Privacy Policy


Effective date: February 1, 2019

Operator: Spotee s.r.o., Poniklecova 5870/24, 84107 Bratislava, IČO (company registration number): 52 057 704

The protection of personal data is in Spotee s.r.o. (thereinafter “Operator”) provided in accordance with the requirements of Regulation 2016/679 of the European Parliament and of the Council (EU) of 27th of April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data of Act no. 18/2018 Coll. on the Protection of Personal Data as amended (thereinafter “Act” or “Regulation”).

The operator declares that according to article 24 of the Regulation he has adopted adequate technical, organizational and personnel security measures to enable the legal, fair and transparent processing of personal data.


The assessment of the impact on personal data protection

It is not possible to ensure the delivery of goods and services without the processing of personal data. To ensure the transparency of the processing of personal data, the operator uses the principle of minimizing the scope of processing.

Information and procedure of personal data processing are specified in Annex No. 1 of this Privacy policy named as “INFORMATION ON PERSONAL DATA PROCESSING”.


A description of planned processing operations and processing purposes

In connection with his business activities, the operator provides a service by an application designed for smartphones, which is used to search for free parking spaces.

In order to ensure proper functionality of the application, it is necessary to process personal data by entities according to the purpose. In addition to the operator’s employees, third parties also participate in the processing of personal data. Measures to ensure transparency and security with the processing of personal data are governed by separate terms and conditions agreed by both parties for this purpose and in accordance with the Regulation.

The operator processes personal data based on a legal basis:

a) Processing is necessary for the performance of the contract – provision of services

In the event that the customer of the services is a legal entity or a natural person-entrepreneur, the operator shall process the data of the business entity. If the customer is a consumer, the operator processes the personal data necessary for the purpose.

As a data repository of personal data that is necessary for the operation of Spotee, the Operator’s subcontractor (Intermediary) is Contabo GmbH, Aschauer Straße 32a, 81549 Munich, Germany, VAT-ID .: DE267602842, which protects data against misuse or loss of encryption and security measures according to European standards.

According to this purpose, the following personal data are processed:

  • Name and surname,
  • permanent address,
  • phone number,
  • login e-mail for the application Spotee and the password for the application Spotee,
  • G-mail account (if a user wants to use G-mail to sign in to the app and sign up),
  • Facebook account (if a user wants to use Facebook to sign in to the app and sign up),
  • an application user’s photo that uniquely identifies the person who offers the parking space,
  • vehicle data to identify the vehicle (make, model, vehicle type, color, license plate, photo, vehicle GPS position) in accordance with the Spotee License Agreement.

b) Processing is essential to comply with legal obligations

For this purpose, the Operator uses a third-party service through the Accounting Service Provider, with whom personal data protection measures have been contractually treated in the Service Agreement. Accordingly, the operator provides personal data about its customers to this extent:

  • Name,
  • surname,
  • permanent address,
  • phone number,
  • e-mail.

The processing, which is necessary for the fulfilment of the legal obligation, also includes the obligation to store and archive documents where personal data can be found for the period stipulated by law (Accounting Act, Income Tax Act, VAT Act). To archive documents, the Operator uses a personal archive, secured by an alarm.


The assessment of necessity and adequacy of processing operations

An operator processes personal data for legitimate purposes, taking into account the necessary data. The operator does not use either automated decision making or profiling systems to achieve the purpose.



Annex No. 1

Information on personal data processing

The protection of personal data is in Spotee s.r.o. (thereinafter “Operator”) provided in accordance with the requirements of Regulation 2016/679 of the European Parliament and of the Council (EU) of 27th of April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data of Act no. 18/2018 Coll. on the Protection of Personal Data as amended (thereinafter “Act” or “Regulation”).

Operator: Spotee s.r.o., Poniklecova 5870/24, 84107 Bratislava, IČO (company registration number): 52 057 704


Processing Purpose:

Your personal data are processed for the following purposes:

  1. the processing of personal data for the purposes of meeting customer requirements, for the purpose of negotiating pre-contractual terms or for the purpose of performing the contract;
  2. ensure the availability of the website and further improve and develop this website;
  3. create usage statistics;
  4. detect, prevent and investigate attacks on our website;
  5. respond to your requests;
  6. send you a newsletter.

Legal basis of processing:

Processing is necessary for the performance of a contract to which the data subject is a party or that, at the request of the person concerned, measures are taken prior to the conclusion of the contract under Art. (1) (b) of the Regulation.

We process the processing purpose (f) based on your consent. You may revoke your consent at any time without prejudice to the legality of the processing operations performed before the date of cancellation.


Recipients:

Operator, Intermediary, the Accounting company.


Retention periods:

We will store data processed in accordance with point (a) for a period of 2 years.

We will store data processed in accordance with points (b) to (e) for a period of three months. Data is stored longer only when necessary to investigate the detected attacks on our site.

If you register to subscribe to our newsletter (f), we will store your data until we receive your notice to which you withdraw your consent and then we will be legally bound to do so.


Reason and consequences of not providing personal information:

The provision of personal data is essential for the purpose. Without this data, it is not possible to meet the requirements of the data subjects.


Transfer of personal data to third countries:

Not performed.


Rights of the person concerned:

The data subject has, irrespective of the legal basis for the processing of personal data:

  • Personal data access (according to no. 15 of the Regulation and § 21 of the Act)
  • The Right to data corrections (according to no. 16 of the Regulation and § 22 of the Act)
  • The Right to erase (according to no. 17 of the Regulation and § 23 of the Act)
  • The Right to processing restriction (according to no. 18 of the Regulation and § 24 of the Act)
  • The Right to data transfer (according to no. 20 of the Regulation and § 26 of the Act)
  • The Right to object (according to no. 21 of the Regulation and § 27 of the Act)
  • Automated decision making (according to no. 21 of the Regulation and § 27 of the Act)
  • The Right to consent to withdraw (according to no.7 of the Regulation and § 14 of the Act)

More about data subjects’ rights: The rights of the persons concerned.


The following data is collected when you visit the website

During your visit to our site, we record the IP address assigned to you by your Internet service provider, from what sites you visited our site, how long you were on our site, which specific subpages you view, and so on. This information is considered to be personal, as it is your online identifier, and we treat this information with increased care.


Cookies

Like many other websites, we also use so-called “cookies”. Cookies are small text files that are saved on your hard drive and associated with the browser used and that provide specific information to us. However, this does not mean that we receive knowledge of your identity in this way.

The use of cookies helps us design our website to be easier for you to use. For instance, we create so-called session cookies to recognize that you have already visited the individual pages of our website. These are automatically deleted upon leaving our site.

In addition, we also use temporary cookies that are saved on your device for a specifically defined period of time for optimizing the user-friendliness of the site. If you visit our site again to take advantage of our services, it is automatically detected that you were previously here, and the entries you made as well as settings you selected are loaded so that you do not have to enter them again.

We also use cookies to collect statistics on the use of our website in order to evaluate these in the interests of optimizing the site and its content. These cookies allow us to automatically detect during a subsequent visit that you were previously here. These cookies are automatically deleted after a specifically defined period of time.

The data processed by means of cookies is required for the specified purposes in order to preserve our justified interests as well as those of third parties according to Art. 6 para. 1 clause 1 item f GDPR. You can configure your browser settings according to your wishes and, for example, refuse the acceptance of third-party cookies or all cookies. Please note that you may not be able to make use of all functions of this website if you refuse cookies.

The legal basis for the use of cookies is Art. 6 para. 1 clause 1 item f GDPR.


Google Analytics

This website uses Google Analytics, a web analytics service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). We use Google Analytics in the interests of ensuring a user-friendly design and continuous optimization of our website as well as to record statistics on the use of our website in order top optimize our offering for you. The legal basis for this is Art. 6 para. 1 clause 1 item f GDPR.

Google Analytics uses so-called “cookies”, text files that are saved on your computer and that enable an analysis of your use of the website. The information generated by the cookie about your use of the website is generally transmitted to a server of Google in the USA and saved there. IP addresses are shortened and processed anonymously; no relationship to an individual person is therefore possible. If the data collected about you constitutes a personal reference, it is therefore immediately excluded and the personal data is immediately deleted. Only in exceptional cases is the complete IP address transmitted to a server of Google in the USA and shortened there. For the exceptional cases in which personal data is transmitted to the USA, Google has undertaken to comply with the EU-US Privacy Shield.

On behalf of the operator of this website, Google will use this information to analyze your use of the Website in order to compile reports on the website activities and to provide other services for the website operator in connection with use of the website and the internet (in particular, functions for display advertising, such as remarketing, reports on impressions in the Google Display Network, integration of DoubleClick Campaign Manager or Google Analytics reports on the performance based on demographic features and interests).

Under some circumstances, Google can analyze your usage behavior over multiple devices (PC, smartphone, tablet, etc.) by means of so-called cross-device functions and evaluate this for us. In this regard, Google can combine information generated via the respective devices for the purposes of personalized advertising as well as with data from your Google account, if you have a Google account and your account settings have been configured such that Google can associate the browser history with the Google account and such that information from the Google account may be used for the personalization of advertisements.

You can prevent the saving of cookies by configuring your browser software; however, please note that in this case you may not be able to make full use of all the functions of this website. In addition, you can prevent the collection of the data generated by the cookie and related to your use of the website (including your IP address) by Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: tools.google.com/dlpage/gaoptout?hl=en.

As an alternative to the browser plug-in or in browsers on mobile devices, you can click on the following link to set an opt-out cookie that will in future prevent the collection of data by Google Analytics within this website (this opt-out cookie functions only in this browser and for this domain; if you delete your cookies in this browser you must click this link again): Click here to set the Opt-Out cookie for Google Analytics.

Third party provider information: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, terms of service: www.google.com/analytics/terms/us.html , data privacy overview: support.google.com/analytics/answer/6004245?hl=en , and privacy statement: policies.google.com/privacy?hl=en.


Use of social media links

On our website, we use links to our profiles on the social networks Facebook, Instagram and the video portal YouTube to increase our visibility in this way.

These services are integrated only as links to the corresponding social networks. No data is transmitted to the provider of the social networks if you do not click on the respective links. After clicking on the embedded links, you will be forwarded to the page of the respective provider. Only then is user information transmitted to the respective provider.


Embedding of YouTube videos

We have embedded YouTube videos from YouTube LLC, 901 Cherry Ave, San Bruno, CA 94066, USA (“YouTube”), in our online offering, which are stored on www.youtube.com and can be played directly from our website. The YouTube videos are embedded to enable you to conveniently make use of the website. The legal basis for this is Art. 6 para. 1 clause 1 item f GDPR.

By visiting this website, YouTube receives the information that you have loaded the corresponding sub-page of our website. Protocol data is also transmitted. This takes place regardless of whether you are logged into a user account provided by YouTube or no user account exists. If you are logged in with Google, your data will be associated directly with your account. If you do not wish this to be associated with your profile at YouTube, you must log out before visiting our website. YouTube stores your data as a usage profile and uses it for the purposes of advertising, market research and/or usage-based design of its website. Such analysis takes place in particular (even for users who are not logged in) for the provision of usage-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of this user profile, and you must contact YouTube to exercise this right.

Additional information about the purpose and scope of the data collection and its processing by YouTube can be found in the privacy policy of YouTube. Here you will also find additional information on your rights and the configuration options for safeguarding your privacy: policies.google.com/privacy?hl=en. Google also processes your personal data in the USA and has undertaken to comply with the EU-US Privacy Shield.


Facebook Conversion Tracking Pixel

This website uses features from the Conversion Tracking Pixel service of Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA (“Facebook”). This tool allows us to follow the actions of users after they are redirected to a provider’s website by clicking on a Facebook advertisement. Facebook Conversion Tracking Pixel also uses cookies. We are thus able to record the efficacy of Facebook advertisements for statistical and market research purposes. The collected data remain anonymous. This means that we cannot see the personal data of any individual user. However, the collected data are saved and processed by Facebook. We are informing you on this matter according to our information at this time. Facebook is able to connect the data with your Facebook account and use the data for their own advertising purposes, in accordance with Facebook’s Data Use Policy found under: https://www.facebook.com/about/privacy/ Facebook Conversion Tracking also allows Facebook and its partners to show you advertisements on and outside Facebook. In addition, a cookie will be saved onto your computer for these purposes.

You can prevent the collection of your data by Facebook Conversion Tracking by clicking on the following link. An opt-out cookie will be set which prevents the collection of your data on future visits to this website. Deactivate Facebook Conversion Tracking on this website.

Please click here if you would like to revoke your permission: https://www.facebook.com/ads/website_custom_audiences/