PERSONAL DATA PROTECTION PRINCIPLES OF DREAMREALITY S.R.O.
Dear users,
this privacy policy applies to you – users of our websites operated on our individual online websites and mobile applications.
We are among the largest providers of online advertising services in Slovakia. We operate online software for submitting offers to real estate agencies and client websites focused on real estate advertising and subsequent export of these offers to online real estate portals. We act as an intermediary between the supply side and the demand side.
Through the creation of a technological background and means of communication, we provide users with the opportunity to offer for sale individual categories of goods on which a specific portal is focused and the opportunity to purchase these goods for other users. At the same time, on our advertising portals, we also allow entrepreneurs whose business is selling goods or mediating the sale of goods (e.g. real estate) to advertise individual goods (e.g. apartments or cars).
We always take your privacy into account when providing our services and products as well as when they are being innovated. We are aware of our commitment to our users. We are fully aware of our obligations towards you stemming from the requirements of legislation regulating your privacy and the protection of your personal data. We approach the protection of your personal data with respect and responsibility. That is why we cooperate with experts from various fields, e.g. from legal, security, IT to make sure that no decision is made without respecting privacy.
Within our services, you can manage your privacy in various ways. At the same time, you always have the opportunity to use your rights arising from Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons in the processing of personal data and on the free movement of such data, which repeals Directive 95/46/EC (general regulation on data protection) (“Regulation”) and Act no. 18/2018 Coll. on the protection of personal data and amendments to certain laws (“the Law”).
The purpose of this personal data protection policy is to provide information about who, why, how your personal data is processed, to whom your personal data is provided, what rights you have under the Regulation and the Act, and how you can exercise them.
Who we are?
Your personal data is processed and protected by RealSoft s.r.o., Odborárska 1381/18, 915 01 Nové Mesto nad Váhom, ID: 46786686, registered in the Business Register of the District Court Bratislava I, section: Sro, insert no. 83355/B. From the point of view of the Law and Regulation, we have the status of an operator or an intermediary.
What types of information do we collect about you?
In order to be able to provide you with our services as well as to continuously improve our services, we collect information about you. The information we collect about you and how we use it depends on which of our particular services you use and how you manage your privacy controls with us. In principle, the information we process about you can be broken down as follows:
- • Information that you submit to us in direct connection with a specific service provided or in connection with an organized competition, namely:
– information related to your inquiries handled by our customer and business support – e.g. complaints, reclamations, suggestions, notices, requesting price lists.
- • Information that we also receive from other sources, namely:
– information about you from other users – we may collect information about you from other users, for example, when they contact us about you, e.g. when they alert us to certain actions of yours or recommend you as a possible user of our services
- • Information obtained in connection with the use of our services, namely:
– information about your interaction with us, for example, how the services were used, login method, from where you visited individual pages and how long you used them, reaction times, download errors, how to access the services and end their use, etc.
– technical data of used devices and settings, for example IP address, browser settings, operating system, platform, cookies; you can find more information on how we use cookies here
– information necessary to be able to use certain functionalities of our services.
For example, in order to conveniently and quickly add or manage an ad, the mobile application requires access to your camera and media storage. To determine the compatibility of your device with our applications, we need access to read the status and identity of the device. In addition, the application has permission to access the network connection (Wi-Fi and mobile data), control vibration, prevent the device from going to sleep mode, receive data from the Internet.
Why do we process your personal data?
In order for us to process your personal data in accordance with the law, it is necessary for us to have a predetermined purpose for their processing. Below we list the purposes for which your personal data is collected and further processed.
- • To fulfill legal obligations
Special legal regulations may impose various obligations on us as a service provider, for the purpose of which the processing of your personal data is necessary. For example, in accordance with the Civil Code and regulations in the area of consumer protection, we process your personal data also for the purpose of processing possible complaints. Another example when the purpose of personal data processing is the fulfillment of legal obligations is the accounting law, according to which we are obliged to store certain data for paid services for the period specified in this law.
- • To evaluate, maintain and improve our services and develop new services
Based on your information, we make sure our services work as you expect them to, for example by monitoring outages or fixing problems you report to us.
With the help of your information, we also try to innovate our services – for example, when, based on your suggestions, we determine the need to improve the quality of the service or register a demand for a new service or evaluate the need for higher user protection, etc. The information we collect as part of existing services helps us develop new services.
- • To provide customized services, including content and advertisements
Based on information from you, we are able to provide our services to ensure that the provided service is “tailored” to your needs and preferences.
We provide you with customized content, e.g. by displaying relevant recommendations of relevant and interesting offers to you that we believe may appeal to and interest you, and other similar measures to facilitate your use of our services and improve your user experience when using our services.
The aim of processing your personal data for this purpose is also to simplify the use of our company’s services, e.g. saving your advertisements or preferred payment methods for the purpose of future payments for our services or recommending relevant products.
The information we collect from your various devices (operating system version, application version, and device hardware information) helps us provide consistent service across all of your devices.
- • To enforce the security of our services, prevent misuse of services and investigate violations of our terms
We care about our services being secure. In order to enforce the security of our services, we process your personal data as part of the prevention of spam, phishing, harassment, misuse of your user accounts or other prohibited activities.
As part of this processing purpose, we implement our commitment to you to ensure the protection of our IT environment against attacks and other interventions, so that the use of our services is safe. We ensure that the terms of our services are respected by other users, thus ensuring a valuable and safe use of the services.
Thanks to information from computers, phones and other devices on which you install and use our services, depending on the permissions you have granted, we can ensure a higher protection of your privacy. We use the obtained data as an aid in the provision and support of our services and also for the purpose of increasing your security. The data obtained from the devices helps us to verify the user’s identity, as we constantly strive to protect your account through a team of engineers and technologies, such as encrypting both communications and other content (such as photos) through the HTTPS protocol.
What is the legal basis for the processing of your personal data in terms of the Act and Regulation?
The legality of processing your personal data is justified by the following legal bases:
We mainly process your personal data, as the processing of personal data is necessary for the fulfillment of the contract that you concluded with us by accepting our terms of use.
Other legal bases include the fulfillment of our legal obligations, your and our legitimate interests, and your consent to the processing of personal data. If we process your personal data based on your consent, you are entitled to revoke this consent at any time.
To whom do we provide or make available your personal data?
From the point of view of the Act, we have the status of operator, which means that it is our company that defines the purpose of processing.
In connection with our activity, your personal data may be transferred or made available to other entities, either in the capacity of an independent operator or an intermediary.
Due to the fact that, as part of our services, we enable our clients (e.g. real estate agencies or professional vehicle dealers) to advertise on our portals, we also fulfill the role of an intermediary within the meaning of the Act. Through the contact form placed next to a specific ad, you can directly contact the seller of the goods listed in the specific ad, and thus the data entered in the contact form is processed by the specific seller as the operator and us as his intermediary.
As an operator, we ensure that everyone to whom your personal data is transferred adheres to a high standard of data protection. In no case do we provide your personal data to an entity where this standard is not ensured.
List of recipients:
Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, United States Matterport, Inc, 352 East Java Drive, Sunnyvale, CA, 94089 YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066, United States Ringier Axel Springer Slovakia, as , Prievozská 14, 821 09 Bratislava, Slovakia, ID: 00678155 United Classifieds sro Prievozská 14, 821 09 Bratislava
Circles of beneficiaries:
Suppliers of programming services, real estate agencies, car dealerships.
Persons to whom we are obliged to provide your data based on the law, e.g. Slovak Trade Inspection, courts, law enforcement agencies.
How long will your personal data be processed?
The processing of your personal data takes place in accordance with legal requirements, which means that we do not keep personal data longer than is necessary for the purpose of processing.
If we process your personal data on a legal basis – performance of the contract, we process your personal data for the entire duration of the contractual relationship between us. If the contract is terminated, we dispose of your personal data, unless it is possible to process your personal data on another legal basis. For example, you delete your only ad, and we are obliged to dispose of your personal data. However, if while using our services you also used some of our paid services (e.g. topping up an ad), we are entitled to continue processing data related to your completed payments for the purposes of fulfilling our obligations arising from tax and accounting legislation.
If we process your personal data on a legal basis – the fulfillment of legal obligations, then we process your personal data for the period specified by law.
If we process your personal data on a legal basis – our legitimate interest or the legitimate interest of third parties, we process your personal data for the duration of the legitimate interest.
If we process your personal data on a legal basis – your consent, we process your personal data for the period for which you have given us your consent to process your personal data. When processing personal data for the purpose of participating in a competition organized by us to support our products or services, this period is specified in the specific statute of the competition or the conditions of the competition.
What rights do you have in relation to our processing of your personal data?
The law as well as the Regulation provides you with several rights that allow you to have the protection of your personal data under your own control. Our company respects your rights. In this section you will therefore learn what they are
- • The right to access personal data
This right means that you are entitled to request confirmation from us as to whether personal data relating to you is being processed. Therefore, if we process such personal data about you, you have the right to obtain access to your personal data and information about:
– why we process your personal data (purpose of processing personal data)
– what data about you we process (category of personal data)
– to whom they can resp. your personal data will be provided (identification of the recipients or range of recipients)
– how long we will keep your personal data (personal data retention period)
– that you have the right to request from us the correction of personal data, their deletion as well as the limitation of their processing or that you have the opportunity to object to processing of personal data
– that you have the right to submit a proposal to initiate proceedings on the protection of personal data according to the Act or the right to file a complaint with the supervisory authority according to the Regulation, which is the Office for the Protection of Personal Data of the Slovak Republic – where your personal data come from (information about the source), unless you have provided us with personal
data directly by you
– whether we use automated individual decision-making, including profiling according to § 28 par. 1 and 4 of the Act; especially about the procedure used, as well as about the meaning and expected consequences of such processing of personal data for you
– about adequate guarantees regarding the transfer, in the event that we transfer your personal data to a third country or an international organization. We will provide you with a copy of your personal data that we process about you. However, if you repeatedly request to provide your personal data, we may charge you a reasonable administrative fee in connection with your request for a copy of your personal data.
- • The right to correct personal data
As part of the terms of the provision of our services, we inform you to provide us with the correct data. However, if we nevertheless happen to process incorrect data about you, the right to rectification of personal data means that you are entitled to request that we correct incorrect personal data relating to you. Also, taking into account the purpose of personal data processing, you also have the right to have your incomplete personal data supplemented.
- • The right to erasure of personal data (the so-called right to be forgotten)
You have the right for us to delete personal data concerning you and at least one of the following reasons is met:
– your personal data is no longer necessary for the purpose for which we obtained it or otherwise processed it – you have withdrawn your consent to processing of personal data, on the basis of which we process your personal data and at the same time there is no other legal basis for their further processing
– you object to the processing of personal data, which is carried out on the legal basis of public interest or legitimate interest and no legitimate reasons for their processing prevail – your personal data was processed illegally
– your personal data must be deleted, as it is necessary to fulfill an obligation under the law of the Slovak Republic or the law of the European Union
– your personal data was obtained in connection with the offer of information company services according to § 15 par. 1 of the Act
, your right to erasure of personal data, however, may not be complied with in a specific case with regard to specific circumstances, if the processing of personal data is necessary for: – to exercise
our right to freedom of expression or the right to information – to fulfill a legal obligation
– to exercise our legal claim
– for the purpose of archiving, for the purpose of historical research or for statistical purposes, if it is likely that the right to erasure would make it impossible for us to achieve the goals of such processing or in a serious way difficult
- • The right to restrict the processing of personal data
You have the right for us to limit the processing of personal data concerning you and at the same time at least one of the following reasons is met:
– during the period allowing us to verify the correctness of your personal data, you challenge the correctness of your personal data
– it will be an illegal processing of personal data, you object to the erasure of personal data and request a restriction of personal data processing instead of erasure
– we will no longer need your personal data for any of the purposes of processing, or you will need them to prove, exercise or assert your legal claims
– you will object to the processing of personal data and that until the verification of whether our legitimate interests prevail over your legitimate interests
- • The right to portability of personal data
If our right to process your personal data is based on your consent or on the fulfillment of obligations arising from the contract we have concluded with you, you have the right to request the transfer of data concerning you and which you have provided to us to another personal data controller.
- • Right to withdraw consent
If we process your personal data on a legal basis – the consent of the person concerned, you have the right to revoke this consent at any time, even before the expiration of the period for which this consent was granted. Withdrawal of consent does not affect the lawfulness of processing based on consent prior to its withdrawal.
- • The right to invalidate automated individual decision-making, including profiling
You have the right to request that automated individual decision-making, including profiling, be ineffective against you.
| RIGHT TO OBJECT |
|---|
| If you have reasons for doing so related to your specific situation, you have the right to object to the processing of your personal data if the legal basis for such processing is our legitimate interest. |
| However, if our legitimate interest in the processing exceeds your personal interest, we may continue to process your data, despite your objection to the processing. We are also entitled to continue processing your data, if this is necessary for proving, exercising or defending our legal claims. |
| Direct marketing (including analyzes carried out for the purposes of direct marketing): |
| You have the opportunity to object to the processing of your personal data for direct marketing purposes. The objection also relates to analyzes of personal data (so-called profiling) that are carried out in connection with direct marketing. If you object to direct marketing, we will stop processing your personal data for this purpose, as well as for the purpose of all types of direct marketing actions. Of course, you can simply opt out of receiving messages and personal offers on specific channels. For example, you can only receive offers from us by e-mail, but not via SMS messages. |
| You can change your settings at any time on the website or in the app. You can also change your settings via email, SMS or a combination of these. If you need help with the settings, you can always contact our customer service. |
If, as a data subject, you do not have full legal capacity, your legal representative can exercise your rights in accordance with the Regulation and the Act. In accordance with the Regulation and the Act, the rights of the affected person who is not living can be exercised by a close person.
If your requests as a data subject are manifestly unfounded or disproportionate, especially due to their repetitive nature, we may request a reasonable fee taking into account the administrative costs of providing the information or refuse to act on the request.