PRIVACY POLICY
WHO ARE WE?
The National Coalition for Digital Skills and Jobs of the Slovak Republic is an interest association of legal entities established on 9 December 2019, with its registered office at Bottova 7939/2A, 811 09 Bratislava-Old Town, Slovak Republic, Company ID: 52828123, registered in the Register of Interest Associations of Legal Entities of the District Office Bratislava (hereinafter referred to as “Digital Coalition”).
Pursuant to Article 13 and Article 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter “GDPR”), the Digital Coalition, as the controller, provides you with information on the purpose of the processing of personal data for which the personal data are intended, even if the personal data are not collected directly from the data subject.
It is necessary to familiarise yourself with this information in order to understand this information at the latest when collecting your personal data.
The Digital Coalition is a national initiative based on the initiative of the European Commission under the Digital Skills and Jobs Coalition policy. The aim of the Digital Coalition is mainly to improve digital skills among all groups of the population in Slovakia, prepare for digital transformation in all sectors and sectors of the economy, public administration and self-government, support technological innovation, etc.
The Digital Coalition implements the IT Fitness Test project, which focuses on testing the digital skills of primary, secondary and university pupils, as well as teachers, company employees and anyone curious and evaluating and analysing the IT Fitness Test, which serve to improve the digital and IT skills of the public (hereinafter referred to as the “Project”).
The project is designed mainly for defined target groups and for those interested in developing their digital skills. Participants must demonstrate compliance with the Project participation criteria to the Digital Coalition by registering in an electronic testing platform. Without registration (verification of fulfilment of the criteria), it is not possible to participate in testing and training according to the Project. On the basis of this authorisation, the Digital Coalition collects the necessary personal data from those interested in education and access to the Project’s testing platform and they are obliged to provide their personal data to the extent required upon registration. Otherwise, it will not be possible to verify the fulfilment of the criteria for one of the target groups of the Project.
CONTINUED COMMITMENT TO PRIVACY
We respect the privacy of all individuals whose personal data we process as part of our activities, and therefore we are committed to protecting your privacy and will treat all information we collect and store about you responsibly.
By familiarising yourself with this information, you acknowledge that we may collect, use and share your personal data with other public authorities as well as third parties to the extent and manner described below.
It is important to us that you understand why and how we handle your personal data.
Therefore, please read the information below on how we collect your personal data, how we further handle it and what are your other rights in relation to the processing of your personal data by the Digital Coalition.
WHAT IS PERSONAL DATA?
We treat as personal data any information about an identified or identifiable natural person, such as first name, surname, e-mail address, date of birth, etc.
As a controller, we may process your data for different purposes, and the legal basis for the processing, the duration of processing and storage may vary depending on the purpose of the processing operations.
WHAT ARE OUR CONTACT DETAILS
If you have any questions or comments regarding the protection of personal data, you can contact us in writing, by e-mail, by phone at the following contact details:
National Coalition for Digital Skills and Jobs of the Slovak Republic
Mlynské nivy 18890/5
82109 Bratislava-Ružinov
Slovak Republic
E-mail: [[email protected]]
Contact with the Data Protection Officer: [[email protected]]
In order to strengthen the guarantee and legal guarantee of your rights and freedoms with regard to the processing of your personal data, we have entrusted a Data Protection Officer with the supervision of the lawfulness of the processing of your personal data.
The Data Protection Officer is your contact point for any questions or requests regarding the protection of personal data and for exercising your rights. You may contact them at the above e-mail address or in writing; always mark the written message “to the hands of the Data Protection Officer”.
PROTECTION OF PERSONS UNDER 16 YEARS OF AGE
If you are under the age of 16, please request your consent before you provide us with any personal information about yourself or legal guardians. Without such consent, you are not authorised to provide us with your personal data.
WHAT CATEGORIES OF PERSONAL DATA DO WE PROCESS ABOUT YOU?
In connection with your participation in the IT Fitness Test project, we process personal data of data subjects, who are persons who meet the criteria of one of the target groups of the Project.
The following categories of persons are included among the target groups of the Project:
- pupils and students of primary, secondary and higher education institutions (including pupils and students from Ukraine), where appropriate their legal representatives;
- educators;
- employees;
- people interested in improving their digital skills.
In connection with your participation in the Project, we process in particular the following categories of personal data:
• identification of project participants (if applicable, their legal representatives): especially your name, surname, date of birth;
• contact details of the participants in the project (including, where applicable, their legal representatives): in particular, the e mail address;
• data on the physical characteristics of the participants in the Project: in particular, data about your gender, if you choose to include them;
• information on the inclusion of project participants in the target group: an indication of whether you are a pupil or student, educator, employee or person interested in improving your digital skills;
• data related to classification: for students, pupils information about their school, grade and class/group, for educators information on their school and class/group, for staff and persons interested in improving their digital skills, information on their country of origin, highest educational attainment, organisation and departments/group (if relevant);
• any other personal data you provide to us about yourself;
Categories of personal data: General personal data.
HOW DO WE PROCESS YOUR PERSONAL DATA?
Processing shall not be carried out in paper form. Processing is carried out in the information system of the controller.
HOW DO WE COLLECT YOUR PERSONAL DATA?
We collect personal data directly from you, unless expressly stated otherwise in this document.
We process personal data on the following legal bases:
• based on consent (Article 6 (1) (a) GDPR).
• on the basis of contractual and pre-contractual relationships (Article 6 (1) (b) of the GDPR);
• on the basis of compliance with a legal obligation (Article 6(1)(c) of the GDPR);
You are obliged to provide your personal data if the processing of your personal data is necessary in relation to compliance with a legal obligation of the controller. You are also obliged to provide personal data in cases where their provision is a contractual requirement resulting from a contract concluded between you and the controller.
The provision of your personal data in the context of pre-contractual and contractual relationships is necessary, otherwise failure to provide it could prevent your participation in the Project, the conclusion of a contract with you and its possible fulfillment.
If the legal basis for the processing of personal data is consent (e.g. consent for marketing and promotional purposes), the granting of consent is voluntary. If we process your personal data based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of the processing based on consent given prior to its withdrawal. Withdrawal of consent is not charged or otherwise sanctioned.
If we process your personal data on the basis of a legitimate interest, you have the right to object at any time, on grounds relating to your particular situation, to processing of your personal data based on this basis, including profiling based on legitimate interest (Art. 21 GDPR). The Digital Coalition shall no longer process the personal data in such a case unless we can demonstrate compelling legitimate grounds which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
FOR WHAT PURPOSES AND ON WHAT LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA?
We will process your data for the following purposes:
ARE YOU OBLIGED TO PROVIDE US WITH YOUR PERSONAL DATA?
In the performance of our activities, we request from you personal data that we process for different purposes and we carry out the processing on different legal bases.
In case of failure to provide personal data, the data subject cannot be included in the database of authorised candidates to participate in the Project.
If the legal basis for the processing of your personal data is compliance with our legal obligation under the provisions of Article 6(1)(c) GDPR and you refuse to provide us with your personal data, this may lead to damage for which we may claim compensation against you.
If the legal basis for the processing of your personal data is the conclusion or performance of a contractual relationship and you refuse to provide us with your personal data, this may lead to frustrating the possibility of entering into a binding contractual legal relationship with us.
If the legal basis for the processing of your personal data is consent to processing in accordance with the provisions of Article 6 (1) (a) of the GDPR, you can withdraw it at any time, and you are entitled to use the same way as you gave us your consent. Consent to the processing of personal data for the requested purposes is never subject to the possibility of entering into a contractual relationship with us.
If the legal basis for the processing of your personal data is the predominance of our legitimate interests and we therefore use the legal basis for the processing of your personal data pursuant to the provisions of Article 6 (1) (f) GDPR, you are obliged to accept this processing, but you have the right to object to it. You will find out more about this right in a separate section below.
If the legal basis for the processing of your personal data is the performance of a task carried out in the public interest in accordance with the provisions of Article 6 (1) (e) of the GDPR, we are entitled to process your personal data under the conditions set out in this document.
IN ADDITION TO THE DIGITAL COALITION, WHO CAN ACCESS YOUR DATA?
We may share your personal data with other third parties, namely with verified and contractually committed external business partners who assist us in the processing and protection of your personal data. These are so-called recipients and processors who create and provide functional and secure systems for the Digital Coalition, provide software or other services that are necessary for the processing of your personal data for the above purposes.
We are also obliged to provide your personal data to authorised public authorities in the event of the exercise of their legal rights under relevant specific laws (e.g. police investigations, etc.), which do not have the status of recipients within the meaning of the GDPR.
In connection with the fulfilment of the legal obligations of the controller, the recipients of your personal data are or may be entities designated by law, in particular the tax office, state administration and public authorities for the exercise of control and supervision, courts and law enforcement authorities.
Based on your consent, we will also provide some of your personal data to your school/organisation, namely the specific results of your tests in conjunction with your name and surname. The school/organisation you provide in the registration form will be able to process this data mainly for the purpose of improving the learning process and increasing digital skills.
Depending on the purpose of the processing and specific circumstances, the recipients of your personal data may also include other persons, in particular:
• trading company Pragmatic Mates, s.r.o., with its registered office at Silk 1291/1, Trebišov 075 01, Company ID: 46706291, entry: Business Register of the District Court Košice I, Section: Sro, Insert number: 30061/V;
• external contractors for programming work and system administration;
• companies that are external suppliers of accounting, auditing or personnel services;
• providers of services in the field of marketing activities;
• external advisers, lawyers, courts and bailiffs;
• the Data Protection Officer within the meaning of the GDPR;
• hosting providers, data centre service providers;
• cloud service providers;
• postal service providers;
• audit authorities at national level, with authorised persons to carry out controls or audits, such as (i) the Supreme Audit Office of the Slovak Republic and its authorised persons or (ii) external audit entities.
If we process your personal data through processors as a special category of recipients of personal data, we ensure that they comply with the applicable legal regulations and conditions agreed by the contract on the processing of personal data or the agreement of joint controllers, and that they are bound by confidentiality and protect your data in accordance with the requirements of the GDPR.
IS THERE AUTOMATED PROCESSING OF YOUR DATA WITH LEGAL EFFECT ON YOU, INCLUDING PROFILING?
No, it doesn’t happen.
IS THERE A CROSS-BORDER TRANSFER OF YOUR PERSONAL DATA?
No, it doesn’t happen.
WHAT ARE YOUR RIGHTS AS A DATA SUBJECT?
Under the applicable data protection law, you have certain rights as a data subject.
[Right to access] You have the right to obtain a copy of the personal data we hold about you, as well as information about how we use your personal data. In most cases, your personal data will be provided to you in written form, unless otherwise requested by you. If you have requested this information by electronic means, it will be provided electronically, if technically feasible.
[Right to rectification] We take reasonable steps to ensure the accuracy, completeness and timeliness of the information we hold about you. If you believe that the data we hold is inaccurate, incomplete or outdated, please do not hesitate to ask us to modify, update or supplement this information. As a data subject, you have the right to have personal data concerning you rectified if they are incorrect or complete if they are incomplete. We are obliged to comply with your request for rectification or completion of personal data without undue delay.
[Right to erasure] In certain circumstances, you have the right to request the erasure of your personal data, for example if the personal data we have collected about you are no longer necessary for the fulfilment of the original purpose of the processing or if you withdraw your consent to the processing. However, your right must be assessed in the light of all relevant circumstances. For example, if the processing of your data is necessary for compliance with our legal obligation or for the establishment, exercise or defence of legal claims, we may not comply with your request.
[Right to limited processing of data] In certain circumstances, you are entitled to ask us to stop using your personal data. For example, this may be the case if you believe that the personal data we hold about you is inaccurate or that we no longer need to use your personal data. Where processing has been restricted in accordance with the provisions of Article 18(1) of the GDPR, such personal data shall, with the exception of storage, be processed: (I) only with the consent of the data subject, or (ii) for the establishment, exercise or defence of legal claims, or (iii) for the protection of the rights of another natural or legal person, or (iv) for reasons of important public interest of the Union or of a Member State.
[Right to data portability] In certain circumstances, you have the right to ask us to transfer the personal data you have provided to us to another third party of your choice. If the processing is based on consent or a contract and is carried out by automated means, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller. If technically feasible, you have the right to have the data transmitted directly from one controller to another.
[Right to object] If the processing is based on our legitimate interests (pursuant to the provisions of Article 6 (1) (f) of the GDPR), you have the right to object at any time, on grounds relating to your particular situation, to such processing of personal data concerning you, including profiling based on those interests. In this case, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds which override the interests, rights and freedoms of the data subject, or (ii) grounds for the establishment, exercise or defence of legal claims. If you object to the processing for direct marketing purposes, including profiling, to the extent that it is related to such direct marketing, the personal data concerning you will no longer be processed for such purposes.
[Rights related to automated decision-making] You have the right to refuse automated decision-making, including profiling, which will result in a legal or similar significant consequence for you.
[Right to withdraw consent] In most cases, we do not process your personal data based on your consent. If in specific cases we process your data based on your consent, you have the right to withdraw your consent to further use of your personal data.
[Right to lodge a complaint or ask for court protection] As a data subject, you also have the right to lodge a complaint with a supervisory authority, which is the Office for Personal Data Protection of the Slovak Republic (more information can be found on the website (www.dataprotection.gov.sk) or apply to a competent court).
SUGGESTIONS REGARDING THE USE OF YOUR PERSONAL DATA
We care about the protection of your personal data and therefore we strive to secure them through individual, modern technical and organizational measures, as well as the possibility to exercise your rights of the data subject under the GDPR at any time through a request.
Requests for the exercise of the right of the data subject may be sent to us electronically or in writing to the above contact details of the Data Protection Officer. This procedure is without prejudice to your right to withdraw your consent to the processing of personal data, which you can always withdraw as easily as you gave it to us (e.g. if you have given your consent electronically, you can always revoke it by email) or your right to object by automated means using technical specifications, if available.
For each request, we recommend that you explain as much as possible what right under the GDPR you exercise, what are your identification data (to verify your identity) or what purposes and data the request relates to. For too general requests, we need to ask for clarification.
The GDPR lays down the general conditions for the exercise of your individual rights. However, their existence does not automatically mean that they will be complied with by us when exercising individual rights, as in a particular case exceptions may also apply or some rights are linked to specific conditions that may not be fulfilled in any case. Your request for a specific right will always be dealt with and examined from the point of view of the legislation and our internal policy for handling the complaints of data subjects.
If the Digital Coalition is not competent to assess your application for the exercise of the data subject’s right, your request will be forwarded to the controller without delay.
Any request to exercise the right of the data subject that will be sent to us will be individually and competently assessed, and we will always inform you of the outcome within one month of receipt of your request.
Please note that when processing your request for the exercise of a data subject’s right under the GDPR, we may ask you to verify your identity credibly, especially in cases where there are doubts about your identity. It is our duty to prevent the provision of personal data about you to an unauthorised person. The process of processing your request related to the exercise of your data subject’s right under the GDPR is free of charge.
If your request is manifestly unfounded or disproportionate, in particular because it is repeated, we are entitled to
a) charge a reasonable fee which takes into account the administrative costs of providing the information or a reasonable fee taking into account the administrative costs of the notification or a reasonable fee taking into account the administrative costs of carrying out the requested action; or
b) refuse to act upon request. The Digital Coalition demonstrates the manifest unfoundedness of the request or the inadequacy of the request. The Digital Coalition may request the provision of additional information necessary to confirm the identity of the data subject if it has reasonable doubts about the identity of the natural person making the request pursuant to Sections 21 to 27 of the Personal Data Protection Act; this is without prejudice to Section 18 of the Personal Data Protection Act. If you have any questions, you can contact the Digital Coalition at any time using the contact form specified and located on the website.
AMENDMENT OF THESE CONDITIONS
The protection of personal data is not a one-off issue for us. The information we are required to provide to you with regard to our processing of personal data may change or cease to be up to date.
For this reason, we reserve the right to modify and change these Terms at any time to any extent. In the event that we change this information substantially, we will notify you of this change, e.g. by general notice on this website or by special notice via e-mail.
This version was released on 5 April 2024.