What is the purpose of this information?
This information about processing and protection of your personal data will explain to you who I am, why and how I process personal data and what your rights are if you are a person affected by such processing and how you may get in touch with me if you need to.
Who am I?
I am Ms Lucia Kleštincová, a Slovak citizen, EU policy maker, career coach, speaker and podcast host. Under relevant data protection legislation, I am also the controller in relation to the personal data processed in accordance with this policy (except where this policy or our agreement with you explains otherwise) and therefore I am responsible for your personal data processing.
My Website includes various information on my engagement in leadership transformation and talent management; my coaching practice, podcast and other projects. Thus, through the Website you may find various information on my activities, you may sign up for my newsletters or submit direct messages to me. Moreover, the Website also includes the information on my paid-for activities like the provision of career coaching services (collectively the “Paid-for Activities”).
My contact and other details can be found at the end of this policy.
When do I process your personal data?
I may process personal data relating to you if:
- you use the Website;
- you are a participant of my Paid-for Activities (the “Participant);
- you are my supplier or business partner;
- you work for the Participant or my supplier or you are a representative, a shareholder, an executive director, a member of advisory board or board of directors or you are in similar position as my Participant or supplier (for simplicity, I use hereafter “person that you work for”);
- you are someone (or you work for someone) to whom I would like to advertise my activities and the Website. In this case, I may have obtained your details directly from you (for example, via the Website, or you may have sent me your email address for the purposes of receiving my newsletter) or from another source.
What personal data do I process?
I may process personal data related to you that I have acquired from you (for example, via the Website), or obtained from elsewhere (for example, from your company). The personal data related to you that I process may include the information set out below.
Your personal data
I may process your personal details, including:
- your name and e-mail address and other contact details;
- who you work for, your function or department;
- in the event that you use the Paid-for Activities, any relevant data needed for the conclusion and the performance of the agreement between you (or person that you work for) and me and relevant payment data. Please note that I require the provision of these data in order to properly provide the Paid-for Activities in accordance with the terms and conditions related to such Paid-for Activities (the “Agreement”) you have concluded with me; in the event of non-provision of this information, I am unable to provide the information and services properly.
Information I gain from our mutual communication
I may process information that I obtain from communicating with you, including:
- information about you that you give me or that results from our mutual communication via telephone, e-mail, or otherwise;
- information you give me or that I obtain when you use my Website or in relation to such use, to obtain or subscribe to my newsletter, to supply me with goods or services, when you inquire about the Paid-for Activities, contact me with your request or when you report a problem, or do any of these things on behalf of the person that you work for;
- information about events to which you or those related to you are invited, and your personal information and preferences to the extent that this information is relevant to organising and managing those events (for example, your dietary requirements).
Please note that I do not provide this information to any third party.
What personal data do I process when you use my Website?
Information that I may automatically obtain from you when you use my website includes:
- specific online identifiers, browser type and version, time zone setting;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
Would you like to receive my newsletter?
You may choose to sign up to my newsletter by providing your email address for subsequent communication. If you subscribe for my newsletter via the Website or via an email, you give me your consent with emailing you with my newsletter.
Your email address will never be shared with any third parties and you will receive only the type of content for which you signed up. You can unsubscribe at any time.
Please note that subscribing to the newsletter is not required to use any part of the Website or the Paid-for Services.
For what purposes do I use your personal data and what are the legal grounds for our processing of your personal data?
I may process your personal data for the following purposes:
To conclude the Agreement and to exercise the rights and fulfilments of the obligations arising from the Agreement under the terms stipulated therein.
- provide access to and operate the Paid-for Activities under the Agreement;
- provide support to you;
- communicate our relationship under the Agreement and respond to your questions or comments.
To manage and administer our relationships and to fulfil our obligations according to applicable legal regulations.
- send you the newsletters and similar information;
- advertise my activities. This may be via direct marketing communications (such as emails). This may include making suggestions and recommendations about my activities that may interest you or the person that you work for.
- administer for internal operations, including troubleshooting, and data analysis, testing, research, statistical and survey purposes
- improve the Website to ensure that content is presented in the most effective manner for you and for your devices.
To maintain the protection and security of the Website.
To prove, enforce or defend our claims, especially in proceedings before public authorities.
The legal basis on which I process your personal data is as follows:
Performance of a contract to which you are a party – on this legal ground I may process data necessary for the provision of the Paid-for Activities and necessary for the exercise of the rights and obligations arising from the Agreement.
Compliance with our legal obligations – on this legal ground, I am for example required to keep certain information related to applicable consumer and accounting laws.
Your prior consent – where it is necessary to obtain your consent to the processing concerned in order for me to be allowed to do it, I will obtain and rely on your consent in relation to the processing concerned (see below for how to withdraw your consent at any time).
The legitimate interest pursued by me as the data controller, provided that this will only be in circumstances in which those legitimate interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data. Please note that when I process your data on a legitimate interest basis, I always carefully assess whether the particular processing does not override your rights and freedoms (see below for how to object to processing at any time).
Who do I share your personal data with?
I respect your privacy and your personal data are safe with me. I do not sell or trade your data with any third parties. Please note that I may only disclose your personal data to service providers that have undertaken the necessary security measures to protect your data. When I share personal information with others, I require them to keep it safe. In this section you may learn more about who I share your personal information with.
I may share your personal data with the following recipients:
- my business partners, suppliers, subcontractors and service providers, for example authorised IT service providers, accounting companies, all to the extent necessary to meet the obligations of these suppliers and service providers in relation to me in the normal course of business;
- other recipients, including:
- my advertising and analytics partners, and
- in some specific situations, auditors, legal advisers and other professional consultants and service providers for the purposes described in this document;
- in relation to information obtained via the Website:
- analytics and search engine providers that may assist me in the improvement and optimisation of the Website.
The recipients to whom personal information is provided is Lucia Klestincova and her IT provider.
Other disclosures I may make
Please be informed that on the basis of the legitimate interest I may disclose your personal data to third parties:
- If I am under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect my rights, property, or safety of IT systems.
- To state authorities, if I have to provide such data under applicable legislation.
Where do I process personal data?
I do not provide your personal data to any third countries, i.e. countries outside of the European Union or the European Economic Area. If I provide your personal data to my service providers situated outside of the European Economic Area (“EEA”), such provision may only be made on the basis of a European Commission decision on the appropriate level of protection of personal data in that third country or on the basis of other appropriate safeguards (see http://ec.europa.eu/justice/dataprotection/internationaltransfers/transfer/index_en.html) in line with Chapter V of the EU Data Protection Directive (so-called GDPR).
How is your data protected?
Protecting your personal information is important to me as the data controller. I have taken security measures to protect your personal data processed in hard copies or/and electronically as well from destruction, loss, alteration, unauthorized provision or access to them.
I take appropriate technical and organisational measures in accordance with the relevant data protection legislation in order to secure my Website as well as other systems used for data processing.
Unfortunately, transferring data across internet is never fully safe. Despite my efforts to do my best to protect your personal data, I cannot guarantee the security of your data transmitted to me and you therefore carry out all data transmission under your sole responsibility. From the moment I receive your data I will take strict steps and security measures in order to prevent any unauthorized access to your data.
Would you like to find out more about our security measures that I have taken to protect your personal data? Please contact me via my contact details stated below.
How long do I process personal data for?
I process your personal data only for so long as it is necessary for the purpose(s) for which it was originally collected, after which it will be deleted or archived except to the extent that it is necessary for me to continue processing it for the purpose of compliance with legal obligations to which I am subject or for another legitimate and lawful purpose.
The maximum period of data processing is as follows:
- personal data processed for the purpose of enforcing the rights and fulfilling the obligations arising from the Agreement (related to the Paid-for Activities) is processed according to the statutory deadlines set out in generally binding legal regulations (typically five to ten years);
- personal data processed on the basis of your consent (for example, your email address for newsletter’s subscription): 5 years (if the consent is not withdrawn earlier);
- personal data processed for the improvement of the Website: 1 year (if not stated otherwise).
After your data has been processed and if there is no legal basis for further processing of your data, it will be removed; this does not apply if further processing is necessary for the fulfilment of our legal obligations or if it is required for any other legitimate and lawful purpose.
What are your rights?
This section explains the rights you have regarding your personal data and which specific terms are set out in Chapter III of the GDPR. If you would like to exercise any of your rights, or receive more information about them, please contact me via the contact details below and I will assist you. Please note that some of the rights may not be applicable to your specific situation, as some of the legal requirements may not be met for the enforcement of such rights.
Regarding your processed personal data, you have the following rights:
- Right of access
- You have the right to gain access to information about the personal data that I process about you. Should you have any questions regarding the processing, or you would like to have more insight about the personal data I process from you, please contact me via the contact details below and I will provide you with further information.
- Right to rectification
- You can request from me to correct information inaccurately stored without undue delay. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
- Right to erasure / right to be forgotten
- You have the right to request from me to permanently delete your personal information. You can make such a request if for example you believe that the personal data are no longer necessary in relation to the purpose for which the personal data were collected or otherwise processed.
- Right to restrict the processing activities
- You have the right to request from me to restrict our processing activities, for example, if you believe I process incorrect personal data about you, for the time being until the correctness of that personal data is verified, or when the processing of your personal data is unlawful.
- Right to data portability
- You have the right to request data that I process about you by automated means based on a contract or a consent in a structured, commonly used and machine-readable format, and you have the right to request that I transmit those data to another controller, if technically feasible.
- Right to lodge a complaint with a supervisory authority
- If you are not satisfied with the method how I process your personal information, you can contact me at any time in order to find a solution for your concern. However, you always have the right to file a formal compliant with the Office for Personal Data Protection of the Slovak Republic (https://dataprotection.gov.sk/uoou/).
How to withdraw your consent to processing?
Where I process your personal data on the basis of your prior consent to that processing, you may withdraw your consent at any time. In which case I shall stop the processing concerned. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
You can withdraw your consent to any relevant processing of personal data:
- By emailing me at firstname.lastname@example.org.
- By writing to me at the address below.
How to exercise your data protection rights?
You can exercise your rights to your personal data here:
- By emailing us at email@example.com.
- By writing to me at the address below.
If you wish to exercise any of your rights as a data subject and from your application it is not possible to verify the identity of the applicant or if I have reasonable doubts as to the identity of the person making the request, I reserve the right to ask for further information necessary to confirm the identity of the person applying the application.
My contact details are:
Email: firstname.lastname@example.org, Phone number: +32 2 296 96 23
Changes to this policy
This policy was last updated on 01.06.2020.