version 1
last update: October 22th, 2024
last update: October 22th, 2024
I. Basic Provisions
The data controller, in accordance with Article 4, point 7 of 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 (hereinafter referred to as the "GDPR"), is Hey Wox, s.r.o., company ID: 10866957, with its registered office at Veslařská 563/197, 637 00 Brno, registered with the Regional Court in Brno, Section C, File 123208 (hereinafter referred to as the "Controller").
- Contact details of the Controller:
- Address: Hey Wox s.r.o., Veslařská 563/197, 637 00 Brno
- Email: info@sindiko.com
- Personal data refers to any information about an identified or identifiable natural person. An identifiable natural person is one 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 to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
- The Controller has not appointed a Data Protection Officer, as it is not required to do so under Article 37 of the GDPR, since the processing of personal data does not occur on a large scale, we do not conduct regular and systematic monitoring of data subjects, and we do not process sensitive data within the meaning of Article 9 of the GDPR.
- The website for the Sindiko service is www.sindiko.com.
II. Sources and Categories of Personal Data Processed
- The Controller processes personal data that you have provided, or personal data that the Controller has obtained through a contact form or through an order of services.
- The Controller processes only the following personal data: name, email, and password. We do not process any special categories of personal data as defined in Article 9 of the GDPR.
III. Legal Basis and Purpose of Processing Personal Data
- The legal basis for processing personal data is:
- The performance of a contract between you and the Controller under Article 6(1)(b) of the GDPR – personal data are processed for the purpose of providing the Sindiko service.
- The legitimate interest of the Controller in providing direct marketing (particularly for sending commercial communications and newsletters) under Article 6(1)(f) of the GDPR – applicable to users already using the service.
- Your consent to the processing of personal data for the purposes of direct marketing (particularly for sending commercial communications and newsletters) under Article 6(1)(a) of the GDPR in conjunction with Section 7(2) of Act No. 480/2004 Coll., on Certain Information Society Services, if you have not placed an order for the service.
- The purposes of processing personal data are:
- Fulfilling legal obligations to the state.
- Sending commercial communications and conducting other marketing activities.
- Offering products and services within the scope of the Sindiko service.
- Managing the user account, where only the data provided by the user is processed.
- The Controller engages in automated individual decision-making within the meaning of Article 22 of the GDPR. You have given your explicit consent to such processing.
IV. Retention Period for Personal Data
- The Controller retains personal data:
- For the period necessary to fulfill the rights and obligations arising from the contractual relationship between you and the Controller and to apply claims from such contractual relationships (for 15 years after the termination of the contractual relationship).
- Until consent to the processing of personal data for marketing purposes is revoked, but no longer than 15 years if personal data are processed based on consent.
- The retention period for personal data will be regularly reviewed, and the data will be deleted once the purpose for which it was processed has been fulfilled. After the expiration of the retention period, the Controller will delete the personal data.
V. Recipients of Personal Data (Controller’s Subcontractors)
- Recipients of personal data include:
- Entities providing marketing and business services for Sindiko.
- Entities ensuring the operation of the Sindiko service.
- The Controller intends to transfer personal data to a third country (outside the EU) or an international organization. Recipients of personal data in third countries are providers of mailing services/cloud services with servers in the USA, Canada, and the United Kingdom. The transfer of data to these recipients is secured using standard contractual clauses under the GDPR, which provide appropriate safeguards.
VI. Your Rights
- Under the conditions stipulated in the GDPR, you have:
- The right to access your personal data under Article 15 of the GDPR.
- The right to rectification of personal data under Article 16 of the GDPR, or restriction of processing under Article 18 of the GDPR.
- The right to erasure of personal data under Article 17 of the GDPR.
- The right to object to processing under Article 21 of the GDPR.
- The right to data portability under Article 20 of the GDPR.
- The right to withdraw consent to processing.
- These rights can be exercised in writing or electronically via email to the Controller's address listed in Article I of these terms, or through the contact form available on the Website or in the Sindiko mobile application.
- You also have the right to file a complaint with the Data Protection Authority if you believe that your right to the protection of personal data has been violated.
VII. Conditions for Securing Personal Data
- The Controller declares that it has taken all appropriate technical and organizational measures to secure personal data.
- Technical measures include encryption of data storage, two-factor authentication, regular software updates, and securing access with strong passwords. Personal data in paper form are stored in locked premises.
- The Controller declares that only authorized personnel have access to personal data.
VIII. Final Provisions
- By submitting a contact form or an order form from the Website or the Sindiko application, you confirm that you have read the privacy policy and that you accept it in its entirety.
- By submitting any other online form from the Website or the Sindiko application, you also confirm that you have read and fully accept the privacy policy.
- The Controller reserves the right to change this privacy policy. In the event of significant changes, users will be informed at least one week before such changes take effect, either via email or through a notification on the Website or in the application. The new version of the privacy policy will also be published on the Controller’s Website.
- The Controller reserves the right to suspend or temporarily interrupt any part or the entire Sindiko service. The Controller shall not be liable to users for any damages caused by the temporary or permanent unavailability of the Website or mobile application.