GDPR

I. INTRODUCTORY PROVISIONS

The following information governs the conditions for the protection of personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council 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 (hereinafter referred to as the "Personal Data Protection Regulation") and Act No. 18/2018 Coll. on the Protection of Personal Data and on Amendments and Supplements to Certain Acts (hereinafter referred to as the "Personal Data Protection Act"), effective from 25.05.2018, in connection with personal data provided by data subjects to the controller on its website.

Controller: A-L-M Consulting L.L.C

Statutory body:
Phone: +971 58 878 8984

Email: office@almconsulting.tech
Web: https://almconsulting.tech/

II. DEFINITION OF TERMS

Personal data means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, surname, identification number, location data, or online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing of personal data means any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Data subject means any natural person whose personal data are processed.

Controller means the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data and processes personal data on its own behalf.

Processor means any natural or legal person who processes personal data on behalf of the controller.

Restriction of processing personal data means marking stored personal data with the aim of limiting their processing in the future based on a request of the data subject under the conditions set out in this information.

III. PRINCIPLES OF PERSONAL DATA PROCESSING

Personal data are processed by the controller lawfully in accordance with the Personal Data Protection Regulation and the Personal Data Protection Act, so as not to violate the fundamental rights of the data subject.

Personal data are collected by the controller for a specific, legitimate and explicitly stated purpose and are not further processed in a manner incompatible with that purpose.

Processing of personal data for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes is in accordance with a special regulation and appropriate safeguards for the rights of the data subject are respected.

The personal data processed are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

The personal data processed must be accurate and, where necessary, kept up to date. Personal data that are inaccurate with regard to the purposes for which they are processed shall be erased or rectified without delay.

The controller retains personal data in a form that permits identification of the data subject for no longer than is necessary for the purposes for which the personal data are processed. Personal data may be stored for longer periods if processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with a special regulation and subject to appropriate safeguards.

Personal data are processed by the controller in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organizational measures.
 

IV. INFORMATION FOR DATA SUBJECTS

The data subject has the following rights in connection with the processing of their personal data:

Right to request access to personal data from the controller

The data subject has the right to obtain from the controller confirmation as to whether or not personal data concerning them are being processed.

The controller is obliged to provide the data subject with the personal data it processes. For repeated provision of personal data requested by the data subject, the controller may charge a fee corresponding to the administrative costs related to handling the request.

The controller is obliged to provide personal data to the data subject in the manner requested by them.

In addition to providing the personal data processed, the controller shall provide the data subject with information on the purpose of the processing, the categories of personal data processed, the identification of the recipient or category of recipients to whom the personal data have been or will be disclosed, if such recipients exist, the retention period of the personal data or, if not possible, the criteria used to determine that period, the right to request correction, erasure or restriction of processing of personal data concerning the data subject, the right to object to processing, the right to lodge a complaint with the supervisory authority under Section 100 of the Personal Data Protection Act, the source of the personal data if not obtained from the data subject, and the existence of automated decision-making including profiling.

Right to rectification of personal data

The data subject has the right to request the controller to rectify inaccurate personal data concerning them without undue delay.

The data subject has the right to request the controller to complete incomplete personal data, taking into account the purposes of the processing; otherwise, the controller may refuse to complete the personal data.

Right to erasure of personal data

The data subject has the right to request the controller to erase personal data concerning them without undue delay under the conditions set out in these paragraphs.

The controller is obliged to erase personal data without undue delay upon request if:

• the personal data are no longer necessary for the purposes for which they were collected or otherwise processed,
• the data subject withdraws consent on which the processing is based and there is no other legal ground for processing,
• the data subject objects to the processing of personal data concerning them for direct marketing purposes including profiling to the extent related to direct marketing,
• the personal data have been unlawfully processed,
• erasure is required to comply with a legal obligation under the Personal Data Protection Act, a special regulation or an international agreement binding on the Slovak Republic.

The above does not apply if processing is necessary for exercising the right of freedom of expression and information, compliance with a legal obligation, performance of a task carried out in the public interest or in the exercise of official authority, archiving purposes in the public interest, scientific or historical research purposes or statistical purposes according to Section 78(8) of the Personal Data Protection Act, if erasure is likely to render impossible or seriously impair the achievement of the objectives of such processing, or for the establishment, exercise or defense of legal claims.

Right to restriction of processing personal data

The data subject has the right to request the controller to restrict the processing of their personal data if:

• the accuracy of the personal data is contested by the data subject during the period enabling the controller to verify the accuracy,
• the processing is unlawful and the data subject opposes erasure and requests restriction instead,
• the controller no longer needs the personal data for the purposes of processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.

Where processing has been restricted, the controller may process personal data only with the consent of the data subject or for the establishment, exercise or defense of legal claims, protection of the rights of another natural or legal person, or for reasons of important public interest.

The controller shall inform the data subject before the restriction of processing is lifted.

Right to data portability

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 those data to another controller where technically feasible.

Exercising the right to data portability does not affect the right to erasure under the conditions described above.

Right to notification of personal data breach if such breach is likely to result in a high risk to the rights of the natural person

The controller shall notify the data subject without undue delay of a personal data breach, providing a clear and simple description of the nature of the breach, contact details of the responsible person or other contact point where more information can be obtained, description of the likely consequences of the breach, and description of measures taken or proposed to address the breach including measures to mitigate its possible adverse effects, if necessary.

Notification is not required if:

• the controller has implemented appropriate technical and organizational protection measures such as encryption or other measures rendering the personal data unintelligible to unauthorized persons,
• the controller has taken subsequent measures to ensure a high level of protection of the rights of the data subject,
• notification would require disproportionate effort; in such case, the controller shall inform the public or take similar measures to inform the data subject effectively.

Right to object to processing of personal data

The data subject has the right to object to the processing of their personal data on grounds relating to their particular situation where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, or for the purposes of the legitimate interests pursued by the controller or a third party, except where overridden by the interests or fundamental rights and freedoms of the data subject, especially if the data subject is a child, including profiling based on these grounds. The controller shall cease processing unless it demonstrates compelling legitimate grounds overriding the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.

The data subject has the right to object to processing of personal data for direct marketing purposes including profiling to the extent related to direct marketing. If the data subject objects, the controller shall no longer process the personal data for such purposes.

Right to lodge a complaint with the Personal Data Protection Office under Section 100 of the Personal Data Protection Act

The data subject has the right to lodge a complaint with the Personal Data Protection Office if they believe their rights have been infringed.

The data subject has been explicitly informed that where the legal basis for processing is consent for a specific purpose, the data subject has the right to withdraw consent at any time.

VI. BASIC INFORMATION ON PERSONAL DATA PROCESSING

The controller processes personal data only to the necessary extent and for a specific purpose in accordance with the legal basis.

The controller has adopted appropriate technical, security and personnel measures to ensure enhanced protection of the personal data of data subjects and handles the processed personal data sensitively in accordance with the principles of data protection.

The personal data processed by the controller originate directly from the data subject or from publicly available sources.

The controller declares that personal data are not transferred to third countries outside the European Union or to international organizations and are not published.

The controller may perform automated decision-making including profiling for direct marketing purposes based on criteria determined by the controller. If automated decision-making including profiling is performed, the controller will specify the basic criteria used.

VII. PURPOSE AND LEGAL BASIS OF PERSONAL DATA PROCESSING:

A) Received and sent correspondence

For the purpose of fulfilling statutory record-keeping obligations, the controller records received and sent mail, processing the following personal data:

• identification data including name, surname, title,
• contact data including delivery address,
• data included in the communication of recipients and senders of correspondence.

These personal data are processed based on Act No. 395/2002 Coll. on Archives and Registries and on amendments to certain acts as amended. Providing personal data is a legal obligation and failure to provide them would prevent the controller from fulfilling its legal obligations.

The controller retains these personal data for 5 years from the first day of the relevant calendar year in which the personal data for correspondence were obtained and 3 years for the registry books of received and sent correspondence.

B) "Contact Form"

For the purpose of contacting back and handling any request or order within the opening hours of the visitor to the website as a data subject, the controller processes the following personal data:

• identification data including name
• contact data including email and phone,
• data included in the message text.

These data are processed by the controller based on its legitimate interests. Providing personal data in this case is neither a legal nor contractual obligation. Failure to provide personal data would prevent the controller from contacting back and handling the request or order.

The controller retains these personal data until the request or order indicated in the form is handled, but no longer than 5 years from the acquisition of personal data.

C) Online form

For the purpose of contacting back and handling any request of the website visitor as a data subject, the controller processes the following personal data:

• identification data including name
• contact data including email and phone
• data included in the message text

These data are processed by the controller based on its legitimate interests, which are the proper handling of the visitor's request. Providing personal data in this case is neither a legal nor contractual obligation. Failure to provide personal data would prevent the controller from contacting back and handling the visitor's request.
 
The controller retains these personal data until the request indicated in the form is handled, but no longer than 5 years from the acquisition of personal data.

D) Order form

For the purpose of contacting back and handling any request of the website visitor as a data subject, the controller processes the following personal data:

• identification data including name
• contact data including email and phone
• data included in the message text

These data are processed by the controller based on its legitimate interests, which are the proper handling of the visitor's request. Providing personal data in this case is neither a legal nor contractual obligation. Failure to provide personal data would prevent the controller from contacting back and handling the visitor's request.
 
The controller retains these personal data until the request indicated in the form is handled, but no longer than 5 years from the acquisition of personal data.

E) Online delivery

For the purpose of proper handling and delivery of the order of the website visitor as a data subject, the controller processes the following personal data:

• identification data of the orderer including name and surname,
• contact data of the orderer including email, phone, residence address, city, postal code, country,
• data included in the message text – note,
• identification data of the recipient including name and surname, possibly gender,
• contact data of the recipient including phone, residence address, city
• data included in the message text – text for the recipient,
• data about the purchased goods,
• data related to payment for goods (account number, paid amount, date of payment credited to the controller's account),
• data related to delivery of goods.

These data are processed by the controller for the purpose and in connection with the conclusion of a purchase or other contract and its performance; providing personal data in this case is a legal and especially contractual obligation. Failure to provide personal data would prevent the conclusion of the purchase contract and thus the delivery of the ordered goods.

The controller retains these personal data until the order is fulfilled or for the duration of the limitation period.

F) Customer complaints and grievances

For the purpose of proper handling of customer complaints and grievances, the controller processes the following personal data:

• identification data including name, surname, data stated in the complaint or grievance
• contact data including address, phone number or email address
• data related to the delivered goods (especially type of goods, delivery address, paid price, etc.)

These data are processed by the controller in connection with the conclusion and performance of a purchase or other contract. Providing personal data in this case is a legal and especially contractual obligation. Failure to provide personal data would prevent the handling of the complaint or grievance related to the concluded purchase contract.

G) Enforcement of the controller's claims

For the purpose of enforcing the controller's claims, the controller processes the following data:

• data stated in contracts with customers and suppliers to the extent necessary for enforcement of claims,
• data stated in complaints, data necessary for filing a proposal to initiate proceedings, data stated in proposals to initiate proceedings against the controller,
• data kept in accounting and other data necessary in connection with possible enforcement of claims or defense of the controller's interests.

These data are processed by the controller based on its legitimate interest, which is the effective protection of its property and other rights and enforcement of claims. Processing of personal data is necessary for the purposes of the legitimate interests of the controller.

Personal data are processed during the duration of court proceedings and during the limitation period during which claims may be asserted against the controller or during which the controller may assert its own claims.

H) Fulfillment of statutory obligations by the controller

For the purpose of fulfilling statutory obligations, the controller processes all personal data listed in Article VII, especially for the fulfillment of statutory obligations arising, for example, from the Accounting Act, Value Added Tax Act, Income Tax Act, Consumer Protection Act, Archives and Registries Act.

Processing of personal data by the controller is necessary for the purposes of fulfilling statutory obligations.

The controller processes these data for the period specified in the relevant legal regulations valid in the Slovak Republic.

I) Career

For the purpose of properly registering a website visitor as a data subject interested in a job position, the controller processes the following personal data:

• identification data of the applicant including name, surname, date of birth, nationality,
• contact data of the applicant including email, phone, permanent address, correspondence address,
• data on employment or field of study,
• data on IT knowledge,
• data on English language proficiency,
• data included in the notes text

These data are processed by the controller based on its legitimate interests, which are proper registration of the website visitor interested in the educational course and also for the purpose and in connection with the conclusion of a contract and its performance. Providing personal data in this case is a legal and especially contractual obligation. Failure to provide personal data would prevent the conclusion of the contract and thus the provision of the educational course to the applicant.
 
The controller retains these personal data until the end of the educational course or for the duration of the limitation period.

1. The controller's website is connected to third-party plugins (applications) such as Facebook, Google Plus, YouTube, Twitter, AddThis, Pinterest, Tumblr, etc. These applications are stored and run on third-party servers. The controller has no influence on the protection of personal data when using third-party applications.

2. The controller's website uses third-party add-ons that allow users to share, comment, rate website content on social networks or register via a third-party account. In such cases, the web browser creates a direct connection between the user and the third party during which cookies are used and user data are transmitted between the website, the user's browser and the third-party server. Data are generally not linked to the user's personal data. The controller uses only reliable sources of plugins and add-ons but cannot guarantee the functionality or reliability of third-party plugins.

3. User actions on these websites via social plugins may be displayed on third-party sites depending on the user's account settings (e.g., Facebook Like, Google Plus, Sharing on social networks, etc.).

VIII. RECIPIENTS OF PERSONAL DATA

The controller provides personal data to third parties exclusively based on a mediation contract in accordance with the purpose and legal basis stated above, as well as in accordance with the Personal Data Protection Act and the Personal Data Protection Regulation.

Recipients of personal data are mainly processors providing accounting and personnel services, recruitment services, delivery-related services, maintenance services, legal services, debt collection services, provision of technical and IT services, other advisory and consulting activities, etc.

Recipients of personal data also include employees of the controller if they have been instructed in accordance with the law and are bound by confidentiality obligations, and only if disclosure of personal data to employees is necessary to achieve one of the purposes of personal data processing.

The controller will provide or disclose personal data to state administration authorities, public administration bodies or other state authorities and institutions if such provision or disclosure is in accordance with generally binding legal regulations valid in the Slovak Republic and if necessary for compliance with the relevant legal regulation or enforceable request of a state authority, enforcement of contractual terms including their compliance control, prevention or procedure aimed at fraud, technical and security incidents, enforcement of rights and claims in accordance with generally binding legal regulations valid in the Slovak Republic.

IX. USE OF COOKIES

To facilitate tracking users on our website, we use protocol files called cookies (i.e., identifiers sent by the web server to the browser on your end device). Cookies are temporary files, meaning they are automatically deleted from the end device after you finish browsing.

When visiting this website, protocol files are generated with the following content:

• IP address,
• page address,
• information about the browser and operating system used,
• website from which you open our page,
• date, time of access and location.

The above information about web behavior is anonymized for maximum protection and therefore cannot be assigned to a specific user.

Cookies do not harm the end device, do not contain viruses, trojans or other malicious software, and do not perform permanent data storage on the data subject's end device.

All cookies used are technical, functional or analytical cookies that serve to improve the functionality of the controller's website.

Each data subject can set their internet browser to reject the use of cookies or to allow only some cookies. However, if the data subject does not allow the use of cookies, some functions may not work properly.

Cookie settings in the most commonly used browsers:

• Chrome - https://support.google.com/accounts/answer/61416?hl=cs
• Firefox - https://support.mozilla.org/cs/kb/vymazani-cookies
• Internet Explorer - https://support.microsoft.com/cs-cz/products/security.

Details of used cookies:

Type of cookies:	Storage duration:	Tracking codes:
_ga - Google Analytics - from connecto.io	2 years	UA-93359328-1
_gid - Google Analytics - from connecto.io	1 day
_gat - Google Analytics - from connecto.io	10 minutes
ci_session - session storage – user identification	2 weeks
c1almconsulting_lang - storage of language used on the site	11 years

 

X. SUPERVISORY AUTHORITY

The Personal Data Protection Office is a state administration authority with nationwide competence that participates in the protection of fundamental rights of natural persons in the processing of personal data and supervises data protection. Any data subject may contact the Personal Data Protection Office if they believe their rights have been violated or are at risk.

Address of the Personal Data Protection Office:

Hraničná 12
820 07 Bratislava 27
Slovak Republic

Company ID: 36064220

Web: https://dataprotection.gov.sk
Email: statny.dozor@pdp.gov.sk

Telephone consultations on data protection only on Tuesdays from 8:00 to 12:00: +421/2/3231 3220.

ATTACHMENTS FOR DOWNLOAD

• Data subject's request for access to personal data
• Data subject's request for correction/completion of personal data
• Data subject's request for erasure of personal data