SETHMARA LIFE (PVT) LTD 

No 19, 1st Floor, City View Shopping Complex, Talbotte Town, Galle 80000 
TIN: PV00238951 

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as the information system operator, publishes this personal data protection statement under the title in order to maintain fairness and transparency towards the data subjects 

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PRIVACY POLICY 

 

pursuant to Article 13 and the relevant recitals of 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 (hereinafter referred to as the "Regulation") and Act of the National Council of the Slovak Republic No. 18/2018 Coll. on the protection of personal data and on the amendment and supplementation of certain acts (hereinafter referred to as the "Act on the Protection of Personal Data"). 

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The purposes of processing personal data are the reasons for which the personal data of the data subjects (employees, clients) are processed in our information systems on precisely defined legal grounds. The purposes are specifically defined, explicitly stated and legitimate, and when processing the personal data of the data subjects, we comply with the principle of lawfulness pursuant to Articles 6 and 9 of the Regulation (individual purposes and legal grounds are listed in the annex to this Privacy Policy). 

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Data subjects whose personal data are processed in our information systems for specifically defined purposes may exercise the following rights in writing or electronically: 
 

1. Right of access to personal data – this is the right to obtain confirmation as to whether your personal data are being processed, as well as the right to obtain access to these data, in terms of the purposes and duration of the processing, the categories of personal data concerned, the recipients, the procedure for any automated processing, and the consequences of such processing. 
   As a controller, we have the right to use all reasonable measures to verify the identity of the data subject requesting access to the data, in particular in relation to online services and identifiers (Article 15, recitals 63, 64 of the Regulation). 
    

2. The right to have inaccurate personal data rectified and incomplete personal data completed (Article 16, Recital 65 of the Regulation). 
    

3. Right to erasure – “forgetting” personal data that are no longer necessary for the purposes for which they were collected and processed; upon withdrawal of consent on the basis of which the processing is carried out; upon unlawful processing; if personal data were collected in connection with an information society offer (in the case of children), provided that the conditions set out in Article 17, recitals 65, 66 of the Regulation are met. 
    

4. The right to restriction of processing can be exercised if the data subject contests the accuracy of personal data and other requirements pursuant to Article 18, Recital 67 of the Regulation, in the form of temporary transfer of selected personal data to another processing system, prevention of users' access to selected personal data or temporary removal of processing. 
    

5. The right to data portability is the right to have the personal data you have provided to our information systems, based on your consent or the performance of a contract, transferred to another controller in a structured, commonly used and machine-readable format, if technically feasible and subject to the conditions of Article 20 Recital 68 of the Regulation, if the processing is carried out by automated means. The exercise of this right is without prejudice to Article 17 of the Regulation. The right to data portability does not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us as the controller. 
    

6. Without prejudice to any other administrative or judicial remedies, you as a data subject have the right to file a complaint with the Personal Data Protection Office of the Slovak Republic pursuant to Article 77 of the Regulation if you believe that the processing of personal data concerning you is in breach of the Regulation or the Personal Data Protection Act. 

 

As a data subject, you also have the right to object at any time, on grounds relating to your particular situation, to processing of your personal data which is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us as the controller, and also where processing is necessary for the purposes of the legitimate interests pursued by us as the controller or by a third party (except for processing carried out by public authorities in the performance of their tasks), except where such interests are overridden by your interests or fundamental rights and freedoms as the data subject which require protection of personal data (in particular where the data subject is a child). 

 

If personal data are processed for direct marketing purposes, you as the data subject have the right to object at any time to the processing of your personal data for the purposes of such direct marketing, including profiling to the extent it is related to such direct marketing. 

  

SETHMARA LIFE (PVT) LTD 

has taken, as the operator of the information system, all appropriate personnel, organizational and technical measures for the purpose of maximum protection of your personal data in order to reduce the risk of their misuse, leakage, etc. to the greatest extent possible. In accordance with our obligation arising from Article 34 of the Regulation, we inform you as data subjects that if a situation arises where we, as the operator, violate the protection of your personal data in a way that is likely to lead to a high risk of violation of the rights and freedoms of natural persons, we will notify you of this fact without undue delay. 

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NOTE: In order to comply with the principle of minimization, all personal data provided by you is only a necessary legal or contractual requirement to fulfill the purpose of their processing. Failure to provide mandatory data necessary for the conclusion of a contract may result in the non-conclusion of the contractual relationship. 

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If your personal data are processed on the basis of consent pursuant to Article 6(1)(a) of the Regulation and the Act on the Protection of Personal Data, as the data subject, you also have the right to withdraw your consent to the processing of personal data at any time, including before the expiry of the period for which this consent was granted, by sending an email request to info@sethmara.com. 

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Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. 

 

In case of any questions related to the protection of your personal data, including the exercise of your rights under the Regulation and the Act on the Protection of Personal Data, please contact us at our email address info@sethmara.com. 

  

Appendix to the Privacy Policy 

Data on individual purposes of processing personal data 

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1. MARKETING 

   1. Purpose of processing personal data: The purpose of processing personal data of natural persons is to process data when providing information related to the operator's offer of goods and services, including sending information about preferential offers, products and other activities, as well as sending commercial communications via electronic means - in the form of postal/email/or telephone contact to the contact details provided by the data subject. 

   2. Name of the information system: IS Marketing. 

   3. Legal basis: Consent of the data subject pursuant to Article 6(1)(a) of the Regulation and the Act on the Protection of Personal Data, with the data subject having the right to withdraw his or her consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. 

   4. Beneficiary categories: None. 

   5. Deadlines for erasing personal data: 3 years from the end of the year in which consent was granted. 
       

2. CUSTOMER REGISTER 

   1. Purpose of processing personal data: Within the information system in question, the personal data of a natural person as one of the contracting parties is processed. The personal data of the data subjects are processed and an agenda is maintained based directly on the preparation and management of contractual relations (Contract for the sale of a motor vehicle) concluded between the contracting parties: the operator (seller) and the data subject (buyer), for the purpose of delivering the vehicle to the buyer and transferring ownership rights to the buyer based on the payment of the purchase price by the buyer under the conditions set out in the contract - i.e. for the purpose of fulfilling the purchase contract and for the purpose of recording and exercising rights and obligations under these terms and conditions. 

   2. Name of the information system: IS Customer Records. 

   3. Legal basis: Performance of the contract pursuant to Article 6(1)(b) of the Regulation. Constitution of the Slovak Republic No. 460/1992 Coll., Act No. 513/1991 Coll. Commercial Code, as amended, Act No. 40/1964 Coll. Civil Code, as amended, and a contractual relationship concluded pursuant to the aforementioned legal regulations. 

   4. Categories of beneficiaries: state administration bodies, public authorities and public administration bodies according to relevant legal regulations. 

   5. We process: first name, last name, email addresses, and phone numbers of clients. 

   6. Unsubscription: to unsubscribe, you can use the email: info@sethmara.com 

   7. Periods for archiving personal data: 10 years. 

   8. Information on the existence of automated decision-making, including profiling: Not carried out. 

   9. Categories of data subjects: contracting party – natural person.
       

3. PHOTOS AND VIDEOS FROM PUBLIC EVENTS 

   1. Purpose of processing personal data: Processing of personal data for the purpose of promoting the operator, in particular by publishing photos and videos with the intention of building its reputation, promoting the operator on its website, in internal premises, on social networks, or on the intranet. 

   2. Name of the information system: IS Photos and videos from public events. 

   3. Legal basis: Legitimate interest within the meaning of Article 6(1)(f) of the Regulation. The main legitimate interest is the promotion of the operator. 

   4. Beneficiary categories: None. 

   5. Cross-border transfer of personal data: Does not take place. 

   6. Periods for archiving personal data: 2 years after the purpose of processing has been fulfilled. 

   7. Information on the existence of automated decision-making, including profiling: Not carried out. 

   8. Categories of data subjects: participants in public events. 
       

4. DIRECT MARKETING 

   1. Purpose of processing personal data: The purpose of processing personal data of natural persons is to process data when providing information related to the operator's offer of similar goods and services, including sending information about preferential offers, products and other activities of the operator via electronic means - in the form of postal/email/or telephone contact. Within the framework of direct marketing, there is a relevant and appropriate relationship between the operator and the data subject, i.e. that the data subject is in the position of a client or in his services towards the operator. 

   2. Name of the information system: IS Direct Marketing. 

   3. Legal basis: Legitimate interest within the meaning of Article 6(1)(f) of the Regulation. The main legitimate interest is the sending of information within the framework of direct marketing, when there is a relevant and appropriate relationship between the data subject and the operator, i.e. the data subject is in the position of a client or in his services towards the operator. 

   4. Beneficiary categories: None. 

   5. Deadlines for deleting personal data: after the end of the contractual relationship. 

   6. Information on the existence of automated decision-making, including profiling: Not carried out. 

   7. Categories of data subjects: natural person - customer. 
       

5.  NON-NECESSARY COOKIES 

   1. Purpose of processing personal data: The purpose of processing personal data is the processing of personal data of natural persons - visitors to the operator's website for the purpose of technical storage of data or access to them, for the purpose of transmitting or facilitating the transmission of a message via a network, or if this is strictly necessary for the operator as a provider of information society services to provide an information society service that is explicitly requested by the data subject as a user. This is to adapt the operation of our website to your needs. 

   2. Name of the information system: IS Necessary cookies. 

   3. Legal basis: Fulfillment of the legal obligation of the controller pursuant to Article 6(1)(c) of the Regulation. Act 351/2011 on electronic communications §55(5). 

   4. Beneficiary categories: None. 

   5. Deadlines for deleting personal data: After you have finished browsing the website. 

   6. Information on the existence of automated decision-making, including profiling: Not carried out. 

   7. Categories of data subjects: data subjects who visited the operator's website. 

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