prepared in accordance with 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 “GDPR”) and Act No. 18/2018 Coll. on the protection of personal data (hereinafter referred to as “Personal Data Protection Act”)

New School Communications s.r.o., with registered office at Továrenská 12, Bratislava – Staré Mesto 811 09, ID No.: 52 348 521, registered in the Commercial Register of the District Court Bratislava I, Section: Sro, Insert No.: 136918/B (hereinafter referred to as “NEW SCHOOL COMMUNICATIONS” or also as “Our Company”) respects the privacy of all data subjects concerned; regardless of whether it processes personal data itself or through third parties. It is extremely important to Our Company that each data subject understands what personal data we process, why we do it, and what rights the data subjects have. We may process the personal data of data subjects in different ways and in different situations depending on the type of data subject. In the document below you will find general information such as:

– identification and contact details of Our Company (Section 1. of this document),

– Your rights in relation to the processing of your personal data (Section 2. of this document),

– information on automated individual decision-making, including profiling (Section 3 of this document);

for more information about the processing of personal data in your specific case, please refer to Section 4 of this document, depending on whether you are:

– visitor to our website (Section 4.1. of this document) (cookie processing)

– newsletter subscriber (Section 4.2. of this document)

– client or prospective client, (Section 4.3 of this document)

On behalf of NEW SCHOOL COMMUNICATIONS, we would also like to ask you to always provide us with only up-to-date and correct personal data, which will then be processed by Our Company. In the event of a change in your personal data, we also ask you to notify us of this circumstance without undue delay.

To protect your personal data against unauthorised persons and against unlawful processing, unforeseen loss, destruction and damage, both online and offline, we use physical, electronic and organisational measures to prevent such situations from occurring in accordance with our internal privacy policy.

dentification and contact details of NEW SCHOOL COMMUNICATIONS are:

Business Name: NEW SCHOOL COMMUNICATIONS, s.r.o.

Headquarters: Továrenská 12, Bratislava – Old Town 811 09

ID: 52 348 521

Registration in: the District Court Bratislava I, Section: Sro, Insert No.: 136918/B

Mailing Address: Továrenská Street 12, Bratislava – Old Town 811 09

Email: ochranaudajov@katedrakomunikacie.sk

Telephone number: +421 908 169 879

NEW SCHOOL COMMUNICATIONS s.r.o. does not have an appointed responsible person (Our Company is not obliged to appoint a responsible person in accordance with the GDPR and the Data Protection Act).

If Our Company processes your personal data, you have the following rights as a data subject:

– Withdraw consent – where we process your personal data on the basis of your consent, you have the right to withdraw that consent at any time. You may withdraw your consent electronically, at the address set out in Part 1 of this document, in writing, by notice of withdrawal (or by any other appropriate means). Withdrawal of consent does not affect the lawfulness of the processing of the personal data that we have already been processing about you on the basis of that consent.

– Right of access – you have the right to be provided with a copy of the personal data we possess about you, as well as the information about how we use your personal data. In most cases, your personal data will be provided to you in electronic form wherever it is technically possible.

– Right to rectification – we take reasonable steps to ensure that the information we hold about you is accurate, complete and up to date. If you believe that the information we hold is inaccurate, incomplete or out of date, please do not hesitate to ask us to rectify, update or complete the information.

– Right to erasure (to be forgotten) – you have the right to ask us to erase your personal data, for example, if the personal data we have collected about you is no longer necessary for the fulfilment of the original purpose of the processing. However, your right must be considered in light of all the relevant circumstances. For example, we may have certain legal obligations meaning we may not be able to comply with your request.

– Right to restriction of processing – in certain circumstances you are entitled to ask us to stop using your personal data. These include, for example, cases where you believe that the personal data we hold about you may be inaccurate or where you believe that we no longer need to use your personal data.

– Right to data portability – in certain circumstances, you have the right to ask us to transfer the personal data you have provided to us to another third party of your choice. However, the right of portability only applies to personal data that we have obtained from you on the basis of consent or on the basis of a contract to which you are a contracting party.

– Right to object – you have the right to object to processing based on our legitimate interests. If we do not have a compelling legitimate ground for processing and you object, we will no longer process your personal data.

– The right to file a petition to initiate a personal data protection procedure – if you believe that your personal data is being processed unfairly or unlawfully, you may file a complaint with the supervisory authority, which is the Office for Personal Data Protection of the Slovak Republic, Hraničná 12, 820 07 Bratislava 27; telephone number: +421 /2/ 3231 3214; e-mail: statny.dozor@pdp.gov.sk, https://dataprotection.gov.sk. If the application is submitted electronically, it must comply with the requirements of § 19(1) of Act No 71/1967 Coll. on Administrative Proceedings (Administrative Procedure Code).

Your personal data will not be used for automated individual decision-making, including profiling.

The provisions of this Section 4. shall not apply to data subjects who have been specifically instructed in writing by NEW SCHOOL COMMUNICATIONS in accordance with § 19 and 20 of the Personal Data Protection Act in the event that the data subject has signed such an instruction in his or her own handwriting, as from the moment of signing such an instruction in his or her own handwriting.

NEW SCHOOL COMMUNICATIONS operates the website located at www.newschool.sk and www.elfovia.newschool.sk (hereinafter collectively referred to as the “Website”).

If you visit a website (including Our Company’s website) that uses cookies, a small text cookie will be created on your computer. A cookie is a short text file that a website stores on your computer or mobile device (including tablet) browser when you browse the website. If you visit the same website repeatedly in the future, it will, for example, make you connect faster or help the website remember certain information about your browsing preferences, browser type, selected website settings, etc. You can control or delete cookies at your discretion. You can delete all cookies stored on your computer and you can set most browsers to prevent them from being stored. Instructions for removing or blocking all cookies, even incorrectly stored cookies, can be found on the web browsers’ websites.

We process cookies for a variety of purposes (listed below), but primarily we use them to be able to display our website in an optimal way for you, to ensure the proper functionality of our Website in accordance with your preferences. For purposes other than those listed above, your cookies will only be stored with your consent.

1. a) Functional (necessary) cookies: Functional (necessary) cookies guarantee functions without which you would not be able to use the Website and ensure, among other things, that when you use the functions of the website, a version corresponding to your internet connection is displayed. In addition, cookies of this type store your decision to use cookies on our site. These cookies do not collect information and data on the basis of which we can individually identify you as a user of our Website. The strictly necessary cookies that we use are (processed for the following purposes): – cookies that are used to secure the transmission of data over the internet; – cookies that are strictly necessary to provide you with a service that you have specifically requested; – cookies that enable our Website to remember the choices made on your device while you are browsing the website and to provide enhanced and personalised features.
2. b) Analytical cookies: These cookies are used to provide statistical information about the performance of our Website (e.g. number of visits, traffic sources, etc.). For example, analytical cookies can recognise repeated visits to our website from the same device and track your activity. In particular, the information obtained helps us to determine the effectiveness of individual parts of our Website, which we then use to improve the Website

We use third-party analytical cookies on our site that are not created or managed by our site, but rather by a third party. We use cookies as part of the Google Analytics platform, which uses cookies to analyse visits to our Website; for more information, please visit this link: (https://support.google.com/analytics/answer/6004245?hl=sk )

By consenting to the use of analytical cookies through the Google Analytics platform, you agree that we may place cookies on your computer through our Website.

You can withdraw your consent to the use of analytical cookies via the Google Analytics platform at any time, including by adjusting settings directly in your web browser or also via this link: ( http://www.aboutads.info/choices or http://www.youronlinechoices.eu. )

When you visit our website for the first time, you will see a pop-up window (bar) with an explanation about cookies. Within this bar, you can choose to consent or not to the processing of individual types of cookies by the website (with the exception of functional or essential cookies for which your consent is not required).

You can also disable the use of cookies at any time directly via your browser (for more information, please refer directly to your browser settings). If you refuse or disable the use of cookies, you will be able to use our website, but some features may not function properly.

We also point out that you have rights in relation to cookies, as set out in Section 2 of this document (above).

We will retain the browsing data stored according to the cookie settings for as long as necessary for the purpose for which it was collected, but for no longer than 2 years.

Newsletter subscription – marketing purposes and the implementation of our marketing activities, which include providing information about our activities, sending newsletters and displaying targeted advertising.

Source of personal data. Personal data is provided to Our Company by the interested party itself, voluntarily by filling in the contact form for the purpose of subscribing to the newsletter, which is located on the Website.

Our Company processes your personal data on the basis of your consent, which you give by ticking the consent box located next to the contact form for the purpose of receiving the newsletter, which is located on the Website.

If you are interested in our newsletter, we collect and process the following data from you: email address.

Personal data is processed directly by Our Company in electronic form. Our Company may share your data with third parties in the following circumstances:

– If required by law or court order, we may share your personal information with, for example, law enforcement or other authorized authorities in Slovak Republic.

– We may also disclose your personal data to companies with an economic or personal link to Our Company in the case of a legitimate interest of Our Company.

Certain activities are carried out for Our Company by subcontractors. In order to carry out these activities, it is required that the personal data of the data subject is provided to such subcontractor to the extent necessary for the performance of the subcontractor’s tasks. Such external subcontractors include, in particular, external marketing agencies, other consultancies and companies providing administrative services, data storage and server management companies. The specific companies and activities may be subject to change according to the current needs of Our Company. In the case of sharing personal data, Our Company will ensure the highest level of protection of your personal data and its processing in accordance with the Data Protection Act.

Our Company may also process some personal data through electronic systems and data storage operated by persons (processors) outside the European Union. Our Company will always verify that they ensure the highest possible protection of personal data in accordance with the relevant legislation (i.e. they are part of the European Commission’s adequacy decision, e.g. as a part of the EU-US Privacy Shield programme if they are located in the USA, etc.).

In accordance with the GDPR principle of proportionality and minimisation of the processing of personal data, we store your personal data for 3 years after you have given your consent. After this period, your personal data will be deleted and destroyed. If you would like us to continue to send you our newsletter, you can re-grant us your consent for this purpose via the Website.

At all times, you have the option to withdraw your consent to receive the newsletter that you have previously provided to us and thus, unsubscribe from receiving it. You can do so by clicking on the “Unsubscribe from newsletter” link in the email message you received from us or by emailing us at our contact details listed earlier in this document.

NEW SCHOOL COMMUNICATIONS product means any service provided by NEW SCHOOL COMMUNICATIONS and/or any goods sold by NEW SCHOOL COMMUNICATIONS.

In order to enter into and perform a contract with you or a company you represent or to be able to use a product we offer, it is necessary to process your personal data.

In particular, the purpose is, in specific cases, the processing of personal data in connection with the following activities: (i) the conclusion of a contract or other contracts and the processing of related documents, their registration or control and modifications, including the provision of performance of these contracts, (ii) the maintenance of the company’s accounting records.

Source of personal data. Contact personal data is provided to Our Company by the person interested in the product itself (e.g. by contacting us via the Website or e-mail), either voluntarily or by Our Company from publicly accessible sources (registers and databases of persons interested in products similar to Our Company’s products) or from cooperating persons (if such processing of personal data is in accordance with the law, taking into account that the confidentiality of personal data is always ensured by contract).

We only process your personal data if we have a legal basis to do so.

– This means that the processing must be necessary for the performance of a contract to which you or the company you represent are a party or to enable steps to be taken on request before the contract is concluded (the legal basis is therefore the contract, including pre-contractual relationships, and the performance of the individual rights and obligations under such contract and related documents).

– In accordance with our legitimate interest, we may also use your data for the proper conduct of Our Company’s business, to provide you with information about our products, prospects, analyses that may be in your best interest or to perform necessary or required tasks arising from a business relationship (the legal basis is therefore the legitimate interest of Our Company).

– We have a legal obligation to disclose your personal data when inspected by authorised institutions and when preventing, monitoring and proving fraud and other crimes (the legal basis is therefore also the law in selected cases).

NEW SCHOOL COMMUNICATIONS processes “ordinary personal data” to the extent necessary to fulfil the purposes set out in Section 4.2.1 of this document, in particular to the following extent:

– name, surname,

– permanent address, correspondence address

– ID number, Tax Identification number, VAT number, place of business, registered office or branch (which may be the same as the place of residence); in the case of clients – self-employed persons

– phone number, e-mail

– account numbers (for sending any contract-based materials)

– signature

Personal data is processed directly by Our Company in written and electronic form. Personal data may be disclosed to entities authorised under specific regulations, which are in particular: law enforcement authorities, courts, bailiff’s offices, etc.

Certain activities are carried out for Our Company by subcontractors. In order to carry out these activities, it is required that your personal data is provided to such subcontractor to the extent necessary for the purposes of carrying out the subcontractor’s tasks. Such external subcontractors include, in particular, external accounting, tax, marketing legal and other consulting companies, web hosting and server and/or data storage management companies, etc. Specific companies and activities may be subject to change, depending on NEW SCHOOL COMMUNICATIONS’ current needs.

In the case of sharing personal data, Our Company will ensure the highest level of protection of your personal data and its processing in accordance with the Personal Data Protection Act.

Our Company may also process some personal data (e.g. name, surname and email) through electronic systems and data storage operated by persons (processors) outside the European Union. Our Company will always check that they ensure the highest possible protection of personal data in accordance with relevant legislation (i.e. they are part of the European Commission’s adequacy decision, e.g. part of the EU-US Privacy Shield program if they are located in the USA, etc.).

Your data will be kept by Our Company for as long as is necessary to fulfil the purpose of the processing according to the special regulations and the purpose for which it was collected (see Section 4.2.1 above), if we have a legitimate interest in keeping your data, for example, until the end of the contractual relationship. After the termination of the contractual relationship and the settlement of all obligations arising out of or in connection with such contractual relationship, Our Company will retain your personal data for the time strictly necessary and for the period required by the relevant legislation. In the absence of such a statutory period, Our Company is entitled to retain your personal data for at least three years from the date of termination of the contractual relationship (up to a maximum of ten years, unless the applicable law provides for a longer retention period). In the event of a legal dispute with you (as the data subject) for at least three years from the date of the final conclusion of the legal dispute.