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Privacy Notice on the Processing of Personal Data

Pursuant to Article 13 of 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 (General Data Protection Regulation – GDPR), and Act No. 18/2018 Coll. on Personal Data Protection, as amended.

A. Identification Details of the Data Controller

The Data Controller is ZION SPA s.r.o., with its registered office at Dvořákovo nábrežie 6, 811 02 Bratislava, Slovakia, Company ID No.: 3666181 (hereinafter referred to as the “Controller”).

B. Purposes of Personal Data Processing

Personal data is processed for the following purposes:

  1. Entering into membership agreements within the framework of pre-contractual and contractual relationships.
  2. Maintaining records in the membership management and reservation systems.
  3. Direct marketing, including sending promotional offers and newsletters.
  4. Providing information about operational updates, terms and conditions, and restrictions.

C. Categories of Personal Data Processed

  • Title, first name and surname
  • Telephone number
  • Email address
  • Residential address
  • Date of birth
  • Photograph

D. Additional Information

1. Personal data, including title, first name, surname, email address, residential address and date of birth, is processed for the purpose of entering into membership agreements within the framework of pre-contractual and contractual relationships.

2. Personal data, including title, first name, surname, email address, residential address, date of birth and photograph, is processed for the purpose of maintaining records in the membership management and reservation systems.

3. Personal data, including first name, surname, email address and telephone number, is processed for the purposes of direct marketing, sending promotional offers and newsletters, and providing information about operational conditions and updates, based on the consent of the data subject.

4. Consent of the data subject.

5. Personal data will be retained for a period of five (5) years.

6. Personal data, including first name, surname and email address, may be disclosed to third parties, namely DS Class, s.r.o., Company ID No.: 47698624, and Zone Media, s.r.o., Company ID No.: 44 278 837 (hereinafter referred to as the “Data Processors”), on the basis of data processing agreements.

7. The Controller declares that, when selecting Data Processors, it has taken into consideration their professional, technical, organisational and personnel capabilities, as well as their ability to ensure the security of the personal data processed through measures in accordance with Section 39 of Act No. 18/2018 Coll. on Personal Data Protection.

8. The Controller declares that it has implemented all necessary measures in accordance with Section 39 of Act No. 18/2018 Coll. and undertakes to protect personal data against accidental or unlawful damage, destruction, accidental loss, alteration, unauthorised access or disclosure, as well as any other unlawful forms of processing, in accordance with the measures established in its data security documentation.

9. The Data Processor undertakes to process personal data only to the extent and under the conditions specified in the relevant data processing agreement.

10. The Controller declares that it will not disclose personal data to any Data Processors other than those specified in this Privacy Notice.

11. The Controller declares that it will collect personal data only to the extent necessary to fulfil the specified purposes and will process such data exclusively in accordance with the purposes for which it was collected.

12. The Controller is obliged to maintain confidentiality regarding the personal data it processes. This obligation of confidentiality shall remain in effect even after the processing of personal data has been completed.

13. A Data Protection Officer has been appointed within the company. The contact details of the Data Protection Officer are as follows:

Jana Vidová General Manager Telephone: +421 910872140 Email: Vidova@zionspa.sk

E. Information on the Rights of the Data Subject

Right of Access

1. The data subject has the right to obtain confirmation from the Controller as to whether or not personal data concerning them is being processed and, where that is the case, the right to access such personal data and the following information:

a) The purposes of the processing;

b) The categories of personal data concerned;

c) The recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organisations;

d) Where possible, the envisaged period for which the personal data will be stored or, if not possible, the criteria used to determine that period;

e) The existence of the right to request from the Controller rectification or erasure of personal data concerning the data subject, restriction of processing, or to object to such processing;

f) The right to lodge a complaint with a supervisory authority;

g) Where the personal data has not been collected from the data subject, any available information as to its source;

h) The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

2. Where personal data is transferred to a third country or an international organisation, the data subject has the right to be informed of the appropriate safeguards pursuant to Article 46 of the GDPR relating to the transfer.

3. The Controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the Controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, the information shall be provided in a commonly used electronic format, unless otherwise requested by the data subject.

4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

Right to Rectification

The data subject has the right to obtain from the Controller, without undue delay, the rectification of inaccurate personal data concerning them.

Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to Erasure (“Right to Be Forgotten”)

1. The data subject has the right to obtain from the Controller the erasure of personal data concerning them without undue delay, and the Controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

a) The personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;

b) The data subject withdraws consent on which the processing is based, pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR, and where there is no other legal ground for the processing;

c) The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR;

d) The personal data has been unlawfully processed;

e) The personal data must be erased to comply with a legal obligation under European Union or Member State law to which the Controller is subject;

f) The personal data has been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

2. Where the Controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the Controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested the erasure of any links to, or copies or replications of, such personal data.

3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:

a) For exercising the right of freedom of expression and information;

b) For compliance with a legal obligation requiring processing under European Union or Member State law to which the Controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;

c) For reasons of public interest in the area of public health in accordance with Article 9(2)(h) and (i), as well as Article 9(3) of the GDPR;

d) For archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) of the GDPR, insofar as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of such processing; or

e) For the establishment, exercise or defence of legal claims.

Right to Restriction of Processing

1. The data subject has the right to obtain from the Controller restriction of processing where one of the following applies:

a) The accuracy of the personal data is contested by the data subject, for a period enabling the Controller to verify the accuracy of the personal data;

b) The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of its use instead;

c) The Controller no longer needs the personal data for the purposes of processing, but it is required by the data subject for the establishment, exercise or defence of legal claims;

d) The data subject has objected to processing pursuant to Article 21(1) of the GDPR, pending verification of whether the legitimate grounds of the Controller override those of the data subject.

2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent, or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or a Member State.

3. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the Controller before the restriction of processing is lifted.

Right to Data Portability

1. The data subject has the right to receive the personal data concerning them, which they have provided to the Controller, in a structured, commonly used and machine-readable format, and has the right to transmit such data to another controller without hindrance from the Controller to which the personal data was provided, where:

a) The processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR, or on a contract pursuant to Article 6(1)(b) of the GDPR; and

b) The processing is carried out by automated means.

2. In exercising the right to data portability pursuant to paragraph 1, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible.

3. The exercise of the right referred to in paragraph 1 shall be without prejudice to Article 17 of the GDPR. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller.

4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

Right to Object

1. The data subject has the right to object, on grounds relating to their particular situation, at any time to the processing of personal data concerning them which is based on Article 6(1)(e) or (f) of the GDPR, including profiling based on those provisions. The Controller shall no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

2. Where personal data is processed for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data concerning them for such marketing, including profiling to the extent that it is related to such direct marketing.

3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

4. The right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject at the latest at the time of the first communication with them and shall be presented clearly and separately from any other information.

5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise their right to object by automated means using technical specifications.

6. Where personal data is processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1) of the GDPR, the data subject has the right to object, on grounds relating to their particular situation, to the processing of personal data concerning them, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

Notification to Third Parties

The Controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 of the GDPR to each recipient to whom the personal data has been disclosed, unless this proves impossible or involves disproportionate effort.

The Controller shall inform the data subject about those recipients if the data subject requests it.

Initiation of Proceedings at the Request of the Data Subject

Pursuant to Section 100 of Act No. 18/2018 Coll. on Personal Data Protection, a data subject has the right to submit a request for the initiation of proceedings if they believe that their rights established under this Act have been directly infringed.

The Personal Data Protection Office of the Slovak Republic shall assess the submission within 30 days of its receipt.

The Office shall inform the applicant of the manner in which the submission has been handled within 30 days of its receipt.