the processing of your personal data by Chianna way is in conflict with the applicable legislation on personal data protection, you have the right to file a complaint with the main supervisory body – the Office for Personal Data Protection of the Slovak Republic.

Chianna way and COOKIES

For all the above purposes of using your personal data, we also use cookies and similar tools, such as pixels. Cookies are small pieces of data that are stored in your browser or mobile device while browsing the website. Pixels are small images or “pieces of code” found on a website or in emails that collect information about your browser or mobile device, and some of them may also store cookies. Each cookie has a different “shelf life” – different storage times on your device. Some cookies are deleted from your device after you close the browser window (session cookie), others remain stored on your device even after you finish browsing our website (permanent cookie).

Cookies allow us to remember your actions and preferences over a period of time, so that you do not have to enter them repeatedly each time you return to the website or switch from one website to another. At the same time, cookies help us to understand what interests you on our website, whether it is clear enough for you and you can find what you are looking for on it. Therefore, we also use cookies in order to improve the user experience. Cookies can also record additional information, such as the number of visitors to our website and also which subpages of our website you visit most often.

We use functional and technical cookies that ensure the proper functioning of our website, for example, ensure the function of logging in to the user account on the site, storing goods in the shopping cart, or detect attempts to log in to the account unauthorized. Without these cookies, our website would not work properly, their use is necessary, and therefore we do not ask your consent for their storage and access.

There are several ways to manage or restrict how we use cookies and similar technologies through (i) browser settings – although most browsers have basic settings that accept cookies, their settings allow you to delete or reject cookies; however, we must warn you that in this case, some of the services provided may not work properly; (ii) third parties – third party solutions may be used to limit cookies, for example at optout.aboutads.info.

Prešov, on 20.10.2020

Record of processing activities of the operator – GRAMS GMC s.r.o., IČO: 52 099 652