Information on the processing of personal data addressed to data subjects

Company SOFTIP, a.s. with its registered office at Krasovského 14, 851 01 Bratislava - Petržalka district, Slovak Republic, ID No. 36785512, registered in the Commercial Register kept by the Municipal Court of Bratislava III, Section Sa, Insert No. 4151/B (hereinafter referred to as "Company") as the controller, in accordance with its information obligation under Articles 13 and 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as the "General Data Protection Regulation") (hereinafter referred to as the "GDPR")EU Regulation"18/2018 Coll. on the Protection of Personal Data and on Amendments and Additions to Certain Acts (hereinafter referred to as "Act") provides the data subjects with the information below on the processing of personal data of the data subjects by the controller. Data subject means an identified or identifiable natural person whose personal data are the subject of processing.

The person concerned confirmsthat he/she has familiarised himself/herself with the information on the processing of personal data by the controller contained in this document, published on the website of SOFTIP, a.s. (www.softip.sk, www.keepi.sk, www.keepi.eu), and that the controller has therefore duly fulfilled its information obligation towards it, in one of the following ways:

  • by concluding the relevant contract,
  • by clicking on the activation link provided in the registration email,
  • by ticking the box next to the link to this document in the web form,
  • or other written confirmation.

SOFTIP, a.s. through policies The Integrated Management System has adopted, inter alia Commitment maintain a high level of information security, including the protection of personal data. The Company has in place and maintains information security management system in accordance with the requirements of ISO/IEC 27001:2013 as part of the Integrated Management System. The basic document regulating the company's information security management is the "ZVN-CPSMIB-Security Policy of SOFTIP, a.s.". All categories of personal data of natural persons are part of the company's information assets and are classified in the inventory lists as "Protected". The company regularly carries out audit the state of information security through internal or external audits. The company has an information security management system Certificate ISO/IEC 27001:2013 issued by a certification body CERTICOM, s.r.o.

Identification and contact details of the operator

Business name:

SOFTIP, a. s.

Headquarters:

Krasovského 14, 851 01 Bratislava - Petržalka district, Slovak Republic

ID:

36 785 512

Entry in the Commercial Register:

Municipal Court Bratislava III, Section Sa, Insert No. 4151/B
E-mail address:

softip@softip.sk

Correspondence address:

SOFTIP, a. s.,

Vajanského námestie 7, 
974 01 Banská Bystrica, Slovak Republic

Telephone contact:
+421 48 4340 111
Contact email of the person responsible for supervision data protection supervisor:

dpo@softip.sk

Processing of your personal data by our company

As the controller, the Company processes the personal data you provide to us provided directly by you, e.g. by attending events organised by our company, by filling in and submitting a contact form with your comments, requests or questions, or by communicating directly with our company employees.

 

However, your personal data we can also get it in other ways, e.g. from your employer or from the company in connection with which we process your personal data. This is most often the case when we enter into or negotiate a contractual relationship and its terms and conditions with that company. Where the obtaining of personal data relates to a contractual relationship, this is most often a contractual requirement or a requirement that is necessary to enter into a contract. Failure to provide personal data (either yours or that of your colleagues) may have negative consequences for the organisation you represent, as the contractual relationship may not be concluded or implemented. In the case of, if you are a member of a statutory body an organisation that is a party to our contract or with whom we are negotiating a contractual relationship, we may obtain your personal data from publicly available sources and registers. In any event, we do not further systematically process any personal data obtained incidentally for any personal data processing purpose defined by us.

 

The company also processes personal data of its Staff, former employees, contract workers, temporary/internship students and jobseekers.

 

Some processing activities with your personal data may also be carried out by intermediaries authorised by us (our subcontractors). Before commissioning them, we carefully check that they meet the organisational and technical requirements for ensuring the security of the processing of your personal data under the EU Regulation.

 

The processing of personal data will be carried out for one or more purposes set out below, whereby processing for each individual purpose will always be carried out on the basis of the relevant legal basis processing and in accordance with the Personal Data Processing Principles.

Purposes and legal bases for processing personal data

  • We are a commercial company and process personal data in connection with the provision of products and services we consider legitimate interest companies under Article 6(1)(f) of the EU Regulation (processing of personal data for the purposes of the legitimate interests pursued by the controller) - this is the need to keep records of transactions and customer relationships.
  • In connection with our product focus, we process personal data on participants and speakers at conferences, trainings and professional seminars organised by us, where the legal basis here is the performance of a contract pursuant to Article 6(1)(b) of the EU Regulation (processing of personal data for the purpose of carrying out pre-contractual measures and/or performance of the contract).
  • If you are one of our customers, we send you offers of the Company's product portfolio and other marketing activities in order to provide you with the Company's products that best meet your financial, social and other needs. In this case, we process personal data for direct marketing purposes on the basis of legitimate interest pursuant to Article 6(1)(f) of the EU Regulation in connection with Section 116(3) of Act No. 452/2021 Coll. on Electronic Communications. We process the personal data collected in the sale of products or services for direct marketing purposes for a maximum period of 24 months from the end of the contractual relationship or the last transaction, in accordance with the applicable Electronic Communications Act. After this period, we will continue marketing communications only with your explicit consent.
  • If you are not yet our customer, marketing communication (sending newsletters) with you solely on the basis of your consent pursuant to Article 6(1)(a) of the EU Regulation (on the basis of the data subject's separate consent with the processing of her personal data for this purpose). It is possible to unsubscribe from the newsletter at any time by clicking "unsubscribe" in each marketing-oriented email.
  • Pursuant to Article 6(1)(b) of the EU Regulation, the company processes personal data that are necessary for the conclusion and performance of various contracts, such as licence agreements, work contracts, employment contracts, but also orders, etc.
  • We are obliged by accounting and tax regulations to process personal data contained in, for example, accounting documents, records or documents (e.g. invoices) - it is about fulfilling legal obligations pursuant to Article 6(1)(c) of the EU Regulation (processing of personal data for the purposes of compliance with a legal obligation of the controller).
  • If we have to prove, assert or defend our legal claims in or out of court or have to communicate certain facts to public authorities (e.g. a bailiff), we consider this to be our legitimate interest under Article 6(1)(f) of the EU Regulation in conjunction with Article 9(2)(f) of the GDPR. Such processing may also include communication or interaction with public authorities.
  • If you are a job applicant for our company, we are entitled to process your CV and cover letter for the purposes of the selection procedure and for storage in our internal database of job seekers for the purpose of finding a suitable employee on the basis of your written consent.
  • For the purposes of protecting our property, preventing damage and preventing crime and vandalism, we use CCTV cameras on the premises of our bike rack on the basis of a legitimate interest pursuant to Article 6(1)(f) of the EU Regulation (processing of personal data for the purposes of the legitimate interests pursued by the controller).

Provision of personal data

We disclose your personal data only to the extent necessary and always in accordance with the confidentiality of the recipient of the data in accordance with Section 79 of the Act. Depending on the purpose of the processing and the specific circumstances, we are among the typical recipients of your personal data:

 

  • providers of standard software, cloud or hosting services (e.g. Microsoft) or technical support for our company;
  • employees and bodies of our company;
  • institutions and public authorities to which data are provided on the basis of laws or special regulations;
  • audit companies, law firms, etc.;
  • our subcontractors.

 

If we are asked by a public authority to disclose your personal data, we examine the conditions set out in the legislation for disclosure and do not disclose your personal data without checking whether the conditions are met.

 

The provision of personal data is voluntary. Failure to provide it may result in the impossibility of the conclusion or performance of a contract by the Operator. More detailed information can be found here under: Voluntary provision of personal data and the consequences of not providing it.

Transfer of personal data to third countries

By default, we restrict any cross-border transfers of personal data to third countries or international organisations outside the European Union.

 

In the case of data processing using Microsoft services - e.g. Office365 or Azure - the location of the user is always defined, which also defines the space for the location of the data: in the case of SOFTIP, all data is stored on servers located in EU and EEA countries.

Retention period of personal data

We store personal data:

 

  • if the basis for their processing is the consent given by you, until the purpose of their processing ceases or until your previous consent is withdrawn (whichever is earlier);
  • for other legal bases, until the purpose of processing personal data ceases to exist, but at least until the time specified by specific laws (on archives and registers, on accounting, on income tax, on health insurance, on social insurance, on the Commercial Code, etc.);
  • the specific retention periods for each category of personal data are determined by the company's records management plan;
  • we will ensure the deletion of personal data after the expiry of the specified periods.

 

More detailed information is available here: Retention period of personal data and criteria for determining it

Rights of the data subject

The EU Regulation lays down general conditions for the exercise of your individual rights. However, their existence does not automatically imply that we will comply with them when you exercise your individual rights, as exceptions may apply in a particular case, or some rights are subject to specific conditions that may not be met in every case. We will always deal with your request concerning a specific right and examine it in the light of the legal provisions and applicable exceptions.

 

In particular, as a data subject, you have:

 

  • the right to apply for access to personal data under Article 15 of the EU Regulation, which we process about you. This right includes the right to confirm whether we are processing personal data about you, the right to obtain access to that data and the right to obtain a copy of the personal data we are processing about you, where technically feasible;
  • the right to rectification and completion personal data under Article 16 of the EU Regulation if we process incorrect or incomplete personal data about you;
  • the right to erasure your personal data pursuant to Article 17 of the EU Regulation;
  • the right to restriction of processing personal data pursuant to Article 18 of the EU Regulation;
  • the right to portability data pursuant to Article 20 of the EU Regulation where the processing of personal data is based on the legal basis of consent pursuant to the performance of a contract;
  • if we process personal data about you on the basis of your consent to the processing of your personal data, you have the right at any time withdraw your consent;
  • You have right at any time effectively object against the processing of personal data for direct marketing purposes (only for the purpose of sending marketing newsletters); you can exercise this right either by unsubscribing in the text of each marketing email or by sending an objection to our contact details below;
  • you also have right Anytime lodge a complaint the Office for Personal Data Protection of the Slovak Republic or bring an action before the competent court. In any event, we recommend that any disputes, questions or objections be resolved primarily by communicating with our company.

 

Detailed information on your rights as a data subject is provided here: Information on the rights of the data subject

All questions and comments on the protection of personal data or requests to exercise your rights under the EU Regulation can be sent to the contact points listed below:

Mailing and contact address:

SOFTIP, a. s.
Vajanského námestie 7, 
974 01 Banská Bystrica, Slovak Republic

Contact email address:

softip@softip.sk

Contact phone:
+421 48 4340 111
Contact email of the person responsible for supervision data protection supervisor:

dpo@softip.sk

Profiling

Company not performed automated profiling - i.e. processing operations which would lead to decisions having legal effect or other substantial influence on your person based solely on the fully automated processing of your personal data.

Cookies

Cookies are small text files that improve the use of a website by, for example, allowing recognition of previous visitors when logging into the user environment, remembering a visitor's choice when opening a new window, measuring website traffic or how the website is used for user enhancement. Our website uses cookies mainly for basic/general traffic measurement purposes. In addition, these technologies help us to better understand user behaviour. Although the information collected by cookies and other similar technologies is typically non-personal in nature, to the extent that Internet Protocol (IP) addresses and similar identifiers are considered personal information by law, we treat these identifiers as personal information. View details

Privacy Policy

The protection of personal data in our company is not a novelty related to the adoption of current legislative standards. Our company has long fulfilled its obligations and commitments regarding the protection of personal data. We have in place and use an information security management system certified in accordance with ISO/IEC 27001:2013, which includes appropriate technical, personnel and organisational measures to protect personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure, access, storage or transfer and against all other forms of unlawful processing, including inappropriate collection or further processing of personal data. These measures ensure an adequate level of protection of personal data in accordance with the principles of the EU Regulation.

 

Data protection is not a one-off issue for us. The information we are required to provide you with in relation to our processing of your personal data may change or cease to be up-to-date. For this reason, we reserve the right to modify and change these terms and conditions at any time to the extent necessary.

 

The controller is entitled to amend this document to fulfil its information obligation to the data subject regarding the processing of personal data. The Controller publishes this document on its website.

Retention period of personal data and criteria for determining it

We only process personal data for as long as is strictly necessary. The criteria and exact retention periods for each purpose are as follows:

 

Purpose of processing Shelf life/Criteria
Contract performance/ Pre-contractual relations For the duration of the contractual relationship and 10 years after its completion for the purpose of fulfilling archiving obligations and proving, asserting and defending legal claims.
Fulfilling a legal obligation For a period of time specified by the relevant legislation (e.g. 10 years for accounting and tax documents).
Direct marketing
(Soft Opt-in - Customers)		 For the duration of the contractual relationship and max. 24 months from the end of the relationship or the last transaction, unless consent has been withdrawn earlier.
Marketing
(by consent)		 For a period of 5 years from the date of consent or until the date of withdrawal of consent granted by the data subject, whichever is the earlier.
Jobseekers For a period of 3 years from the date of consent to storage.
Legitimate interest
(other purposes)		 For as long as the legitimate interest lasts and at most until the data subject exercises his or her right to object.

After the expiration of the aforementioned periods of processing and storage of the personal data of the data subjects, the controller shall ensure the erasure of the personal data without undue delay.

Information on the rights of the data subject

Right of access to personal data relating to the data subject

The data subject shall have the right to obtain confirmation from the Data Controller as to whether it processes personal data relating to him or her.

 

Where the Controller processes personal data concerning the data subject, the data subject shall have the right to obtain access to such personal data and other information to be provided to him or her in an intelligible form.

 

The controller shall provide the following information in response to the data subject's request:

 

  • a list of the purpose(s) of the processing of personal data;
  • a list of categories of personal data processed;
  • a list of recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations (if any);
  • the envisaged period of retention of the personal data, if it can be determined, otherwise the criteria for determining it;
  • information on the existence of the right of the data subject to request from the controller the rectification of personal data relating to the data subject or their erasure or restriction of processing, or information on the existence of the right of the data subject to object to such processing by the controller;
  • information about the right to file a complaint (a petition to initiate proceedings pursuant to Section 100 of the Act) with the supervisory authority, which is the Office for Personal Data Protection of the Slovak Republic;
  • details of the source from which the personal data were obtained, if the personal data were not obtained directly from the data subject;
  • where the Controller uses automated individual decision-making, information about the existence of such decision-making, including profiling as referred to in Article 22(1) and (4) of the EU Regulation, and in these cases at least meaningful information about the procedure used as well as the significance and envisaged consequences of such processing for the data subject;
  • where the personal data of the data subject are transferred to a third country or an international organisation, information on the appropriate safeguards adopted pursuant to Article 46 of the EU Regulation.

 

The controller shall provide the data subject, free of charge, with a copy of the personal data processed about the data subject by electronic means, unless the data subject requests otherwise. For any further copies requested by the data subject, the controller may charge a reasonable fee corresponding to the administrative costs.

Right to rectification of personal data relating to the data subject

The data subject shall have the right to require the Data Controller to rectify incorrect, incomplete or outdated personal data of the data subject without undue delay and to complete incomplete personal data with regard to the purposes of processing by the Data Controller on the basis of a supplementary declaration provided by the data subject to the Data Controller. A request pursuant to the preceding sentence may be made by the data subject electronically to the e-mail address of the Data Controller or by any other appropriate means.

Right to erasure of personal data relating to the data subject

In the cases provided for in the EU Regulation and the Act, the Data Controller is obliged to erase the personal data of the data subject upon his or her written request. The data subject's request for erasure of personal data must be evaluated separately by the Data Controller, as the Data Controller may be obliged by the EU Regulation and the Act to further process personal data, or further processing of personal data may be necessary for the purposes of the legitimate interests pursued by the Data Controller.

 

The controller shall erase the personal data of the data subject without delay if one of the following grounds is met:

 

  • the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
  • the data subject withdraws the consent on the basis of which the processing is carried out and there is no other legal basis for further processing;
  • the data subject objects, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her where the processing is necessary for the performance of a task carried out in the public interest or for the purposes of the legitimate interests of the Controller or of a third party, including an objection to profiling; in this case, the Controller may no longer process the personal data of the data subject unless he or she demonstrates compelling legitimate grounds for further processing which override the interests, rights and freedoms of the data subject or grounds for establishing, exercising or defending legal claims;
  • personal data have been unlawfully processed;
  • personal data must be erased in order to comply with a legal obligation imposed by European Union law or Slovak law,
  • the personal data was collected in connection with the offer of information society services pursuant to Article 8(1) of the EU Regulation.

 

Where the Controller has disclosed the personal data of the data subject and has received a request for erasure from the data subject, the Controller shall erase the disclosed personal data, taking into account the available technology and the cost of implementing the measures, and shall take appropriate measures, including technical measures, and shall inform other controllers processing the personal data of the data subject that the data subject has requested them to erase all references to, or copies or replicas of, those personal data.

 

The controller has the right to refuse the data subject's request for erasure of personal data if further processing of the personal data is necessary:

 

  • to exercise the right to freedom of expression and information;
  • to fulfil a legal obligation arising from European Union law or from the legal order of the Slovak Republic or to fulfil a task carried out in the public interest;
  • for reasons of public interest in the field of public health in accordance with Article 9(2)(h) and (i) as well as Article 9(3) of the EU Regulation;
  • for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes, where the right to erasure is likely to render impossible or seriously impede the achievement of the purposes of such processing, or
  • to prove, exercise or defend legal claims.

Right to restriction of processing of personal data

The data subject shall have the right to have the Controller restrict the processing of his or her personal data in respect of one of the following cases:

 

  • the data subject contests the accuracy of the personal data, during a period allowing the Controller to verify the accuracy of the personal data;
  • the processing is unlawful and the data subject objects to the erasure of the personal data and requests instead the restriction of their use;
  • The controller no longer needs the personal data for the purposes of the processing, but the data subject needs them to establish, exercise or defend legal claims;
  • the data subject has objected to processing necessary for the purposes of the legitimate interests of the Controller and/or third parties or to processing necessary for the performance of a task carried out in the public interest on grounds relating to his or her particular situation, to the processing of personal data concerning him or her, including objections to profiling, pending verification that the legitimate grounds on the part of the Controller outweigh the legitimate grounds of the data subject.

 

If the Data Controller has restricted the processing of personal data pursuant to any of the aforementioned points, such personal data shall, with the exception of storage, be processed only with the consent of the data subject or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or of a Member State. The controller shall inform the data subject within a reasonable time before lifting the restriction on processing.

 

The controller shall notify each recipient to whom personal data have been disclosed of any rectification or erasure of personal data or restriction of processing carried out pursuant to Articles 16, 17(1) and 18 of the EU Regulation, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject of these recipients if the data subject so requests.

Right to portability of personal data

The data subject shall have the right to obtain from the controller only the personal data relating to him or her which he or she has provided to the Controller in a structured, commonly used and machine-readable format and shall have the right to transfer such data to another controller without being prevented from doing so by the controller to whom the personal data have been provided, where the Controller carries out the processing of personal data on the basis of consent or a contract by automated means.

 

The data subject may request the transfer of personal data directly from one controller to another controller, provided that this is technically feasible and not prevented by other legal or significant obstacles.

 

The exercise of the right of portability is without prejudice to the right to erasure under Article 17 of the EU Regulation. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

 

The controller shall be entitled to refuse the data subject's request to transfer the data if such a transfer could have adverse effects on the rights and freedoms of others or if the legal conditions for the exercise of the right to transfer within the meaning of the EU Regulation are not met.

Right to object to the processing of personal data concerning the data subject

The data subject shall have the right to object at any time, on grounds relating to his or her particular situation, to processing of personal data concerning him or her which is carried out on a legal basis pursuant to Article 6(1)(e) or (f) of the EU Regulation, including to profiling on the basis of those provisions. The controller shall not further process the personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

 

Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for the purposes of such marketing, including profiling to the extent that it is related to such direct marketing. If the data subject objects to the processing of personal data for the purpose of direct marketing, the controller may no longer process the personal data for the purpose of direct marketing.

 

In relation to the use of information society services, the data subject may exercise his or her right to object by automated means using technical specifications.

 

Where personal data are processed for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) of the EU Regulation, the data subject shall have the right to object, on grounds relating to his or her particular situation, to processing of personal data concerning him or her, except where the processing is necessary for the performance of a task carried out for reasons of public interest.

Right to withdraw consent to the processing of personal data of the data subject at any time

If the Controller processes the personal data of the data subject on the basis of the consent given by the data subject, the data subject shall have the right to withdraw the consent at any time. In particular, the withdrawal of consent may be made in one of the following ways:

 

  • by sending the withdrawal of consent in electronic form to the e-mail address of the Operator;
  • by sending the withdrawal of consent in paper form to the Operator's correspondence address;
  • by withdrawing consent through the relevant functionality on the website of the Controller, if the performance or service provided to the data subject by the Controller allows the use of such functionality.

 

Withdrawal of consent does not affect the lawfulness of the processing of personal data based on consent granted before its withdrawal.

Right to lodge a complaint with the supervisory authority

If the data subject considers that the processing of personal data concerning him or her is in breach of the EU Regulation or the Act, he or she shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement; administrative and judicial remedies shall be without prejudice.

 

In the Slovak Republic, the supervisory authority is the Office for Personal Data Protection of the Slovak Republic, located at Hraničná 12, 820 07 Bratislava.

 

The data subject has the right to file a petition with the Office for Personal Data Protection of the Slovak Republic to initiate proceedings for the protection of personal data pursuant to Section 100 of the Act, in particular if the Controller does not comply with the request or objection. The purpose of the personal data protection procedure is to determine whether the rights of natural persons in the processing of their personal data have been violated or whether there has been a violation of the EU Regulation or the Act in the area of personal data protection, and, in the event of a finding of deficiencies, if it is reasonable and expedient, to impose remedial measures or, where appropriate, a fine for a violation of the EU Regulation or the Act.

Voluntary provision of personal data and consequences of non-provision

The provision of personal data for the purposes of pre-contractual measures at the request of the data subject and/or the performance of a contract is a requirement necessary for the conclusion of a contract between the Controller and the data subject or a third party on whose behalf or on whose behalf the data subject acts. The data subject is not obliged to provide personal data to the Controller; however, failure to provide personal data for this purpose may result in the impossibility of the conclusion or performance of a contract by the Controller. In the event of failure to provide the data subject's personal data for this purpose, the Controller may likewise refuse to conclude the contract.

 

The provision of personal data for the purpose of fulfilling the legal obligation of the Controller is a contractual requirement of the Controller. The data subject is not obliged to provide personal data to the Controller; however, failure to provide personal data for this purpose may result in the inability to fulfil the Controller's legal obligations, as a consequence of which the Controller may refuse to conclude a contract in the event of the data subject's failure to provide personal data for this purpose.

 

The provision of personal data for the purposes of the legitimate interests pursued by the Controller is a contractual requirement of the Controller. The data subject is not obliged to provide personal data to the Controller; however, the consequence of the failure to provide personal data for this purpose may be the impossibility of properly exercising or defending the Controller's rights and legal claims against the data subject in relation to the Controller's services provided to the data subject, which arose on the basis of or in connection with the Controller's contractual relationship with the data subject, as a result of which the Controller may refuse to enter into a contract in the event of the data subject's failure to provide personal data for this purpose.

 

The provision of personal data for the purpose of sending commercial notifications, advertising offers and information about promotions and news of the Operator is voluntary and the Data Subject is not obliged to provide personal data to the Operator for this purpose.

Further information

Any of the aforementioned rights to which the data subject is entitled, as well as other rights arising from the EU Regulation or the Act, may be exercised by the data subject at the contact addresses indicated above, by means of a written request or an e-mail request (electronic written form) sent to the correspondence or e-mail address of the Data Controller. From the written request of the data subject, the identity of the data subject must be unquestionably and clearly established by the Data Controller, in particular by indicating the first and last name, date of birth, permanent address and e-mail address, together with a clear indication of the right which the data subject claims against the Data Controller. If necessary, in view of the lack of identification and the credibility of the request, the Data Controller shall have the right to ask the data subject to prove his or her identity in order to prevent the leakage of personal data concerning the data subject, i.e. an incident.

 

The data subject shall, where possible, always provide his or her e-mail address in communication with the Controller so that the Controller may be notified by electronic means at his or her request, unless the data subject has requested notification in another manner and form.

 

The controller shall provide the data subject with information on the measures taken on the basis of the request without undue delay, but at the latest within one (1) month from the date of receipt of the request by the controller. The Controller shall be entitled to extend that period by a further two (2) months, if necessary, taking into account the complexity and scope of the request and the number of requests. The Controller shall inform the data subject of any such extension within one month of receipt of the request, together with the reasons for which the time limit for processing the request will be extended.

 

All information and statements concerning the rights exercised by the data subject shall be provided by the Controller free of charge. If the request is manifestly unfounded or excessive, in particular because it is repetitive, the Controller shall be entitled to charge a reasonable fee which takes into account the administrative costs involved in providing the information requested. Where requests from the data subject are manifestly unfounded or excessive, in particular because of their repetitive nature and their chicanery, the controller may, in such cases, charge a reasonable fee, taking into account the administrative costs of providing the information or of notifying or taking the action requested, or refuse to act on the request.

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