- On 25. 5. 2018, the EU General Data Protection Regulation (GDPR) and Act No. 18/2018 Coll. on the Protection of Personal Data come into force.

Our company Auto SOWA, s.r.o. with its registered office at Lediny 21, 84103 Bratislava is the controller of your personal data. In connection with this fact, we would like to inform you about the main facts arising from the above-mentioned law.

1. How we collect your personal data
- If you contact us directly, e.g. via email or our homepage in order to request information about our products and services.
- If you purchase a product or service directly from us.
- If other business partners transfer your personal data to us based on permission.

- If you provide data on behalf of someone else, you must ensure that they have been provided with this privacy policy beforehand. If you are under 16, please do not provide us with any of your information unless you have the consent of your parent or legal guardian. We also ask that you help us keep your information up to date by informing us of any changes to your contact information or preferences.

2. What information may be collected about you
- Contact information – name, title, address, telephone numbers, email address.
- Business information – Company business name, registered office address, VAT number, VAT number.
- Your vehicle information – VIN, vehicle type, serial number of installed equipment, vehicle configuration information.
- Vehicle/device location information – the location of your vehicle or mobile device.

3. How your data may be used

- The use of personal data under EU data protection regulations must be based on legal grounds and we are required to determine the legal basis for each use of personal data set out in this Privacy Policy.

- Customer support and marketing - responding to customer inquiries and requests, informing the customer.

The operator collects contact and technical data in order to identify the customer when providing technical support or when sending notifications about security software updates for its own products.

- The operator may also obtain certain vehicle location data during the installation process of the devices or during their operation in the vehicle, which will only be used in accordance with the guarantees regarding location data.

- The provision of personal data for the purpose of selling and servicing the devices is a contractual requirement; failure to provide it will affect the proper performance of the contract or may make it impossible to perform it at all.

- Legitimate requests for the provision of your data - compliance with legal obligations to law enforcement authorities, regulators and courts.

- Transfer to third parties - The operator provides personal data to third parties only in exceptional cases in accordance with the law.

4. How we maintain the security of your data

- We use various security measures, including encryption and authentication tools, to help protect and maintain the security, integrity and availability of your data. Among other things,
we use measures such as:

- strictly limited personal access to your data on a "need to know" basis and only for the communicated purpose,
- transmitting collected data only in encrypted form,
- storing highly confidential data only in encrypted form,
- storing personal data on local storage without access to the internet
- using a firewall on IT systems to prohibit unauthorized access to the local network

- In cases where we have provided you with (or where you have chosen) a password that allows you to access certain parts of our online system, application or service that we operate, you are responsible for keeping the password confidential and following any other security procedures that you have been informed of. We ask that you not share your password with anyone.

Location data guarantees

- Some services can only be provided if you make your
location or the location of your vehicle available. We take the confidentiality of this location data very seriously.

The following guarantees apply to location data:

- The data is stored in a form linked to you or your vehicle in encrypted form
- The data is obtained or accessed in this form in cases where it is necessary to provide the requested service or where we are required by law to retain and/or provide this data (and where we are required to provide this data to law enforcement authorities).
- Any other use of location data (e.g. for analytical purposes) will only be made with the customer personal consent.

- At the time of purchase of the device or activation/configuration of the service or application (e.g. SOWA Mobile), you will be provided with a detailed description of the location data collected by us for the purpose of providing the service dependent on location data. You can control whether we continue to store or collect this data through the settings of the application mentioned above, so that future location data will no longer be collected. Please note that we may not be able to provide some features of our services if you restrict the collection of your location data.

5. How long do we keep your data

- We keep your data only for as long as is necessary for the purpose for which we collected it and any other permitted related purposes (for example, where it is relevant to the defence of a claim against us). If the data is used for multiple purposes, we will retain it until the expiry of the longer purpose, but will cease using it for the shorter purpose as soon as that period has expired.

- We limit access to your data to those who need to use it for the relevant purpose.

- Our retention periods are based on business and legal needs, and your data that is no longer required is either irreversibly anonymized (anonymized data may be retained) or securely destroyed.

- Use for customer support and marketing: In relation to your data used for customer support and marketing purposes, we may retain your data for this purpose until you withdraw your consent.
- Use for the performance of a contract relating to the sale and servicing of goods/equipment: In relation to your data used to perform any contractual obligation to you, we may retain this data for the duration of the contract, plus 10 years for the subsequent resolution of any queries or claims.
- In cases where claims are contemplated: in relation to any data in cases where we reasonably believe that it will be necessary to defend or sue or make a claim against you, us or a third party, we may retain this data for as long as it is possible to assert such a claim.

6. Transfers of your data to third countries

- Your personal data may be transferred in exceptional cases to a country outside the European Union (EU) for any of the above purposes, where the data protection laws may be of a lower standard than those within the EU. We will ensure that any of your data that is made available outside the EU is treated in accordance with appropriate safeguards.

- The European Commission has approved certain non-EU countries, such as Canada and Switzerland, as providing essentially equivalent protection to EU data protection regulations and therefore no additional legal safeguards are required. In countries that do not have such approval, such as India or Japan, we will ask for your consent to the transfer or transfer it on the basis of contractual clauses approved by the European Commission that directly impose equivalent data protection obligations on the recipient - unless we are allowed by the relevant data protection law to carry out the transfer without such formalities.

7. Contacting us, your data protection rights and your right to lodge a complaint with a data protection authority

You have the right
- to request from us to provide you with further details about our use of your data,
- to obtain access to your personal data and a copy of the data you have provided to us,
- to receive from us the personal data concerning you which you have provided to us in a structured, commonly used and machine-readable format and - where technically feasible - to transmit those data to another controller without restriction, as long as the processing of your data is based on your consent or a contract and is carried out by automated means,
- to request from us to update any inaccuracies in the data we hold,
- to request from us to erase any data for which we no longer have a legal basis to use,
- to object to any processing, including profiling, on the basis of legitimate interests, due to your particular situation, unless our reasons for carrying out the processing override your data protection rights,
- to request that we restrict the way in which we use your data, e.g. while investigating a complaint.

- Your exercise of these rights is subject to certain exceptions in the interests of the public interest (e.g. the prevention or detection of a criminal offence), our interests (e.g. the preservation of confidentiality recognised by law) or the rights and freedoms of others. If you exercise any of these rights, we will verify your entitlement and will respond without undue delay, but no later than within one month. In complex cases or when we receive many requests, this period may be extended by a further two months, of which we will inform you.

- If you are dissatisfied with our use of your data or our response to any exercise of these rights, you have the right to lodge a complaint with your data protection authority https://www.dataprotection.gov.sk.