Dear clients,

in this information memorandum, we want to provide detailed information about personal data processing following Act 18/2018 Coll. on personal data protection and amending and supplementing certain Acts.

Regulation (EU) 2016/679 on personal data protection (hereinafter referred to as the "Regulation") constitutes a legal regulation on the protection of natural persons concerning the processing of personal data and on the free movement of such data. It protects the fundamental rights and freedoms of natural persons, especially those concerning the right to personal data protection.

Personal data is any information relating to an identified or identifiable natural person.

Processing of personal data is an operation or a set of operations with personal data or sets of personal data that is carried out by automated or non-automated means such as

acquisition, recording, arrangement, storage, modification, search, browsing, use, transmission, restriction, deletion, and disposal. (Article 4(2) of the Regulation).

Please read the information below regarding the processing of personal data, which we have prepared in the form of questions to make this information memorandum as comprehensible and practical as possible from the point of view of searching for information. In case of any questions or comments regarding your consent to the processing of personal data, do not hesitate to contact us by phone at 0903 234 507 or by email at glombova@gmchem.eu

CONTENTS

Who is the personal data administrator?

What personal data do we process?

What are personal data sources?

What is the purpose of personal data processing?

What is the retention period for personal data?

Who are our business partners?

What are "COOKIES"?

What are the social media contest rules?

Who can access personal data?

What are your rights when processing personal data?

How can you withdraw consent to personal data processing?

WHO IS THE PERSONAL DATA ADMINISTRATOR?

The personal data administrator is the company that determines the purpose and means of personal data processing:

Skeeneffect, s. r. o., Kutlíková 17, Bratislava 852 50. ID 55 473 491

WHAT PERSONAL DATA DO WE PROCESS?

Processing is lawful only if and only to the extent that at least one of the following conditions is met:

The data subject has expressed its consent to personal data processing for one or more specific purposes;

Processing is necessary for the performance of a contract to which the data subject is a party or to take measures before concluding the contract based on the request of the data subject;

Processing is necessary to fulfill a legal obligation;

Processing is necessary for legitimate interests pursued by the operator or a third party, except in cases where such interests are overridden by the interests or fundamental rights and freedoms of the data subject that require personal data protection.

We only process personal data that you have provided to us.

WHAT ARE PERSONAL DATA SOURCES?

We obtain personal data directly from you. You provide these personal data in the client contract, in the order form, or you have provided them on other documents.

Publicly available sources, registers, and records, such as the commercial register may also be the sources of personal data. We can get personal data from third parties being authorized to handle them.

At public events organized by the operator and attended by the data subjects, they can promote the operator by publishing their photos, video recordings, and video-audio recordings on the operator´s website and social networks. Personal data is processed based on a specific need and request.

WHAT IS THE PURPOSE OF PERSONAL DATA PROCESSING?

I process your data for processing and fulfilling your order or request, issuing a tax document, delivering goods or services, and handling complaints.

The seller hereby informs the buyer that personal data processing is permitted following Article 6 par. 1 letter b of the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of natural persons concerning the processing of personal data and on the free movement of such data.

According to Article 6 para. 1 letter b of the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of natural persons concerning the processing of personal data and on the free movement of such data, the seller, as the operator in the process of concluding the purchase contract, will process the buyer's data without its consent as the data subject, since the seller will process the buyer's data in pre-contractual relations with the buyer and the processing of the buyer's data is necessary for the performance of the purchase contract, in which the buyer is one of the contracting parties.

We process the personal data of unregistered customers that you provided in your order to fulfill the purchase contract. The legal basis is the performance of the contract.

We process the personal data of registered customers to register and maintain their electronic accounts and subsequently fulfill the purchase contract. By registering, the customer receives various benefits like an electronic account with the purchase history.

We process e-mail addresses to send e-mail offers of similar goods that you have already purchased from us and that you might be interested in, possibly at a promotional price.

If the customer is not interested in sending the mentioned offers, it is possible to revoke the sending. The automatic unsubscribe is displayed at the bottom of the sent email.

In the case of granting consent for marketing purposes, it includes the following activities:

• Offer of products and services. Based on your consent, we may send you offers electronically, mainly via e-mail messages or messages sent to mobile devices, via the web client zone, in writing, or by telephone.
• An automated personal data processing to adapt the business offer to your needs. 
• Market surveys and customer satisfaction surveys concerning the products and services used.

Consent given for marketing purposes is voluntary but necessary for us to send you product and service offers. Without such consent, we cannot send you offers of products and services. You can withdraw your consent in writing at any time.

When you visit our website, we may collect certain information about you, such as IP address, date and time of access, information about your internet browser, operating system, or language settings. We may also process information about your behavior on our website, i.e. e.g. links you visit or goods you are shown. However, information about your behavior on the website is anonymous to preserve your maximum privacy, and we cannot assign it to a specific user, i.e. a specific person.

If you access our website from a mobile phone or similar device or via one of our mobile applications, we may also process information related to your mobile device (data related to your mobile phone, possible records of application failures, etc.).

The e-mail addresses of customers who have made a purchase may, based on their consent, be forwarded to the company, which subsequently addresses customers with a survey of satisfaction with the purchase.

We determine your satisfaction with the purchase through an e-mail survey as part of the Verified by Customers program, in which our e-shop is involved. We send you emails after each purchase unless you refuse to be sent emails for direct marketing purposes, following § 62 of Act no. 351/2011 Coll. on electronic communications, as amended. We process personal data to send questionnaires within the Verified by Customers program based on our legitimate interest, which consists of ascertaining your satisfaction with your purchase from us. To send questionnaires, evaluate your feedback, and analyze our market position, we use a data intermediary who can access information about purchased goods and your e-mail address for these purposes. When sending e-mail questionnaires, your data is not transferred to any third party for its purposes. You can reject e-mail questionnaires as part of the Verified by Customers program at any time via the link in the e-mail with the questionnaire. In this case, we will not send you the questionnaire any further.

WHAT IS THE RETENTION PERIOD FOR PERSONAL DATA?

You have given your consent to Skeeneffect, s.r.o. for the duration of the contractual relationship and the next ten years following the termination of the contractual relationship or until you withdraw your consent.

If you are not, nor will you become, a client of the company, your consent will be valid for five years following the date it was granted or until you withdraw it.

After the relevant time has passed, your data will be deleted, but only to the extent and for the purposes for which consent is not required according to legal regulations.

Legal basis for personal data processing.

WHO ARE OUR BUSINESS PARTNERS?

To fulfill the contractual obligations concerning the delivery of ordered goods, your contact personal data is transferred, to the necessary extent, to our selected business partners. Our business partners also comply with the principles of personal data protection and we have concluded a mutual contract on personal data processing.

Our business partners are:

ČSAD Invest, s.r.o.

Your data is transferred to countries outside the EU only if you choose to have the goods delivered to a country outside the EU.

In such a case, your data is transferred to the delivery person responsible for delivering the goods, according to your choice.

WHAT ARE “COOKIES”?

Cookies are small text files that support the use of the website, e.g. by making it possible to recognize previous visitors when logging into the user environment, by remembering the visitor's choice when opening a new window, measuring website traffic, or by the way it is used for its user improvement. Our website uses cookies for purposes (measuring the number of visits, the average time spent on the page, and the number of pages viewed). You can prevent cookies from being stored on your device by setting up your web browser. Following § 55 par. 5 of the Electronic Communications Act, your browser settings are considered your consent to the use of cookies on our website.

WHAT ARE THE SOCIAL MEDIA CONTEST RULES?

Any natural person with a delivery address in the territory of the Slovak Republic who is over 18 years old, who is registered on the social network Instagram (https://www.istagram.com) or Facebook (https://www.facebook. com), has an active account for the entire duration of the competition and fulfills the established rules of the competition (hereinafter also referred to as "participant" or "contestant"). The organizer will enter a status with the conditions of competition. Contest winners will be announced via a comment under the contest status. We will contact the winner by message. The winner will be asked to provide their contact information via private message or email so that the Organizer can send them the winnings or conclude an agreement about taking over the winnings with a representative of Skeeneffect, s.r.o. If the winner does not send their contact information, the prize will be forfeited to the Organizer.

By participating in the competition, the contestant voluntarily grants the organizer (the operator within the meaning of the Personal Data Protection Act) consent to the processing of their data provided to the organizer during the duration of the competition, as well as in connection with the possible awarding of prizes, evaluation of the competition and delivery of the winnings. The competitor has the right to request from the operator access to personal data concerning the data subject, the right to correct personal data, the right to delete personal data and the right to limit the processing of personal data, the right to object to the processing of personal data, as well as the right to portability of personal data.

The operator stores the winner's data to the extent and for the time required to deliver the prize. This consent to the processing of personal data is voluntary. Withdrawal of consent during the duration of the competition is effective at the moment of its delivery to the organizer. It results in the exclusion of the contestant from the competition.

WHO CAN ACCESS PERSONAL DATA?

Other entities that process personal data, such as the so-called intermediaries whose task is to provide services to the company, can access your data.

To send email offers and information about new products, we use the services of a company that sends mass emails.

The above does not apply if you have not agreed to send these offers to your e-mail.

For archiving purposes of phone call records, we use the services of a company that performs these activities.

To fulfill contractual relations with our customers concerning the delivery of the ordered service, we use the services of intermediaries /our specialists/ who participate in service delivery on our behalf according to the instructions. Intermediaries can access personal data to the extent necessary for service delivery.

We have concluded a contract with intermediaries on personal data processing, based on which they are also obliged to follow strict principles of personal data protection.

Personal data is not transferred to a third country or international organization.

Let us assure you that our employees and coworkers who will process your data shall be obliged to keep them confidential. This confidentiality shall last even after the end of our mutual contractual relationship.

Your data is safe with us. We have implemented adequate technical and organizational measures to prevent unauthorized access and misuse of your data. The protection of your data is important to us. That's why we not only regularly check their security, but we continuously improve their protection. We try to take such security measures that consider the current state of technology.

WHAT ARE YOUR RIGHTS WHEN PROCESSING PERSONAL DATA?

Proper processing of personal data is important for companies in the Slovak Republic, and their protection is a matter of course. When processing personal data, you can exercise the following rights:

Information on personal data processing

The information mainly includes identification and contact details of the administrator, its representative, and possibly also the responsible person, purposes of processing, categories of personal data concerned, recipient or categories of recipients of personal data, information on the transfer of personal data to third countries, retention period for personal data, authorized administrators, a list of your rights, the possibility to contact the Office for Personal Data Protection, the source of processed personal data, information on whether and how automated decision-making and profiling occur.

Right to access personal data

You have the right to confirmation as to whether or not personal data is being processed. If so, you have access to information about the processing, the categories of personal data concerned, the recipients or categories of recipients, the retention period for personal data, as well as the right to information about your rights, the right to file a complaint with the Office for Personal Data Protection, information on the source of personal data, information on whether automated decision-making and profiling occur, information and guarantees in case of transfer of personal data to a third country or international organization. You have the right to receive copies of processed personal data.

Right to rectification

Do we process your data that is outdated or inaccurate? Have you changed your home address, for example? Please let us know, and we will rectify your data.

Right to erasure (right to be forgotten)

In some cases provided by law, we shall be obliged to delete your data on your instructions. However, each such request is subject to individual evaluation because Skeeneffect s.r.o. has an obligation or a legitimate interest in keeping personal data.

Right to restriction of processing

If you wish your data to be processed exclusively for the most necessary legal purposes or if you wish to block personal data.

The right to data portability

If you wish us to provide your data to another company, we will transfer your data in the appropriate format to the entity you designate unless there are legal or other significant obstacles preventing us from doing so.

The right to object and The right not to be subject to automated individual decision-making, including profiling

If you discover or believe that we are processing personal data in violation of the protection of your private and personal life or violation of legal regulations, do not hesitate to contact us and ask for an explanation or removal of the inappropriate situation.

The right to file a complaint with the Office for Personal Data Protection

With your initiative or complaint regarding personal data processing, you can contact the supervisory authority at any time, which is the Office for Personal Data Protection of the Slovak Republic with its headquarters at Hraničná 12, 820 07 Bratislava 27, email: statny.dozor@pdp.gov.sk, website: www.dataprotection.gov.sk/uoou/

Where can you exercise your rights, and is it charged?

You can exercise individual rights at Skeeneffect, s. r. o., Kutlíková 17, Bratislava 852 50

All information and statements concerning the rights are free of charge.

When can you expect a response from the company?

We will provide you with statements and any information concerning the measures taken as soon as possible, but within one month at the latest. If necessary, and taking into account the complexity and number of requests, we can extend this period to two months. We will inform you about the extension, including the reasons.

HOW CAN YOU WITHDRAW CONSENT TO PERSONAL DATA PROCESSING?

Consent to personal data processing is voluntary. This means that you can revoke it at any time. Do you not want to continue receiving product and service offers from our business partners? We are sorry, but we fully respect your decision.

What should the withdrawal of consent contain?

• The person who submits the withdrawal of consent. Please include your first and last name, residential address, and date of birth so that we can identify you.
• To whom you submit the withdrawal of consent. You can address all the affiliates or, if you want to keep sending offers from selected affiliates, indicate only those you do or do not want to allow to contact you further.
• Information that you do not wish us to process your data. If you wish to receive only selected offers, please indicate which offers so we can accommodate you.
• Your handwritten signature.

How can I send the withdrawal of consent?

• The withdrawal of consent to the processing of personal data for marketing purposes can be sent in writing so that we have a proper record of your withdrawal. Do not forget to sign it.
• Send a written statement to the registered office or the company's mailing address

Skeeneffect, s. r. o., Kutlíková 17, Bratislava 852 50

• Send a written statement to the email address info@skeeneffect.sk
• Cancellation of consent when sending newsletters can also be done electronically by unsubscribing from the mailing list. The automatic unsubscribe is displayed at the bottom of the newsletter message that will be sent to the e-mail address you entered.