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PRIVACY AND COOKIES POLICY

 

1. GENERAL INFORMATION AND TERMS OF PROCESSING OF PERSONAL DATA

1.1 This privacy policy (the “Privacy Policy”) shall govern the processing of information and data regarding your person (the “Personal Data”) by Spalneo in relation to, and in connection with, the provision of Our Services and access to the Spalneo Platform.

1.2 Unless expressly provided herein otherwise, the capitalised terms shall have the meaning ascribed to them in the General Terms and Condition.

1.3 If “Spalneo”, “we”, “our”, “us” or other similar term is used in this Privacy Policy, this term shall refer to the company responsible for the processing of Personal Data under this Privacy Policy (i.e. the controller pursuant to Article 4(7) of the GDPR), provided that:

• if you are using the services of the Slovak or English version of our Spalneo Platform, it shall be Spalneo, s.r.o., with its registered office at Strakova 3, 811 01 Bratislava, Identification No.: 50 164 465, registered in the Commercial Register of the District Court Bratislava I, section: Sro, insert No.: 109476/B;

• if you are using the services of the Hungarian version of our Spalneo Platform, it shall be Spalneo, Kft., with its registered office at Váci út 191. A/Floor 3., H-1138 Budapest, Identification No.: 01 09 293170.

 

2. LIST OF PROCESSED PERSONAL DATA
We process the following four basic categories of Personal Data:

2.1 Data provided to us by you

1. Data that is necessary for the use of our Spalneo Platform and our Services

The legal basis for processing the following Personal Data is that these are indispensable for the provision of Our Services and our Spalneo Platform, for the proper fulfilment of our obligations towards you, and our statutory legal obligations. Without this Personal Data, we cannot provide you with Our Services or full access to our Spalneo Platform. This includes in particular the following data:

1. Registration and reservation data: Data provided by you to us in the Registration Form (including your name, surname, e-mail address) or the Reservation Form (including your name, surname, e-mail address, telephone number, permanent residence address or billing address, your profile picture);

2. Data necessary to process a Reservation / an order of a Gift Card: Data regarding a Reservation, purchase of a Gift Card and/or any purchases you make in connection with our Spalneo Platform as well as any change or cancellation made in connection with a Reservation (including your name, address, phone number, e-mail address and credit card details, bank account details);

3. Data provided to file a complaint regarding Our Services: Data you provide us in order to process your complaint (including your name, address, telephone number, e-mail address, the purchased Service and/or Accommodation details);

4. Payment data: Data you provide us or our Operator of the Payment Platform with when making payments (including bank account, credit card details); and

5. Data obtained from our communication: Data contained in, or resulting from, our mutual communication that you send to us through our Spalneo Platform (including the content of that communication and communication-related metadata).
   
   b. Data provided to us by you at your sole discretion
   
   By virtue of your consent on the processing of your Personal Data and pursuant to this Privacy Policy, we will process the following Personal Data:
   
   i. Data of marketing nature: Data you provide to us in order to subscribe to our e-mail newsletters and/or notifications;

2. Data provided to us when posting a Rating: Data published by you on our Spalneo Platform or otherwise entered by you;

3. Other data: Any other data you decide to provide us with.

 

2.2 Data we automatically collect when you visit the Spalneo Platform or Our Services
By virtue of your consent on the processing of your Personal Data and pursuant to this Privacy Policy, we will process the following Personal Data:

1. Data about your devices: Data regarding your Mobile Device or computer, visits to or use of our Spalneo Platform and/or Our Services (including your IP address, geographical location, type and version of your browser/operating system, source references, the length of visit of the visited websites and Website navigation paths or any similar data that the Company may collect directly or indirectly from third party providers, the length of use of the Application, records of navigation on our Spalneo Platform and other similar data);

2. Data about your use of Our Services and the Spalneo Platform: The data generated while you use our Spalneo Platform (or generated during the use of this Spalneo Platform, including the timetable, frequency and pattern of use of the Spalneo Platform), Our Services or the Partners Services;

 

2.3 Data we collect from third parties

Under the agreement entered into between us (as processor or secondary controller) and the controller to whom you have provided your Personal Data, we will process the following Personal Data:

1. Data collected from Providers:
   Name, Surname, e-mail and/or phone number.

2. Data collected from other Providers:
   Name, Surname, e-mail and/or phone number, profile image, profile ID.

 

2.4 Data collected to secure our legitimate interests

We collect the following Personal Data to protect our legitimate interests, such as crime prevention, network and data security, direct marketing, and transfer of Personal Data between us and the other companies listed in clause 1.3 above:

1. Data necessary to enforce your obligations owed to us: Data we will need in order to judicially resolve any disputes relating to the enforcement of your obligations owed to us under the General Terms and Conditions (including your name and surname, permanent residence address, and date of birth);

2. Data necessary to resolve disputes between us: Data necessary to resolve any litigation, regardless of whether we are the claimant or the defendant in such disputes (including your name and surname, permanent residence address, and date of birth); and

3. Data necessary to resolve disputes by an arbitration tribunal: Data collected in order to resolve a dispute relating to your complaint by an alternative dispute resolution entity (including your name, surname, permanent residence address, and date of birth).

 

3. PURPOSE OF PROCESSING OF PERSONAL DATA

3.1 We will be processing your Personal Data for the purpose of:

1. registration and signing into the Spalneo Platform;

2. reservation of the Partner’s Services under the terms stipulated in the General Terms and Conditions; in that case, the Personal Data will be provided to the Service Providers pursuant to clause 6.1;

3. dealing with your Reservation, sending the payment data;

4. dealing with any of your complaints;

5. communication about your individual requirements or any communication with us through the Spalneo Platform;

6. sending information e-mails about updates, security alerts, and notifications;

7. enabling the use of the Payment Platform services;

8. communication with Partners through the Spalneo Platform;

1. your identification when entering a Rating on our Spalneo Platform;

10. customising and personalising the Spalneo Platform and Our Services to your requirements (for example by customising search results); for this purpose, we are using profiling (we analyse your previous searches, Reservations, etc.);

11. providing information of marketing nature, in particular sending you promotional e-mails, marketing, advertising and other information, personalisations;

• dealing with individual requests, Reservation change requests, and cancellations;

13. providing Our Services at the highest possible quality;

• resolving any disputes that might arise between us and you; and

• fulfilling our statutory obligations.

 

3.2 We process your Personal Data pursuant to clause 2 above, on the following legal bases:

	Legal base	Purpose (as indicated in clause 3.1)	Categories of Personal Data (as indicated in clause 2)
1.	entering into a contract (in the wording of the General Terms and Conditions) or fulfilling our contractual obligations	(a), (b), (c), (d), (e), (g), (j), (l), (m), (n)	2.1. (a) (i), (ii), (iii), (iv); 2.4. (ii), (iii)
2.	on the basis of your consent	(k)	2.1. (b) (i), (ii), (iii); 2.2. (i), (ii)
3.	for the purposes of our legitimate interests	(d), (e), (f), (h), (n)	2.1. (a) (iii), (v); 2.4. (i), (ii), (iii)
4.	on the basis of a statutory obligation	(c), (o)	2.1. (a) (iv)

 

4. TERM OF VALIDITY OF CONSENT

4.1 The authorisation to process and retain Personal Data shall exist from the day on which the consent was granted under these terms and conditions until its withdrawal or for as long as they are necessary for the achievement of the objective for which the Personal Data is being processed. Our authorisation to process and retain your Personal Data may also be extended by any necessary time after your consent has been withdraw, provided that the processing or retention of the Personal Data is necessary to comply with our statutory obligations and/or for the purpose of protection of our statutory rights.

 

5. WITHDRAWAL OF CONSENT

You can withdraw your consent at any time at your own discretion.

 

6. DISCLOSING YOUR PERSONAL DATA

6.1 In order to provide our Services (and if necessary given the circumstances), we may disclose your Personal Data (and your consent to such a disclosure) in accordance with the minimisation principle only to a restricted group of persons, namely to our employees, sub-contractors, advisors, sales representatives, related entities of the Company and the Service Providers to the extent to which it is reasonable and necessary to achieve the purpose stipulated in this Privacy Policy.

6.2 Furthermore, we may disclose your Personal Data:

1. in cases in which applicable law requires so;

2. in cases in which we are authorised to do so by applicable law; and

3. in cases where it is necessary to protect our rights and legitimate interests (including prevention of fraud and fraudulent behaviour, verification and credit risks prevention).

6.3 While operating our Spalneo Platform, we may provide access to our Spalneo Platform certain third parties (and the infrastructure they operate) for the purpose of publishing advertisements and marketing information. These third parties use technology that sends offers or links to offers – that will then appear as part of the website being browsed – directly to your browser. These technologies may also perform identifications of your IP address or use other technologies that collect data about the use of your Mobile Device or computer (e.g. cookies, JavaScript or web beacons); however, we will not provide these third parties with data enabling them to personalise data thus acquired. The purpose of these terms and conditions is not to regulate your relationship with any third party using the above-mentioned technologies.

6.4 Your Personal Data may be transmitted between the member countries of the European Economic Area for the purpose of processing specified in this policy.

6.5 When a Rating has been entered in the Spalneo Platform, it shall be published under your name and profile image. By entering a Review, you agree to its publishing on the Spalneo Platform as specified in the GTCs.

 

7. YOUR RIGHTS

1. access your Personal Data, in particular:

• request information about the purpose of their processing;

• the category of Personal Data being processed;

• the identity of the recipient to whom the Personal Data are to be provided; and

• the period for which the Personal Data shall be stored.

  2. have your Personal Data rectified without undue delay;

  3. have your Personal Data erased without undue delay if you request us to do so;

  4. have the processing of your Personal Data restricted;

  5. the right to receive Personal Data relating to you that you have provided us with, in a commonly used machine-readable format;

  6. object to the processing of your Personal Data for the purposes of direct marketing, profiling and in other cases stipulated by law, except when that processing is necessary for the performance of a task on the grounds of public interest, for scientific and statistical purposes or for historical research;

  7. withdraw your consent to the processing of your Personal Data at any time; and

  8. submit a motion to initiate the proceedings on the protection of Personal Data to the relevant supervisory authority.

 

8. PROTECTION OF PRIVACY OF CHILDREN AND JUVENILES

8.1 The protection of your childrens privacy is of great importance to us. We do not knowingly collect any Personal Data of persons who have not reached the age of 16 years. Please do not send us any Personal Data of such persons, including their name, surname, phone number, permanent residence address, etc.. If we find out that any piece of Personal Data that we process regards a person who has not reached the age of 16 years, we will promptly delete such Personal Data or otherwise destroy it so that it cannot be matched with a specific person.

 

9. PROCESSING OF FINANCIAL TRANSACTIONS

9.1 All financial operations and transactions carried out electronically on our Spalneo Platform will be processed via the Payment Platform. Processing of your Personal Data in such transactions will be carried out by the Operator of the Payment Platform, under the terms and conditions set out by the Operator of the Payment Platform that are made available on https://stripe.com/privacy.

 

10. THIRD PARTY WEBSITES

10.1 There are hypertext links and details of third party websites made available on our Spalneo Platform.

10.2 We have no control and we do not assume any liability for the terms of processing by, and procedures of processing of, third parties in the area of Personal Data protection.

 

11. FINAL PROVISIONS

11.1 If you wish to contact us with regard to the processing of your Personal Data, including if you wish to exercise any of your rights set forth in clause 8 of this Privacy Policy, our contact details are given below:
ADDRESS: Strakova 3, 81101 Bratislava, Slovakia, e-mail: info@spalneo.com

11.2 If you don’t agree with our decision, you have the right to an effective judicial remedy or to lodge a complaint to the competent supervisory authority in your European Union Member State or to the Office for Personal Data Protection of the Slovak Republic (contact available at https://dataprotection.gov.sk/uoou/).

11.3 We reserve the right to amend this policy in the manner set out in the GTCs.

 

COOKIES POLICY

Our Spalneo Platform uses Cookies:

1. A Cookie is a file containing an identifier (a string of characters and numerals) that is sent by the web server to the web browser and is stored by the browser. The identifier is then sent back to the server whenever the browser requests a page view from the server (the Cookie).

2. We use Cookies to be able to adapt to your needs, to distinguish you from other users, to prevent displaying unnecessary advertisements in your internet browser, and to prevent you from having to repeatedly sign in to our Spalneo Platform.

3. Cookies can be either “permanent” Cookies or “session” Cookies. A permanent Cookie will be stored in a web browser and will remain valid until the specified expiration date or until the user deletes it before its expiration date; on the other hand, a session Cookie will expire at the end of the users connection, that is, when the web browser is closed.

4. Cookies typically do not contain any data that would personally identify the user, but your data processed by us may be linked to data stored in or obtained from Cookies.

5. On our Spalneo Platform and/or in relation to Our Services, in addition to session Cookies and permanent Cookies, we also use other categories of Cookies listed below. The Cookies we use fall into the following categories:

 

Processes The process Cookies allow our Spalneo Platform to provide Our Services in line with your expectations. This includes, for example, the navigation on the website or access to secure website areas. Without these Cookies, we will not be able to provide you with the full services of our platform.
Name	Provider	Purpose	Validity	Type
PHPSESSID	Spalneo	Identifies user data stored in a php -session.	120 minutes	Functionality

 

Presets These files allow your internet browser to remember the information that affects the appearance or behaviour of the website. This includes information about the preferred language, the currency used or the territory in which you are located.
Name	Provider	Purpose	Validity	Type
PHPSESSID	Spalneo	Identifies user data stored in a php -session.	120 minutes	Functionality

 

Security We use security Cookies to verify your identity when signing in, to prevent fraudulent use of login information, and to protect your user data from unauthorised access.
Name	Provider	Purpose	Validity	Type
PHPSESSID	Spalneo	Identifies user data stored in a php -session.	120 minutes	Functionality

 

6. If you do not wish for us to use Cookies that are not necessary for the proper functioning of our platform (advertising Cookies, analytic Cookies, presets Cookies), select only processes Cookies when granting your consent to using Cookies.

7. However, you may block all Cookies in your web browser at any time, but this may restrict your access to certain parts of our Spalneo Platform.

Effective from August 22, 2018