Valid from July 1, 2021. You can find the previous version of the privacy policy here. Slowhop.com makes every effort to protect the privacy of the users of its services. This document defines how we care for your rights and personal data.
- TERMS WE USE IN THE PRIVACY POLICY
Slowhop – company Slowhop sp. z o.o. with its registered office in Krzywe (19-411), ul. Krzywe 3
Website – website belonging to Slowhop. The website is located at: www.slowhop.com
User – adult physical person who has an Account and uses the services offered on the Website
Not logged in User – adult physical person who uses the services offered on the Websites that do not require creating an Account
Account – a set of information and settings created by the User on our Website
Profile – Account functionality, allows the user to show and collect selected information, including description, photos, favourite places
Service Provider – the owner of the venue or the organiser of the activity who offers its services through the Website (a physical person running a business, legal person or organisational unit without legal personality, which the law grants legal capacity)
Terms & Conditions – Terms and conditions for the provision of services by electronic means in the framework of the services of Slowhop
GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
Settings (Privacy) – functionality of the Account, allows the User to use defined and selected services to properly manage these services, including independent modification of their scope and selection of preferences regarding the protection of their privacy
- WHO IS THE CONTROLLER OF YOUR DATA, AND HOW CAN YOU CONTACT THEM?I
The controller of your personal data in connection with the use of the Website is Slowhop. If you have any questions regarding the processing of your personal data and your rights, please contact us by e-mail: inspektor@slowhop.com
- WHY ARE WE PROCESSING YOUR DATA?I
To allow the reservation of services by the Service Provider, e.g. a stay at a guest house or a trip through the Website
For this purpose, we process your basic personal data: name and surname, description of your profile, telephone number and e-mail address. We provide the Service Provider with the name, surname and profile description at the time of booking request. Telephone number and e-mail address at the time of booking confirmation and payment of prepayment. To enable the Service Providers to issue an invoice/VAT invoice to Users for the service, we process personal data such as name, surname, company name, home address, company address, tax identification number.
In this regard, the basis for the processing of your personal data is Art. 6(1)(b) GDPR, i.e. the necessity of processing for the provision of services by Slowhop consisting in providing Customers with the possibility of making reservations with Service Providers.
To ensure harmonious cooperation between Service Providers and Customers, in particular, to build mutual trust, at the time of requesting a reservation, we also provide the Service Provider with the following information about your profile:
- information on how many times you have used the services of the Service Providers via the Website
- information about the ratings and reviews that you have provided for the services you have used - if you have provided such ratings and reviews,
- information about the ratings and opinions issued by the Service Providers, whose services you used – if the Service Providers gave such ratings and opinions.
In this regard, the basis for the processing of your personal data is Art. 6(1)(f) GDPR, i.e. the legitimate interest pursued by Slowhop and by Service Providers, consisting of ensuring harmonious cooperation and building mutual trust between Service Providers and Customers. You have the right to object to the processing of your personal data in this regard.
If you have given your consent, we will also provide Service Providers with information about the scope of services you have used through the Website, especially about the locations you have visited. In this regard, the basis for the processing of your personal data is Art. 6(1)(a) GDPR, i.e. your voluntary consent to the processing of your personal data. You can withdraw your consent at any time without affecting the lawfulness of the processing, which was carried out based on consent before its withdrawal. To withdraw consent, you must change the Account settings.
To allow you to add information about your services and accept reservations from Website Users (only for Service Providers)
This service applies only to approved Service Providers and their data. For this purpose, we process the data provided in the Profile: name, surname, address, telephone number, e-mail address. The data provided in the Service Provider's Profile (name, surname, address) are generally available to Website Users. We provide the e-mail address and telephone number when the User confirms the reservation and payment of the prepayment.
In this regard, the basis for the processing of your personal data is Art. 6(1)(b) GDPR, i.e. the necessity of processing for the provision of services by Slowhop consisting in providing Customers with the possibility of making reservations with Service Providers.
To allow you to sign up for the Slowhop newsletter
For this purpose, we process the data provided in the Profile: name, surname, e-mail address. Subscribing to the newsletter is voluntary and is not a requirement to use other services of the Website.
In this regard, the basis for the processing of your personal data is Art. 6(1)(a) GDPR, i.e. your voluntary consent to the processing of your personal data, expressed by subscribing to the newsletter. You can withdraw your consent at any time without affecting the lawfulness of the processing, which was carried out based on consent before its withdrawal. A link to unsubscribe from the newsletter, i.e. to withdraw consent to data processing in this regard, is included in each newsletter.
To transfer prepayments and invoice the marketing service (only for Service Providers)
This service applies only to approved Service Providers and their data. For this purpose, we process data such as company or individual address data, tax identification number, bank account number. This data is not available to other Website Users.
In this regard, the basis for the processing of your personal data is Art. 6(1)(b) GDPR, i.e. the necessity of processing for the provision of services by Slowhop consisting in providing Customers with the possibility of making reservations with Service Providers. To the extent that we are required to process and store data for tax purposes, the basis for processing your data is also Art. 6(1)(c) GDPR.
Statistics on the use of particular Website functionalities, facilitating the use of the Website and ensuring the IT security of the Website
For these purposes, we process personal data regarding your activity on the Website, such as: visited pages and subpages of the Website and the amount of time spent on each of them, as well as data on your search history, your IP address, location, device ID, as well as browser and operating system data.
In this regard, the basis for the processing of your personal data is Art. 6(1)(f) GDPR, i.e. the legitimate interest pursued by Slowhop, consisting in collecting statistical data to improve the Website. You have the right to object to the processing of your personal data in this regard.
Survey of your satisfaction
For this purpose, we process your personal data, including e-mail address and answers to the questions we have prepared, contained in surveys and forms used for satisfaction surveys.
In this regard, the basis for the processing of your personal data is Art. 6(1)(a) GDPR., i.e. your voluntary consent to the processing of your personal data, expressed by sending us a questionnaire or form. You can withdraw your consent at any time without affecting the lawfulness of the processing, which was carried out based on consent before its withdrawal.
- HOW DO WE ADJUST OUR SERVICES TO YOUR INTERESTS?I
Marketing of our products and the services of our Service Providers
For this purpose, we process the personal data provided by you when creating the Profile and data regarding your activity on the Website, which is recorded and stored via cookies. Activity data relates in particular to such data as search history, clicks on the Website, visits to the main pages of the Website and its subpages, login and registration dates, data on the use of specific services on the Website, history and your activity related to our e-mail communication with you.
Profiling. We use the data mentioned above to create your profile representing your interests and preferences of places and geography. Then, based on this professional profile, we adjust marketing information about our products and services of our Service Providers that may be of interest to you.
Remarketing. To reach you with our marketing messages outside the Website, we use the services of external providers. These services consist of displaying our marketing messages on websites other than the Website.
For this purpose, external providers install, for example, the relevant code or pixel to download information about your activity on the Website. After considering our interest and your interests, rights and freedoms, we decided that marketing combined with profiling will not excessively interfere with your privacy or be an excessive nuisance to you. As part of the marketing of our Service Providers' products and services, we do not transfer your personal data to these Service Providers; in this way, we limit the circle of people who have access to your personal data. We only use data about your activity on the Website. We are interested in what offers of places and trips you are looking for and which offers interest you, not what you do on other websites.
We respect your will, and we make it easier for you to exercise your rights. For this purpose, we provide the ability to quickly withdraw consents from receive marketing messages by e-mail from the level of e-mail messages received. At the same time, we treat the withdrawal of consent to receive such messages as an objection to profiling for marketing purposes.
- WHO DO WE SHARE YOUR PERSONAL DATA WITH?I
We provide your data to the following categories of recipients:
Service Providers and Users
We provide data to Service Providers only when you make a reservation through the Website. Service Providers or Users with whom we share your personal data independently determine the purposes and methods of processing this data without being subject to our instructions in this regard. Therefore, we are not responsible for their actions and omissions.
Service Providers
We provide your personal data to Service Providers that we use to run the Website. Service Providers to whom we transfer your personal data, depending on contractual arrangements and circumstances, are either subject to our instructions as to the purposes and methods of processing this data (processors, e.g. cloud hosting service, online marketing systems, systems for displaying notifications web push, systems for sending e-mail messages, systems for analysing traffic on the Websites, systems for analysing the effectiveness of marketing campaigns) or they independently define the purposes and methods of their processing (administrators, e.g. remarketing campaign services). You can find a list of the providers we use here. The list is regularly updated.
Location. Our suppliers are based mainly in Poland and other European Economic Area (EEA) countries, e.g. in Ireland. Some of our suppliers are based outside the EEA. In connection with the transfer of your data outside the EEA, we ensured that our suppliers guarantee a high level of personal data protection. These guarantees result, mainly representing the obligation to use standard contractual clauses adopted by the Commission (EU). You have the right to request us to provide you with a copy of standard contractual clauses by sending a request in the manner indicated in point 2 of the Privacy Policy.
State authorities
We will provide your personal data if it’s requested by authorised state authorities, in particular organisational units of the prosecutor's office, the Police, the President of the Personal Data Protection Office, the President of the Office of Competition and Consumer Protection or the President of the Office of Electronic Communications.
- HOW LONG DO WE STORE YOUR PERSONAL DATA?I
We store your personal data for the period of having an Account on the Website. After deleting the Account, your data will be anonymised, except for the following data: name, surname, e-mail address, booking history and information on consents (we will keep this data for three years from deleting the Account to handle complaints and claims related to using our services). We store the personal data of users who are not logged in for a time corresponding to the life cycle of cookies stored on their devices.
- WHAT ARE YOUR RIGHTS RELATED TO THE PROCESSING OF YOUR PERSONAL DATA?I
We ensure the implementation of your rights listed below. You can exercise your rights by submitting a request to the email address provided in point 2 of the Privacy Policy. Additionally, you can make selected changes to your Account Settings in the Settings tab after logging in to the Website.
Right to withdraw consent
You have the right to withdraw any consent you gave at the time of registration to the Website and when you use individual services and functionalities offered on the Website. Withdrawal of consent is effective since the withdrawal of consent. Withdrawal of consent does not affect the processing carried out in accordance with the law before its withdrawal. Withdrawal of consent does not entail any negative consequences for you. However, it may prevent you from using the services or functionality that we can legally provide only with your permission (e.g., sending a newsletter). Legal basis: Art. 7(3) GDPR
Right to object to the use of the data
You have the right to object at any time to the use of your personal data, including profiling, if we process your data based on our legitimate interest, for example, in connection with the marketing of our products and services of our Service Providers, statistics for the use of individual Website functionalities and facilitating the use of the Services, as well as satisfaction testing.
Objecting to receiving marketing messages regarding our products or services of our Service Providers will also mean that you object to the processing of your personal data, including profiling for these purposes. If your objection turns out to be justified and we have no other legal basis for processing your personal data, we will delete your data, the use of which you objected to. Legal basis: Art. 21 GDPR
Right to erasure (“right to be forgotten”)
You have the right to request the deletion of all or some of your personal data. We will treat the request to delete all personal data as a request to delete the Account.
Despite the request to delete personal data, we may retain specific personal data to the extent necessary to establish, assert or defend claims in connection with the objection or withdrawal of consent. This applies in particular to personal data, including name, surname, e-mail address and application history, which we retain for handling complaints and claims related to the use of our services. Legal basis: Art. 17 GDPR
Right to restriction of processing
You have the right to request a restriction on the processing of your personal data. If you submit such a request, we will prevent you from using certain functionalities or services that will result in the processing of the requested data until we process your request. We will also not send any messages to you, including marketing ones.
You have the right to request restrictions on the use of your personal data in the following cases:
a) when you question the correctness of your personal data - then we will limit their use for the time needed to verify the accuracy of your data, but no longer than seven days;
b) if the processing of your data is against the law, and instead of removing the data, you will demand a restriction of its use;
c) when your personal information has ceased to be necessary for the purposes for which we have collected or used it, but you must determine, assert or defend claims;
d) when you object to the use of your data, then the restriction occurs for the time needed to consider whether, due to your particular situation, protection of your interests, rights and freedoms outweighs the interests that we process when processing your personal data. Legal basis: Art. 18 GDPR
Right of access to data
You have the right to obtain confirmation from us whether we process your personal data, and if this is the case, you have the right to:
a) access your personal data;
b) obtain information about the purposes of the processing, categories of personal data processed, recipients or categories of recipients of these data, the planned period of storage of your data or the criteria for determining this period, your rights under the GDPR and the right to lodge a complaint with the supervisory authority, the sources of these data, about automated decision-making, including profiling, and about the security measures used in connection with the transfer of these data outside the European Union;
c) obtain a copy of your personal data. Legal basis: Art. 15 GDPR
Right to rectification
You have the right to rectify and supplement the personal data you provided. You can do it yourself in the Settings tab. Concerning other personal data, you have the right to ask us to correct this data (if it is incorrect) and to supplement it (if it is incomplete). Legal basis: Art. 16 GDPR
Right to data portability
You have the right to receive your personal data that you provided to us and then send it to another personal data controller of your choice, e.g. another operator of similar websites. You also have the right to request that personal data be sent by us directly to another controller if it’s technically possible. Legal basis: Art. 20 GDPR
When will we fulfil your request?
If you make a request by exercising the rights mentioned above, we will comply with this request or refuse to comply as soon as possible, but no later than one month after we receive it. However, if - due to the complexity of the request or the number of requests - we will not meet your request within a month, we will meet it within the next two months, and we will inform you in advance about the necessary extension.
For technical reasons, we always need 24 hours to update the settings you choose in our systems. Therefore, you may receive an e-mail from us during the system update, even though you have already opted out of receiving it.
Reporting complaints, inquiries and requests
You can submit complaints, inquiries and requests to us regarding the processing of your personal data and the exercise of your rights.
Suppose you believe that your right to personal data protection or other rights granted to you under the GDPR have been violated. In that case, you have the right to lodge a complaint with the President of the Personal Data Protection Office.
- HOW DO WE CARE ABOUT THE SAFETY OF YOUR PERSONAL DATA?I
We make every effort to ensure the security of your personal data. The websites use encrypted data transmission (SSL) during registration and logging in, which protects the data identifying you and significantly hinders the interception of access to your Account by unauthorised systems or persons.
- HOW DO WE USE COOKIES?I
You can find details on how we use cookies in the Cookie Policy.
- CHANGES IN THE PRIVACY POLICYI
We can change and supplement the Privacy Policy as needed. We will inform you about any changes or additions by posting relevant information on the main pages of the Services. In the event of significant changes, we may also send you separate notifications to your provided e-mail address.
The Privacy Policy does not limit any rights you are entitled to under the Terms & Conditions and the law.
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