We appreciate your interest in our Privacy Policy. At Caiz, we take the protection of your data very seriously, and in the below we explain what data we collect when you use our website and services and how it is used. 

General Information 

1. a) What law applies?

Our use of your Personal Data is subject to both Slovakia`s Act No. 18/2018 Coll. on the Protection of Personal Data (the “PPA”) and the EU`s General Data Protection Regulation (the “GDPR”), and of course we process your Personal Data accordingly. 

1. b) What are personal data? 

Personal data is any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data. 

Personal data that has been de-identified, encrypted or pseudonymized but can be used to re-identify a person remains personal data and falls within the scope of the GDPR. 

Personal data that has been rendered anonymous in such a way that the individual is not or no longer identifiable is no longer considered personal data. For data to be truly anonymized, the anonymization must be irreversible. 

The GDPR protects personal data regardless of the technology used for processing that data – it’s technology neutral and applies to both automated and manual processing, provided the data is organized in accordance with pre-defined criteria (for example alphabetical order). It also doesn’t matter how the data is stored – in an IT system, through video surveillance, or on paper; in all cases, personal data is subject to the protection requirements set out in the GDPR. 

Most Important personal data are the following: 

a name and surname; 

a home address; 

an email address such as [email protected]; 

an identification card number; 

location data (for example the location data function on a mobile phone) 

an Internet Protocol (IP) address; 

a cookie ID*; 

the advertising identifier of your phone; 

 

 

1. c) What is data processing?

Data processing occurs when data is collected and translated into usable information. Usually performed by a data scientist or team of data scientists, it is important for data processing to be done correctly as not to negatively affect the end product, or data output. 

1. d) Who is responsible for data processing?

The responsible party within the meaning of the PPA and the GDPR is Caiz Trade S.r.o. of Mostová 185/2 Bratislava – mestská časť Staré Mesto 811 02, Slovakia (“Caiz”, “we”, “us”, or “our”). If you have any questions or if you wish to exercise your rights, please contact us using [email protected] or through our Contact Form. 

1. e) What are the legal bases of processing?

In accordance with the PPA and the GDPR, we have to have at least one of the following legal bases to process your Personal Data: 

Any processing of personal data is only lawful where it has what is known as a ‘legal basis’. Article 6 of the General Data Protection Regulation (GDPR) sets out what these potential legal bases are, namely: consent; contract; legal obligation; vital interests; public task; or legitimate interests (lawfulness of processing). 

The aim of this guidance is primarily to assist Caiz as controller in identifying the correct legal basis for any processing of personal data which Caiz may undertake or plans to undertake – and the obligations which go with that legal basis.  

We have a data protection officer in accordance with Art 37 GDPR. You can reach the Data Protection Officer Mr. Ilyas Güclü under the following contact details: 

Mr. Ilyas Güclü, 

Goldcliff Consulting & Services GmbH 

Wächtersbacher Str. 90, 60386 Frankfurt am Main 

Email: [email protected] 

Tel: +49 69 95518950 

For the fulfilment of contractual obligations 

The purposes of the data processing are primarily based on the service we provide. 

Within the framework of our legitimate interests 

Where necessary, we process your data beyond the actual performance of the contract in order to safeguard legitimate interests of us or third parties. Examples are: 

Ensuring IT security and IT operations, 

Measures for business management and further development of our services, 

Defense against third-party claims and enforcement of own claims. 

Based on your consent 

Insofar as you have given us your consent to process personal data for certain purposes. 

1. f) Is there an obligation for me to provide data?

Within the scope of our business relationship, you are only required to provide personal data that is necessary for the establishment, implementation, and termination of a business relationship or that we are legally obliged to collect. Without this data, we will usually have to refuse to conclude the contract or will no longer be able to perform an existing contract and may have to terminate it. 

Data we collect automatically 

1. a) Log data

Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user’s device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest. 

1. b) Content Delivery Network

We use a Content Delivery Network (CDN) to distribute our online content. Our CDN is a network of regionally distributed servers of our technical service providers connected via the Internet. When our website is visited, your device`s browser transmits information to these service providers, which is collected in corresponding server log files. Server log files are generally anonymized and then transmitted without any personal reference. Server log files include, in particular, i) details of the browser and operating system used, ii) the previously visited pages (so-called referral URL), iii) the IP address of the device used, iv) the name of the Internet provider, as well as v) the date, time of all page views including the amount of data transmitted. The legal basis for processing is our legitimate interest. 

1. c) Use of cookies

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: 

1. a. Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and
2. b. Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyses your behavior on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).

As set out in Slovakia`s Act No. 351/2011 Coll. on Electronic Communications of 14 September 2011 (the “ECA”), and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies and do so when you visit our website for the first time through our Cookie Consent Management Tool. For further information on the Cookies we use, please refer to our Cookie Policy. 

1. When you watch our videos

On our website, we implement videos of the video portal “YouTube” of the company Google LLC. When you call up a page that has an embedded video, a connection is established to Google’s servers and in the process the content is displayed on the website by notifying your browser. According to Google’s information, in “extended data protection mode” your data – in particular which of our Internet pages you have visited as well as device-specific information including the IP address – is only transmitted to the YouTube server in the USA when you watch the video. By clicking on the video, you consent to this transmission. 

Data we collect directly 

1. a) Contacting us

In addition to your name, e-mail address, IP address or telephone number, if provided, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and contract. 

1. b) Social media

We are present on social media(currently, Instagram, Facebook, Twitter, Instagram, TikTok, LinkedIn,  YouTube, Telegram, Medium, and) on the basis of our legitimate interest.  

If you contact or connect with us via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contractual service, if any. 

 

1. c) User account and registration

If you want to use our services, you are required to create a user account. For this purpose, you can choose a password together with your e-mail address and name. We store the data you enter to set up your account. The legal basis of the data processing is our obligation to fulfil the contract and/or to fulfil our pre-contractual obligations and/or your consent. 

Alternatively, you are able to sign up using the convenience log in and sign up from available wallet providers. Using convenience log in and sign up, you will be asked to provide your basic wallet information (i.e., wallet address) linked to your account. When registering via convenience connect functions, you agree to the relevant terms and conditions of your wallet provider and consent to certain data from your respective wallet provider being transferred to us. 

1. d) When using our services

We process the Personal Data involved in your use of our services in order to be able to provide our contractual services. This includes in particular our support, correspondence with you, invoicing, fulfilment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations. 

1. e) Administration, financial accounting, office organization, contact management

We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest. 

1. f) Newsletter

If you have consented to receive our newsletter, we will use your e-mail address and, if applicable, your name to send you information about us, our books and publications, promotions, and news. You can revoke your consent to receive the newsletter or to the creation of personalized user profiles at any time with effect for the future. You will find the unsubscribe link at the end of each newsletter. The revocation leads to the deletion of the collected user data. 

1. g) Careers and Applications

If you apply for a role or job, we process the information we receive from you as part of the application process, e.g., through your letter of application, CV, references, correspondence, telephone, or verbal details. In addition to your contact details, information about your education, qualifications, work experience and skills is particularly relevant to us. 

As a rule, we do not require any special categories of Personal Information for the application process. We ask you not to provide us with any such information from the outset. If such information is relevant to the application process, we process it together with your other data. 

The legal basis for processing data during the application process is the initiation of a contract and, if you have given your consent, for example by sending us information that is not necessary for the application process, it is consent. The legal basis for data processing after a rejection is our legitimate interest. 

Data processing through integration of third-party services and content 

We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services (“content”). 

This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content. 

The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any, 

Analytics and Tracking: Google Analytics by Google LLC, 

Fonts: Google Font API by Google LLC, 

Fonts: Google Font API by Google LLC, 

Tag Management: Google Tag Manager and Google Site Tag by Google LLC, 

Spam protection: reCAPTCHA by Google LLC, and 

Remarketing: TikTok, and Facebook, If you do not wish to participate in our advertising personalization or retargeting/tracking you can object to behavioral advertising at the following websites: Your Online Choices, Digital Advertising Alliance of Canada, Network Advertising Initiative or AdChoices. 

General Principles 

1. a) Who receives my data?

Within Caiz, those that need your data to fulfil our contractual and legal obligations will receive access to it. 

Processors used by us may also receive data for these purposes. These are companies in the categories of IT services, telecommunications, and sales and marketing. Where we use processors to provide our services, we take appropriate legal precautions and corresponding technical and organisational measures to ensure the protection of personal data in accordance with the relevant legal provisions. 

Data is only passed on to third parties within the framework of legal requirements. We only pass on users’ data to third parties if this is necessary, for example, for contractual purposes or on the basis of legitimate interests in the economic and effective operation of our business or you have consented to the transfer of data. 

1. b) How long will my data be stored?

As far as necessary, we process and store your personal data for the duration of our business relationship, which also includes, for example, the initiation and execution of a contract. 

In addition, we are subject to various storage and documentation obligations, which result from the minimum statutory retention periods among others. The retention and documentation periods specified there are up to 8 years. 

1. c) How do we secure your data?

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of content or contact requests that you send to us. We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website. 

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered. 

1. d) Are data transferred to a third country or to an international organization?

Your data is not transferred to third countries (countries outside Slovakia and the EEA). 

1. e) Special Category Data

Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data. 

1. f) Minors

We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties. 

1. g) Automated decision-making

Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place. 

1. h) Do Not Sell

We do not sell your Personal Data. 

Your Rights and Privileges 

1. a) Privacy rights

Under the PPA and GDPR, you can exercise the following rights: 

Right to information 

Right to rectification 

Right to object to processing 

Right to deletion 

Right to data portability 

Right of objection 

Right to withdraw consent 

Right to complain to a supervisory authority 

Right not to be subject to a decision based solely on automated processing. 

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us. In case of exercising your right to deletion please use the following erasure request form. 

1. b) Updating your information

If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us. 

1. c) Withdrawing your consent

You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation. 

1. d) Access Request

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why. 

1. e) Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in Slovakia is The Office for Personal Data Protection of the Slovak Republic (Úrad na ochranu osobných údajov), Hraničná 12, 820 07 Bratislava 27, Slovakia, www.dataprotection.gov.sk 

Validity and questions 

This Privacy Policy was last updated on Monday, 10 April 2023, and is the current and valid version. However, we want to point out that from time to time due to actual or legal changes a revision to this policy may be necessary. If you have any data protection questions, please feel free to contact us.