Personal data is defined as any information relating to an identified or identifiable data subject. A data subject may be identified, directly or indirectly, by reference to a number, code or to one or more elements specific to his or her physical, physiological, psychological, economic, cultural, or social identity. Personal data include, in particular, the contact details of natural persons, their IP address, which may be information about the use of services or about the activities and preferences of a natural person. The protection of personal data is regulated by Act No. 122/2013 Coll. and Act No. 18/2018 Coll. on the Protection of Personal Data with effect from 25. 5. 2018 by the Regulation (EU) 2016/679 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 referred to as “GDPR”).
Information on the processing of personal data
The purpose of this information is to explain how the Slovak Gas and Oil Association, with its registered office at Mlynské nivy 44/a, 821 09 Bratislava, Slovak Republic, Company ID: 30845475, registered by the Ministry of the Interior of the Slovak Republic under the number VVS/1-2200/90-237 (“Association”) processes personal data of the data subjects and what are their rights are under the Regulation and the Act on Personal Data Protection.
1.1 How SGOA obtains personal data
The Association obtains personal data in the following ways:
- directly from its members when concluding a collective membership agreement or an individual member’s application;
- from publicly available sources, such as public registers and registers;
- from persons who voluntarily provided the company with their personal data and granted their consent to their processing (by phone, e-mail, through the company’s website, when registering for an event organized by the union, etc.);
- from authors of contributions to events and to the journal and competition of diploma theses
The Association collects and processes personal data only to the extent that is appropriate for the purpose of their processing. In doing so, the company places particular emphasis on the security and protection of personal data and the rights of data subjects.
1.2 What is the legal basis and purpose of the processing
The Company processes personal data on the basis of the following legal titles established by the Regulation and the Act on Personal Data Protection:
- legitimate interests
The Union may process personal data of data subjects where necessary for the purposes of the legitimate interests of the company or of third parties, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data, in particular where the data subject is a child. Such legitimate interests of the company are in particular:
- protection of the rights which the company derives from generally binding legal regulations and contracts in relation to contractual partners and other persons; for this purpose, the company retains personal data for no longer than is necessary to protect such rights and legitimate interests;
- marketing activities of the company, which means in particular informing about activities organized by the association and through a 100% subsidiary Slovenská plynárenská agentúra, s.r.o. This marketing communication is sent occasionally, usually several times a year; and for this purpose, the company retains personal data for the maximum duration of the legitimate interest of the company.
The Association processes the personal data of the data subjects for purposes related to the fulfilment of the contractual obligations of both Parties, in particular the conclusion, amendment and termination of the Agreement and contractual relations resulting from the application for an event organized by the Association. The provision of personal data by the data subject to the extent necessary is a condition for the conclusion of a contract or participation in an action. Failure to provide personal data may prevent participation in the event organized by the association. The association shall provide the data subject with information on which personal data are necessary for the conclusion of the contract and which may be provided, for example, for the purpose of increasing the effectiveness of communication.
The Association retains personal data for the purposes of the performance of the contract for the duration of the contractual relationship between the company and the data subject and the necessary time after its termination.
- Compliance with a legal obligation
The Association may process personal data, including their provision to state authorities and other persons, if such an obligation arises from the law. Due to a legal obligation, the Association may, for example, provide personal data to the Office for the Regulation of Network Industries, the Slovak Trade Inspection Authority, law enforcement authorities or other authorities or persons.
The Association retains personal data for the purpose of fulfilling a legal obligation for a maximum period necessary to fulfill the relevant legal obligation provided for by generally binding legal regulations.
- Consent given by the data subject
The Association processes personal data of the data subjects on the basis of the consent expressly granted by the data subject.
The Association shall store personal data processed on the basis of the consent of the data subject for a maximum duration of such consent or until its withdrawal, whichever is the earlier.
1.3 Who are the recipients of personal data
The Association may entrust the processing of personal data to third parties, so-called intermediaries. The company’s intermediaries are, for example, persons who arrange for the company to publish Slovgas magazine, an external employee for economic activities to perform certain marketing activities, external sellers, consulting companies or security services. Intermediaries process personal data for the Company solely on the basis of a personal data processing agreement, which must meet the requirements set out in the Regulation and the Act on Personal Data Protection, and the Company in such cases strictly takes care to protect personal data provided by the Intermediaries.
1.4 What are the rights of data subjects?
The data subject shall have the right:
- require the union to:
- confirmation as to whether or not his or her personal data are being processed; if the personal data have not been obtained from the data subject, the data subject may require the provision of any available information as to its source (‘right of access to personal data’);
- if its personal data is processed, to obtain access to personal data and other information and to receive a copy of the personal data processed by the association (“right to be informed about the processing”); the company is entitled to charge the data subject a reasonable administrative fee in connection with the request for a copy of personal data;
- correcting incorrect/incomplete personal data processed by the association (“right to rectification”);
- the erasure of personal data where one of the grounds set out in the Regulation or the Act on Personal Data Protection is met; in particular, where the personal data are no longer necessary for the purposes for which the association obtained or processed them, where the data subject withdraws his consent and the association has no other legal basis for processing, where the data subject objects to processing or where the association has processed personal data unlawfully; where official documents containing personal data are the subject of processing, the data subject may request their return (‘right to erasure’);
- the restriction of the processing of personal data where one of the grounds set out in the Regulation and the Act on Personal Data Protection is fulfilled; for example, where a data subject reports that a company is processing inaccurate personal data about him or her, he or she may request that such personal data not be processed until they have been rectified (‘right to restriction’);
- the acquisition of personal data relating to him which he has provided to the Union in a structured, commonly used, and machine-readable format; the data subject shall have the right to transfer such personal data to another controller, where technically possible and subject to the conditions laid down in the Regulation and the Act on Personal Data Protection (‘the right to portability’);
- object, on grounds relating to a particular situation, to the processing of personal data concerning it which is necessary for the performance of a task carried out in the public interest, including objection to profiling; object to the processing of personal data for the purposes of direct marketing without its consent, including profiling, to the extent that it is related to such direct marketing (‘the right to object’);
- object to being subject to a decision of a federation based solely on automated processing, including profiling, which produces legal effects concerning it or similarly significantly affects it, unless otherwise provided for in the regulation and the law on the protection of personal data (‘automated decision-making, including profiling’);
- revoke at any time the consent to the processing of personal data granted to the Association with effect from the moment of revocation of consent (“right to revoke consent”);
- if it is suspected that its personal data are being unlawfully processed, submit a proposal to initiate the personal data protection proceedings to the Office for Personal Data Protection of the Slovak Republic, with its registered office at Hraničná 4826/12, 820 07 Bratislava, Slovak Republic, phone number: + 421 2 3231 3220, www.dataprotection.gov.sk.
Should the data subject fail to possess full legal capacity, his or her rights under the Regulation and the Act on Personal Data Protection may be exercised by a legal representative. Pursuant to the Regulation and the Act on Personal Data Protection , the rights of the data subject who has deceased may be exercised by a close person.
1.5 How data subjects can exercise their rights
With regard to the possible risks of misuse and ensuring the protection of personal data of the data subjects, the Association sets out the means of communication by which the data subject can receive and respond to the request in relation to the personal data processed by the Association. The Association also takes into account the technical aspects of some of the data subject’s rights and adapts the means of communication to ensure these data subject’s rights. In case of doubt about the identity of the data subject, the Association is entitled to request additional verification of their identity.
The data subject may exercise his or her rights in the following ways:
- in person at the SNCC Secretariat;
- by postal consignment (the signature of the person concerned must be officially certified) sent to the address of the seat of the union;
- by e-mail to email@example.com;
1.6 What is automatic decision making and profiling?
In some cases, the Union carries out automated decision-making, including profiling of personal data of the data subject, which has legal effects concerning him or her or similarly significantly affects him or her. In such cases, the Union shall notify the data subject of such processing in an appropriate manner.
For this purpose, the union may inform the data subject who provided them to the union in the context of previous participation in the union’s shares (application) about the most appropriate actions of the union.
The consequence of analyzing and evaluating the interest in the data subject is the adaptation of offers for the activities of the association (conferences, seminars on diverse topics), as close as possible to the needs of the data subject.