According to law no. 18/2018 Z. z. on the protection of personal data (hereinafter referred to as the "law") and pursuant to regulation (EU) 2016/679 of the European Parliament and of the Council of 27. April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (the "regulation")
Right to Information (§19 of the act; art. 13 of the regulation)
In order to fulfill the information obligation of the controller, which corresponds to the right of the data subject to information, the controller in accordance with § 19 of the act and art. 13 of the regulation provides the data subject with the following information:
I. Identification and contact details of the controller:
Business name: European Modern Development s.r.o.
Seat: 811 07 Radlinského 7917/49 Bratislava, Slovensko
IČO: 53 728 921
DIČ: 2121486609
DPH: SK2121486609
Tel.: +421 903 530 158
E-mail: info@emd.sk
II. Cookies
We do not track you on our website, so only those of your personal data that you agree to us will get to us. Cookies are small text files that are stored on your device (computer, tablet, smartphone) when you visit our website and contain information necessary for your device to communicate with our website. These files are stored on your device temporarily or permanently. Most internet browsers are initially set to automatically accept cookies. Cookies do not harm your device.
We process cookies on the basis of your consent, except for the necessary cookies, which we can also process without your consent, on the basis of legitimate interest and in accordance with the act on electronic communications. Providing consent for cookies is voluntary and you are not obliged to give consent. Browsing our website is not subject to consent to cookies. Provision of cookies, especially marketing and analytical cookies.
III. The purposes of the processing of personal data:
A. Mediation of purchase, sale and lease of real estate, preparation of documents necessary for the transfer of ownership of real estate (real estate activities).
Purpose of personal data processing
Mediation of purchase, sale and lease of real estate, preparation of documents necessary for the transfer of ownership of real estate.
We need your personal data from you because in case of failure to provide them, a contractual relationship between you and our company cannot arise, as they are a necessary part of the contracts concluded between you and our company in accordance with the law. no. 40/1964 Coll. Civil Code as amended and zák. no. 513/1991 Coll. Commercial Code as amended. As a result, we would not be able to provide you with the real estate services we offer. However, if you decide not to provide us with your phone number or e-mail address, this does not prevent the establishment of a contractual relationship or the provision of real estate services, but our mutual communication will not be as effective as if you had provided them to us.
Legal basis for processing
In this case, we process your data on the basis of a concluded contract (e.g. the processing is necessary for the performance of a contract to which you are a party.
Data retention period
We will store your personal data during the validity of the contract and after its termination for the period necessary to assert liability claims, i.e.j. after 4 years from the termination of the contract.
Categories of beneficiaries
Depending on our contractual obligations, we may transfer your data to a lawyer for the purpose of preparing and assessing contractual documentation (for example, for the preparation of a purchase contract), or to perform an authorization for a contract, to a notary for the purpose of preparing a notarial deed or a bank for the purpose of preparing a bank vignette, to an expert for the purpose of preparing an expert opinion or an energy certificate for a real estate, to a financial intermediary for the purpose of arranging a loan to finance the purchase price for a real estate or to another real estate agency that represents the interests of the other party in a business relationship, the competent district office (Cadastral department) when submitting a proposal for registration in the land register, the administrator of an apartment building or the Slovak trade inspection as a supervisory authority.
B. Accounting
Purpose of personal data processing
Fulfillment of our obligations under the Accounting Act (bookkeeping and preparation of accounting documents, in particular administration and invoicing of services provided under contracts, processing of accounting, tax documents and invoices).
We need your personal data from you to fulfill our legal obligation.
Legal basis for processing
In this case, we process your data on the basis of Act no. Regulation (EC) no 431/2002 z. on accounting, as amended, Act no. Regulation (EC) no 595/2003 z. on income tax as amended, Act no. Regulation (EC) no 222/2004 z. on Value Added Tax as amended and other legislation.
Data retention period
We are required by law to keep accounting documents for a period of ten years.
Categories of beneficiaries
Statistical Office of the Slovak Republic, executor, bankruptcy administrator, preliminary administrator, auditor, Tax Office, health insurance agency, Social Insurance Agency, accountant, tax advisor.
C. Prevention of money laundering
Purpose of personal data processing
To fulfill the obligations of the obliged entity under the law on protection against legalization of proceeds from crime and on protection against terrorist financing.
We need your personal data from you to fulfill our legal obligation.
Legal basis for processing
Based on Act no. Regulation (EC) no 297/2008 z. on protection against the legalization of proceeds from crime and on protection against the financing of terrorism, and on amendments to certain laws.
Data retention period
We are obliged to keep the data for five years after the termination of the contractual relationship with the client in accordance with Section 19 of Act no. Regulation (EC) no 297/2008 z.
D. Enforcement of legal claims
Purpose of personal data processing
Exercise of legal claims (e.g. unpaid commissions, contractual penalties for breach of contractual obligations) and protection against claims of third parties, bankruptcy proceedings, restructuring proceedings, assignment of claims.
The processing of the personal data of the data subject is necessary to achieve the purposes of the processing. Without the personal data, we would not be able to make a legal claim.
Legal basis for processing
On the basis of our legitimate interest pursuant to Article 6 para. Article 1 (1) f) General Data Protection Regulation (processing is necessary for the purposes of the legitimate interests pursued by the controller).
Data retention period
Until the termination of the claim, respectively. until the limitation period for making a claim expires.
Categories of beneficiaries
Slovak trade inspection, Court, lawyer or other legal representative, law enforcement authorities.
E. Registration and handling of received complaints
Purpose of personal data processing
Fulfilment of our obligations under the Consumer Protection Act (registration and handling of received complaints).
We need your personal data from you in order to be able to handle your complaint in accordance with the law.
Legal basis for processing
Fulfilment of our legal obligations under Act no. Regulation (EC) no 250/2007 z. on consumer protection.
Data retention period
We will store your personal data until the expiry of the period for granting a fine by the Slovak trade inspection, i.e.j. within three years from the settlement of the claim or complaint, respectively. after the deadline for applying the law in court.
Categories of beneficiaries
Slovak trade inspection, Court, lawyer or other legal representative, mediator, Alternative Dispute Resolution entity, our real estate agent.
F. Handling of data subjects ' complaints
Purpose of personal data processing
For the purposes of processing complaints from data subjects who have exercised their rights under the General Data Protection Regulation (GDPR).
The provision of your data is necessary for the processing of the complaint.
Legal basis for processing
Regulation (EU) 2016/679 of the European Parliament and of the Council 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 (General Data Protection Regulation) and act no. 18/2018 Z. z. on the protection of personal data and on amendments to certain acts
Data retention period
During the period for the imposition of sanctions by the Office for personal data protection of the SR, t.j. after 5 years from the exercise of the right of the person concerned.
Categories of beneficiaries
Office for personal data protection of the Slovak Republic, Court, lawyer or other legal representative, real estate agent.
G. Newsletter
Purpose of personal data processing
Newsletter sending (advertising and marketing of the operator's services and products, in the form of sending information newsletters about our products and services and the current offer of real estate, etc.) in electronic form to interested parties and visitors of the website who have expressed interest in sending the newsletter.
Legal basis for processing
We will process your e-mail address based on your consent. You can withdraw your consent at any time, either by unsubscribing from the newsletter (by clicking on the link contained in each message) or by sending a message to one of our contacts. Providing consent is voluntary and you are not obliged to give consent. However, entering your e-mail address is necessary for sending the newsletter and we cannot send you the newsletter without entering it.
Data retention period
We will process your e-mail address for the duration of your consent, for a maximum of four years from the withdrawal of consent (§ 116 para. 5 of the Electronic Communications Act
H. Registration of requests for real estate agency services and their contact
Purpose of personal data processing
Registration of requests for real estate agency services and contacting them. The operator processes the basic contact details of candidates who contact him themselves and who are interested in selling/ buying or renting real estate in order to contact them back with the offer of real estate agent services or to answer their questions about real estate agent services.
Legal basis for processing
We will process your request based on the legitimate interest of the controller. The operator processes the basic contact details of candidates and information about real estate who contact him/ her and who are interested in selling / buying or renting real estate, so that he / she can contact them back with an offer of real estate agent services or answer their questions about real estate agent services. By processing personal data, the operator pursues its interest in obtaining clients, orders and orders.
Data retention period
Your personal data
I. Database of job seekers
Purpose of personal data processing
Processing of personal data for the purpose of registration of job seekers in case of the need to hire a new employee in the future.
Legal basis for processing
We will process your request based on your consent. You can revoke your consent at any time by sending a message to one of our contacts.
Providing consent is voluntary and you are not obliged to give consent. However, entering your identification data and data on work and professional competence is necessary in order to be able to include you in the database of job seekers and to contact you in case of filling a vacancy.
Data retention period
Your personal data will be processed for a maximum period of 12 months from the date of receipt of the request for employment directly to the operator via the form on the website of the operator or after 12 months from the end of the selection procedure in the event that the unsuccessful candidate has given consent to be included in the Register of candidates in the selection procedure for a specific job. After this period or if you withdraw your consent, your data will be deleted. However, if we conclude a contract together (e.g. employment contract), personal data will continue to be processed, but no longer on the basis of consent, but on the basis of a concluded contract.
J. Contact back with satisfaction survey
Purpose of personal data processing
Sending a satisfaction questionnaire in electronic form to clients or contacting clients by phone to whom the operator has provided brokerage real estate activities.
Legal basis for processing
We will process your request based on the legitimate interest of the controller. By processing personal data, the operator pursues its interest in obtaining feedback from clients and improving its services.. The operator has developed a proportionality test of legitimate interest.
Data retention period
Your personal data is not stored for this purpose, they are only used by the operator once to contact us with a satisfaction survey.
Categories of beneficiaries
Our real estate agent.
K. Reviews
Purpose of personal data processing
Publishing reviews and experiences of clients with the operator's services on the website.
Legal basis for processing
We will process your request based on your consent. You can revoke your consent at any time by sending a message to one of our contacts.
Providing consent is voluntary and you are not obliged to give consent. However, the processing of your basic identification data, data on the property for which the service was provided and your review is necessary in order for us to publish your review.
Data retention period
Your personal data will be deleted immediately after fulfilling the purpose or after exercising the right to delete, otherwise after 7 years from providing the review.
Categories of beneficiaries
Our real estate agent, website visitors (data disclosure).
IV. Automated decision-making and profiling
No automated decision-making or profiling is used in the processing of personal data.
V. Transfer of personal data to third countries
We do not transfer your personal data to third countries. Your personal data is not processed outside the territory where the common rules established by the General Data Protection Regulation apply. The free movement of data within the member states of the European Union is guaranteed by this regulation.
VI. Other rights of the person concerned
Right of access to personal data (Article 15 of the regulation)
You have the right to obtain from us confirmation as to whether we process your personal data and, if so, access to such personal data (copies thereof), as well as additional information to the extent provided for in Article 15 of the regulation.
In most cases, we will provide you with these copies of your personal information and additional information in writing, unless you request otherwise. If you request this information by electronic means, it will be provided to you electronically if technically possible.
The right to rectification of personal data (Art. 16 of the regulation)
We take reasonable steps to ensure the accuracy, completeness and timeliness of the information we hold about you. However, this right allows you to ask us to correct your incorrect personal data without undue delay or to complete your personal data if it is inaccurate, incomplete or out of date. Please note that you are only required to provide us with personal data that is complete and correct, and you are responsible for the falsity of the personal data you have provided to us.
Right to withdraw consent
If we process your personal data also on the basis of consent, you have the right to withdraw this consent to the processing of personal data at any time. The withdrawal of consent does not affect the lawfulness of the processing of personal data based on consent before its withdrawal, however, it prevents us from further processing your data for the purposes for which we needed your consent to the processing of personal data. You can withdraw your consent in the same way as you did or by notifying us of your withdrawal at any of our contacts.
Right to erasure of personal data (right to "be forgotten") (art. 17 of the regulation)
You have the right to request that we delete your personal data without undue delay after exercising this right if one of the following reasons is met: :
you have withdrawn the consent on which we processed your personal data and there is no other legal basis for the processing of your personal data (e.g. compliance with our legal obligations),
you have objected to the processing of your personal data on the basis of a legitimate interest and there are no overriding legitimate grounds for the processing,
the personal data are no longer necessary for the purposes for which they were collected or processed.,
the personal data have been processed unlawfully; or
the personal data must be erased for compliance with a legal obligation.
However, we cannot comply with your request for deletion of data under applicable rules if we still need the personal data to fulfil our legal obligations or if further processing is necessary for the establishment, exercise or defence of legal claims.
Right to restriction of processing of personal data 18 of the regulation)
You have the right to request that we restrict the processing of your personal data if:
at the same time, you contest the accuracy of the personal data (for a period enabling us to verify the accuracy of the personal data) or the processing is unlawful and you do not request their deletion, or we no longer need them, but you need them to assert your claims, or you have objected to the processing on the basis of legitimate interest, until it is verified that the legitimate reasons on our part outweigh the legitimate reasons on your part.
The data subject shall have the right granted by the European legislator to object at any time to processing of personal data concerning him or her for such purposes as may be necessary for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or of a member state. If we restrict the processing of your data and later the reasons for which the processing has been restricted no longer apply, we will inform you before the restriction of processing is lifted.
Right to data portability 20 of the regulation)
You have the right to obtain from us your personal data that you have previously provided to us in a structured, commonly used and machine-readable format and you have the right to request that we transfer your personal data to another controller subject to legal conditions; the exercise of this right is without prejudice to your right to delete personal data. However, the right to portability applies only to personal data that we have obtained from you on the basis of your consent or on the basis of a contract to which you are a party.
The right to object to the processing of personal data 21 of the regulation)
If the processing of your personal data is based on our legitimate legitimate interest or the processing of your personal data is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, you have the right to object to the processing of your personal data. In this case, if you object and we do not demonstrate compelling legitimate grounds for the processing of your personal data, or if you object to the processing of your personal data for the purposes for which your personal data are processed, we will no longer process your personal data for these purposes.
The right to the ineffectiveness of automated individual decision-making, including profiling (art. 22 of the regulation) when processing your personal data by us, there is no automated decision-making or profiling.
The right to file a petition for the initiation of proceedings on the protection of personal data (§100 of the Act; art. 77 and 79 of the regulation)
If you believe that the processing of your personal data is contrary to the law or regulation, you have the right to submit to the Office for personal data protection of the Slovak Republic, with its Registered office at Hraničná 12, 820 07 Bratislava, Slovak Republic, ID No: 36 064 220 (hereinafter referred to as the "office") or to another competent authority, in particular in the member state of your habitual residence, place of work or place of alleged violation, a proposal to initiate proceedings on the protection of personal data.
The application to initiate proceedings (hereinafter referred to as the "application") must contain the name, surname, mailing address and signature of the applicant, an indication of the person against whom the application is directed, indicating the name, surname, permanent residence or name, registered office and identification number, if assigned, the subject of the application indicating the rights that should have been violated during the processing of personal data, evidence to support the claims made in the application, a copy of the document or other evidence proving the exercise of the right under Part Two of the second title of the Act or regulation, if the data subject has exercised such a right, or an indication of the reasons worthy of special consideration for the non-exercise of the right in question, if the application is made by the data subject.
A sample of the application to initiate proceedings before the Office is published on the Office's website (
https://dataprotection.gov.sk/).
Without prejudice to your right to seek the protection of your rights on the basis of an application to initiate proceedings before the office, you also have the right to seek your rights in the materially and locally competent court of the Slovak Republic if you believe that as a result of the processing of your personal data in violation of the regulation, your rights under the regulation have been violated.
In case you need any part of the text to explain, advise or discuss further processing of your personal data, you can contact us at any time at the e-mail address: info@emd.sk
This document shall enter into force: 03.04.2023