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Terms and Conditions Relating to Personal Data Processing
Suppliers, customers and business partners

The company SEQ-Control, s. r. o., Reg. No.: 54 242 860, with its registered office at Odbojárov 64/4, 831 04 Bratislava, City Court Bratislava III, Section: Sro, Insert No.: č. 157354/B (“Company“) as a personal data controller collects and processes personal data of data subjects pursuant to the 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 (hereinafter as “GDPR”) and with regard to Act No. 18/2018 Coll. on personal data protection and on amendments to certain acts (hereinafter as “APDP”).

The below table presents the purposes of processing of personal data (hereinafter also referred to as “PD”) and clearly identifies the category of data subjects, legal basis for personal data processing, categories of processed PD as well as the period for which the PD shall be stored and processed by the Company.

#	Purpose of personal data processing	Legal basis for personal data processing	Data subjects	Processing period	Recipients
1	PERSONAL AGENDA – HSE TRAININGS Note: The purpose of data processing is the provision of HSE trainings	Processing is necessary according to Art. 6 section 1 letter c) of the GDPR – processing is necessary to perform STATUTORY OBLIGATIONS of the controller (Act No. 124/2006 Coll., Act No. 355/2007 Coll.)	Employees, natural persons present in the workplace or premises of the employer with the employer´s consent	5 years following the year in which the training was performed	Subjects to whom the provision of personal data by controller applies based on legislation, external company ensuring HSE trainings, expert consultants and advisors bound by statutory and/or contractual confidentiality
2	BUSINESS COMMUNICATION AGENDA Note: The purpose is the processing in the interest of preserving contact details of business partners	Processing is necessary according to Art. 6 section 1 letter f) of the GDPR for the purpose of LEGITIMATE INTEREST of the controller	Suppliers, customers, their employees and other natural persons communicating on their behalf	5 years following the year in which the communication was concluded	Subjects to whom the provision of personal data by controller applies based on legislation, expert consultants and advisors bound by statutory and/or contractual confidentiality, companies providing IT support, accounting
3	BUSINESS PARTNERS – ACCOUNTING OF NATURAL AND LEGAL PERSONS Note: The accounting system of the processor also contains the database of suppliers for the purpose of invoicing	Processing is necessary according to Art. 6 section 1 letter c) of the GDPR – processing necessary to perform STATUTORY OBLIGATIONS of the controller in accordance with Act No. 431/2002 Coll., Act No. 222/2004 Coll., Act No.40/1964 Coll., Act No. 311/2001 Coll., Act No.595/2003 Coll., Act No. 582/2004 Coll., Act No. 283/2002 Coll. and related legislation	Employees and statutory body of business partners, cooperating entities	10 years following the year to which it pertains	Subjects to whom the provision of personal data by controller applies based on legislation, expert consultants and advisors bound by statutory and/or contractual confidentiality, companies providing administrative and accounting services
4	LITIGATION, EXECUTION AND CLAIMS AGENDA	Processing is necessary according to Art. 6 section 1 letter c) of the GDPR – necessary for the performance of STATUTORY OBLIGATIONS of the controller in accordance to Act. No. 160/2015 Coll., Act. No. 244/2002 Coll., Act. No. 301/2005 Coll., Act. No. 7/2005 Coll., Act. No.38/1993 Coll., Act. No. 162/2015 Coll., Act. No. 233/1995 Coll., and related legislation	Parties to the litigation, participants to the proceedings and other related persons	10 years following the final legally valid conclusion of the respective proceeding	Courts, executors, attorneys and other public authorities and subject to whom the provision of personal data by controller applies based on legislation, expert consultants and advisors bound by statutory and/or contractual confidentiality
5	DATA SUBJECT RIGHTS CLAIMS	Processing is necessary according to Art. 6 section 1 letter c) of the GDPR – necessary for the performance of STATUTORY OBLIGATIONS of the controller in accordance to the GDPR and the APDP and related legislation	Natural persons exercising data subject rights	5 years following the year in which the claim was handled	Subjects to whom the controller provides personal data based on legislation, expert consultants and advisors bound by statutory and/or contractual confidentiality
6	PROVISION OF PERSONAL DATA TO PUBLIC AUTHORITIES BASED ON THEIR REQUEST Note: Provision of personal data based on a request of public authority e.g. in case authority active in criminal proceeding requests camera recordings, however not for a purpose related to SEQ-Control	Processing is necessary according to Art. 6 section 1 letter c) of the GDPR – necessary for the performance of STATUTORY OBLIGATIONS of the controller in accordance to Act No. 171/1993 Coll., Act No. 160/2015 Coll., Act No. 370/1990 Coll. and related legislation	Natural person whose personal data is requested by public authorities	5 years following the year in which the request was processed	Subjects to whom the provision of personal data by controller applies based on legislation, company providing technical support, expert consultants and advisors bound by statutory and/or contractual confidentiality
7	PROTECTION OF COMPANY ASSETS – CAMERAS Note: The purpose is the monitoring of company premises in the interest of protecting company assets, life and health via CCTV	Processing is necessary according to Art. 6 section 1 letter f) of the GDPR – LEGITIMATE INTEREST of the controller	Natural person recorded on a camera recording	5 days following the execution of the recording (in case of minor offence, insurance or criminal proceeding – 10 years after the conclusion of the proceeding)	Subjects to whom the provision of personal data by controller applies based on legislation, company providing technical support, expert consultants and advisors bound by statutory and/or contractual confidentiality
8	PROTECTION OF COMPANY ASSETS – INSURANCE Note: The purpose is the processing of personal data during the entire process from entry into the insurance contract until the liquidation of insurance event (insurance of assets, persons…)	Processing is necessary according to Art. 6 section 1 letter f) of the GDPR – LEGITIMATE INTEREST of the controller	Employees, external cooperating parties, third parties (injured persons other than employees and external cooperating parties, witnesses, doctors, persons involved in the process of liquidation and other natural persons whose personal data is processed for the respective purposes)	10 years following the year in which the insurance event was closed	Subjects to whom the provision of personal data by controller applies based on legislation, company providing services based on act on financial intermediation, expert consultants and advisors bound by statutory and/or contractual confidentiality, financial intermediator
9	ELECTRONIC MAILBOX	Processing is necessary according to Art. 6 section 1 letter c) of the GDPR – necessary for the performance of STATUTORY OBLIGATIONS of the controller in accordance to Act No. 305/2013 Coll. and related legislation	Natural persons – senders and recipients of correspondence and persons whose personal data is present in the deliveries	10 years following the year to which it pertains	Subjects to whom the provision of personal data by controller applies based on legislation, expert consultants and advisors bound by statutory and/or contractual confidentiality, company providing administrative and accounting services
10	WORK RELATED INJURIES	Processing is necessary according to Art. 6 section 1 letter c) of the GDPR – necessary for the performance of STATUTORY OBLIGATIONS in accordance to Act No. 124/2006 Coll., Act No. 355/2007 Coll. and related legislation	Employees, natural persons present in the workplace or premises of the employer with the employer´s consent	permanent archiving, 5 years following the year to which is pertains	Subjects to whom the provision of personal data by controller applies based on legislation, company ensuring HSE agenda, expert consultants and advisors bound by statutory and/or contractual confidentiality
11	RECORDS ON SUPPLIER AND EMPLOYEE QUALIFICATION Note: Processing of personal data is necessary for the purpose of recording of expert qualification of supplier in case of control (verification whether the persons providing technical support dispose with qualifications – certificates and such, fire shutters, dampers, extinguishers, hydrants)	Processing is necessary according to Art. 6 section 1 letter f) of the GDPR – LEGITIMATE INTEREST of the controller	Employees of supplier and other natural persons providing services	Personal files of employees for a period of 70 years after the date of birth	Subjects to whom the provision of personal data by controller applies based on legislation, expert consultants and advisors bound by statutory and/or contractual confidentiality
12	REGISTRY OF RECEIVED AND SENT POST	Processing is necessary according to Art. 6 section 1 letter f) of the GDPR – LEGITIMATE INTEREST of the controller	Natural persons – senders and recipients of post and persons whose personal data is contained in the respective deliveries	10 years following the year to which it pertains	Subjects to whom the provision of personal data by controller applies based on legislation, expert consultants and advisors bound by statutory and/or contractual confidentiality, company providing administrative and accounting services

The Company shall not process personal data for the purposes of automated decision-making, including profiling.

If any of the purposes of processing has a contract as the legal basis for personal data processing, provision of such data represents a contractual requirement for performance under the respective contract. In case such data is not provided, neither can the contractual relationship be concluded, nor can the performance under the contract take place. If the legal basis for personal data processing is a law, provision of such data shall be a legal requirement. In case such data is not provided, the Company cannot duly perform its duties arising from the relevant general legislation.

The Company obtains personal data primarily from data subjects. The Company may also obtain personal data from public sources and registers, or from third parties, mainly regarding conclusion or performance of a contract. In case the Company is provided with personal data from a person different from the data subject, by providing such data the provider confirms that the data subject whose data is provided to the Company has given consent to process its personal data within the meaning hereof and pursuant to Section 78 (6) of APDP.

The data subject shall have mainly the following rights relating to its personal data processing:

1. Based on its application, request from the Company to issue a confirmation whether its personal data is being processed, under what conditions, including the scope, purpose and period of the processing thereof, as well as information on the source of obtaining the personal data in question;
2. Based in its application, request from the Company to correct incorrect or outdated personal data and/or complete the incomplete personal data;
3. Based in its application, request from the Company to erase/destruct personal data, if:
   1. the personal data is not required for the purpose they were obtained or otherwise processed,
   2. in case the personal data have been processed based on a consent and such consent has been withdrawn, while there is no other legal basis for personal data processing or other legal exception;
   3. if the data subject objects personal data processing based on a legitimate interest and no legitimate reasons for processing prevail, or the data subject opposes direct marketing;
   4. personal data is unlawfully processed;
   5. the personal data shall be erased for compliance with a legal obligation;
4. Based in its application, request from the Company to restrict personal data processing, if:
   1. the data subject objects the correctness of personal data during the period that shall enable the Company to verify the correctness of personal data;
   2. the personal data processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
   3. the Company does not need such personal data for the purpose of their processing, but the data subject needs such data to exercise their legal claim;
5. Based in its application request from the Company the personal data provided to the Company relating to the data subject, and if it is technically feasible and the processing is carried out by automated means, the data subject is also entitled to transfer such personal data to another controller.
6. Withdraw its consent, in case the legal basis for personal data processing is consent;
7. Object to personal data processing relating to the data subject and carried out either (A) on the basis of performance of a task in the public interest or (B) based on the legitimate interest of the Company as the controller in personal data processing, including objecting to profiling on the given legal bases (in cases where the Company performs profiling based on automated decision-making);
8. file an application to initiate proceedings at the Office for Personal Data Protection of the Slovak Republic.

The data subject shall be entitled to submit its applications in connection with the above rights at info@seq-control.com or in the form of a registered letter delivered to the Company to the address specified in the first section of these terms. The e-mail/letter shall contain an explicit remark “PERSONAL DATA“.

Responses to the above applications of the data subject or measures taken upon such applications shall be provided by the Company free of charge. If an application of the data subject is manifestly unfounded or inappropriate, mainly due to its repeated nature (a repeated application), the Company shall be entitled to charge a fee taking into account its administrative costs for the provision of information, or a reasonable fee taking into account its administrative costs of notification and/or costs of implementation of the requested measure, or shall be entitled to refuse to act upon such application.

In case of doubts as to compliance with the obligations relating to personal data processing, you may contact the Company directly at info@seq-control.com. You may also file a complaint to the Office for Personal Data Protection of the Slovak Republic, registered office at Hraničná 12, 820 07 Bratislava 27, e-mail: statny.dozor@pdp.gov.sk, www: https://dataprotection.gov.sk/.