Privacy Policy
Personal Data Processing Terms
Last updated: 10 July 2024
This is a translation provided for your convenience. The legally binding version is the Slovak original.
These personal data processing terms (the “Terms”) describe how 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 (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 within the “Initial Session”, the “Workshop” and/or the “Consulting” in person, by phone or via video conference (the “Services”), on the website www.adrianfric.com/ (the “Website”), as well as through other means of distance communication, in particular the social networks Instagram, X and LinkedIn (the “Social Networks”).
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 with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (the “GDPR”), and Act No. 18/2018 Coll. on the protection of personal data and on amendments to certain acts, as currently in force (the “Act”).
The Company has adopted all appropriate technical and organisational measures to ensure the protection of personal data. Through these Terms, the Company fulfils its information obligation under Articles 13 and 14 of the GDPR. We update the Terms regularly and publish them on the Website.
If you have any questions regarding these Terms, the processing of your personal data, or the exercise of your rights under the GDPR and the Act, you can contact us by email: hello@adrianfric.com or by post at the address of our registered office.
What is personal data and why do we process it?
Personal data is any information on the basis of which you can be identified as a natural person, or which is specific to you.
Processing of personal data is an operation or set of operations performed on personal data or on sets of personal data, in particular collection, recording, organisation, structuring, storage, alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise, restructuring or combination, restriction, erasure, whether or not carried out by automated or non-automated means.
Processing of personal data is necessary on our part mainly so that we can provide the Services and fulfil various legal and contractual obligations.
What information do we collect and for what purpose?
We collect the following personal data about you (the “Personal Data”), depending on how and to what extent you use our Website and/or Services:
| Purpose of processing | Legal basis for processing | Personal data processed | Mandatory/voluntary provision of personal data | Retention period |
|---|---|---|---|---|
| Online sale of Services (Initial Session, Workshop, Consulting) | Article 6(1)(b) GDPR (performance of a contract with the data subject) | ordinary personal data (e.g. title, first name, surname, email). | provision of personal data is 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) | ordinary personal data (e.g. title, first name, surname, email, position, phone number, Teams/Skype/Zoom ID). | provision of personal data is voluntary | 4 years from the end of the contractual relationship |
| Presentation of the Company in the online environment (i.e. Website, Social Networks, conferences, taking photographs and audiovisual recordings), including publishing your references about the Services | Article 6(1)(a) GDPR (consent of the data subject) and Article 6(1)(f) GDPR (legitimate interest of the Controller) | ordinary personal data of various kinds that you provide to us in the online environment (e.g. photograph, audiovisual recording, title, first name, surname, position, email, phone number) | provision of personal data is voluntary | depending on the type of legal basis for processing, either the duration of the consent, or until a legitimate objection to the processing is raised |
| Sending marketing communications and the advertising newsletter | Article 6(1)(a) GDPR (consent of the data subject) and Article 6(1)(f) GDPR (legitimate interest) | ordinary personal data (e.g. title, first name, surname, email, position) | provision of personal data is voluntary | Under Article 6(1)(a) GDPR – the duration of the consent. Under Article 6(1)(f) GDPR – 4 years from the end of the contractual relationship or until the right to object to the sending of marketing information is exercised |
| Communication with a person who completed the contact form on the Website or sent a message on the Social Networks | Article 6(1)(a) GDPR (consent of the data subject) | ordinary personal data (e.g. title, first name, surname, email, phone number, position, content of the communication, any other necessary data you decide to provide in the communication) | provision of personal data is voluntary | 90 days from the day the relevant enquiry is handled |
| Handling complaints | Article 6(1)(c) GDPR (compliance with a legal obligation, in particular under Act No. 250/2007 Coll. on consumer protection, as amended, and Act No. 40/1964 Coll. the Civil Code) | ordinary personal data (e.g. title, first name, surname, email, phone number, address and IBAN) | provision of personal data is mandatory – it is a statutory requirement under the relevant legislation | for the archiving period required under specific legislation and by supervisory authorities |
| Processing of cookies on the Website | Article 6(1)(a) GDPR (consent of the data subject) and Article 6(1)(f) GDPR (legitimate interest of the Controller) | ordinary personal data | provision of personal data is voluntary | depending on the category of cookies |
| Protection of the Company’s legal claims | Article 6(1)(f) GDPR (legitimate interest) | ordinary personal data (e.g. title, first name, surname, address, contact email and phone number, the existence of an employment or other relationship with the person who raised a legal claim against the Company, and job position) | provision of personal data is voluntary | until an out-of-court settlement of the dispute, or until a final decision of a court or another authority in the matter |
| Keeping the Company’s own corporate agenda | Article 6(1)(a) GDPR (consent of the data subject) | ordinary personal data stated in corporate documents (i.e. personal data of statutory bodies, persons authorised to act on behalf of the company) | this is further processing of personal data originally provided for another purpose, which is compatible with the original purpose of processing | for the duration of the Company’s existence |
| Bookkeeping | Article 6(1)(c) GDPR (compliance with a legal obligation) | ordinary personal data (e.g. business name, place of business, Company ID, Tax ID, VAT ID and the bank account number of a self-employed natural person, and the first name and surname of the statutory representative of a legal entity) | provision of personal data is mandatory – it is a statutory requirement under the relevant tax and accounting legislation (e.g. the VAT Act, the Accounting Act) | 10 years following the year to which they relate |
| Archiving (records management) | Article 6(1)(c) GDPR (compliance with a legal obligation) | ordinary personal data stated in archival records | this is further processing of personal data originally provided for another purpose, which is 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 accordance with applicable legislation and will protect your Personal Data against misuse and/or unlawful disclosure.
How long will we process your personal data?
Unless applicable legislation provides otherwise, 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 period during which you visit our Website or use our Services and/or the entire period during which the purpose of processing the Personal Data lasts), unless stated otherwise, for the length stated in Table No. 1 separately according to the purpose of processing the Personal Data.
We also have the right to process your personal data for a period longer than stated in Table No. 1 if it is necessary to fulfil our legal obligations, in order to establish, exercise or defend our legal rights (including providing information to third parties for the purpose of preventing fraud and minimising payment risks).
Where do we obtain your personal data?
When processing Personal Data, we obtain your Personal Data directly from you, where you provide it to us yourself (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 upon your visit to the Website (online identifiers).
If the Services on the Website are ordered by a business company of which you are a representative or contact person, the source of your Personal Data is that company.
How do we share your personal data?
For the purpose of making our Website and/or Services available (and where necessary under the circumstances), we have the right to provide your Personal Data (and you consent to such provision) in accordance with the principle of minimisation only to a limited circle of persons, namely our employees, subcontractors, officials, advisers, sales representatives, suppliers or persons related to the Company, to the extent that this is appropriate and necessary to achieve the purpose stated in these Terms, in particular to the following service providers:
| Area | Service provider | Transfer outside the EEA |
|---|---|---|
| IT services | IT services provider | No |
| Domain and 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 | Operator of the newsletter distribution platform Mailjet (applies only if you have given consent to receive the newsletter) | Yes (USA) |
| Accounting and taxes | Provider of the accounting platform (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 meeting scheduling | Provider of the Cal.com meeting scheduling platform | Yes (USA) |
| Online payments | Payment processor (Stripe) | Yes (USA) |
Table No. 2
Furthermore, we may provide your Personal Data:
- to the extent required by applicable legislation,
- in connection with any ongoing or future legal proceedings, or
- in order to establish, exercise or defend our legal rights (including providing your Personal Data to third parties for the purpose of preventing fraud and minimising payment risks).
Other recipients of your Personal Data also include companies operating the Social Networks, in particular if you contact us through a message on a Social Network, give us consent to publish your reference about our Services or your photograph (Meta Platforms Ireland, Twitter International Unlimited Company / X Corp. and LinkedIn Ireland Unlimited Company).
If you visit our Website and give consent to the use of analytical and marketing online tools (so-called “cookies”), your Personal Data will be transferred to the USA, to Google LLC, Meta Platforms and LinkedIn Corporation, as the parent companies of the European providers of the mentioned services, which we use for the purpose of measuring traffic and activity on the Website.
For completeness, we note that we use the Google Analytics, Google Ads Remarketing Tag and Meta Pixel tools on the Website. Google Analytics and the Google Ads Remarketing Tag are provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, and the 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 the use of the Website, in particular to process information that your device generates about the use of our Website, interactions with our Website and advertising activity, as well as your IP address, browser information, previously visited websites and the date and time of access, for the purposes of analysing and graphically displaying the reach of our advertising and showing customised advertising. For this purpose it may also be determined whether you or your household own various end devices. Using “remarketing”, users of our Website can be re-identified and recognised on other sites within the Google and Meta advertising network (e.g. in Google search or when using Facebook, Youtube and Instagram). They may then be shown advertising tailored to their interests. The information generated by cookies (e.g. IP address; time, place and frequency of Website visits) is transferred to the USA. You can prevent cookies from being downloaded to your computer by adjusting your internet browser settings. However, this may affect the proper functioning of some Website features; if a feature is not working, it is advisable to check the cookie settings in your web browser. You can find the personal data processing terms of Google Inc. here: https://policies.google.com/privacy and the personal data processing terms of Meta Platforms Ireland Limited here: https://www.facebook.com/privacy/policy.
We do not share your Personal Data, on the basis of which you can be identified or located, with third parties for direct marketing purposes.
How do we process service orders and financial transactions?
When you order the “Initial Session”, the “Workshop” and/or the “Consulting”, the scheduling of the meeting at which the ordered Service is to be provided takes place via the “Cal.com” platform of Cal.com, Inc., intended for online meeting scheduling. You can find the personal data processing terms of this provider here: https://cal.com/privacy.
Ordering the “Workshop” and/or the “Consulting” with a meeting scheduled via the “Cal.com” platform involves payment of the Company’s fee for providing the ordered Service. All financial operations and transactions for Services carried out electronically via the “Cal.com” platform will be processed through the online payment service provider Stripe Technology Europe, Limited. You can find the personal data processing terms of this provider here: https://stripe.com/en-sk/privacy.
We will provide your Personal Data to the online meeting scheduling platform provider and the online payment service provider only to the extent necessary to arrange the meeting date and to process payments for the ordered Services that you make through our Website, the “Cal.com” platform and the payment services of Stripe Technology Europe, Limited, to refund such payments and to resolve complaints and queries relating to such payments and refunds.
Who processes personal data on social networks
As part of supporting marketing and advertising, you will find links to the Social Networks on the Website. Please note that after clicking on a plugin on the Website and moving to a Social Network, the privacy rules of the operator of the social network begin to apply, except where you contact us through a message on a Social Network (in which case the processing of your Personal Data is also governed by these Terms and we will process your Personal Data in accordance with the information stated above).
You can find more detailed information about the processing of your Personal Data by the operators of the Social Networks at the following links:
- LinkedIn: https://www.linkedin.com/legal/privacy-policy
- Instagram: https://sk-sk.facebook.com/help/instagram/155833707900388/
- X: https://x.com/sk/privacy
We have no control over and bear no responsibility for the processing terms and practices of third parties in the area of personal data protection.
Do we transfer your personal data to third countries?
When processing your Personal Data, we try to minimise any transfer of Personal Data outside the European Economic Area (the “EEA”). However, in carrying out our business activity we also use global service providers that may transfer Personal Data outside the EEA as well (stated in particular in Table No. 2). In these cases, the Company will ensure that the GDPR conditions for such processing are met, and will carry out the transfer only on the basis of an existing adequacy decision of the European Commission under Article 45 of the GDPR, or on the basis of standard data protection clauses under Article 46(2) of the GDPR (e.g. transfers to the USA).
How can you withdraw your consent?
If we process your Personal Data on the basis of your consent, you can withdraw your consent at any time at your own discretion by email at: hello@adrianfric.com or by post at the address of our registered office.
The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Regardless of this, you have the right to object at any time to the processing of 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:
Access your Personal Data
in particular to request information about:
- the purpose of processing the Personal Data,
- the categories of Personal Data processed,
- the recipients to whom the Personal Data is provided,
- the retention period of your Personal Data,
- the right to request that we rectify Personal Data concerning you, erase it or restrict its processing, or the right to object to the processing of Personal Data,
- the right to file a motion to initiate proceedings on the protection of personal data before the Office for Personal Data Protection,
- the source of the Personal Data, if the Personal Data was not obtained from you.
The Company will provide you without undue delay with your Personal Data that it processes, in the manner you request. For a repeated provision of Personal Data that you request, we may charge a reasonable fee corresponding to the administrative costs.
Rectification of Personal Data
If you find out that we are processing your incorrect Personal Data, please inform us of this fact and we will rectify such incorrect data without undue delay. You also have the right to request the completion of incomplete Personal Data.
Erasure of Personal Data (Right to be forgotten)
We will erase your Personal Data in particular if: (i) the Personal Data is no longer necessary for the purpose for which it was obtained, (ii) you withdraw your consent to the processing of personal data under the conditions stated in these Terms, (iii) you object to the processing of Personal Data, (iv) we obtained your Personal Data unlawfully, or if (v) we have a legal obligation to erase your Personal Data.
In the event of erasure of Personal Data at your request, we will at the same time take reasonable security measures for the purpose of informing other controllers that process your Personal Data of this request, so that those controllers erase links to this Personal Data and its copies or replicas.
Restriction of the processing of Personal Data
You have the right to restrict the processing of your Personal Data if: (i) you contest the accuracy of the Personal Data, for a period enabling its accuracy to be verified, (ii) the processing of your Personal Data is unlawful and you object to the erasure of the Personal Data instead of the restriction of its use, (iii) we no longer need your Personal Data for the purposes of processing, but you need it for the establishment of a legal claim, or (iv) you object to the processing of Personal Data, pending verification of whether the legitimate grounds on our side override your legitimate interests.
If the processing of Personal Data has been restricted, apart from storage we process the Personal Data only with your explicit consent, or for the purpose of establishing a legal claim, for the protection of persons, or for reasons of public interest.
Portability of Personal Data
You have the right to obtain from us your Personal Data that we process, in a structured, commonly used and machine-readable format, for the purpose of transmitting this Personal Data to another controller.
Object to the processing of Personal Data
You have the right to object to the processing of Personal Data for the purpose of direct marketing, including profiling, to the extent that it relates to direct marketing.
Initiate proceedings before the supervisory authority
If you suspect that your rights relating to the protection of your Personal Data have been violated, you have the right to file a motion to initiate proceedings before the supervisory authority – the Office for Personal Data Protection, Hraničná 12, 820 07 Bratislava 27, Slovak Republic, https://dataprotection.gov.sk/uoou/sk, pursuant to Section 100 et seq. of the Act.
Do we use automated decision-making and profiling?
We do not use automated individual decision-making, including profiling, to provide our Services.
Do we process children’s personal data?
We consider the protection of the privacy of your children to be particularly important. For this purpose, we knowingly do not collect any personal data of persons under the age of 18. If you are under 18, please do not send us any of your Personal Data, including your name, permanent residence address, phone number or email address. No person under 18 is entitled to provide their Personal Data on the Website or to place an order for Services. If we find out that any Personal Data we process concerns a person under the age of 18 and we have not been granted the consent of that person’s legal representative, we will erase such Personal Data without delay. If you suspect that we might be processing information from or about persons under 18, please contact us by email at: hello@adrianfric.com, by phone at: +421 907 188 008 or by post at the address of our registered office.
How do we update our personal data processing terms?
We reserve the right to change these Terms. If we change the Terms or processes, we will publish these changes on the Website, so that you always have an overview of what information we collect, how we use it and under what circumstances we may provide it to a third party. It is important that you regularly monitor these Terms to ensure that you are aware of any changes.
hello@adrianfric.com