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Privacy Policy – Personal Data – GDPR

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  • Privacy Policy – Personal Data – GDPR

Instructions on the processing of personal data provided by the data subject

In connection with the processing of your personal identifiable data (hereinafter referred to as „PII„) by Feel Free Factory s.r.o., IČO: 53105907, with registered office: Košická 2503/6, 06601 Humenné, as the controller, we hereby provide you, as the person who provides his/her personal data and whose personal data we process (hereinafter referred to as the „data subject„), with information pursuant to Articles 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27.12.2016. April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as „GDPR„) and pursuant to Article 19 of Act No. 18/2018 Coll. on the Protection of Personal Data and on Amendments and Additions to Certain Acts (hereinafter referred to as „PDPA„).

Operator:

Feel Free Factory s.r.o., ID: 53105907, registered office: Košická 2503/6, 06601 Humenné, (hereinafter referred to as „FFF„); mobile: +421 915 304 205, email:/fffkids@feelfreefactory.sk/ , web: https://fffkids.feelfreefactory.sk/.

Feel Free Factory s.r.o. = Feel Free Factory Ltd.
The abbreviation s.r.o. (spoločnosť s ručením obmedzeným) is translated into English as Ltd. (Limited) or LLC (Limited Liability Company)

Purpose of the processing of PII:

  1. Conclusion of the contract for the organisation of the trip – children’s camp (hereinafter referred to as „the contract„) and performance of the contract
  2. Marketing and Advertising FFF
  3. Production, storage and publication of visual and audio-visual records of FFF activities and events organised by the FFF
  4. Accounting and tax purposes
  5. Archival purpose
  6. Statistical purpose
  7. Other processing under applicable law

Legal basis and purpose of the processing of PII:

  1. The legal basis for the processing of PII is its necessary processing for the purposes of concluding the contract and the performance of the contract itself. This legal basis includes the following PI: data on the parent – name, surname, place of residence, address of the parent’s place of residence during the event, contact email and mobile phone number of the parent; data on the child – name, surname, gender, date of birth, medical capacity, medications taken, restrictive load, copy of the child’s health card.
  2. The legal basis for the processing of personal data is also specific regulations that the FFF is obliged to comply with (e.g. Act No. 355/2007 Coll. Act No. 395/2002 Coll. on Archives and Registers, Act No. 431/2002 Coll. on Accounting, Act No. 40/1964 Coll. on the Civil Code as amended, Act No. 281/2001 Coll. on the Protection, Promotion and Development of Public Health and on Amendments to Certain Acts, Act No. on tours, conditions of business of travel agencies and travel agencies, other special regulations). The above mentioned legal basis also includes the processing of the PII of the taxpayer who has transferred a share of the tax paid to the FFF account pursuant to Article 50(8) of Act No. 595/2003 Coll. on income tax, as amended, for which purpose the FFF processes the taxpayer’s personal data in the scope of the taxpayer’s name, surname, residence and the amount of the share of income tax.
  3. The legal bases for the processing of PHI relating to the health of the child are specific regulations and also the protection of the health and life of the child. The following legal bases are used to process the PHI – medical fitness, medication taken, restrictive load, copy of the child’s health card.
  4. The legal basis for the direct marketing of FFF’s products and services is its legitimate interest in the further promotion of its products and services relating to the concluded contract. FFF’s legitimate interest lies in its constant efforts to maintain its legal relationship with the parent, to build and maintain FFF’s reputation, and to inform the parent of new offers of FFF services and products related to the concluded contract. On this legal basis, the PI is processed to the extent of the parent’s contact email and mobile phone number.
  5. The legal basis for making, storing and publishing visual and audio-visual recordings of the activities of the FFF and events organised by the FFF (hereinafter referred to as „recordings„) is the consent of the data subject. The data subject is not obliged to give consent to the processing of the PII and such consent is not a condition for entering into a contract. The data subject is free to decide whether to give consent to the controller:
  • for documentary purposes i.e. capturing the event in question as a relic of the event, whereby in this processing of PII, records are only made available to parents who express an interest in the records; and/or
  • for advertising and marketing purposes of the FFF, i.e. also for publication of the OU on the FFF website, on social networks, etc.
  1. The legal basis for the processing of Personal Data (except for records ad E/) for marketing and promotional purposes of third party products and services is the consent of the data subject. The data subject is not obliged to provide consent to the processing of Personal Data and such consent is not a condition for entering into a contract. On this legal basis, the PII is processed to the extent of the parent’s contact email and mobile phone number.

Categories of processed PII:

  • Title, first name, last name, residence, address of the parent’s place of residence during the event, contact email and mobile phone of the parent, sex of the child, date of birth of the child
  • Taxpayer’s name, surname, place of residence and amount of income tax share
  • Visual and audio-visual recordings
  • Special categories of personal data shall be processed by the controller to the following extent: the child’s medical capacity, the child’s medication taken, the child’s restrictive load, a copy of the child’s health card

Categories of entities to which PII may be provided (beneficiaries):

The FFF is authorised or obliged to provide PII to other entities. Such disclosure is a processing operation carried out on the relevant legal basis within the meaning of the Regulation and the PSO. Such entities will include, in particular:

  • Public authorities
  • Visitors to the FFF website and social media profiles
  • Intermediaries (e.g. external accountant, animators, IT administrator) with whom the OC has concluded intermediary contracts, and therefore intermediaries are primarily obliged to maintain confidentiality of the provided PII and have sufficient technical and organisational measures to guarantee the security of the PII

Transfer of PII to third countries:

The RoW transfers IP to third countries outside the EU – the US – and, following a decision by the European Commission, those countries guarantee an adequate level of protection for the IP.

Retention period of the PII:

The retention period of the PII is primarily determined by the duration of the contractual relationship and the period during which claims under the contract can be asserted, i.e. 3 years after the termination of the contract. After this period, the RO shall be kept for registration purposes for a maximum of 5 years. The accounting records of the FFF shall be kept by the FFF for 10 years following the year to which the accounting records relate, in accordance with the legislation in force.

If the data subject objects to the processing of the PII obtained on the basis of the data subject’s consent or a legitimate interest of the FFF and requests erasure or restriction of processing, the FFF shall delete the specific PII without undue delay.

Rights of the data subject:

  • right of access to personal data – individuals have the right to know whether the FFF processes their personal data; if the FFF processes it, they have the right to request access to the personal data and information (purpose, categories, recipients, retention period, rights of the data subject, source of the personal data, existence of automated individual decision-making, including profiling);
  • the right to rectification of personal data – data subjects whose personal data is processed by the FFF have the right to have their processed personal data correct, complete and up-to-date; they have the right to request rectification or completion of their personal data;
  • the right to erasure of personal data – data subjects have the right to have their personal data erased by the FFF in certain circumstances; at the request of the data subject, the FFF will erase the personal data if:
    1. are no longer needed for the purpose for which they were granted
    2. the data subject withdraws his or her consent to the processing of personal data
    3. the data subject objects to the processing of his or her personal data
    4. the processing of PII is unlawful
    5. the reason for deletion is the fulfilment of a legal obligation
    6. the data subject is a child under the age of 16 and his or her personal data have been obtained on the basis of his or her consent in connection with the offer of information society services (§ 15(1) of the GDPR)
    7. the right to restriction of processing of personal data – data subjects have the right to restriction of processing of personal data upon request; FFF will continue to store the personal data only without further processing; restriction of processing will be implemented if:
      1. the data subject objects to the accuracy of the MAs, pending verification of their accuracy
      2. the processing is unlawful, the data subject objects to their erasure and requests instead that their use be restricted
      3. OUs are not necessary for the purposes of the FFF, but are needed by the data subject to assert a legal claim
      4. the data subject objects to the processing, pending verification that the legitimate grounds on the part of the FFF outweigh the legitimate grounds of the data subject
  • the right to object to processing of personal data – the data subject has the right to object to the processing of his or her personal data; upon the data subject’s objection, the personal data will be erased if the FFF processes them for the performance of a task carried out in the public interest or in the exercise of official authority, for legitimate interest, including direct marketing and profiling; the data subject has the right to object to the processing of his or her personal data on grounds relating to his or her particular situation;
  • the right to portability of personal data – the data subject has the right to request the provision of personal data for the purpose of transferring them to another controller if their personal data is processed on the basis of consent or for the performance of a contract or if it is a special category of personal data and the processing is carried out by automated means;
  • the right to withdraw consent to the processing of personal data – the data subject has the right to withdraw his or her consent to the processing of personal data at any time, where his or her consent is the legal basis for the processing of personal data. The data subject is entitled to withdraw consent in the same way as he or she gave consent;
  • the right to submit a petition to the Office for Personal Data Protection of the Slovak Republic to initiate proceedings to verify the violation of the data subject’s rights in the processing of his/her personal data. The address of the seat of the Office: Hraničná 12, 820 07 Bratislava 27 (the Office for Personal Data Protection of the Slovak Republic will publish a model of the petition on its website https://dataprotection.gov.sk/uoou/);
  • The provision of PII for the purposes of A/ – C/ is both a legal and contractual requirement without which the conclusion and performance of a contract is not possible.
  • The data subject is not obliged to provide the PII for the purposes of ad D/ – G/ and therefore has the right to request the FFF to delete the designated PII, to restrict the PII processed or to withdraw his/her consent to the processing of PII for the purposes of ad E/ and F/ at any time.
  • FFF does not process personal data in the form of automated individual decision-making, including profiling.

Security of the processing of PII:

  • Technical measures:
    • Regular update of all software
    • Encrypted database security on an external server
    • Regular change of individual access codes

Method of exercising rights:

The exercise of the rights of data subjects is possible upon request:

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