Information on the processing of personal data and cookies (Privacy policy)

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, and repealing Directive 95/46/EC (hereinafter referred to as "GDPR"), Act No. 18/2018 Coll. on the Protection of Personal Data and on Amendments and Additions to Certain Acts, as amended (hereinafter referred to as "Personal Data Protection Act") and Act No. 452/2021 Coll., on electronic communications, as amended (hereinafter referred to as the "EC Act"), we would like to inform you about the processing of your personal data and cookies.

Definitions:

Data subject: A data subject is an identified or identifiable natural person. An identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or by reference to one or more elements specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. A data subject in relation to the www.attellu.com website is any natural person who uses this website. Data subjects may be customers, potential customers or visitors to the website www.attellu.com who browse its content (also referred to as “Data subject”, “You” or “Customer”);

Personal Data: Any information relating to the Data Subject (hereinafter also referred to as “Data” or “Information”);

Controller: An entity which, alone or jointly with others, determines the purposes and means of processing Personal Data and Cookies. The Controller of Personal Data and Cookies in relation to the website www.attellu.com is the company ATTELLU s.r.o., with its registered seat at Palárikova 76, 022 01 Čadca, the Slovak Republic (hereinafter also referred to as the “Controller”);

Purpose of processing of Personal Data: The reasons for which Personal Data is processed, e.g. preparation of a price offer, contractual and pre-contractual relations, the fulfilment of various legal and contractual obligations, handling of complaints and suggestions, sending of commercial notifications, display of advertisements based on the interests and preferences of Customers, protecting the legitimate interests of our clients, our company and others, etc.;

Cookies: The Cookies are short text files that a website sends to your browser, which then saves them. Most cookies contain a unique identifier, called a cookie ID. This is a string of characters that websites and servers assign to the browser that stored the Cookie. This allows websites and servers to distinguish and identify individual browsers. Cookies are used to improve the functioning of websites, to evaluate their traffic and to better target marketing activities They allow a website to record information about your visit, such as your chosen language, etc., so that future visits to the website are easier and more enjoyable for You. Cookies are important because without them, browsing the internet would be much more difficult and complicated. Cookies allow you to make better use of our website www.attellu.com and to tailor its content to your needs; they are used by almost all websites in the world. Cookies are useful because they increase the user-friendliness of a repeatedly visited website. Cookies do not cause any damage to your end device and do not contain viruses, Trojan horses or other malicious software;

Third countries: The countries outside the European Economic Area, which primarily includes the Member States of the European Union, Iceland, Liechtenstein and Norway.

Legal Basis and Purposes for Processing Personal Data
Your Personal Data is processed on the basis of the legal grounds set out below:
1. Processing based on the performance and conclusion of a contract pursuant to Article 6(1)(b) GDPR. For the purpose of concluding a contract, we process Personal Data in the following way:
  - Contact details (telephone number, e-mail address) for the purpose of communication within the framework of the contract or the pre-contractual relations;
  - Order processing - processing is necessary for the performance of a contract to which the Customer is a party, or for the performance of acts at the request of the Concerned Party prior to the conclusion of the contract;
  - Improving Customer service - the processing of Personal Data may be justified to improve Customer service, for example to provide Customer support and resolve complaints;
  - Contact form processing - Data processing is necessary to answer the question asked by the Customer;
  - Processing of contract withdrawal - processing is necessary for the purpose of processing the contract withdrawal notice;
  - Complaint handling - the processing of Personal Data is necessary for the purposes of complaint handling;
2. Processing on the basis of the legitimate interests of the Controller within the meaning of Article 6(1)(f) GDPR. For the purposes of the legitimate interests of the Controller, we process Personal Data in the following way:
  - Processing of Personal Data for statistical purposes, such as the collection and analysis of data on website traffic and Customer behaviour;
3. Processing based on the fulfilment of the legal obligations of the Controller pursuant to Article 6(1)(c) GDPR. We process Personal Data to comply with the legal obligations of the Controller, for example:
  - Issuing a tax document (invoice) in accordance with tax regulations;
  - Archiving of order and payment transaction Data for a certain period of time specified by law (e.g. up to 10 years under tax regulations);
  - Compliance with obligations related to consumer protection and terms & conditions;
  - Compliance with obligations related to complaints, returns, etc.
4. Processing based on the Data subject pursuant to Article 6(1)(a) GDPR. We process Personal Data with the explicit consent of the Data subject, for example:
  - Sending of direct commercial communications - the processing of Data for the purpose of sending marketing information via the communication channel designated by the Customer is carried out in accordance with Section 116 of the EC Act;
  You have the right to withdraw your consent at any time.

Information about the obligation to provide Data and the consequences of not providing Personal Data
1. The provision of Personal Data is voluntary, however, if you do not provide it, the Controller will not be able to perform the requested actions based on your request, conclude a contract with you, provide you with relevant services, send you the requested business information or otherwise communicate with you in this regard. The provision of the Data necessary for the issuance of an invoice is a legal obligation and results from Section 74 of Act No. 222/2004 Coll., on Value Added Tax, as amended.
2. If you are an intermediary, representative or contact person acting on behalf of or in the interest of the Data Subject with whom the Controller enters into a contract, the provision of your Personal Data is also voluntary, but at the same time necessary for the conclusion and performance of the contract between the Controller and the Data Subject whom you represent or in whose interest you otherwise act.
3. The provision of Personal Data on the basis of consent to the processing of Personal Data is always voluntary and failure to provide it (failure to give consent or withdrawal of consent) has no sanctionable consequences.

Recipients of Personal Data
1. Recipients of your Personal Data will only be entities authorized by law, including financial administration authorities or other public authorities.
2. Your Data may be transferred to entities that process Personal Data on behalf of the Controller, e.g. IT service providers, parcel carriers, entities providing accounting, marketing, legal and consulting services and other entities processing Data for purposes specified by the Controller.
3. We may disclose your Personal Data to affiliated parties.
4. The Controller collects service records but does not link them to Personal Data in any way. Log files may be used to generate statistics to assist in the administration of the website. Aggregate reports in the form of these statistics do not contain any identifiers of website visitors.
5. When providing our services, we use technical solutions offered by entities that may process Personal Data outside the European Economic Area (EEA), such as Google, Facebook, YouTube, Instagram, LinkedIn and Pinterest. Please note that if You visit our company’s account on the social network Instagram or LinkedIn, your Personal Data is also collected by the controllers of these social networks, in accordance with their Personal Data processing rules and your settings. We do not and cannot control these circumstances.
6. Any transfer of Personal Data to countries outside the European Economic Area, including subsequent transfers of Personal Data from the third country in question or from the international organisation in question to another third country or another international organisation, shall only take place within the framework of strict compliance with the protection of Personal Data within the meaning of Article 6(1) GDPR and Articles 44 to 50 GDPR. This includes ensuring an adequate level of Data protection by means of approved safeguards, Commission adequacy decisions or specific exemptions in cases where the Data subject has given his or her explicit consent, the performance of a contract, important public interests, the defence of legal claims or the protection of vital interests are at stake. Supervisory authorities monitor and approve these transfers to ensure compliance with Data protection standards.

Retention Period of Personal Data
Your Personal Data will be processed during the term of the contract and after its termination:
1. for as long as necessary to comply with a legal obligation under the relevant tax regulations;
2. for the purpose of protecting the rights and legitimate interests of the Controller, in particular for the assertion or defence of claims, at least for the duration of the relevant limitation periods;
3. until the withdrawal of consent to the processing of Personal Data for marketing purposes, if the Personal Data is processed on the basis of consent.

Rights of Affected Persons
In connection with the processing of your Data, you have the right to:
1. access to your Personal Data (see Article 15 of the GDPR for more information);
2. rectification of Personal Data (see Article 16 of the GDPR for more information);
3. erasure of Personal Data (see Article 17 of the GDPR for more information);
4. restriction of the processing of Personal Data (see Article 18 of the GDPR for more information);
5. portability of Personal Data (see Article 20 of the GDPR for more information);
6. object to the processing of Personal Data (see Article 21 of the GDPR for more information);
7. withdraw consent to the processing of Personal Data at any time without affecting the lawfulness of the processing carried out prior to its withdrawal - if the processing is based on the consent granted to the Controller, in the cases and under the conditions set out in the GDPR. The rights referred to in points a) to g) above may be exercised by the Data subject by contacting the Controller using the contact details provided at the head of this Information (for more information, see Article 7(3) of the GDPR).

Right to lodge a complaint with the supervisory authority
In connection with the processing of your Personal Data, you have the right to file a petition for the initiation of proceedings for the protection of Personal Data with the Office for Personal Data Protection, located at Hraničná 4826/12, 820 07 Bratislava 27, the Slovak Republic, tel.: 02/323 132 14, website: https://dataprotection.gov.sk/uoou/, if you believe that your right to the protection of Personal Data has been violated.

Automated individual decision-making with legal or similar effects, including profiling
Profiling means any form of automated processing of Personal Data that uses Personal Data to assess certain personal aspects of a natural person, in particular for statistical purposes, to analyse or predict aspects relating to the performance of the natural person. You agree and acknowledge that our website may carry out automated individual decision-making, including profiling, based on your Personal Data, in accordance with Article 22 of the GDPR. This profiling is carried out solely for the purpose of collecting statistical information and analyses in order to improve and customize our services and offerings (see Article 22 of the GDPR for more information).

Cookies
1. Types of Cookies:
  - Temporary (Session) Cookies allow us to link your individual activities while you are browsing the website. These cookies are activated when you open the browser window and deactivated when you close the browser window. With temporary Cookies, all of these files are deleted when you close your browser;
  - Persistent Cookies help to identify your computer when you visit our website again. Another advantage of persistent Cookies is that they allow us to tailor our website to your specific needs.
2. In accordance with § 111 of the EC Act, we hereby inform you that our website uses Cookies for its operation. This means that Cookies are stored in accordance with the terms set out in the EC Act and we process your Cookies, including persistent Cookies, and the Personal Data they collect in accordance with the terms set out in the GDPR and the Data Protection Act.
3. The processing of Cookies serves the following purposes:
  - Technically necessary Cookies are a basic type of Cookie that are necessary for the proper functioning of the website and enable basic functions such as navigating between pages, displaying the content of the website, etc. These Cookies do not require your consent and are always allowed;
  - Preference Cookies are another type of Cookie that collects information about a user's preferences on a website, such as language preferences or display settings. These Cookies allow websites to provide personalized content to its users and improve the overall user experience. Preference Cookies do not require your consent if they are used solely to store your choices, such as language preferences, on a website;
  - Statistical Cookies collect information about how users use a website, such as how much time they spend on a page, which pages they visit most often, etc. This information helps to optimise the performance and functionality of the website. These Cookies do not require your consent;
  - Marketing Cookies are used to serve personalised advertising on the Website. These Cookies may be used to track your browsing on the Website and collect information about your interests to make advertising as relevant as possible. These Cookies require your consent.
  - Social Cookies allow you to share content from the website on social networks and allow you to interact with content from different social networks. These Cookies require your consent.
4. The legal basis for the use of marketing cookies is your consent pursuant to Article 6(1)(a) GDPR. The legal basis for the use of technically necessary cookies, preference cookies and statistical Cookies is Article 6(1)(f) GDPR, i.e. we process your Data on the basis of the legitimate interests of the Controller and pursuant to Article 6(1)(b) GDPR, i.e. for the purpose of concluding a contract.
5. You may withdraw/change your consent at any time with effect for the future, without affecting the lawfulness of the processing carried out prior to the withdrawal of consent.

Conclusion
Legislation and our methods of processing your Personal Data may change. If we decide to update this Policy, we will post the changes on our website and notify you of the changes. If there is to be a more fundamental change to this Policy or if we are required by law to do so, we will notify you in advance. This Privacy Policy is valid and effective as of 12.10.2023.

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