PERSONAL DATA PROTECTION POLICY
Protection of your personal data is essential for Innovatrics, s.r.o.
With regard to the adoption of the Regulation of the European Parliament and of the Council (EU) 2016/679 of 27 April 2016 on the protection of natural persons in the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (“GDPR”), Innovatrics adopts this personal data protection policy.
In this document you will learn:
- Where to contact us for your personal data protection questions
II. How we process personal data when you:
- visit our website fingera.com;
- communicate with us, for example, through a contact form, chat, or electronically;
- subscribe to our newsletter;
- download or watch materials on our website fingera.com ;
- use the support services provided through our website fingera.com;
- use our FINGERA call center .
III. What your rights are as a data subject
Our website and its sub-domains may contain links to third-party websites. These third party websites have their own personal data protection policies and we do not assume any responsibility for these policies. Before submitting any personal data to such third-party websites please make sure that you are thoroughly informed about their policies.
- THE CONTROLLER AND ITS CONTACT INFORMATION
The Controller is Innovatrics, s.r.o., with its registered seat at: Pri vinohradoch 82, 831 06 Bratislava, Slovak Republic, ID No.: 36 280 712, registered in the Commercial Register of District Court Bratislava I, Section Sro, File No. 39481/B.
If you want to communicate with us about personal data protection issues, please use the following contacts:
- E-mail: firstname.lastname@example.org
- Mail – contact address: Innovatrics, s.r.o., Tomášikova 64, 831 04 Bratislava, Slovak Republic.
- HOW WE PROCESS PERSONAL DATA
1) Visitors to our website www.fingera.com
We do not process any personal data about visitors to our website that would enable us to individually identify a visitor to our website.
2) Communication using, for example, a web form, chat, e-mail or other means.
If you communicate with us through our website (e.g. by using chat or a contact form, or by sending an email), we receive your personal data you provide in such communication (in particular, e-mail, name, surname, employer, job position, etc.). We assume that you provide such personal data voluntarily, at your own discretion, and that the data you provide is correct and up-to-date. Handling of your correspondence is our legitimate interest (Art. 6 par.1 letter f) of the GDPR), and we base our right to process your personal data on this legal basis.
We also assume that by sending such correspondence you are expecting and agreeing that we may subsequently contact you by e-mail, phone or by an electronic message with the aim of dealing with your correspondence or request. Your personal data obtained in this manner are processed only for the duration of the purpose of their processing, for a maximum of 12 months after the last communication has ended.
Passive access to your personal data may be available to intermediaries with whom the Controller cooperates when providing the services and which include, in particular, the web hosting providers (servers in Germany) and the web site administrator. For e-mail communication we use services of The Rocket Science Group LLC d/b/a Mailchimp (“Mailchimp”) with its seat in the Atlanta, USA. On July 16, 2020, CJEU invalidated the EU-US Privacy Shield. However, Mailchimp guarantees that it will continue to protect EEA data and contractually commits to transfer and process all of its users’ EU and UK data in compliance with the Standard Contractual Clauses, which automatically apply in accordance with Mailchimp’s Data Processing Addendum (https://mailchimp.com/help/mailchimp-european-data-transfers/ ). Data subjects have the right to object to processing performed based on legitimate interest according to Art. 21 GDPR on our contact details listed above.
On our web site, we offer an opportunity to subscribe to a newsletter where we provide information about our news, offers, information about our product, our company or other business information about our products and services.
If you subscribe to our newsletter, Innovatrics s.r.o. will receive the e-mail address you provide in the subscription request.
Subscribing to the newsletter is not your legal obligation and is completely voluntary. We will assume that the data you provide when subscribing is correct and up-to-date. The legal basis for processing is your consent, which you confirm by checking the box and subsequently confirm it by clicking on the link in the e-mail that will be sent to you immediately after you subscribe. The purpose of processing is our direct marketing – i.e. sending of business information as described above. By subscribing to the newsletter, you also agree that Innovatrics, s.r.o. will send the newsletter to you by e-mail.
We process your personal data only for the duration of the purpose of processing, for a maximum of five years. You can withdraw your consent at any time by writing to the address: Innovatrics, s.r.o., Pri vinohradoch 82, 831 06 Bratislava, Slovak Republic, or by e-mail to: email@example.com or directly by clicking on a special link in each received newsletter. Withdrawal of your consent shall not affect the lawfulness of processing based on consent before its withdrawal.
We point out in particular that according to Article 21 of the GDPR you have the right to object at any time to the processing of your personal data for the purposes of direct marketing. You can send the objection in writing to our address provided above. Unsubscribing from the newsletter will be available to you in each newsletter received.
Access to your personal data may be available to intermediaries with whom the Controller cooperates when providing the services and which include, in particular, the web hosting provider (servers in Germany), the e-mail platform provider (Mailchimp – please see above), and the web site administrator.
4) Downloading or watching materials on our website (“content”)
We are regularly spending a significant amount of our resources for creating specialized content for our customers and prospective customers. Such content presents unique solutions, contains our know-how and instructions on how our biometric software works.
Passive access to your personal information may be available to intermediaries with whom the Controller cooperates when providing the services and which include, in particular, the web hosting providers (servers in Germany) and the web site administrator. Your personal data are processed only for the duration of the purpose of their processing, for a maximum of 4 years after the download/view of the content.
5) Use of support services provided through www.fingera.com.
Existing clients may be granted an access to our support section of www.fingera.com, where we provide specific information and technical assistance to our clients. In order to access the support section, the client will be provided with login and password information, which should be used by a person/persons who will be entitled to request/access our services on behalf of the client. The personal data processed are name, surname, company name, job title, phone and e-mail contact, profile photo (if provided), user role, password and login data. These personal data shall be processed by us only in order to provide the support service, on your request/on the request of the authorized person. The legal basis for processing is Art. 6 par. 1 letter b) of the GDPR (contract) or Art. 6 par. 1 letter f) of the GDPR (it is our legitimate interest to process personal data of employees of our customers who may request/use our services on behalf of our customer). Access to personal information may be available to intermediaries with whom the Controller cooperates when providing the services and which include, in particular, the web hosting providers (servers in Germany) and the web site administrator. Personal data are processed only for the duration of the purpose of their processing, i.e. for as long as the need for the support exists, or as long as our obligation to provide the services lasts. Data subjects have the right to object to processing performed based on legitimate interest according to Art. 21 GDPR on our contact details listed above.
6) Use of FINGERA Call center
We have established a call center for our clients, where we provide service support related to the FINGERA product. In order to provide our clients with the best, fastest, most efficient and highest quality support and service (in particular, shortening the reaction time to the client’s request, eliminating the error rate when transcribing the problem, allocating the problem directly to a specialist and thereby speeding up the provision of the service), calls in the Call center are recorded. The data subjects are informed about the recording by an announcement at the beginning of the call. The voice recording of the conversation, the data given in the conversation, the identification data of the caller, his affiliation with the client, the number from which the call is made, the time and place of the call are processed. We will process this personal data only for the purpose of providing the requested service through the Call center. The legal basis for processing is Art. 6 par. 1 letter f) GDPR (it is our legitimate interest to provide clients with quality services and properly and timely fulfill obligations arising from concluded contracts, we also have an legitimate interest in ensuring the company’s competitiveness). Personal data may be accessed by a processor with whom we cooperate – the call center service provider CloudTalk, s.r.o., IdN: 46817832. Recordings are stored for 3 months, other personal data are processed as long as there is a need for support on the part of the client or as long as our obligation to provide service lasts. Data subjects have the right to object to processing on the basis of legitimate interest according to Art. 21 GDPR on our contact details listed above.
III. YOUR RIGHTS
Please note that Innovatrics does not perform any automated individual decision making nor profiling.
As a data subject under the GDPR, you have the right:
(i) based on a written (including electronic) request to access your personal data (in particular, to require confirmation of whether or not the data is being processed, the category of data being processed, the purpose of the processing, the source of the data, and the duration of retention);
(ii) to repair the incorrect or supplement the incomplete data;
(iii) to restrict the processing of data under Art. 18 of the GDPR (e.g., if the data is incorrect or processed illegally);
(iv) to obtain personal data related to you and which you have provided to the Controller in a structured, commonly used and machine readable format, and the right to transfer such data to another controller under the conditions specified in Art. 20 of the GDPR;
(v) if we process personal data on the basis of your consent, you have the right to withdraw your consent; withdrawal shall not affect the lawfulness of the processing based on consent before its withdrawal.
(v) to object in the cases referred to in Art. 21 of the GDPR (mainly in the cases of processing based on legitimate interests, direct marketing);
(vi) to the erasure of data the purpose of the processing of which has ended or in the cases listed in Art. 17 of the GDPR.
You can exercise your rights on our contact details listed above.
If you believe that your rights are being violated in the processing of personal data or that there is a violation of the Personal Data Protection Act or the GDPR, you may file a motion to initiate personal data protection proceedings at the Office for Personal Data Protection of the Slovak Republic, Hraničná 12, 820 07 Bratislava 27, Slovak Republic; www.dataprotection.gov.sk.
We may change or modify this PERSONAL DATA PROTECTION POLICY at any time, in particular with regard to legislative changes in the area of personal data protection which may be adopted in the future. If we do so, we will inform you accordingly.