2RING PRIVACY POLICY

Beginning on May 25th 2018 all personal data is processed in accordance to 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).

1. The Joint Controllers:

The joint controllers of personal data are:

2 Ring, spol. s r.o.

Plynárenská 5,

829 75 Bratislava,

Slovak Republic

Company ID 35812010

And

2Ring America, Inc.

8880 CAL CENTER DR STE 400

SACRAMENTO, CA  95826

United States of America

CA ID: C3577724

 

2. Rights of the Data Subject:

 

Right of access by the data subject (Article 15 EU GDPR):

 

1)     The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the 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 recipient to whom the personal data have 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 or restriction of processing of personal data concerning the data subject or to object to such processing;

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

g)      where the personal data are not collected from the data subject, any available information as to their source;

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

 

2)     Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 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, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.

 

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 (Article 16 EU GDPR):

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

 

Right to erasure ('right to be forgotten') (Article 17 EU GDPR):

 

1)     The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her 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 are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

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

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

d)     the personal data have been unlawfully processed;

e)     the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;

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

 

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 controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those 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 which requires processing by 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 points (h) and (i) of Article 9(2) as well as Article 9(3);

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

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

 

Right to restriction of processing (Article 18 EU GDPR):

 

1)     The data subject shall have 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 their use instead;

c)     the controller no longer needs the personal data for the purposes of the processing, but they are 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) pending the verification 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 Union or of 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 (Article 20 EU GDPR):

 

1)     The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

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

b)     the processing is carried out by automated means.

2)     In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have 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 of this Article shall be without prejudice to Article 17. 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 (Article 21 EU GDPR):

 

1)     The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller 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 are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes 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)     At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject 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 his or her right to object by automated means using technical specifications.

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

 

Automated individual decision-making, including profiling (Article 22 EU GDPR):

 

1)     The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

2)     Paragraph 1 shall not apply if the decision:

a)     is necessary for entering into, or performance of, a contract between the data subject and a data controller;

b)     is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or

3)     In the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

4)     Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9(1), unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject's rights and freedoms and legitimate interests are in place.

 

Right to lodge a complaint with a supervisory authority (Article 77 EU GDPR):

1)     Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes this Regulation.

2)     The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 78.

 

Right to withdraw consent:

Where processing is based on consent, the data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Prior to giving consent, the data subject shall be informed thereof. It shall be as easy to withdraw as to give consent.

To withdraw a consent the data subject can contact the controller using following means:

1)     Sending an email describing the withdrawal to privacy@2ring.com

2)     Calling corporate phone number +421 (2) 5822 4550, or

3)     Sending a written request for withdrawal of a consent to the corporate headquarters of the controller labeled "GDPR – consent withdrawal" on the envelope.

 

3. Purpose and Legal Basis for the Processing of Personal Data

 

The Joint Controllers process personal data of data subjects for the following purposes:

a)      For the purpose of preparation and providing of a demonstration of products and services based on explicit consent of the data subject. The personal data will be processed for a period of time no longer than five years after the demonstration has been performed. The personal data may be transferred to a location outside of the EU. The consent for processing the personal data can be withdrawn at any time. The personal data may be provided to public authorities.

b)      For the purpose of sending informational email messages providing news and other information about the products and services of the joint controllers based on explicit consent of the data subject. The personal data will be processed for a period of time no longer than five years after the consent has been provided. The consent for processing the personal data can be withdrawn at any time. The personal data will be made available to external marketing agency residing in the USA and if requested, to any public authorities. 

c)      The purpose of the processing of personal data in the area of Personal and Payroll agenda is to prepare and enter into an full-time or par-time employment contract or ad-hoc work agreement, evidence of work statements and capacity, payment of wages, withholdings, performance of obligations to Public authorities, work records, education records, records of issued mandates and confirmations /certificates, evidence of provided protective equipment, property or equipment, entering into agreements on material liability, the provision of employee benefits, providing employee benefits, evidence of damages caused, by employees on the employer’s property, catering, copying of documents necessary for the purpose of a labor or business relationship, as well as the fulfilment of other legal and contractual obligations. The legal basis for processing of data is the fulfilment of a legal obligations within the meaning of art. 6, paragraph 1, letter c) Regulations and the employment contract or agreement within the meaning of article 6, paragraph 1, letter b) Regulations entered into with person in accordance with the Labor Code.

The Person concerned shall be obliged to provide personal data to the extent necessary; In the event of failure to provide personal data, a work or a similar contract may not be entered into. The personal data of the employee will be provided to the following recipients: health insurance companies, supplementary pension savings banks, pension managers, an entity providing statistics, guard service, educational agencies and trainers, companies providing work health services, occupational health assessments and health assessment, entities providing postal services, document archiving entities, bodies providing development, administration and support of information technologies & systems, entities providing external audit performance, telecommunications service providers, the company on which the personal data are stored, employers ' customers, employers ' suppliers, operating internal information systems for the controller, public authorities, lawyers and, where appropriate, the courts, law enforcement authorities and executors. The period of retention of personal data in the personal file of an employee shall be that defined by the preparation of the employment relationship and reaching 70th year of the employee's life (including former employees).

d)      The purpose of the processing of personal data in the field of accounting and commercial matters is to fulfil the legal obligations of the Controller under the Specific regulations (Accounting Act, Value Added Tax Act, Income Tax Act, etc.). The legal basis for the processing of personal data (including their provision to third parties) is the fulfilment of a legal obligation within the meaning of art. 6, paragraph 1, letter c) of the regulation. The retention period for personal data is 10 years. The recipients of personal data are public authorities, suppliers of audit and legal services, parent company, auditor, lawyer, companies operating internal information systems for the Controller.

e)      The purpose of the processing of personal data in the field of recruitment and selection of candidates is to ensure human resources for the implementation of the Controller's business activities. The legal basis for processing is the arrangements for concluding a contract of employment or an agreement within the meaning of art. 6, paragraph 1, letter b) a regulation concluded with the person concerned under the Labor Code. The beneficiaries of personal data are the intermediaries of candidates.

f)       The purpose of processing personal data in the field of commercial communication is to prepare and implement the business activities of the Controller. The legal basis for the processing of personal data is the legitimate interest pursued by the Controller within the meaning of art. 6, paragraph 1, letter f) of the regulation. The legitimate interest of the controller is the right to operate within the scope of the subject matter. The retention period of personal data is determined the preparation and duration of the business relationship as well as the period of 2 years from the end of this business relationship. The recipients of personal data are companies that are managing and supporting information technology, entities providing external audit performance, legal service providers, telecommunication service providers, data providers and, where appropriate, the courts and law enforcement agencies, companies operating internal information systems for the Controller.

g)      Personal data for the purpose of marketing offers and communication shall be processed on a legal basis of a legitimate interest under art. 6, paragraph 1, letter f) Regulations and Act No 351/2011 on electronic communications, as amended. A legitimate interest is to offer business partners the best possible marketing offers. The period of processing of personal data is 10 years from the date of the last end of the trade. The recipients of personal data are marketing service suppliers and companies operating internal information systems for the Controller.

h)      The purpose of the processing of personal data in the field of Work Safety is to fulfil the related obligations of the employer, in particular, but not limited to the implementation of training, the recording of accidents at work and the provision of medical examinations. The legal basis for the processing of personal data (including their provision to third parties) is the fulfilment of the legal obligations of the controller within the meaning of art. 6, paragraph 1, letter c) Regulation (in particular the obligations under the Work Safety Act). Personal data of the employee will be provided to the following recipients: An external work safety company, a labor inspectorate, and, where appropriate, law enforcement authorities, companies operating internal information systems for the Controller. The time limit for the retention of personal data is the period bounded by the preparation of the employment relationship and the expiry of 2 years from the end of that relationship. The disclosure of personal data is the legal obligation of the data subject.

i)        Personal data for the purpose of the Registry are processed in compliance with the legal obligations of the controller within the meaning of art. 6, paragraph 1, letter c) The regulation (in particular the obligations under Act No 395/2002 of the archives and registries and of the amendment of certain laws, as amended, and obligations under Law no 305/2013 about the electronic form of enforcement of the authorities and amending certain laws-the E-Government Act). The disclosure of personal data is the legal obligation of the data subject. The personal data of the employee will be provided to the following recipients: bodies providing development, management and support of information technology, entities providing external audit performance, telecommunications service providers operating internal information systems for the Controller. Retention periods are laid down by specific rules.

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