1. Data controllers:
1) Novian group company that manages an appropriate social media account and whose details are listed in the account’s contact information (Data Protection Officer’s e-mail address: email@example.com)
2) social media platform operators: Facebook Int., Linkedin, Youtube.
In certain cases of data processing, together with platform operators we act as joint controllers within the meaning of Article 26 of the GDPR.
2. Liability of Platform Operators
We can make only limited influence on the processing of data by operators of social media platforms, such as administration of members and posting of information. Where we can make influence and set data processing parameters, we oversee, to the extent we can, that processing by a social media platform operator is carried out in a manner that is conducive to the protection of privacy. However, in many instances we cannot influence the processing of data by a social media platform operator and we do not know what data it processes.
A platform operator administers the whole IT infrastructure, sets its own data protection rules and maintains the relationship it has built with you as a user (if you are a registered user of a social media channel). In addition, only the operator is responsible for your user account data to which we as a company do not have access.
3. Purpose and legal ground for processing
The purpose of our processing of data within our accounts is to inform potential and existing customers about offers, products, services, IT news and to communicate with social media visitors on these topics, answer their questions, respond to positive feedback, criticism, and organise marketing games. The legal ground for this is Article 6(1)(1)(f) of the GDPR, i. e. our legitimate interest or that of third parties, i.e. provision of information and communication about our products.
We reserve the right to delete comments if it proves to be necessary. For example, in the case of posts that are infringing or illegal, hate comments, obscene (sexually explicitly content) or profane reviews or attachments (e.g. photos or videos) which, inter alia, infringe copyright, rights of individuals, provisions of the Criminal Code or Novian principles of ethical conduct. If necessary, we share your content on our account and contact you via the social media platform.
4. Data recipients / categories of data recipients
Data is transferred to third parties (e. g. other companies within the Novian group) only if doing so is necessary to answer your question. Please note that the content of some social media networks may also be shared directly on publicly available websites (e. g. in a questionnaire or comments), so other users may also see the fact of your involvement from your interactions with us. For example, in such cases, your win in a game can also be seen from social media posts. If you have registered with your real name on a social media network or you can be identified from photos in your account, it cannot be excluded that you will be identified by other visitors to our account.
We normally do not transfer data that you transmit to us through confidential channels (e. g. personal message, letter or e-mail) to third parties not related to the Novian group.
Upon your request, we can send you free of charge the current list of our partners who are recipients of your data.
5. Data Retention
We delete or make completely anonymous all personal information that you send us in secure messages to make queries (when you make suggestions, give positive feedback or criticism) no later than 90 days after we give our final reply to you.
All of your public posts in our accounts and in our timeline remain for indefinite time unless we delete them if the main topic has been updated, the posts are in breach of law or these posts have been deleted by you.
We cannot make influence in the cases where your data is deleted by the platform operator itself. In this context, data protection rules of each individual platform operator are applied.
6. Joint data controllers under GDPR Article 26(1)
Certain relationships with a social media operator are subject to Article 26(1) of the GDPR (Joint Controllers).
When a social media platform operator applies user tracking methods, the platform operator and we act as joint data controllers. User tracking can be implemented regardless of whether or not you are registered on the social media platform. The legal ground for the use of web tracking methods is Article 6(1)(f) of the GDPR. In accordance with the above provision, we have a legitimate interest to optimise the operation of the social media platform and the relevant follower account.
For more information about options available to you in order to exercise your rights to prohibit the use of tracking methods please read the privacy policies of platform operators.
We can only partially influence or disable the statistics provided to us by a social media platform operator but we monitor that the data we receive is not additional and not necessary.
Importantly, it cannot be excluded that a social media platform provider uses your account and behavioural data, for example, to analyse your habits, personal relationships, hobbies, etc. In this respect, Novian cannot influence the processing of your data by the social media platform provider.
7. Rights you have as a data subject
You have the following rights:
- Access your data and be informed how they are processed (right of access);
- Request rectification of personal data or, taking into account the purposes of the processing of personal data, have incomplete personal data completed (right to rectification);
- Obtain the erasure of your data (except storage) (right to erasure and ‘right to be forgotten’);
- Request that the data controller restrict the processing of personal data (right to restriction of processing);
- Exercise the right to data portability (right to data portability);
- Where the processing in based on the ground of a legitimate interest or based on your consent, object to the processing or, if your consent has been given, withdraw your consent at any time;
- Lodge a complaint with the State Data Protection Inspectorate.
You can exercise your rights as a data subject by contacting us using the details provided above.