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PRIVACY POLICY

  1. IDENTIFICATION OF CONTROLLer, circle of data subjects and initial information
  2. Fullframe s.r.o., with its registered office at Karpatské námestie 10/A, 831 06 Bratislava, Slovak Republic, Identification No.: 46 999 337, registered in the Commercial Register of the District Court Bratislava I, section: Sro, insert No.: 86971/B, is the controller of personal data (the “Controller”) in the information systems in which the personal data of the Data Subjects are processed. The words “we”, “our” and any modifications to these words may be used to identify the Controller in the text of the Document.
  3. The Data Subjects shall be in particular the Consumer who concludes the Agreement with the Controller in accordance with the Controller’s general terms and conditions (the “GTCs” or the “General Terms and Conditions”) through an Order of the Goods and/or Services executed on the Website or otherwise in accordance with the General Terms and Conditions. The Data Subjects shall also be other natural persons who have granted us consent to the processing of personal data for the relevant purposes, such as the persons who have subscribed to the newsletter via the appropriate form available on the Website. The words “you”, “your” and any modifications to these words may be used to identify the Data Subject in the text of the Document.
  4. We have created this Privacy Policy (the “Document”) for the Data Subjects in order to enhance sufficient transparency and clarification of the basic rules we follow when protecting privacy and your personal data, as well as to comply with the information obligation pursuant to Articles 13 and 14 of the GDPR, while ensuring that you are informed about the content of this Document even before collecting personal data when you provide us with your personal data for the first time or directly when you grant us your consent to the processing of personal data for the specified purposes.
  5. This Document deals with the processing of personal data and adherence to the basic principles of lawful processing of personal data based in particular on performing the necessary processing of personal data lawfully, fairly vis-à-vis all interested parties and transparently vis-à-vis the Data Subjects. We continually place great emphasis on the security of personal data processing, while minimizing data and processing operations to the minimum necessary to properly conclude our mutual Agreement and fulfil the obligations under it.
  6. You make a declaration of having familiarized with this Document published on the Website, valid at the time of conclusion of the Agreement, in the form of a confirmation of your will to be bound by its provisions as well as the provisions of the General Terms and Conditions, by sending an Order of the Goods and/or Services using the electronic order form on our Website, or another form of action in accordance with the General Terms and Conditions (for example, by e-mail order), by which you express your will to conclude an Agreement with us.
  1. LIST OF PERSONAL DATA SUBJECT TO PROCESSING, PURPOSE OF PROCESSING AND LEGAL BASIS

Conclusion of the agreement

    1. The processing of your personal data takes place within the process of conclusion of the Purchase Agreement in several stages. First, these are pre-contractual acts aimed at purchasing the Goods. We process your personal data for the purposes of ordering the Goods on the legal basis of performance of the Agreement pursuant to Article 6(1)(b) of the GDPR to the following extent: 

name, surname, telephone number, e-mail address, address for delivery of goods, information on goods purchased and information related to payment for goods (especially account number, amount paid, date of crediting the payment to our account).

The provision of personal data pursuant to this clause shall constitute compliance with the requirement to conclude an agreement, and you are not obliged to provide us with these personal data. However, the possible consequences of not providing the personal data shall constitute the impossibility to execute a binding order of the Goods and the subsequent impossibility to conclude the Purchase Agreement. The retention period applicable to personal data pursuant to this clause shall be the period until the conclusion of the Purchase Agreement. If the Purchase Agreement is concluded, the processing will then be governed by clause 2.2 of this Document, and if the Purchase Agreement is not concluded, the processing and retention of your personal data will be terminated.

    1. After executing the order of the Goods, the order is confirmed and subsequently the Purchase Agreement is concluded. We process your personal data for the purposes of concluding the Purchase Agreement on the legal basis of performance of the Agreement pursuant to Article 6(1)(b) of the GDPR to the extent pursuant to clause 2.1 of this Document. In this case, however, the purpose of processing of your personal data changes, being the conclusion of the Purchase Agreement itself, and the provision of your personal data shall constitute the fulfilment of the contractual requirement; if the personal data is not provided, it will not be possible to conclude the Purchase Agreement. The period of processing of personal data shall constitute the period from the conclusion of the Purchase Agreement, during the performance of mutual obligations, until the expiration of the period for exercising any rights and legal claims arising from the Purchase Agreement (for example, the period for making a warranty claim, the period for claiming damages).

conclusion of the service agreement

    1. In the event that acts leading to the conclusion of the Agreement are performed on the Website, the subject of which may be the provision of Services Access to audio-visual recording, processing Your personal data is used to order the Service on the legal basis of performance of the Agreement pursuant to Article 6(1)(b) of the GDPR to the following extent:  

e-mail address and data related to the payment for the provision of the service (especially the account number, the amount paid, the date of crediting the payment to our account).

The provision of personal data within the meaning of this point constitutes compliance with the requirement to conclude an agreement and you are not obliged to provide this data to us. However, the possible consequences of not providing data represent the impossibility of executing a binding order for the Service and the consequent impossibility of concluding a Service Agreement. The data retention period according to this point represents the time until the conclusion of the Service Agreement. In the event that the Service Agreement is concluded, the processing will continue to be governed by clause 2.4 of this Document and in the event that the Service Agreement is not concluded, the processing and storage of your personal data will be terminated.

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    1. After the execution of the order for the Services, the order is confirmed and subsequently the Agreement for the provision of the Services is concluded. For the purposes of concluding the Agreement for the provision of the Services, we process on the legal basis of performance of the Agreement pursuant to Article 6(1)(b) of the GDPR your personal data to the extent specified in clause 2.3 of this Document. In this case, however, the purpose for processing your personal data changes, which is the conclusion of the Agreement for the provision of the Services and their provision represents the fulfillment of the contractual requirement. In the absence of personal data, it will not be possible to conclude the Service Agreement and provide the Services. The period of processing personal data represents the period from the conclusion of the Service Agreement, during the performance of mutual obligations, until the expiration of the period for exercising any rights and legal claims arising from the Service Agreement (for example, the period for claiming, damages). 

Post-contractual obligations

    1. We process your personal data even after the termination of the fulfilment of obligations arising from the contractual relationship. In fact, both parties have the right to exercise claims for liability for defects and damages as well as to make warranty claims and they also have a statutory or contractual right to withdraw from the Agreement. For the purposes of making a warranty claim, withdrawing from the Agreement, exercising claims for liability for defects and damages (the “Post-contractual Obligations”), we process your personal data on the legal basis of statutory obligation pursuant to Article 6(1)(c) of the GDPR to the extent specified in clause 2.1 and 2.3 of this Document based on what type of Agreement the Data subject concluded (Purchase Agreement or Service Agreement) as well as data on the Goods and/or Services which are the subject to the warranty claim and data provided when making the warranty claims. 

The provision of personal data pursuant to this clause shall constitute fulfilment of the statutory requirement, which creates an obligation for you to provide us with the data. The possible consequences of failing to provide these data shall constitute the impossibility to fulfil our obligations under the Post-contractual Obligations arising from both the contractual provisions and laws. The retention period of personal data shall be the period from the date of exercising the claim for performance arising from the Post-contractual Obligation until the end of the provision of our performance and possible subsequent settlement of mutual performances (for example, until you pick up your repaired Goods or until the legal proceedings are finally completed).

    1. In addition to processing your personal data on the legal basis of statutory obligation, we also process your personal data for the purpose of exercising our claims only. These are, for example, cases where, due to non-compliance with the contractual conditions, we have a receivable owed to us by the customer, or where damage has been inflicted on us. In such a case, we process your personal data on the legal basis of legitimate interest pursuant to Article 6(1)(f) of the GDPR to the following extent:

data contained in the Agreement pursuant to clause 2.1 and 2.3 of this Document based on what type of the Agreement Data subject concluded (Purchase Agreement or Service Agreement), data processed within the process of making a warranty claim pursuant to clause 2.5 of this Document, data kept by third parties (e.g. data kept in accounting).

The purpose of the processing of your personal data pursuant to this clause of this Document is our legitimate interest, being the protection of our property and protection against unjust enrichment, and you shall tolerate this processing even without your consent. The retention period of personal data shall constitute the statutory limitation period of individual rights and the limitation period for the exercise of individual claims arising from the contractual relationship as well as from breaches of laws in force during the validity of the Agreement.

MARKETING 

    1. Our interests also include staying in touch with you and being able to inform you about news, special offers and other offers of the Goods and Services we provide. To this end, we offer you the possibility to express your consent to the processing of your personal data for marketing purposes and subscribing to the Newsletter. We process your personal data for marketing purposes on the legal basis of consent pursuant to Article 6(1)(a) of the GDPR to the following extent: 

name, surname and e-mail address.

The provision of these personal data shall not constitute the fulfilment of the contractual requirement; therefore, you are not obliged to provide us with these personal data. You can withdraw this consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. The retention period of personal data shall be the entire period of validity of the consent, usually not longer than for 3 years, unless the consent is renewed.

    1. Except where you grant us your consent to the processing of your personal data for marketing purposes (for example, by subscribing to the Newsletter or expressing consent when executing the Order), we process your personal data for marketing purposes on the legal basis of legitimate interest pursuant to Article 6(1)(f) of the GDPR to the following extent: 

name, surname (if the Purchase Agreement is concluded), e-mail address, order history.

In this case, it is legitimate interest, being the sale of the same Goods, similar Goods or Goods related to the Goods that you have already purchased from us; for this reason, your special consent is not required. When processing these personal data, we also rely on the provisions of Act No. 351/2011 Coll. on Electronic Communication, that authorises us to do so. The duration of the processing and retention of personal data shall be the duration of the legitimate interest; you always have the option to refuse to send marketing materials and express your disagreement with the processing of your personal data. 

COOKIES And use of the website

    1. In order to provide you with high-quality and trouble-free operation of our Website, as well as to facilitate the process of creating an Order and purchasing the Goods, we use cookies on our Website, which fact you are notified of when visiting the Website and at the same time invited to consent to their use. Cookies used on our Website can be specified as cookies that allow you to use the primary functionality of the Website (for example, to select one of the options offered) and cookies that extend the functionality of the Website while storing information about your steps and preferences for certain period of time (such as login name, language or the Goods added to the Cart), so you do not have to re-enter them the next time you visit the Website or browse individual subpages. 
    2. Cookies the use of which is necessary for the proper functioning of the Website are used without your consent; in the case of cookies that improve the functionality of the Website and store some of your data and information, you have the opportunity to grant or not grant consent to their use immediately upon visiting the Website. 
    3. The use of cookies can cause individual files to be included in a chain of other data related to your person, as a result of which they will become personal data. For the purpose of improving the functionality of the Website, facilitating the process of creating an Order and purchasing the Goods, as well as adapting the Website to your preferences, we process the personal data on the legal basis of consent pursuant to Article 6(1)(a) of the GDPR and on the legal basis of legitimate interest according to Article 6(1)(f) of the GDPR in the form of cookies. 

The legitimate interest in the processing of personal data under this clause is the interest in the proper functioning of the Website, its protection, as well as the proper performance of business activities operated through the Website. In the case of processing personal data on the legal basis of consent, you have the possibility to withdraw your consent at any time, which, however, will not affect the lawfulness of the processing based on the consent before its withdrawal. The retention period of personal data shall be the duration of the legitimate interest or the duration of validity of the consent, usually not longer than 48 hours.

    1. All cookies that our Website may store on your end device can be checked and deleted. By appropriately setting the preferences of the internet browser, it is possible to effectively and completely prohibit the use of the cookies. Generally, it can be stated that it is necessary to switch on the function that is usually called “Protection against spying” in the internet browser.

DELIVERY

    1. After executing the Order of the Goods selected by you, you have the option to choose the method of delivery of the purchased Goods on our Website. In such a case, your personal data is processed on the legal basis of consent pursuant Article 6(1)(a) of the GDPR to the following extent:

name, surname, telephone number, delivery address. 

You can withdraw this consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Withdrawal of consent or failure to provide the data necessary for this purpose has possible consequences in the form of impossibility to deliver the Goods purchased by you. The retention period of personal data shall be the entire period of validity of the consent, usually not longer than is necessary for the act of delivery and settlement of all rights and obligations arising therefrom.

    1. During the delivery process, the personal data of the data subject other than the person who concluded the Purchase Agreement may be processed. This situation may occur, for example, if you have the Goods purchased by you delivered to the address of a family member who promised to take over the shipment, or, for example, if the Goods purchased by you are a gift for the recipient of the shipment. In such a case, we process both the Purchaser’s personal data to the extent specified in clauses 2.1 to 2.2 and 2.5 to 2.13 of this Document, as well as the data of the data subject to whom the shipment will be delivered to the extent of: 

name, surname, delivery address, telephone number.

The processing of personal data of the data subject pursuant to this clause shall be performed for the purpose of delivery of the purchased Goods on the legal basis of legitimate interest pursuant Article 6(1)(f) of the GDPR, being our interest in fulfilling the provisions of the Purchase Agreement concluded between us and the Purchaser. In this case, the exception from the information obligation pursuant to Article 14 of the GDPR against the data subject to whom the shipment will be delivered shall also be applied, and this will be fulfilled only at the moment of delivery of the shipment (the Goods). 

  1. instructions about the rights of the data subject
    1. We are committed to preserve the integrity and confidentiality of your personal data; therefore, we strive for the strong protection of personal data not only through individual modern technical and organisational precautions, but also through the possibility to exercise the rights of the Data Subject at any time through a written signed application implying the identity and the right that the Controller is requested to exercise by the Data Subject. You may send the applications to exercise the right to the Controller to our e-mail address: libertasfilm@protonmail.com.
    2. Please note that in cases where the legal basis for the processing of personal data is your consent, you may withdraw your consent at any time. You may withdraw your consent to the processing of personal data at any time by contacting the Controller by sending a written request to the e-mail address libertasfilm@protonmail.com.; withdrawal of your consent shall not affect the lawfulness of processing of your personal data before its withdrawal.
    3. In cases where the legal basis for the processing of your personal data is the protection of the rights and legally protected interests of the Controller (Article 6(1)(f) of the GDPR), we may process your related personal data even without your consent, and you shall tolerate such processing. Notwithstanding the above, if we process your personal data on the legal basis of legitimate interest, you have the right to object to the processing of your personal data. In such a case, we will consider whether there are, in a particular case, the necessary legitimate reasons for processing which override your interests, rights and freedoms (for example, reasons to prove, exercise or defend legal claims). In the case of direct marketing pursuant to clause 2.7 of this Document, the processing of your personal data for this purpose after you have exercised your right will be terminated. 
    4. At the same time, you have the right of access to personal data (Article 15 of the GDPR), right to rectification (Article 16 of the GDPR), right to erasure (Article 17), right to restriction of processing (Article 18 of the GDPR), right to data portability (Article 20 of the GDPR), right to object to processing (Article 21 of the GDPR), right to request a review of an individual decision based on the automated processing of personal data (Article 22 of the GDPR).
    5. Please note that we may request that you credibly demonstrate your identity when dealing with your application to exercise the right of the data subject, especially if you apply to exercise your right in a manner other than a signed written letter, e-mail with credible qualified electronic signature or in person at the registered office of our company (e.g. in the case of common e-mail requests or telephone calls).
    6. Each delivered application to exercise the right of the data subject will be assessed individually and competently; we will always inform you about the result within 30 (in words: thirty) days of the receipt of the application. 
  1. Controller’s policy and guarantees
    1. We do not publish or transfer personal data without your consent to any third country that would not provide for the appropriate level of protection of personal data. We guarantee that your personal data be processed solely in the territory of EU member states; more specifically, at the time when this version of the Document is in effect, all personal data of the Data Subjects are processed and physically stored solely in the territory of the Slovak Republic.
    2. Personal data may be published only based on your individually expressed consent or your conscious conduct (e.g., posting content in the form of reviews of our Goods and Services on our Website or official profile created on social networks). In this context, we inform you that by posting posts, photos or performing any activity resulting in you being identified on our official profile on the social network, your personal data is processed in the information systems of that social network and on our profile. By acting in accordance with the previous sentence, you provide a “tacit” consent to the processing of your personal data for our marketing activities.
    3. We regularly review and revise not only the security measures taken to ensure a high security of personal data processing, but also other procedures and rules designed to protect privacy and personal data, and we can work together with an expert appointed as Data Protection Officer (DPO).
    4. During the data transfer through a publicly accessible computer network between your end device and our server, we use appropriate means of encrypted protection of information. Similarly, we store all data and personal data on the specified data storages that are protected by appropriate means of encrypted protection of information.
    5. We guarantee that we will not make any consents to the processing of personal data conditional on the conclusion or performance of an agreement.
    6. We process and use your personal data solely for the purpose defined in this Document. If the purpose of processing your personal data ceases to exist (in whole or in part), we examine whether there is another purpose for processing specific personal data at that time and if not, the processing and storage of personal data will be terminated, and this in relation to personal data in full, or in relation to individual personal data for which the purpose of processing has ceases to exist.
    7. All entities other than us that legally participate in the process of processing of personal data are transparently identified in this Document together with their status under the GDPR. We will not perform any processing operation on your personal data in respect of a third party and/or a recipient if the third party and/or the recipient is not transparently identified in this Document and at the same time we lack the legal basis to do so pursuant to Article 6 of the GDPR.

The recipients of personal data are the following persons:

  • provider of accounting services, legal advice and legal representation services, 
  • Trust Pay, a. s., with its registered office at Za kasárňou 315/1, 831 03 Bratislava, Identification No.: 36 865 800, registered in the Commercial Register of District Court Bratislava I, section: Sa, insert No.: 4919/B – Payment gateway,
  • CryptoDiggers s. r. o., with its registered office at Gallayova 15, 841 02 Bratislava, Identification No.: 47 879 726, registered in the Commercial Register of District Court Bratislava I, section: Sro, insert No.: 100330/B – Payment gateway for digital currencies/cryptocurrencies
    1. All recipients of personal data access these personal data exclusively based on an authorisation granted by us; they are legally bound by specific obligations and legal guarantees enhancing the personal data protection of the Data Subjects. 
    2. We guarantee that we will not disclose any information and personal data about the content of internal communication conducted through our Website or through other means to any unauthorised natural or legal persons, except for the authorised government authorities of the Slovak Republic in the exercise of their powers in accordance with the relevant special laws in effect in Slovak laws.
    3. We do not disclose your personal data to any parties for commercial purposes without you granting your individual and free consent in advance. We also consider it necessary to inform you that part of the processing of personal data related to the use of the features integrated into the Website may be performed separately and completely independent of us by third parties acting as independent controllers different from our personal data information systems; in those cases, these are mainly operators of “payment gateways” for making cashless payments via the Internet. You disclose your personal data to these third parties directly without us entering or influencing this process in any way. This part of the processing of personal data is governed by internal policies and precautions adopted by these third parties and we have no influence on that processing of personal data, including the possibility to exercise the rights of the Data Subject about which we inform you in this Document.
    4. We carefully screened our business partners (the so-called processors) who we allowed to process your personal data in light of their practical ability to ensure the safety and lawfulness of the processing of your personal data.
    5. However, as part of disclosing your personal data to third parties, we follow the rule to disclose personal data only to the extent necessary to achieve the required purpose (for example, in the case of delivery, the necessary extent includes the name, surname, delivery address, or telephone number if the Goods are delivered by courier).
    6. When processing personal data and communicating with the Data Subjects, we use, in addition to regular telephone and email communication, the communication options provided through our Website.
    7. We process the personal data of minors only if they have been provided to us by their legal representative for the purposes of performing the Agreement, for the purpose of fulfilling our legal obligations, protecting rights and legally protected interests or for the purpose of processing them for purposes to which consent is required provided that the legal representative has granted this consent to the processing of the personal data of the children. 
    8. If within our communication and in addressing specific requests, in addition to the information we request, you include on your own initiative information that we do not need and at the same time that could be sensitive or could result in a sensitive nature revealing data from a specific category of personal data that we do not require or are not necessary to provide proper contractual performance, we will (if possible) ensure their immediate erasure or modification to a more neutral meaning, which does not allow the creation of a special category of personal data from such additionally obtained additional information. At the same time, we would like to ask you not to state any unnecessary data and information of a private nature about yourself in our mutual communication when ordering the Goods or Services, which are not directly related to our contractual performance and conclusion of the Agreement.
  1. final provisions
    1. If you do not agree or do not sufficiently understand the content or meaning of any part of this Document, we will welcome your factual reservations and comments that we will discuss with you with a view to protect and support your rights and prevent the occurrence and increase of any risks for your rights and freedoms that could be caused or influenced by the conclusion of the agreement to purchase the Goods and/or other processing of personal data in this Document.
    2. We regularly revise and update this Document; the current version of the Document published on the Website is always valid.
    3. You may address your complaint related to the processing of personal data to the supervision authority, which is the Office for Personal Data Protection of the Slovak Republic. Contact details of the supervision authority:

Office for Personal Data Protection of the Slovak Republic (Úrad na ochranu osobných údajov Slovenskej republiky) 

Hraničná 12

820 07 Bratislava

Slovak Republic

+421 /2/ 3231 3214 

statny.dozor@pdp.gov.sk

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