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We have written this document to provide you - our clients and anyone with whom we have any contractual or other relationship - with clear and understandable information, particularly about how Refundio works and
You can rely on us to take the protection of your personal data seriously and to comply with applicable law. We protect your data to the extent that we are permitted to do so by commonly available technical means.
The processing of personal data is governed by 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 (better known as "GDPR") and Act No. 110/2019 on the processing of personal data, as amended.
Do you not understand any part of this Policy or have any questions about personal data? Feel free to email us at: air@refundio.eu
To start with, let's talk about what personal data actually is. GDPR describes it as information about an identified or identifiable natural person.
To give you a better idea, let's talk about it with examples. Typical personal data can be name, surname, telephone number, email, home address, birth number, gender, nationality, type and number of identity document. However, it must be possible to infer a specific person from the data or a combination of such data.
We work primarily with data relating to users of our services, including potential future clients who are interested in our services. Depending on the nature of the situation, we also process data about representatives.
In addition to your basic personal data, we also process a lot of other data. For example, what services you use with us and how you use them. We also work with data that we learn from the way we talk, call or write to each other. We also look at personal data, such as your age. We only work with the personal data we need to provide you with our services.
We want you to know that we process the following data in particular:
Identification data such as your name, surname, gender, date of birth, birth number, identity card number, home address, nationality, nationality and the form of your signature are part of the framework agreement or other contractual documents we enter into with you.
We also work with your contact details, which primarily include your email and telephone number, without which we would not be able to provide you with our services. The Refundio website is operated and your personal data is processed by Verdikto Group s.r.o., with registered office at Žižkova 13, 040 01 Košice, Slovak Republic, ID No.: 54 625 637, registered in the Commercial Register maintained by the District Court in Košice.
The processing of personal data is carried out for a specific purpose and there must be a legal basis for this purpose. We always state why we collect personal data and what entitles us to do so (the legal reason) for the purpose in question.
Therefore, we process your personal data on the basis of the performance of a mutual contract, on the basis of the performance of our legal obligations and on the basis of our legitimate interest. Before using information for a purpose not listed in this Policy, we will always evaluate whether your consent or another reason for processing is required based on a compatibility of purpose assessment pursuant to Article 6(4) of the GDPR.
We use your data in our internal documentation, where we keep a record of data flows about where your personal data is stored, how it is secured, whether your data has been deleted, who within our company deleted it and when, so that we are able to demonstrate our compliance with data protection legislation.
All your personal data is processed by us only and is not transferred to other processors.
Personal data may also be transferred to, for example, police authorities or other authorities, for the purpose of defending our own claims or where we are required to do so by law. All personal data is processed only within the European Union.
We will only process your personal data for as long as is necessary to fulfil the above purposes for which it was collected - registration, defending legal claims, customising our services, fulfilling legal obligations and more.
The actual retention period may vary for each purpose. The criteria used to determine the retention period include.
- How long is the personal information needed to provide services and keep our company running? This includes activities such as maintaining our service offerings, maintaining the security of our systems and maintaining relevant business and financial records. This is a generally applicable rule of thumb that is the basis for determining the retention period in most cases.
- Does the law require us to keep the data? Typically, this will be accounting regulations, tax regulations or the provision of legal services. In this case, we will keep it for that specified period of time.
- Are we subject to legal, contractual or similar obligations to retain data? Examples include laws governing mandatory data retention, government regulations to retain data related to investigations or data that must be retained for litigation purposes.
- Is there a contractual relationship between us? We will retain personal data for the duration of that relationship.
- Have you given us consent for any processing? If so, we will process your data for the duration of that consent.
Did you receive a business communication from us? Then you are our contractual partner to whom we provide our services. The commercial communication contains an offer of our other services or other offers for similar products and services. Since you have voluntarily chosen to use our services, we may send you commercial communications based on our legitimate interest. However, we will always properly indicate that these are commercial communications, including the ability to opt-out of receiving any commercial communications at any time.
We will send commercial communications from the email address air@refundio.eu for as long as your account or the contractual relationship exists.
You have the following rights in relation to our processing of your personal data.
Your rights are explained below to give you a clearer idea of their content.
The right of access means that you can ask us at any time to confirm whether or not the personal data concerning you are being processed and, if so, for what purposes, to what extent, to whom they are disclosed, for how long we will process them, whether you have the right to rectification, erasure, restriction of processing or to object, where we obtained the personal data and whether automated decision-making, including possible profiling, is taking place on the basis of the processing of your personal data. You also have the right to obtain a copy of your personal data, the first provision of which is free of charge, and we may charge a reasonable administrative fee of €10 for further provision.
The right to rectification means that you can ask us to correct or complete your personal data at any time if it is inaccurate or incomplete.
The right to erasure means that we must erase your personal data if (i) it is no longer necessary for the purposes for which it was collected or otherwise processed, (ii) the processing is unlawful, (iii) you object to the processing and there are no overriding legitimate grounds for the processing, (iv) we are under a legal obligation to do so, or (v) in relation to personal data for which you have given consent to the processing, you withdraw that consent.
The right to restrict processing means that until we have resolved any disputed issues regarding the processing of your personal data, we may not process your personal data other than by storing it and, where appropriate, using it only with your consent or for the establishment, exercise or defence of legal claims.
The right to object means that you can object to us processing your personal data based on legitimate interest. If submitted, this objection will be evaluated and we will then tell you whether we have complied with it and will no longer process your data, or that the objection was not justified and the processing will continue. In any case, processing will be restricted until the objection is resolved. If you object to direct marketing (sending commercial communications), we will stop sending you further commercial communications.
The right to data portability means that you have the right to obtain personal data relating to you which you have provided to us on the basis of consent or a contract and which is also processed by automated means, in a structured, commonly used and machine-readable format, and the right to have that personal data transmitted directly to another controller.
If you have a comment or complaint about data protection or a query about the person responsible for data protection in our company or exercise any of your rights, please contact us at air@refundio.eu. We will respond to your queries or comments within one month.
Our activities are also supervised by the Data Protection Authority, to whom you can lodge a complaint if you are dissatisfied.
Changes to the policy
The Policy may change over time. If a change occurs, we will provide you with sufficient notice. You also need not worry and we will send you the original version of this Privacy Policy upon request.
This Policy is effective as of June 20, 2024.