PRIVACY POLICY TO USERS

D&G group s.r.o., with registered office in Grösslingova 4, Bratislava – Mestská Časť Staré Mesto, 81109, VAT number SK2023577028 (hereinafter referred to as the owner) is the owner and the responsible person for data processing.

Source of data: www.social-application.net (hereinafter also the “Site”)

Data processed and data source

Data provided by the User voluntarily when registering on the Site or in subsequent phases in order to use the Services offered. The User’s data collected by the Data Controller for the purposes of registration on the Site and registration for services, competitions, events (hereinafter referred to as Services) include: e-mail address, mobile phone, account profile, date of birth, gender, province, municipality of residence as well as any other personal information the User may voluntarily provide.

Navigation data: computer/telematic systems and software procedures used for the useful operation of the Site acquire, during their normal operation, some data of a personal nature, the transmission of which is implicit in the use of web communication protocols or is useful for the better management and optimization of the system for sending data and e-mails. This acquisition, which takes place exclusively for statistical purposes or to monitor the correct functioning of the Site, is not aimed in any way at identifying the User. The data on web contacts are not stored after their processing, except in the case of computer crimes against the Site.

Protection of minors

The services offered by the Site are expressly and exclusively dedicated to an adult audience. Therefore, the Site does not accept registration by minors. Registered Private Users and/or Companies may report any violations of this article to the Owner, at the addresses indicated in article 8 of this policy.

Consent and legal basis for processing

The provision of consent for the purposes referred to in paragraph 1) is mandatory for the provision of services on the site.

The legal bases for the processing of personal data collected for the purposes referred to in paragraph 1) are: the fulfillment of contractual obligations, execution of pre-contractual activities, administrative-accounting; legal obligations.

The provision of consent for the purposes referred to in paragraphs 2) and 3) is always optional.

The user is free to optionally provide informed consent, without being precluded from using the services of the site.

The Data Controller hereby provides the Privacy Policy drawn up pursuant to Article 13 et seq. of European Regulation 679/2016 (“GDPR”), in its capacity as Data Controller of the personal data of users registered on the Site (hereinafter, the “Users”).

The Owner takes into the utmost consideration the right to Privacy and protection of personal data of its Users. For any information in relation to this Privacy Policy, Users may contact the Data Controller at any time, using the contacts indicated in paragraph 8 below.

You may revoke your consent at any time.

1.    Contractual, pre-contractual and legal obligations

In order to use one of the Services of the Site, the personal data of the Users will be processed by the Data Controller for the following purposes:

a) contractual obligations or to perform the services requested on the Site and provide assistance to the User. Unless the User gives the Data Controller a specific consent to the processing of his/her data for marketing purposes pursuant to paragraph 2 below, the contact data (e-mail address and telephone number) will be used by the Data Controller for the exclusive purpose of ascertaining the identity of the User (also by validating the e-mail address), thus avoiding possible fraud or abuse, and to contact the User for service reasons only (e.g. to send notifications regarding the services offered on the Site). The Owner may also request the communication of the User’s mobile phone number. In this case, the User’s e-mail address and telephone number will be used to communicate any information about the services requested;

b) contractual and pre-contractual purposes, of an administrative-accounting nature, or to carry out activities of an organisational, administrative, financial and accounting nature functional to the fulfilment of contractual obligations;

c) legal obligations, i.e. in order to fulfil the obligations provided for by the law, by a regulation or by the European legislation (e.g. tax legislation; legislation on prize competitions – D.P.R. 430/2001; legislation on privacy, such as, for example, queries from the Privacy Authority).

The personal data that are necessary for the pursuit of the processing purposes described in this paragraph 1 are indicated with an asterisk in the registration form on the Site.

  • 2. Further processing purposes: marketing (sending of advertising material, direct sales and commercial communication)
  • With the free and optional consent of the User, personal data (name, surname, sex, e- mail address, mobile phone, postal address and date of birth) may be processed by the Data Controller also for marketing purposes, by means of telephone contacts and postal communications for commercial, promotional and advertising purposes, direct sales, for prize-giving events, surveys; or by means of mobile phone (with automated calling or calling communication systems and/or SMS and/or MMS) and/or e-mail to propose to the User the purchase of products and/or services offered by the Owner, by third companies and/or on behalf of their customers, to present offers, promotions and commercial opportunities, as well as to inform the User of the launch of Services on the Site.

Consent to the processing of personal data for this purpose is not mandatory and refers to all data collected on the Site. If consent is not given, the possibility of registering on the Site and/or using its Services will not be affected.

If consent is given, the User may revoke it at any time by making a request to the Data Controller in the manner indicated in paragraph 8 below.

The User may also easily object to further promotional email communications by clicking on the appropriate unsubscribe link for the revocation of consent, always present in each promotional email sent. Once the revocation of consent has been made, the Owner will send the User an email to confirm the revocation. If the User wishes to revoke his consent for only one of the accepted methods of contact, he can also request it by following the procedures indicated in paragraph 8 below.

  • 3. Further processing purposes: communication of data to Third Parties
  • With the free and optional consent of the User, his/her personal data (i.e. gender, name, surname, postal address, e-mail address, telephone), will be communicated by the Data Controller to the following categories of third party companies: (i) fixed, mobile and ADSL telephony companies; (ii) companies active in the world of publishing (print media, internet, television and new media); (iii) companies active in the e- commerce sector of products and services; (iv) companies operating in the electricity and/or energy sector; (v) companies operating in the travel and leisure sector; (vi) companies dealing with professional and/or educational training; (vii) advertising and communication agencies, media and contact centres, companies operating in direct marketing and list brokerage; (viii) companies operating in the food sector; (ix) NGOs and non-profit organisations; (x) companies operating in the financial sector, credit brokers, banks, finance companies, agents in financial activities and the insurance sector; (xi) bodies and/or companies for public utility communications (xii) companies operating in the marketing and web communication sector, as well as their business partners, belonging to the e-commerce, mail order, publishing, utilities, tourism, sports, communication, entertainment, financial, insurance, automotive, office equipment suppliers, digital and/or satellite TV service providers and TV broadcasters, manufacturers and/or distributors of children’s items sectors, companies operating in the consumer goods sector, for the sending of advertising material and other promotional and commercial purposes using the following means (telephone with operator and/or automated call systems or call communication without the intervention of an operator, email, sms, Whatsapp, Messenger, fax, mms, push notifications, messages on social networks, autoresponders and/or paper mail).

The Third Parties, as independent data controllers, will process the User’s personal data for the purposes indicated in point 2 of this policy.

It is possible to request the complete list of companies that are autonomous owners of the data processing, by sending a communication to the Owner in the manner indicated in paragraph 8 below.

The Data Controller informs that, following the exercise of the right to object to the sending of promotional communications via email, it is possible that, for technical and operational reasons (e.g. the formation of contact lists already completed shortly before the receipt by the Data Controller of the request for objection), the User will continue to receive some further promotional messages. Should the User continue to receive promotional messages after 72 hours from the exercise of the right to object, please report the problem to the Controller using the contacts indicated in paragraph 8 below.

  • 4. Processing for further profiling purposes
  • For marketing purposes and to improve the services and functionalities of this website, the Data Controller may process data for so-called “profiling” purposes. In this case, according to the indications of the Working Group WP29 – Guidelines on Automated individual decision-making and Profiling for the purposes of Regulation 2016/679 – the profiling activity may concern both “individual” and “aggregated” personal data.

Profiling” means the activity of structuring data on the basis of predefined parameters identified from time to time, depending on the company’s needs, which leads to the definition of user “profiles” (for example, by consumption bands, level of expenditure, active services, commercial attitude, etc.).

Such profiles would not derive from the mere informative attitude of the data individually or separately considered. It is therefore through such structuring activity that the definition of user profiles can be achieved.

In general, profiling is aimed at providing an added value to the information, consisting in the ability to establish correlations between the individual data collected, in order to obtain additional useful information.

The processing operations illustrated above will hereinafter be collectively referred to as “Profiling Processing”.

In order to proceed with the Profiling Treatment, the Owner will acquire in advance the user’s specific, express and completely optional consent. Failure to provide consent does not affect the possibility of registering on the site and using its Services.

The purposes of the profiling treatment are of a specific commercial, advertising, promotional and marketing nature in the broadest sense.

Finally, it should be noted that the provision of personal data for purposes related to the Profiling Treatment and the provision of consent to the treatment for the same purposes are revocable at any time, according to the procedures set out in paragraph 8 below.

  • 5. Modalities of data processing and retention times
  • The Owner will process the personal data of the Users by means of manual and computerized tools, with logics strictly related to the purposes and, in any case, so as to ensure the security and confidentiality of the data.

In the cases referred to in paragraph 1 above, the personal data of the Users of the Website will be kept for the time strictly necessary to carry out the primary purposes related to the use of the Services by the User or, in any case, for the time necessary to protect the interests of both the Users and the Data Controller in civil proceedings, and therefore for a period of time between 5 and, in case of litigation, 10 years.

In the cases referred to in paragraphs 2 and 3 above, the personal data of Users will be stored by the Data Controller for the time strictly necessary to carry out the purposes illustrated therein and, in any case, for no longer than twenty-four (24) months from the time of collection and/or receipt of such data and/or from the last use of the services offered by the Website. Exceptionally, personal data intended for independent data controllers belonging to the following categories: i) fixed-line, mobile and ADSL telephone companies; ii) companies active in the world of publishing (print media, internet, television and new media) iii) companies active in e-commerce of products and services, iv) companies operating in the utilities sector – gas, electricity, water, photovoltaic and water purification, referred to in paragraph 3 above, will be stored by the Owner, by virtue of the specific type of products and services offered by them and taking into account the evaluations made in terms of data retention, for no more than forty-eight (48) months.

  • 6. Scope of communication and dissemination of data
  • The personal data of the Users may be disclosed to the employees and/or collaborators of the Owner in charge of managing the Site. These subjects, who have been instructed to do so by the Owner pursuant to Article 29 of the Regulations, will process the User’s data exclusively for the purposes indicated in this information notice and in compliance with the provisions of the Applicable Regulations.

Users’ personal data may also be disclosed to third parties who may process personal data on behalf of the Data Controller in their capacity as “Sponsors – Independent External Data Controllers”, such as, for example, suppliers of IT and logistical services functional to the operation of the Site, suppliers of outsourced services or cloud computing, professionals and consultants.

Users have the right to obtain a list of any data processors appointed by the Data Controller, by making a request to the Data Controller in the manner indicated in paragraph 8 below.

  • 7. The List of Sponsors – independent external holders of the treatment:

8. Rights of the interested parties

Users may exercise the rights guaranteed to them by the Applicable Rules by contacting D&G group s.r.o. in the following ways: by sending an email to info@dg-group.sk or deg.group.sro@gmail.com.

Pursuant to current and applicable Legislation, the Data Controller informs that Users have the right to access their Personal Data, object to the processing or request the deletion, modification or updating of all Personal Information collected, exercise the right to restriction of processing and the right to data portability.

For the purposes of processing personal data based on the optional consent of the user, the same may at any time revoke it.

If you believe that the processing of your personal data is in breach of the Regulation, you have the right to lodge a complaint with the supervisory authority of the Member State in which you have your habitual residence, in which you work or in which the alleged breach occurred.

  • 9. Further clarifications in relation to the granting of consent
  • By selecting the appropriate flags on the Registration Form, the user declares that he/she has received complete information from the Controller regarding the use of his/her personal data and explicitly consents to the processing of the same by the Controller, for the specific purposes to which they refer. By ticking the relevant boxes, the user therefore indicates his conscious and free choice as to whether or not to grant consent for the individual purposes of processing his personal data, i.e. in relation to both the purposes related to the use of the Services, marketing, promotion and sales, and profiling.

  1. 10. Cookies Policy
  2. The data controller will use the personal data communicated in order to allow Users to take advantage of certain services or to obtain information in relation to the use of the services provided by the Site, however, the computer systems and software used to operate the Site may acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

This information is not collected to be associated with identified interested parties, but by its very nature could, through processing or association, allow the user to be identified. This category includes IP addresses of computers used by users who connect to the Site, the url of the requested resources, the time of the request, the size of the file obtained in response, etc.. These data are used only to obtain anonymous statistical information on the use of the Site (such as, in particular, the number of accesses) and to check its correct functioning and are deleted immediately after processing. No directly identifying information is processed in this process.

The Site also uses cookies, i.e., lines of text that are used to perform automatic authentication, track sessions and store specific information about users.

The Internet browser offers the possibility of preventing the Site from saving and using cookies. However, this may prevent the full or correct functioning of the functions offered by the website.

D&G group s.r.o. uses cookies on the Site mainly for the purpose of collecting data that help us to improve the Site itself and to draw up usage statistics relating to navigation, pages viewed, favourite elements, clicks made by users, as well as cookies of third party partners of D&G group s.r.o.

The types of cookies, both of the Site and of third parties, used on the Site are the following:

session management cookies: they facilitate access to the Site and navigation within it;

performance monitoring cookies: these allow the performance of the Site to be verified by monitoring the use of the Site by users; the data collected through these cookies are processed in an anonymous and aggregate form and therefore provide mere statistical information on the number of visitors to the Site, where they come from and the pages they visit;

functionality cookies: they allow to store the settings selected by users on the Site in order to improve usability and functionality for the user;

On the Site, Users may at any time choose which cookies they wish to receive and which they do not wish to receive by using their browser settings panel. However, if you choose not to accept certain cookies, you may not be able to properly use certain features of the Site.

Below, Users will find the updated list of third-party cookies used on the Site and the relevant personal data processing information:

Google Analytics – http://www.google.com/intl/it_ALL/analytics/learn/privacy.html

For further information on the use of cookies you can contact us at info@dg-group.sk or deg.group.sro@gmail.com

  1. 11. Updating and modification of the Privacy Policy
  2. D&G group s.r.o. reserves the right to modify this information and the conditions of use by highlighting the changes made on the Website in the “Privacy Information” section; we therefore advise Users to periodically visit this page to view any changes and updates.