Personal Data Protection

The basic mission of Slovenská pošta, a. s. (hereinafter referred to as “SP”), also resulting from Act No. 324/2011 Coll. on Postal Services and on Amendments to Certain Acts as amended, is to provide quality, reliable and efficient postal services in the postal market. To achieve this mission, it is essential to ensure adequate protection for all SP assets, to minimize potential losses in accordance with the applicable legislation and international norms and standards. Security is an integral part of all SP activities.

The protection of privacy with regard to the processing of personal data is a fundamental human right. Protecting rights of natural persons from unauthorized interference with their private life when processing their personal data is also in line with Art. 19 of the Constitution of the Slovak Republic, as personal data shall be deemed the key to our privacy.  

In order to ensure the protection of fundamental rights and freedoms of natural persons with regard to the processing of personal data and to contribute to the free flow of personal data between the EU Member States, 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, has been adopted. This Regulation entered into force on 24 May 2016 and shall apply from 25 May 2018, after a two-year transitional period. The Regulation is commonly referred to as General Data Protection Regulation (GDPR).    

Pursuant to Article 288 of the Treaty on the Functioning of the European Union (hereinafter referred to as “TFEU”), the Regulation is a generally and directly applicable legal act of primary Union legislation, regulating the rules on the protection of natural persons with regard to the processing of personal data and on the free flow of personal data uniformly for all Member States. In order to comply with the obligations of the Slovak Republic arising out of the TFEU, a new Act No. 18/2018 Coll. on Personal Data Protection and on the amendment to certain Acts has been adopted. The aim of the new Act is to harmonise the legal regulation of the processing of personal data of natural persons in the Slovak legislation with the new Community legislation on processing and protection of personal data stipulated by the GDPR. 

In connection with the processing of your personal data by SP (as “Controller”), we hereby provide you – as a person whose personal data is being processed (hereinafter referred to as “Data Subject”) – with information pursuant to Articles 13 and 14 of the GDPR, conceived as questions to make this information clear, transparent and practical for you:

1) Who is the Controller of your personal data?

    Slovenská pošta, a. s.
    Partizánska cesta 9                                
    975 99 Banská Bystrica
    Slovak Republic                          
    Company Registration No.: 36 631 124, Tax Registration No: 2021879959       
    VAT Registration No.: SK 2021879959                 
    The Commercial Register of the Banská Bystrica District Court, section Sa, insert no. 803/S

Our company has appointed a Personal Data Protection Officer to oversee the proper processing of personal data. You can contact this Officer at any time by writing to the address of Slovenská pošta, a. s., Data Protection Department, Partizánska cesta 9, 975 99 Banská Bystrica, Slovak Republic, or electronically at “zodpovedna.osoba@slposta.sk”. 

2) Why we do process your personal data and for what purposes?

SP as the Controller processes your personal data especially for the purpose of providing postal services and postal payment service. The legal basis for personal data processing shall be:

  • Act No. 324/2011 Coll. on Postal Services and on Amendments to Certain Acts as amended (hereinafter referred to as “Postal Services Act”),
  • Act No. 297/2008 Coll. on the Prevention of Legalization of Proceeds of Criminal Activity and Terrorist Financing and on Amendments and Supplements to Certain Acts as amended, which entitles SP to carry out identification and verification of the customer's identification in the course of a business operation whose value reaches at least EUR 1,000.   

When concluding agreements between SP and customers, personal data shall be processed for the purpose of fulfilling the obligations of SP arising from the legislation (tax laws or other public-law regulations).

SP also processes the contact details of its customers beyond the scope of Postal Services Act, i.e. e-mail and phone number, based on legitimate interests of the Controller in accordance with Art. 6 par. 1 point f) of GDPR. These contact details are obtained by SP when providing certain products and services, if their use is justified for the benefit of the customer, e.g. e-shop, ePosting Sheet, electronic shipment notification, track & trace via mobile application “Slovenská pošta” and any other. In the event that SP needs to process personal identification data for the purpose of the execution and defense of its legal claims (complaints, litigation), it is also considered to be processing of personal data for the purposes of legitimate interests of SP.   

Moreover, it is also legitimate interest of SP to reach out its contractual customers with marketing offers, taking into account the reasonable expectations of customers towards SP. This means that SP does not need to have customer's consent for such addressing. If the customer objects to such addressing, SP shall no longer address the customer in marketing terms.   

If we do not have any agreement concluded with you, SP shall process personal data for marketing purposes only if we have voluntary consent given by you. You may withdraw the given consent at any time at the branch office of SP or through a written request addressed to – Slovenská pošta, a. s., Branch Network Back Office Department (BOPS), Komenského 16, 975 88 Banská Bystrica, Slovak Republic.  

SP also processes personal data as the Processor based on instructions from controllers agreed in contracts in accordance with Art. 28 and Art. 29 of GDPR. 

As the Processor, SP processes personal data in particular for:

  • delivery of pensions and payment of social benefits,
  • provision of Electronic State Services (IOM),
  • provision of Joint Collection of Utility Payments (SIPO),
  • provision of services of Poštová banka, a. s.,
  • provision of payment service for SPPS, a. s.,
  • provision of Western Union,
  • processing of requests for reimbursement of court and administrative fees, resp. for payment of expenses,
  • provision of services of SWAN telecommunications company,
  • mediation of application (or change and cancellation of registration) in the register of payment payers according to the applicable Act on Payment for Public Services provided by the public broadcaster Rozhlas a televízia Slovensko.

3) What are the legitimate interests we do have for processing personal data?

Based on legitimate interests, SP processes personal data:

  • for marketing purposes (Postal Card – Loyalty Programme),
  • for the purpose of preventing security and protecting of persons, property and values entrusted to SP (Camera systems).

4) What subjects do have access to your personal data?

Third parties also have access to personal data to ensure the proper functioning of our company. In particular, they are IT service providers, providers of paper carrier shredding services, auditors and other persons who provide services to SP and with whom we do have concluded fair personal data processing agreements.

5) Does Slovenská pošta make the transfer of personal data to third countries?

SP electronically transmits addressed personal data of the Addressees and Senders to countries that are the destination of items for the purpose of improving and speeding up their delivery. 

6) How long do we store your personal data?

The personal data that SP processes on the basis of Postal Services Act in operating documents and services shall be mainly stored for three years. In some cases, under any other law, for a period that is required by relevant legislation in accordance with Act on Archives and Registries.    

The personal data provided for marketing purposes by consent shall be stored in accordance with the Loyalty Programme Agreement (Postal Card).

7) What are your rights regarding the processing of personal data?             

Whenever you have the right to contact a person being responsible in SP for the protection of personal data and to request information and access to personal data concerning you as the person concerned. Moreover, you have the right to correct inaccurate and incomplete personal data, the right to delete personal data, the right to limit the processing of personal data, the right to object to processing and the right to portability of personal data, the right to withdraw consent, the right to object to profiling and automated decision making, the right to lodge a complaint with the supervisory authority which is the Office for Personal Data Protection of the Slovak Republic.  

8) Do we use profiling and automated decision making in processing your personal data?

SP does not use automated decision making and profiling within its activities. 

 

If you are interested in more detailed information, please do not hesitate to contact us by e-mail at zodpovedna.osoba@slposta.sk, by phone at +421 850 122 413 or by writing to: Slovenská pošta, a. s., Data Protection Department, Partizánska cesta 9, 975 99 Banská Bystrica, Slovak Republic.

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