Privacy Policy

1. BASIC INFORMATION, PURPOSE OF PERSONAL DATA PROCESSING AND DEFINITIONS

The purpose of this personal data protection policy of NVZ s. r. o., with its registered office at Palárikova 2311/6, 052 01 Spišská Nová Ves, Company ID (IČO): 57013659, registered in the Commercial Register of the Municipal Court Košice, Insert No. 62596/V, Section: Sro (hereinafter the "Policy"), is to provide Clients, cooperating real estate brokers, job applicants and employees, and, where applicable, other data subjects with information about:

what personal data NVZ s. r. o. processes about Clients – natural persons – in the provision of services of brokering the sale or purchase of real estate, real estate rental, real estate management and other services, in the brokering of other real-estate-related services and in contact with potential Clients, about job applicants, about Cooperating real estate brokers and about other data subjects;
the purpose of the processing of personal data;
how long personal data are processed; and
what rights the persons whose personal data are processed (hereinafter the "Data Subjects") have in connection with the processing of their personal data.

This Policy applies to the processing of personal data of Clients and, correspondingly, of their representatives or contact persons, potential Clients and persons interested in the services of NVZ s. r. o., Cooperating real estate brokers, job applicants and other Data Subjects, in each case to the extent of the personal data corresponding to their relationship with NVZ s. r. o.

A Client means a natural or legal person who has expressed an interest in carrying out a business transaction through NVZ s. r. o., e.g. the purchase or rental of real estate. As a rule, these are persons who request more information about real estate, transaction conditions and the services of NVZ s. r. o. They are also persons who ask NVZ s. r. o. to broker negotiations with a future contractual counterparty or request that NVZ s. r. o. negotiate with the counterparty directly, acting on behalf of the Client.

A Cooperating real estate broker is a natural or legal person who regularly or occasionally procures Clients for NVZ s. r. o. – persons interested in the purchase or rental of real estate – under the conditions agreed in the contractual relationship between NVZ s. r. o. and the Cooperating real estate broker.

A Job applicant is a natural person who is interested in performing dependent work for NVZ s. r. o. under labour-law regulations in a vacant position and who has provided the company with personal data for the purpose of assessing their suitability for the vacant position. An Employee is a natural person who performs dependent work for NVZ s. r. o. on the basis of an employment relationship.

A Business partner means a natural or legal person who has expressed an interest in carrying out a business transaction through NVZ s. r. o., e.g. the sale or rental of real estate. As a rule, these are persons who offer real estate for sale or rental through NVZ s. r. o. for the purpose of concluding contractual relationships with third parties interested in the purchase or rental of real estate (e.g. Clients).

2. WHO PROCESSES PERSONAL DATA

The controller is NVZ s. r. o., with its registered office at Palárikova 2311/6, 052 01 Spišská Nová Ves, Company ID (IČO): 57013659, registered in the Commercial Register of the Municipal Court Košice, Insert No. 62596/V, Section: Sro (hereinafter the "Controller").

3. LEGAL FRAMEWORK OF PERSONAL DATA PROCESSING

The Controller processes personal data on the basis of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of personal data (hereinafter the "GDPR"), zákon č. 18/2018 Z. z. (the Slovak Act on Personal Data Protection) and other related legal regulations.

4. METHOD OF PROCESSING AND SCOPE OF THE DATA PROCESSED

Personal data are processed fairly, lawfully and in a transparent manner. Personal data are collected for specified, explicit and legitimate purposes.

The Controller obtains personal data through the contact form on the website https://www.nehnutelnostivzahranici.sk or other websites, through applications, through any electronic or telephone contact, personal meetings, through the Controller's Cooperating real estate brokers, and in other ways. In most cases, personal data are provided by the Data Subject themselves when contacting the Controller via websites and applications, by e-mail, by telephone, in person or in other ways, or they are provided by cooperating entities – real estate brokers.

The Controller processes personal data:

on the legal basis under Art. 6(1)(b) GDPR – processing is necessary for the performance of a contract to which the Client, the Cooperating real estate broker, the Business partner or the Employee is a party, or in order to take steps at the request of the Data Subjects prior to entering into a contract. The purpose of processing personal data on this legal basis is the conclusion of a contractual relationship and related acts, such as communication with the Client, the Cooperating real estate broker or the Business representative regarding the services and real estate offered, etc. The data are provided to the Controller by the Client or by the Cooperating real estate broker. If the Client did not provide personal data, no contract could be concluded with them, no negotiations aimed at its conclusion could take place, and the service the Client requested could not be provided (hereinafter "Performance of a Contract");

on the legal basis under Art. 6(1)(c) GDPR – processing is necessary for compliance with a legal obligation of the Controller, such as the performance of statutory obligations arising in particular from the following Slovak acts:

Zákon č. 18/2018 Z. z. – Slovak Act on Personal Data Protection and on amendments to certain acts;

Zákon č. 222/2004 Z. z. – Slovak Act on Value Added Tax;

Zákon č. 595/2003 Z. z. – Slovak Act on Income Tax;

Zákon č. 563/2009 Z. z. – Slovak Act on Tax Administration (Tax Code) and on amendments to certain acts;

Zákon č. 431/2001 Z. z. – Slovak Act on Accounting;

Zákon č. 297/2008 Z. z. – Slovak Act on the Prevention of Money Laundering and Terrorist Financing and on amendments to certain acts;

Zákon č. 311/2001 Z. z. – Slovak Labour Code;

Zákon č. 5/2004 Z. z. – Slovak Act on Employment Services and on amendments to certain acts;

Zákon č. 580/2004 Z. z. – Slovak Act on Health Insurance and on amendments to Act No. 95/2002 Z. z. on Insurance and on amendments to certain acts;

Zákon č. 395/2002 Z. z. – Slovak Act on Archives and Registries and on amendments to certain acts;

Zákon č. 40/1964 Z. z. – Civil Code;

Zákon č. 160/2015 Z. z. – Code of Civil Contentious Procedure;

Zákon č. 161/2015 Z. z. – Code of Civil Non-Contentious Procedure;

Zákon č. 513/1991 Z. z. – Commercial Code;

Zákon č. 301/2005 Z. z. – Code of Criminal Procedure;

and other legal regulations imposing obligations on the Controller.

The purpose of processing personal data on this legal basis is compliance with the Controller's statutory obligations. The data are provided by the Client or by the Cooperating real estate brokers. If the Client did not provide personal data, no contract could be concluded with them, no negotiations aimed at its conclusion could take place, and the service the Client requested could not be provided (hereinafter "Legal Obligation");

on the legal basis under Art. 6(1)(f) GDPR – processing is necessary for the purposes of the legitimate interests of the Controller. The Controller's legitimate interest is establishing, exercising and defending legal claims, i.e. situations where the Controller has legal claims against Data Subjects arising from non-performance of a contract, occurrence of damage, etc., in which case the Controller processes personal data for the purpose of enforcing and defending its legal claims. A legitimate interest is also the Controller's response to enquiries from potential Clients who have decided to contact the Controller via the websites or in another manner mentioned above (hereinafter "Legitimate Interest").

More detailed information on the processing of personal data is set out in the tables below:

Table: Purpose and legal basis of processing

|---|---|---|---|---|

| 1. | Contact for the purpose of requesting the Controller's services / preparation for concluding contracts with Clients | Depending on the type of services requested, this may include academic title, first name, surname, phone number, e-mail, residence, permanent residence | for the purpose of contacting the Client back and concluding contracts with the Client – pre-contractual relations | Performance of a Contract |

| 2. | Concluding contracts with the Client and implementing brokerage contractual relationships with the Client and the Business partner, concluding contracts with Real estate brokers, concluding contractual relationships with Business partners and performing contractual relationships | Clients: title, first name, surname, phone number, e-mail, residence, permanent residence, birth surname, date of birth, personal identification number, phone number, e-mail, payment details, permanent residence and residence, ID card and/or passport number and their period of validity, making a copy or scan of the ID card and/or passport, and signature; Brokers: title, first name, surname, address, personal identification number, phone number, e-mail, bank details and signature; Business partner: title, first name, surname, address, phone number, e-mail, bank details and signature. | concluding contracts and implementing brokerage contractual relationships with Clients of the real estate agency (exclusive contract, sale, purchase, rental of real estate); completion of the Client's business transaction; conclusion and registration of contracts with cooperating brokers | Performance of a Contract |

| 3. | Correspondence | title, first name, surname, address, data on business partners, e-mail, phone number, contact person, etc. | sending and receiving postal and electronic documentation | Legitimate Interest, Performance of a Contract, Legal Obligation |

| 4. | Complaint proceedings | title, first name, surname, permanent residence address, delivery address, complaint, description of the complaint, date and time of filing, signature | handling complaints and claims in connection with the services provided by the Controller | Performance of a Contract, Legal Obligation |

| 5. | Accounting | data on business partners, billing data, delivery address, first name, surname, title, bank details, information on the goods or service provided | processing the accounting agenda under special accounting regulations | Legal Obligation |

| 6. | HR and payroll | title, first name, surname, personal identification number, address, bank details, information concerning education, etc. | processing of personal data in connection with the selection procedure for job applicants; payment of wages/remuneration; contributions and other statutory obligations arising from the Labour Code, the Health Insurance Act and other legal regulations governing the Controller's obligations | Legal Obligation, Performance of a Contract |

| 8. | AML agenda | data and documents obtained for the purpose of fulfilling a statutory obligation | protection against money laundering and terrorist financing – performance of statutory obligations. Processing of personal data in connection with the Act on the Prevention of Money Laundering and Terrorist Financing and on amendments to certain acts | Legal Obligation |

Retention period and recipients of personal data for the individual activities:

| No. | Retention period | Recipients of personal data |

|---|---|---|

| 1. | for the period of concluding the contract, at most one month from the contact | recipients of personal data may include: a law firm |

| 2. | for the duration of the contract and subsequently for 10 years | recipients of personal data may include: a law firm; the Business partner, if the Client asks the Controller to communicate with the Business partner on their behalf; and, in the case of the Client's personal data, also cooperating brokers |

| 3. | for 2 years | recipients of personal data may include: the Tax Office, pension insurance institution, Enforcement Office, Slovak Post, the Social Insurance Agency, courts of the Slovak Republic, health insurance company, District Office – cadastral department, a law firm |

| 4. | for 5 years from the settlement of the complaint | recipients of personal data may include: the Police Force of the Slovak Republic, the Prosecutor's Office of the Slovak Republic, Slovak Post, courts of the Slovak Republic, the Slovak Trade Inspection |

| 5. | the current year and subsequently for 10 years | recipients of personal data may include: the Tax Office, the Police Force of the Slovak Republic, the Prosecutor's Office of the Slovak Republic, courts of the Slovak Republic, the provider of accounting services |

| 6. | in the case of job applicants, for two years from the date of receipt for the purpose of possible future contact or until an employment relationship is concluded; in the case of employees, for the duration of the employment relationship and for the period of fulfilling statutory obligations related to the employment relationship for the individual documents of the HR and payroll agenda | recipients of personal data may include: health insurance company, the Social Insurance Agency, pension insurance institution, the Tax Office, Slovak Post, courts of the Slovak Republic, Enforcement Office, a law firm and other state administration bodies where special regulations so provide |

| 7. | for 10 years, unless a special regulation provides otherwise | recipients of personal data may include: the Tax Office, pension insurance institution, Enforcement Office, the Police Force of the Slovak Republic, the Prosecutor's Office, the Social Insurance Agency, courts of the Slovak Republic, health insurance company, the Statistical Office and other state administration bodies |

| 8. | pursuant to the law, for the period during which the natural person has the status of ultimate beneficial owner and for a further five years after the termination of that status or the dissolution of the legal person | recipients of personal data may include: the Financial Intelligence Unit, the Police Force of the Slovak Republic, the Prosecutor's Office, courts of the Slovak Republic |

| 9. | for the duration of court proceedings or out-of-court settlement, but no longer than until the claim in question is extinguished by limitation or preclusion | recipients of personal data may include: a law firm, the Police Force of the Slovak Republic, the Prosecutor's Office, courts of the Slovak Republic, Slovak Post, other state administration bodies |

4. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

The Controller does not carry out cross-border transfers of personal data to third countries outside the European Economic Area (EU, Iceland, Norway and Liechtenstein) unless this is necessary for the performance of the services provided or unless the Client expressly requests it. This is the case where the Client asks the Controller to communicate with the Business partner on the Client's behalf for the purpose of concluding a contractual relationship between the Client and the Business partner regarding the purchase, sale or rental of real estate abroad. In such a case, the Controller provides the Client's personal data to the foreign Business partner or to Cooperating real estate brokers abroad to the extent necessary for the conclusion and implementation of the requested contractual relationships (purchase contract, lease contract between the Client and the Business partner), all on the basis of the Client's authorisation and on the Client's behalf.

5. RIGHTS OF DATA SUBJECTS

Right of access

The Data Subject has the right to request information on whether personal data are being processed, to what extent, how their personal data are processed and for how long. If the Controller processes personal data, the Data Subject has the right of access to those personal data or to a copy of the personal data processed. Copies of personal data are subject to a fee.

Right to rectification

The Data Subject has the right to rectification, which consists in the correction of inaccurate personal data or the completion of incomplete personal data by the Controller.

Right to erasure

The Data Subject has the right to erasure where the Controller processes personal data unlawfully (without reason or for longer than necessary).

Right to restriction

The Data Subject has the right to restriction of processing from the moment they requested the rectification of personal data or objected to the processing, until we are able to investigate the issue or confirm the accuracy of the personal data (or change them according to your instructions). The Data Subject also has the right to restriction where the processing is unlawful and they do not exercise the right to erasure.

Right to object

The Data Subject has the right to object to the processing of personal data if they believe that the Controller is not entitled to process the personal data. The Controller may always process personal data where this is necessary for the establishment, exercise or defence of legal claims.

Right to data portability

The Data Subject has the right to have the personal data they provided to the Controller on the basis of consent or Performance of a Contract provided in a structured, commonly used and machine-readable format. The Data Subject also has the right to request the transfer of this information to another data controller.

Withdrawal of consent

The Data Subject has the right to withdraw consent to the processing of their personal data where the personal data are processed on the legal basis of the Data Subject's consent.

Right to lodge a complaint

The Data Subject has the right to lodge a complaint pursuant to § 100 of the Slovak Personal Data Protection Act (zákon č. 18/2018 Z. z.) with the competent supervisory authority.

6. CONTACT DETAILS

Questions regarding the processing of personal data may be raised, and rights may be exercised, with the Controller by sending a letter to the address of the Controller's registered office or by sending an e-mail to the Controller's e-mail address: nehnutelnostivzahranici@gmail.com.

7. CHANGES TO THESE PERSONAL DATA PROTECTION TERMS

Personal data protection is not a one-off matter. The information which the Controller is obliged to provide with regard to its processing of personal data may change or cease to be up to date. For this reason, the Controller reserves the right to amend and change these personal data protection terms at any time and to any extent. If these terms are changed in a substantial way, the Controller will bring the change to attention by a notice on its website or by notifying the Data Subjects by e-mail.

This translation is provided for information only; the legally binding version is the Slovak original.