Privacy Policy
We respect the privacy of every person who visits or registers with www.platonfinance.com or uses the Platon Finance mobile applications for iPhone and Android (the “Sites”) and who uses the services that we make available from the Sites as well as through our customer services facilities (our “Services”) and we are committed to ensuring a safe online experience.
1. Purpose Of This Policy
This privacy policy (“Privacy Policy”) explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party, including someone who has purchased a gift for you, and the purposes for and the basis on which we process your personal information. This Privacy Policy also sets out your rights in respect of our processing of your personal information.
This Privacy Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer it and/or provide you with access to it.
This Privacy Policy is intended to assist you in making informed decisions when using the Sites and our Services. Please take a moment to read and understand it. Please note that it should be read in conjunction with our General Terms and Conditions.
This Privacy Policy may be amended from time to time so please check it regularly.
2. Who Are We And What Do We Do?
The Sites and our Services are operated by Platon Finance s.r.o. (“we”, “us” or “our”).
Platon Finance s.r.o. is the data controller responsible for your personal information obtained in connection with the provision of our Sites and Services.
Platon Finance s.r.o. is a company with Identification No. 51402343, with its registered office at Klincová 37/B, Bratislava – Ružinov district, 821 08.
3. How To Contact Us?
If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by:
- sending an e-mail to: policy@platonfinance.com; or
- post at: Platon Finance, s. r. o., Klincová 37/B, Bratislava – Ružinov district 821 08
4. What Personal Information Do We Collect And How Do We Use It?
- Directly from you, either in person, via our Sites, on our social media pages or when you contact us or someone contacts us on your behalf;
- Automated technologies, cookies, server logs and other similar technologies;
- From our group companies and third party service providers in the course of providing their services to us in connection with your use of our Sites and Services. Please see section 7 Who do we share your personal information with? to find out more about these group companies and third party service providers;
- Providers of social media platforms (such as Facebook, Twitter and Instagram) where you share our content through social media, by liking us on Facebook, following or tweeting about us on Twitter; and
- Otherwise as explained below in this What Personal Information do we collect and how do we use it? section.
Our primary goal in collecting personal information about you is to: (i) provide our Services to you and carry out requests made by you; (ii) verify your identity and age; (iii) help us improve our products and services and develop and market new products and services; (iv) investigate or settle inquiries or disputes; (v) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vi) enforce our agreements with you; (vii) protect the rights, property or safety of us or third parties; (viii) provide support for the provision of our Services; and (ix) use as otherwise required by law.
In particular, we use your personal information for the following purposes:
4.1 Fulfilment Of Products And Services
We collect and maintain personal information that is voluntarily submitted to us during the use of the Sites and/or our Services. We use the contact and payment details which are provided to us so that we can fulfil the supply of products and services which have been ordered from our Sites. We will use the contact information to send you service related communications relating to these orders. This includes your purchase of products and services, your attendance at events hosted by us or our third party partners.
What is our legal basis?
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you.
4.2 Providing And Administering Online Accounts
If you register for a Platon Life online account (including an online account created in connection with your Platon Life membership), we will ask you to provide your name, family name, email address and a country where your stay. We will also ask you to provide a password for your account. You can update and amend the contact details and some other personal information we hold about you at any time through your account. You can change your email address provided to us by sending a request to our technical support via email to support@platonfinance.com.
We will use this personal information to provide you with the online functions available within the account, including facilitating your purchase of our products and services via your account (where this function is available) and service communications. This personal information is also used to identify you when you visit and interact with other areas of our Sites.
You can also ask for secured storage of payment card details by our payment service providers who process payments and store your payment card details to speed up the process of purchasing products and services online. Please note that payment card details you provide, and choose to store, are always provided directly by you to the chosen payment service provider and they will store the payment card details for you.
What is our legal basis?
It is necessary for us to use your personal information to perform our obligations and exercise our rights in accordance with any contract that we may have with you.
4.3 Your Feedback About Our Products And Services
From time to time we will contact you to invite you to provide feedback about our products and services in the form of online surveys or providing us with your feedback. We use this information to help us improve the quality of service provided by our staff or cooperating persons. We also use your feedback to monitor the quality of our products and services, to develop our business and to assist with the selection of future product and service lines.
What is our legal basis?
It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.
4.4 Customer Insight And Analysis
Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Sites, or from your mobile. This includes the following:
- an IP address to monitor Sites traffic and volume;
- a session ID to track usage statistics on our Sites;
- information regarding your personal or professional interests, demographics, buying habits, experiences with our products and contact preferences.
Our web pages, mobile applications and e-mails contain “cookies” "web beacons" or “pixel tags” (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag.
In some of our e-mail messages, we use a “click-through URL” linked to certain websites or applications administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications. Please, see our Cookie Policy for further information.
This information is used to create profiles and insights about your habits and the habits of our other customers and helps us to get to know our customers better. Where we have your permission to use information about your location, we may use it for customer insight purposes and to provide you with information about the services available within your local area, for example by sending you push notifications sent via mobile applications.
By using this information, we are able to measure the effectiveness of our content and how visitors use our Sites and our Services. This allows us to learn which pages of our Sites are most attractive to our visitors, which parts of our Sites are the most interesting, how customers use our Services and what kinds of offers our customers like to see.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other customers.
4.5 Marketing Communications
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Email, text and push notification marketing.
We use the information that we observe about you from your interactions with our Sites, our email communications to you and/or your email address and mobile phone number to send you marketing communications by email and text message, where you have consented to receive such marketing communications, or where we have another lawful basis to do so.
What is our legal basis?
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.
We will only send you marketing communications via email, text message and/or push notification where you have consented to receive such marketing communications, or where we have a lawful right to do so. -
Online personalised advertising.
We use the information that we observe about you from your interactions with our Sites, our email communications to you and/or the products and services you have purchased or viewed to provide you with personalised online advertising.
What is our legal basis?
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes. -
Social media remarketing.
We use the information that we observe about you from your interactions with our Sites, our email communications to you and/or the products and services you have purchased or viewed to provide you with personalised advertising on social media channels operated by Facebook and/or Google where you are a registered user of such services.
We do this using Facebook Customer Audiences and/or Google Customer Match respectively. Please note that such activity requires that we share your encrypted email address with Facebook and/or Google and is also subject to the privacy choices you have elected to make on such services.
What is our legal basis?
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes. -
Social media insight.
Where you are a registered user of Facebook, or of a Google service, we may use your email address in an encrypted format to enable Facebook and Google to find other registered users of their services that share similar interests to you based on:
•information that we observe about you from your interactions with our Sites, our email communications to you and/or the products and services you have purchased or viewed; and
•the information Facebook and/or Google hold about you.
We do this using Facebook Custom Audiences and/or Google Similar Audience respectively. Please note that such activity is subject to the privacy choices you have elected to make on such services.
What is our legal basis?
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.
Use of Anonymised Personal Information
Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
4.6 Business Administration And Legal Compliance
- to comply with our legal obligations;
- to protect our business and your accounts from fraud and other illegal activities;
- to protect our property;
- to enforce our legal rights;
- protect rights of third parties; and
- in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
What is our legal basis?
Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.
4.7 Other Purposes
5. How Do We Obtain Your Consent?
Where our use of your personal information requires your consent, you can provide such consent:
- at the time we collect your personal information following the instructions provided; or
- by informing us by e-mail, post or phone using the contact details set out in this Privacy Policy.
The legal basis of consent is only used by us in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way.
You may at any time withdraw the specific consent you give to our processing your personal information. Please note even if you withdraw consent for us to use your personal information for a particular purpose we may continue to rely on other bases to process your personal information for other purposes.
6. Our Use Of Cookies And Similar Technologies
Our Sites use certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please, see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.
8. Transfers Of Your Personal Information Overseas
8.1 Internally within our group
We do not transfer your personal information abroad.
8.2 To external third parties
Where we transfer your personal information to external third parties, we take appropriate steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy and all applicable laws.
9. How Long Do We Keep Your Personal Information For?
Whenever we collect or process your personal information we will usually keep it for one year after our last interaction with you or otherwise in accordance with our data retention policy pursuant to which we do not retain personal information for longer than is necessary for the purposes for which it is collected. We will keep personal information you give us in relation to any contract that we have with you for three years and in some circumstances such as in relation to damages caused to you, us or any third party for ten years. If your information is only useful for a short period e.g. for specific marketing campaigns we may delete it. At the end of that retention period, your personal information will either be deleted or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning. We keep the length of time that we hold your personal information for under review.
10. Confidentiality and security of your personal information
- unauthorised access;
- improper use or disclosure;
- unauthorised modification; and
- unlawful destruction or accidental loss.
All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.
11. How To Access Your Information And Your Other Rights
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Your right of access.
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee. -
Your right to rectification.
If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
If you have an online account, you can log in and amend your contact details and email and text marketing preferences whenever you like. -
Your right to erasure.
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly. -
Your right to restrict processing.
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly. -
Your right to data portability.
You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice. -
Your right to object.
You can ask us to stop processing your personal information, and we will do so, if we are:
- relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
- processing your personal information for direct marketing.
You can ask us to stop sending you marketing communications sent to you by email or text at any time by using the ‘opt-out’ or ‘unsubscribe’ link that we will present to you in the marketing communication. This will be considered as withdrawal of your consent, as our legal basis to contact you by email or text for marketing purposes is ‘consent’. Please note that it may take us a few days (but usually no longer than 14 days) to ensure our marketing systems are updated and during this period you may still receive marketing communications from us. -
Your rights in relation to automated decision-making and profiling.
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us. -
Your right to withdraw consent.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. -
Your right to lodge a complaint with the supervisory authority. For more information click here.
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the Office for Personal Data Protection, seated at Pplk. Sochora 727/27, 170 00 Prague 7-Holešovice. You can find details about how to do this on the website at https://www.uoou.cz or by calling their helpline on +420 234 665 111, or by email: posta@uoou.cz.
12. Changes To The Privacy Policy
To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will post any changes on our Sites to keep you aware and if you have an active Platon Life online account we will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.