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Privacy Policy 21.03.2017

Effective Date: 21 March 2017. This Privacy Policy completely replaces the previous version.

INITIAL PROVISIONS

Exponea s.r.o., Business ID No. 50017560, with its registered office at Twin City B, Mlynské Nivy 12, 821 09 Bratislava — Staré Mesto, Slovakia, registered in the Commercial Register maintained by the County Court in Bratislava I, Section Sro, Insert 107011/B (“Exponea” or “we”) as the controller is committed to protecting the personal data of its customers (and the personal data of their clients) in accordance with applicable data protection legislation. This Privacy Policy describes how Exponea collects, processes and protects the personal data of its customers during visits to our websites at the domain exponea.com (“our websites”) and/or when using our Services.
The provisions of this Exponea Privacy Policy shall apply from the Effective Date stated above.
Capitalised words not defined in this Privacy Policy shall have the meaning ascribed to such words in the General Terms and Conditions.

DATA COLLECTION

When you register or sign up for an Account, submit an Order Form, or contact us via the “Have us contact you” form or otherwise via our website, Exponea requires you to provide information that includes your name, surname, company name, identification number, username, password and contact information such as e-mail addresses or phone numbers. If you decide to purchase the Services, Exponea requires you to provide details of a payment instrument such as a credit/debit card number, address and additional information needed for the issuing of invoices. While using our Services, we further collect track your activity via cookies or web beacons or other similar means (e.g. heatmaps or screen recordings), which may include your IP address, browser settings, preferences or other activities on our websites (see further clause 5).
If you contact us as an applicant for a job (or as a candidate for other type of cooperation with Exponea), Exponea requires you to provide information that includes your name, surname, and contact information such as e-mail addresses or phone numbers. Moreover, we require you to submit your curriculum vitae with additional information about your education, previous work experience and other information that may be required for the purpose of evaluating your abilities for the position applied for.

PURPOSE OF DATA PROCESSING

We process your personal data for the purpose of (i) registering and granting you access to your Account and our Services; (ii) providing the Services requested by you; (ii) optimising and enhancing our Services provided to you; (iii) paying for Services (if applicable); (iv) protecting the legitimate interests of our assets or interests of our other customers; (v) evaluating job applications; (vi) analysing visits to our websites; and (vii) direct marketing (if you have presented your interest in further information via the “Have us contact you” or similar form – see further clause 6).
The personal data you provide us with is only processed and used in the manner adequate for the purpose for which it was collected. Exponea does not combine personal data that was obtained for a variety of purposes. We will not store your personal data for longer than is necessary for the purpose for which it was provided or collected. We will only retain the personal data that serves a legitimate purpose (e.g. applicable legal regulations may require the retention of data, or some data may be necessary for the purposes of billing outstanding amounts).
We will neither collect an excessive amount of personal data nor data that is not relevant for the purposes for which the personal data is being collected.

YOUR CLIENTS’ DATA

By using our Services, you may be providing us with your clients’ personal data. You should therefore ensure that you have collected your clients’ respective consents and approval in order to process their data in accordance with applicable data protection law and the General Terms and Conditions. We shall be entitled to: obtain, collect, distribute, record, organise, adapt or alter, retrieve, consult, align, combine, transfer, use, store, block, destroy, and manage the cross-border flow of the personal data you provide us with.

COOKIES AND WEB BEACONS

For the purpose of analysing your visits to our website, we also collect cookies (files stored locally on your device). By enabling cookies in your browser, you have expressed your consent to our collection of cookies for this purpose. We use the following types of cookies: (i) essential cookies, which are essential for the provision of access to our websites; (ii) functionality cookies, which are crucial for the proper functioning of our websites (if these cookies are disabled, our website may not work properly); (iii) performance cookies, which do not identify you individually (until you enter your identification details in any of our forms) but help us to personalise your content in accordance with your actions on our websites; and (iv) targeting/advertising cookies, which help make advertisements more relevant to visitors of our website.
We also use Google Analytics and similar services that collect third-party cookies. The information about your use of the websites (including your IP address) generated by the cookies will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not have full functionality of this website. By using our websites, you consent to the processing of your data by Google in the manner and for the purposes set out above. Please see further Google policies at: http://www.google.com/intl/en/policies/technologies/ads/.
The collection of cookies may be stopped by resetting your browser; however, if you turn off cookies, the functionality of our platform may be limited (i.e. in the case of essential cookies you may not be able to access our websites). Our Services and/or websites and the communications generated from using and/or registering for our Services and/or platform, such as promotional emails, may contain electronic images known as “web beacons”. Web beacons generally work in conjunction with cookies, and we may use them in the same way we use cookies (see above).

DIRECT MARKETING

You agree that we may also use your electronic contact details, which may be derived from your past usage of Services, for marketing purposes, i.e. to keep you informed about our Services. These communications shall strictly adhere to applicable legal regulations. You may opt out of marketing communications by disabling this function via the unsubscribe link provided in each email you receive.

PERSONAL DATA SHARING

In line with the provisions of the General Terms and Conditions, we may also provide certain Services aimed at connecting our customers to services, such as e-mail or SMS, of other providers such as the providers of messaging platforms. By clicking the “I agree” button that completes the registration process and creates the Account for you or by submitting the respective Order Form to Exponea, you provide us with the express consent to share your personal data with these third-party providers for the purpose of fulfilling the Agreement (typically, you as our client provide us with all data required for such connection). We may also provide the data to third parties such as (i) hosting providers; and/or (ii) advertising partners. Any such partners will be available on our websites (typically in our Guides), and such parties will then act as processors of your data. Subject to the previous sentence, your personal data shall not be shared or provided to any other third party without your consent except for the following cases: (i) where Exponea is obliged to provide personal data by law or an order of public authority; or (ii) if personal data sharing is specifically allowed by applicable legal regulations.
If third-party providers are established outside of the EU/EEA, you agree that we may transfer your data to these third parties. In such cases, Exponea shall ensure that it cooperates only with third-party providers that are located in countries that ensure adequate levels of protection based on the European Commission’s adequacy decision, or that Exponea has entered into agreements with corresponding Model Contractual Clauses that ensure adequate safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals.
We are committed to storing your data securely. Therefore, we have implemented adequate physical, technical and organisational measures and plans for protecting and securing data collected from you (which do not, however, deprive you of your duty to take proper steps to secure your data, particularly for the transmission of data to our Account). The aim is to eliminate unauthorised or unlawful processing of your personal data or the accidental, unauthorised or unlawful accessing, use, transferring, processing, copying, transmitting, alteration, loss or damage of your data. Despite all efforts to meet the rules set out in applicable legal regulations, it is not possible to ensure the security of your data if it is transferred or transmitted in an unsecured way. We will protect your data in the following ways:
using cryptography, where necessary;
using password or secured token protection, where necessary; and
restricting access to your data (i.e. access to your personal data is granted only to those of our employees or contractors for whom the access is necessary).

RIGHT TO ACCESS AND COMPLAINT

You have the right to be provided with details of the personal information processed by us and to request the rectification or deletion of inaccurate personal data or the restriction of the processing of data concerning you. You may edit your data using your Account, or contact us at privacy@exponea.com should you have any request about data held. However, where requests from you are manifestly unfounded, excessive or repetitive, we may either: (i) charge a reasonable fee, taking into account the administrative costs of taking the actions requested; or (ii) refuse to act on the request.
If you feel that your data has been processed unlawfully, contact us at privacy@exponea.com and we will undertake to resolve the problem. You have the right to lodge a complaint with the supervisory authority, the Office for Personal Data Protection of the Slovak Republic.

CHANGES OF PRIVACY POLICY

We may, from time to time, change and/or update the terms of this Privacy Policy and you shall be notified hereof via your Account or on our website prior to the change taking effect.

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