KOUD foundation, o. z., with its registered office at Zochova 754/6-8, 811 03 Bratislava – Staré Mesto, Slovak Republic, ID No.: 51901277 (the “KOUD” or the “Data controller”) hereby provides information about the manner and scope of personal data processing including the rights relating to personal data processing.
Privacy and data security are KOUD’s priority. Personal data processing is regarded as strictly confidential and personal data are treated in accordance with data protection laws in force and effect, in particular the General Data Protection Regulation EU 2016/679.
KOUD as a data controller collects, stores and uses (and otherwise processes) personal data relating in particular to the following data subjects:
(hereinafter jointly referred to as the “Data Subject”).
The respective purposes for which personal data is processed are defined more precisely below.
KOUD is authorised to process personal data for the following purposes:
KOUD may process the following personal data for the following purposes:
|Data subject’s personal data||Purposes of processing:|
|E-mail address||Performance of a contract and the provision of our services; Data controller’s legitimate interest; Sending commercial communications and approaching the User with other commercial offers|
|Identification and contact details (in particular name, surname; address; phone no.)||Performance of a contract and the provision of our services; Legal compliance; Data controller’s legitimate interest; Protection of the vital interests of the User or of another natural person; Sending commercial communications and approaching the User with other commercial offers|
|Information contained in your Facebook / Google account (in accordance with Facebook / Google privacy settings), such as your interests, gender, nationality, birthday, education, current city of residence, photographs and videos, personal description, a list of friends and information and photos of your friends who can be friends on Facebook with other KOUD users||Performance of a contract and the provision of our services; Data controller’s legitimate interest|
|Details on the User’s cryptocurrency wallet, including Ethereum address, other blockchain address||Performance of a contract and the provision of our services; Data controller’s legitimate interest|
|Geolocation data||Performance of a contract and the provision of our services; Data controller’s legitimate interest|
|Device and application information, such as the device name, device identification code (IMEI, ESN, MEID, and SN), device activation time, hardware model, OS version, application version, software identification code, and device and application settings (such as region, language, time zone, and font size)||Performance of a contract and the provision of our services; Data controller’s legitimate interest|
|Mobile network information, such as the public land mobile network (PLMN) provider ID and Internet Protocol (IP) address||Performance of a contract and the provision of our services; Data controller’s legitimate interest|
KOUD is authorised to process an e-mail address pursuant to Section 62 (3) of Act no. 351/2011 Coll., on Electronic Communications and on amendments to certain laws, for the purposes of distributing commercial communications concerning products or services of third parties and/or its own products or services, if the User initially did not refuse such distribution.
We will collect, use, and process the approximate or precise location of your device upon your consent. Geolocation data can be obtained based on the GPS, WLAN, and service provider network ID. You are free to choose if you want to enable gathering of geolocation data. Please note that simply by installation of the applications on your devices, geolocation data are not gathered from you. Geolocation data are gathered solely on your decision to enable collection of geolocation data in the settings menu of the installed application. In the same settings menu of the installed application, you can disable the location permissions to reject sharing your geolocation data.
We do not intend to process special categories of data, such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or a natural person’s sex life or sexual orientation, unless the individual has given explicit consent to the processing of such data.
KOUD processes personal data both manually and by automated means. The processing of personal data by automated means takes place in particular for the purposes of performance of a contract and the provision of our services and for KOUD’s legitimate interest. The processing of personal data by automated means also occurs when your consent to the processing of personal data for personalized marketing communications has been granted by you; in these cases, profiling may also occur.
Personal data is disclosed only to KOUD’s authorised employees, the respective KOUD’s data processors engaged by KOUD under relevant contracts, or to other controllers as applicable, but in any case within the scope necessary to achieve the purposes of the processing and on the basis of the relevant legal title for the processing of the personal data.
The categories of KOUD’s personal data recipients are as follows:
KOUD will process and retain your personal data for a period of time necessary to safeguard all the rights and obligations resulting from the relevant contract, and thereafter for a period for which KOUD, as data controller, is required to retain personal data under applicable laws, or for which you have granted to KOUD your consent with such processing. In other cases, the period of processing is based on, and must be proportionate to, the purpose of the processing, or is stipulated by applicable data protection laws.
We process personal data, based on the purpose of their processing, for the periods specified below:
|Purpose of processing||Retention period|
|Performance of a contract and the provision of our services||For the period of 1 year from the moment of uninstalling or deletion of the Application or, as applicable, for as long as KOUD has claims against the User of the Application|
|Legal compliance||For the period stipulated by applicable legal regulation|
|Data controller’s legitimate interest||For the period of 1 year from the moment of uninstalling or deletion of the Application or, as applicable, for as long as KOUD has claims against the User of the Application|
|Protection of the vital interests of the User or of another natural person||For the period of 1 year from the moment of uninstalling or deletion of the Application|
|Sending commercial communications and approaching the User with other commercial offers||For as long as consent is granted to sending of commercial communications or, as applicable, until withdrawal of the consent for the processing or, as applicable, in accordance with applicable legislation or, as applicable, from the moment of uninstalling or deletion of the Application|
The following is processed based on consent
The Data Subject acknowledges that the consent is granted voluntarily and that it can be withdrawn in writing at any time via e-mail at [•].
The consent to receive commercial communication is given until its withdrawal.
The consent to process geolocation data is given until the moment of uninstalling or deletion of the Application or until its withdrawal.
The refusal to give consent by the User has no impact on the possibility to enter into the Agreement.
The services are not intended or directed at individuals under the age of 18. We do not knowingly collect personal information from individuals under 18 (the “Age Limit”). If you are under the Age Limit, please do not use the services and do not provide any personal information to us.
You, as a data subject, have rights in connection with the processing of personal data, which result from applicable laws and which you may exercise at any time. These involve the right (i) of access to personal data, (ii) to rectification of inaccurate personal data and to have incomplete personal data completed, (iii) to erasure of personal data where the personal data is no longer necessary in relation to the purposes for which they are collected or otherwise processed or if personal data is found to have been unlawfully processed, (iv) to restriction of processing, (v) to data portability, (vi) to object, after which the personal data processing will be terminated unless there are demonstrated compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, namely where the grounds lie in the enforcement of legal claims, and (vii) the right to refer to the Office for Personal Data Protection (www.uoou.sk).
In the event of recurring or manifestly unfounded requests to enforce the above rights, KOUD will be entitled to charge a reasonable fee for the enforcement of the right or will refuse to act on it. You will be notified accordingly.
Further information in relation to the personal data processing will be provided at [•]. A Data Subject asserting his/her rights may send his/her request in writing via e-mail at [•]. KOUD reserves its right to adequately verify the identity of the data subject asserting the above rights.
Last updated: 2018