Privacy Statement of 5.0 technologies j.s.a
At twinzo – Digital Twin, accessible from https://twinzo.eu, one of our main priorities is the privacy of our visitors. This Privacy Statement document contains types of information that is collected and recorded by twinzo – Digital Twin and how we use it.
1. THE PURPOSE OF THIS STATEMENT. THE DATA CONTROLLER
1.1 What is the purpose of this privacy statement?
This privacy statement (“Statement”) is intended to help business partners and other private individuals to understand how 5.0 technologies j.s.a., with its registered seat at Nezábudkova 471/8, 929 01 Dunajská Streda, Slovakia, ID No. 54 530 300, registered in the Commercial Register of the District Court Trnava, Section: Sja, Insert No. 29/T (“twinzo”) processes personal data of private individuals having dealings (directly or indirectly through their employers) with twinzo.
The Statement is addressed to any private individual who has or (to the extent applicable) had relationship with twinzo or whose personal data were provided to twinzo by employer of such private individual. Whether you are our contractual partner, representative of our contractual partner or whether you have been nominated by our contractual partner as his/her contact person or you have been appointed by our contractual partner as an administrator of our services or whether you have only sent an email, mail or other form of communication to twinzo or whether you have used our website, to the extent our encountering with you led to twinzo having access to your personal data, this Statement is relevant to you.
This Statement, however, does not cover processing operations with personal data carried out by twinzo in context of employment (including the recruitment process), where separate rules available at twinzo’s Human Resources department apply.
The Statement shall be read carefully and in its entirety. twinzo strived to ensure that the Statement contains complete and comprehensible information about the processing activities regarding your personal data. However, if you have any questions or if you are not sure about any aspects of processing of your personal data by twinzo, please, do not hesitate to contact us at the following email address: info@twinzo.eu
1.2 Who is the data controller?
The data controller with respect to the personal data is twinzo.
twinzo needs to process your personal data to fulfil its contractual and other legal obligations. At the same time, twinzo may need to process your personal data to protect its legitimate interests, including operating its business activities in appropriate manner.
It is our objective to process all personal data in line with the applicable data protection laws, particularly (i) the Regulation of the European Parliament and of the Council (EU) 2016/679 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, and (ii) Slovak Act No: 18/2018 Coll. on Protection of Personal Data and On Amendment and Supplement of Certain Acts (to the extent applicable). It is also our objective to ensure that all processing operations are conducted in a secure way only to the extent necessary for achieving purpose of the processing as described below.
1.3 What could happen if personal data are not provided to twinzo?
twinzo has numerous contractual and legal obligations towards its business partners and towards the public authorities or other public bodies.
If your personal data are not provided to twinzo, twinzo may not be able to fulfil its obligations, which may result in twinzo not being able to enter into contract with its business or contractual partners or to respond to your communication.
2. PERSONAL DATA. PROCESSING OPERATIONS
2.1. Where does your personal data come from?
twinzo collects the personal data directly from you or from your employer who provided your personal data to twinzo in the course of the business relationship. twinzo may obtain personal data directly from you or through twinzo’s website https://www.twinzo.eu as well as by other means (including public sources) directly from entities that use or wish to use the services provided by twinzo. twinzo may also receive some of the personal data from public authorities in relation to their queries or investigations. It may be also the case that twinzo will process personal data which are publicly available, particularly with respect to contact data. Please, also be aware that twinzo may create other data about you, which could qualify as personal data and twinzo will use and store also such personal data
2.2 What kind of personal data are processed by twinzo?
Unless a particular situation requires otherwise, the personal data that twinzo will process may include:
(a) identification and characteristic information: such as name, surname, title, details of your employer, job position;
(b) contact data: such as address, business address, (business) phone number, (business) e-mail address, job position;
(c) background information and skills overviews: such as information stated on any professional certificate or license (to the extent applicable);
(d) any data provided by you either when using our website or through the established for use of twinzo services.
If other personal data are provided to twinzo, twinzo will always carefully evaluate whether such personal data are necessary for the intended processing purposes. To the extent not necessary, twinzo will not process such personal data.
2.3 What are the purposes for processing of your personal data by twinzo?
twinzo processes personal data of its business partners, representative(s) of business partners and/or business partner’s contact persons to fulfil its contractual obligations and statutory obligations (such as keeping of accounting, tax purposes and similar). Such personal data may also be processed for purposes of legitimate interests of twinzo aimed at ensuring effective and secure conducting of twinzo’s and twinzo group’s business activities. The personal data may also be used for distribution of marketing and promotional materials to the business partner by the third party.
Your contact data will also be used to for communication purposes, including responding to any queries you may address to twinzo as well as sharing with you promotional and marketing materials regarding twinzo’s and twinzo group’s business activities and products.
twinzo does not intent to process any personal data uploaded by you through account created for use of twinzo’s services. Such personal data may, however, be stored at twinzo’s technological equipment.
2.4 What is the legal base for the processing operations?
Pursuant to applicable data protection laws, personal data may only be processed based on adequate legal base. twinzo processes personal data based on the following legal bases:
(a) performance of a contract
Data processing by twinzo is necessary to enable twinzo to fulfil its obligations deriving from the agreement concluded with you or with your employer.
(b) fulfilment of legal obligation
Data processing by twinzo is necessary to enable twinzo to comply with its obligations prescribed in law, including the transmission of data to authorities and keeping of accounts.
(c) legitimate interest of twinzo
In certain cases, twinzo will also process personal data on the basis of the fact that twinzo has a legitimate interest to do so. These cases include:
(i) making or defending against claims;
(ii) proving compliance with applicable laws (such as upon requests of supervisory authorities);
(iii) security of twinzo assets (including infrastructure used for providing services);
(iv) sharing your business personal data with other companies from the same group of companies to conduct twinzo’s (and twinzo group’s) business activities effectively and securely.
In cases where data processing by twinzo is based on the legitimate interest of twinzo, twinzo has, upon thorough deliberation, arrived at the conclusion that your interests or fundamental rights and freedoms that require protection of personal data do not override the legitimate interest of twinzo.
2.5 For how long will your personal data be processed?
twinzo will not store or process personal data for a period longer than necessary to fulfil the purpose of the processing or as prescribed or allowed by applicable laws. Accordingly, when the purpose has been fulfilled in relation to a specific type of personal data, we will stop using the personal data for that purpose and, if the same data is not relevant for any other purpose, delete the relevant personal data as soon as reasonably possible.
The basic rule is that twinzo will store and process your personal data throughout the duration of the contract with the business partner and for a period of 5 years after its termination, unless the applicable laws provide for different period. To the extent possible, twinzo will anonymize your personal data for their use for statistical purposes.
3. YOUR RIGHTS
3.1 What does twinzo do to protect your personal data?
twinzo ensures that the principles of protection of personal data laid down by the applicable data protection laws are strictly followed and adhered to. Particularly, twinzo ensures that (i) only those personal data are processed which are necessary for the purpose of processing, (ii) personal data are processed only for purpose for which the data were collected or (to the extent permitted by the applicable data protection laws) for purpose which is compatible with the original purpose, and (iii) the personal data are processed no longer than necessary.
The personal data will be stored and processed manually and also automatically with the help of electronic devices.
twinzo has taken appropriate technical, administrative, physical and procedural protection measures for the protection of personal data in their use and possession in order to ensure that such personal data are protected against misuse, unauthorized access, publication, corruption, modification and destruction. Such measures include the following:
(a) technical protection measures: e.g., firewalls, anti-virus and endpoint protection software, encryption technologies, password-protected access and monitoring of our systems and data centers to ensure compliance with our security policies,
(b) physical protection measures: e.g., closed doors and file cabinets, controlled entry to the premises of twinzo, and
(c) organizational protection measures: by means of educational and awareness-raising programs regarding security and confidentiality, with the purpose of securing that the employees of twinzo understand and know the importance of protecting personal data and the tools that are mandatory to use, further, also by means of a data protection policy and regulations that define how twinzo processes personal data.
3.2 What are your rights with regard to processing of personal data?
The applicable data protection laws confer on you several rights when it comes to processing of your personal data. Details of these rights are outlined below. Be aware that the rights below could be qualified in certain circumstances (e.g., in case of legal proceedings regarding you). Please, do not hesitate to contact twinzo, if you have any questions regarding your rights.
Right to be informed
As a data subject you have a right to be informed about all important aspects of the processing operations regarding your personal data, unless the applicable data protection laws provide otherwise. twinzo fulfils its obligation to inform you, primarily, through this Statement. Though, from time to time, twinzo may distribute further information or update this Statement to ensure that you have correct and up to date information.
Right to access and rectification
You have the right to request access to the personal data relating to you. This includes the right to be informed whether personal data about you are being processed, what personal data are being processed, and the purpose of the processing. We do not have to provide your personal data if this would adversely affect the rights and freedoms of others. You also have the right to rectify or add personal data if the personal data are inaccurate or incomplete.
Right to erasure (“right to be forgotten”)
You have the right to request that your personal data are erased in certain cases, e.g., if the personal data are no longer necessary for the purposes for which these were collected and no other legal basis exist for continuing to process such data, if the processing is unlawful, or if the personal data have to be erased in order to enable twinzo to comply with a legal requirement. Please note that we could reject your request if the processing is permitted or required according to law or any other relevant legal base.
Right to object and restriction of processing
You are also entitled to object to certain processing or to request that the processing of the personal data is restricted such as if you believe the personal data may not be correct, if you believe the processing is unlawful, or if you believe that twinzo no longer needs the personal data for the purposes stated in this Statement.
Right to data portability
You are also entitled to request that personal data about you that you yourself have provided, if such personal data are being processed with your consent or in accordance with a contract between you and twinzo, are provided to you in a structured, commonly-used and machine-readable format and you may also request that such personal data are transmitted to another controller, if this is technically feasible.
3.3 What should you do, if you want to exercise your rights or if you have a complaint?
o exercise your rights, you can contract twinzo using the above contact details. Be aware that you may be contacted to verify your identity so that your personal data are not disclosed or discussed with other person than you.
If you have a complaint regarding the processing of your personal data by twinzo, please, contact twinzo at the above contact details and submit to it your complaint. You can also submit your complaint directly to the supervisory authority, which is:
Name: Úrad na ochranu osobných údajov Slovenskej republiky (Office for Personal Data Protection of the Slovak Republic)
Address: Hraničná 12, 820 07, Bratislava 27, Slovak Republic
Phone: +421 2 323 132 14
Fax: +421 2 323 132 34
E-mail: statny.dozor@pdp.gov.sk
Webpage: https://dataprotection.gov.sk/
You have undisputable right to submit your complaint directly to the above-mentioned supervisory authority or to use other remedies available to you under the applicable (data protection) laws. However, we believe that any request or complaint you may have may be dealt with between you and twinzo, and therefore we encourage you to first submit your request or complaint to twinzo before approaching the authorities. We assure you that we will handle any request or complaint in line with the applicable data protection laws.
4. DATA RECIPIENTS. THIRD PARTIES. TRANSFERS
4.1 Who has access to your personal data?
twinzo processes your personal data through its employees or through external service providers.
Every employee having access to your personal data has been duly trained and informed about the rules and principles of handing your personal data. These employees only get access to your personal data in accordance with the principle of minimization, meaning that they will only have access to personal data that is strictly necessary for the purpose of the processing to perform their work.
In cases where your personal data are processed by a service provider (e.g., IT) engaged by twinzo, twinzo and the service provider concluded a data processing agreement in accordance with the applicable data protection laws. Every person processing your personal data must follow the instructions of twinzo.
twinzo may also transfer your personal data to third parties, who process them for their own purposes. Such third parties include (without limitation) (i) public authorities or bodies (e.g., tax authority) particularly in connection with fulfilment of twinzo’s obligations or in order to respond to queries the public authorities or bodies may have, (ii) twinzo group companies, particularly to ensure efficient operation of the entire group to which twinzo belongs to or to accept services which are provider by specific companies from the group to all other members of the group, and (iii) other third parties who may be engaged by twinzo to provide specific services to twinzo in relation to the relationship with you, but who will not process personal data in the name of and on behalf of twinzo.
4.2 To what countries will your personal data be transferred?
Your personal data are primarily processed within the European Union, European Economic Area and Switzerland where adequate level of protection of your personal data is secured.
It may be the case that from time-to-time twinzo may transfer your personal data or other data derived from your personal data (such as statistical data) to companies located in countries which offer a lower level of protection than applicable in the European Union, European Economic Area or Switzerland. In such cases, twinzo ensures that the transfer is made in accordance with the rules laid down by the applicable data protection laws, particularly (but without limitation) based on the Model Contractual Clauses adopted by the European Commission. For further details, please, contact twinzo.
5. MISCELLANEOUS
5.1. To ensure that twinzo complies with the applicable data protection laws or to reflect any changes in the processing operations, this Statement may be changed by twinzo at any time. You will be informed of any such changes made via the commonly used means and forms.
5.2. We encourage you to report any non-compliance with this Statement to twinzo. twinzo will thoroughly investigate any such allegations and will take steps and actions necessary to ensure compliance with the applicable data protection laws.
5.3. Please notify the human resources department of twinzo of any changes to the personal data relating to you to enable twinzo to process personal data accurately and securely.
5.4. Please, if you are our business partner, be sure to notify any of your employees whose personal data will be provided to twinzo about this Statement and all relevant aspects of processing of their personal data. If you fail to do that, please inform twinzo immediately so that we can comply with the information obligation and notify the affected data subjects directly.