Privacy policy

(Updated as of 08.07.2022)

This Privacy Policy defines the principles of Personal Data processing by Transportly s. r. o., with its registered office at Tolstého 170/22, 040 01 Košice – municipal district Sever, Slovak Republic; identification no. 53 692 462; registered at Business Register of the District Court Košice I; section: Sro; insert No. 51258/V (hereinafter referred to as “Transportly” or “we”), in order to create an effective and consistent Privacy Policy pursuant to the applicable law.

1. General Introduction

This Policy on the Processing and Protection of Personal Data (hereinafter referred to as the “Privacy policy”) reflects the relevant European legislation, i.e. 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 (General Data Protection Regulation) (hereinafter referred to as the “GDPR”) and the legislation of the Slovak Republic, in particular the Act No. 18/2018 Coll. on the Protection of Personal Data, and on the amendment of certain acts (hereinafter referred to as the “Data protection act”), as well as any subordinate legislation. Its aim is to regulate the way of working with Personal Data within Transportly.

We are aware that the protection of Personal Data depends on specific powers in the field of Personal Data processing, as well as on the day-to-day actions of authorized persons, and/or all parties involved in Transportly’s business activities. The protection of Personal Data, as a type of information assets subject to the specific regulation and protection within the meaning of the Data protection act, falls within a broader framework of the protection of information assets. Adherence to the principles and rules of this Privacy policy shall contribute to the spread of a positive culture in the work with Personal Data, and to the overall level of security and protection of Personal Data in Transportly. The promotion of the principles set out herein is part of an ongoing and purposeful process covering several levels, i.e. the methodological, executive and control one.

Transportly, as the Controller under the GDPR and the Data protection act, headed by its statutory body, is responsible for the overall supervision of the system of protection and processing of Personal Data within Transportly, especially for the adoption and approval of the appropriate technical and organizational measures that correspond to the method of processing of the Personal Data, taking into account, in particular, the applicable technical means, the confidentiality and importance of the Personal Data processed, as well as the extent of possible risks that are capable of compromising the security of the Personal Data processing.

For the purposes hereof, Transportly is considered to be the Controller.

2. Definitions

Terms used in the text hereof have the meanings as defined below:

• Data Subject is any natural person, to whom the Personal Data relate;

• Supervisory Authority is an independent public authority set up by a Member State under Article 51 of the GDPR. In the Slovak Republic, the Office for Personal Data Protection of the Slovak Republic is considered as the Supervisory Authority;

• Processing Restriction is an identification of the retained Personal Data in order to limit the processing thereof in the future;

• Personal Data are any information relating to an identified or identifiable natural person, who is in any case the Data Subject. An identifiable natural person is a person, who can be identified directly or indirectly, in particular by reference to an identifier, such as the name, identification number, location data, and, online identifier, or by reference to one or more elements specific to the physical, physiological, genetic, mental, the economic, cultural or social identity of that natural person;

• Location data are any data processed in an electronic communications network or by an electronic communications service indicating the geographical position of Data Subject, including data relating to:
(a) latitude, longitude or altitude in relation to location of Data Subject;
(b) the direction of transport; or
(c) the time the location information was recorded

• Controller is Transportly as a legal entity that determines the purposes and means of Personal Data processing;

• Recipient is a natural or legal person, public authority, agency or other entity, to which Personal Data are provided, regardless of whether or not it is a third party. Public authorities, which may receive Personal Data for the purpose of the particular collection pursuant to the law of the EU or a Member State, shall not be considered Recipients;

• Profiling is any form of automated Personal Data processing, which consists of the use of such Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyze or anticipate aspects of the Data Subjects related to their work performance, assets, health, personal preferences, interests, reliability, behavior, positions or movements;

• Pseudonymization is the Personal Data processing in such a way that the Personal Data can no longer be assigned to a specific Data Subject without the use of additional information provided that such additional information is kept separate and is subject to the technical and organizational measures to ensure that the Personal Data cannot be assigned to an identified or an identifiable natural person;

• Processor is a natural or legal person, public authority, agency, or other entity that processes Personal Data on behalf of the Controller. Based on a special agreement with the Controller, the Processor may also be any of the Partners, as well as the persons, who provide services to Transportly upon special contractual relationships;

• Data Subject’s Consent is any freely given, specific, informed and unambiguous expression of the Data Subject’s will, by which he/she expresses his/her consent to the Personal Data processing concerning him/her in the form of a declaration or unambiguous confirmatory act;

• Third Country is a country, which is not a Member State of the European Union or a party to the Agreement on the European Economic Area;

• Transportly Driver App means the Transportly’s software application “Transportly Driver” designed to run on a mobile device such as a phone, tablet, or watch, available via official distribution storefront Google Play and App store;

• Transportly Website means the Transportly’s website www.transportly.eu

• Contract means, in particular, but not exclusively, any agreement that Transportly has entered into with any legal or natural person, and from which Transportly derives certain rights and obligations.

3. Process Management Strategy within Personal Data Processing and the Personal Data Processing Principles

The system of monitoring, management and control of activities within the Personal Data processing is an integral part of the system of effective governance and functioning of Transportly as such.

Transportly’s Personal Data Protection Strategy is based on the Personal Data Processing Principles, defined by Transportly’s setting, daily operation and activities in the Personal Data processing operations. The Personal Data Processing Principles identified herein shall also guide and build the overall awareness in the field of Personal Data processing among representatives and agents of Transportly. This Privacy policy also aims to ensure and maintain the integrity and protection of Personal Data within Transportly.

In connection with any possible legislative changes in the area of Personal Data protection, as well as possible changes in the technical standards, Transportly ensures constant monitoring of the relevant regulation, as well as evaluation of potential non-compliance of the Privacy policy with the above-mentioned regulation.

To ensure a comprehensive and detailed fulfillment of Transportly’s obligations as an Controller arising from the GDPR and the Data protection act, Transportly has defined the main principles in the Personal Data processing (hereinafter referred to as the “Personal Data Processing Principles”). These are the following Personal Data Processing Principles:

• Legality, Fairness and Transparency: The Personal Data processing is legal and transparent in relation to the Data Subject;

• Restriction of the Purpose: Personal Data are collected for the specific, explicit and legitimate purposes and may not be further processed in a way incompatible with those purposes;

• Data Minimization: Personal Data processed shall be adequate, relevant and restricted to the extent necessary for the purposes, for which they are processed;

• Accuracy: Personal Data shall be correct and, where necessary, kept up to date, and any and all necessary measures must be taken to ensure that Personal Data, which are incorrect in view of their purposes, are deleted or rectified without delay;

• Minimization of Storage: Personal Data shall be kept in a form, which permits identification of the Data Subject for no longer than is necessary for the purposes, for which the Personal Data are processed;

• Integrity and Confidentiality: Personal Data are processed in a way that guarantees adequate security thereof, including protection against any unauthorized or illegal processing and accidental loss, destruction or damage thereof, through the appropriate technical or organizational measures. Within Transportly, only representatives and agents, who necessarily need Personal Data within the scope of their job classification, have access thereto;

• Responsibility: Transportly, as the Controller, is responsible for compliance with the referred Personal Data Processing Principles in Transportly.

4. Scope of Personal Data Processed

Transportly processes only such Personal Data that it necessarily needs primarily for the purpose of fulfilling the Contract, as well as for the fulfillment of its legal and contractual obligations, and for the protection of its legitimate interests.

Transportly ensures that it processes only the scope of Personal Data about/of the Data Subject that is necessary for the fulfillment of the purpose of the respective processing.

Transportly also applies the principle of minimizing the Personal Data processing in connection with the Personal Data provided to Transportly upon the Consent of the Data Subject.

The processed Personal Data of the Data Subjects may include, but are not limited to, the following categories of Personal Data:

Data you submit to us in direct connection with the service provided by Transportly or in connection with the competition organized by Transportly, namely:

• data required to register and create an account in the Transportly Driver App - registration data such as name, surname, e-mail address or telephone contact;

• data needed to create an order and use the Transportly Driver App features - for example, name, surname, delivery address, payment details, e-mail address, telephone contact and Location data. Depending on the chosen feature, it may also be necessary for its proper functioning to process the data listed on identity document, photo, data from the criminal record or financial data, if these are considered personal data;

• data you provide when using the selected service - for example, photos, posts, comments;

• data necessary to participate in the competition, manage it and evaluate the competition we organize, if you choose to participate in them - for example, name, surname, address of permanent residency, photo;

• data necessary to participate in promoting events, if you choose to participate in them for example, name, surname, address of permanent residency, photo;

• data related to your inquiries resolved by our customer support - e.g. complaints, suggestions, notices;

Data we 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 the services we provide or provide;

• analytical data on traffic and use of our services;

Data obtained in connection with the use of our services, namely:

• information about the interaction with Transportly, for example, how the services were used, how to log in, where you are from our company and how long you used them, reaction times, download errors, how to access the services and stop using them, 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 at the link: www.transportly.eu

The specification of the categories of Personal Data per Data Subject is always only a subset of the above list.

If the consent of the Data Subject is required for the processing of certain categories of Personal Data, the Data Subject is notified of this fact; the relevant Consent of the Data Subject shall indicate all Personal Data that will be processed upon such Consent of the Data Subject, including the purpose, for which such Personal Data will be processed.

5. Sources of Personal Data

In most cases, Transportly processes Personal Data provided to it in connection with the performance of the Contract, or directly by the Data Subjects.

The Personal Data of the Data Subjects may also be obtained from the publicly available sources, which have been disclosed under the applicable legislation.

6. Purposes and Legal Bases of Personal Data Processing

It is in the interest of Transportly to process the Personal Data of the Data Subjects only for a specific and current purpose.

Transportly primarily processes Personal Data, as this is necessary for the purpose of fulfilling the Contract.

Transportly also processes certain Personal Data of the Data Subjects, as such processing is necessary for the purposes of legitimate interests, which Transportly pursues as the Controller.

Transportly requires the consent of the Data Subjects with the Personal Data processing in adequate cases, if the nature of the Personal Data processing so requires.

6.1. Contractual Relations

The purpose of the Personal Data Processing is to conclude, and fulfill the subject of, the Contract.

To use the Transportly Driver App and its features, it is necessary to register in the Transportly Driver App and create a user account. In most cases, the legal reason for processing your personal data is the fulfillment of a contract.

The legal basis for the processing is the performance of the Contract, as well as the legitimate interests of Transportly as the Controller, by which Transportly monitors effective communication with the Data Subjects. Consent to the Personal Data Processing is not required in this case. The provision of Personal Data of the Data Subject is a legal and contractual requirement; if these are not provided, Transportly cannot fulfill its legal obligations arising from the relevant legislation, or the Contract cannot be fulfilled. The Data Subjects is obliged to provide his/her Personal Data or, pursuant to the GDPR and the Data protection act, tolerate the provision of his/her Personal Data because, if the Personal Data had not been provided, Transportly would be unable to communicate effectively with the other party or with Data Subjects.

In this case, we will work with the contact information you provide us while using Transportly Driver App, especially through the registration form.

Through the Transportly Driver App’s user account, you are able to:

place your own transport order;
match vehicles and drivers;
monitor transport in real time;
use the invoicing module of the Transportly Driver App;
store the history of transports and documents.

For this purpose, we obtain your personal data because we provide you with our service (use of the Transportly Driver App), freely chosen by you in accordance with our terms and conditions of the chosen service. By accepting terms and conditions of your chosen service, a contract is concluded between you and Transportly.

6.2. Legitimate Interests of Transportly

The purpose of Personal Data Processing is the legitimate interests of Transportly. The legitimate interests of Transportly include:

Protection of the security and interests of the Data Subjects;
Protection of the Transportly’s assets;
Prudent business of the Transportly;
Promotion of goods, services, reputation, and image of Transportly. The legal basis of the processing includes the legitimate interests of Transportly, which, however, must not prevail over the interests or fundamental rights of the Data Subjects. Consent to the Personal Data Processing is not required in this case.

6.3. Fulfillment of Legal Obligations

The purpose of Personal Data Processing is to fulfill the legal obligations, which the relevant legal regulations or other legislation do/may impose on Transportly.

The legal basis of the processing is the fulfillment of the legal obligations of Transportly, which do/may result for it from the relevant legal regulations or other legislation. Consent to the Personal Data Processing is not required in this case.

6.4. Direct Marketing − Market Research and Distribution of General Business Information

The purpose of Personal Data processing is the implementation of direct marketing, i.e. a market research and distribution of commercial communications by all means, including the electronic means of communication. The market research includes an evaluation of the Transportly’s activities in connection with the operation of the Transportly Website or Transportly Driver App, data on the use of the distributed business announcements and subsequent outputs.

The legal basis for the processing is the Consent of the Data Subject. For the Data Subjects to make a choice, segmentation may be performed based on the data obtained (e.g. by age, areas of interest, identified preferences, etc.).

This processing is optional and voluntary for the Data Subjects and may be terminated at any time at the request of the Data Subject.

6.5. Legal Disputes and Other Legal Proceedings

The purpose of Personal Data processing is to keep records and handle legal disputes and other legal proceedings, by which Transportly monitors, in particular, proving, asserting, or defending its legal claims.

The legal basis for the Personal Data processing is the legitimate interests of Transportly as the Controller, by which it monitors the proving, asserting, or defending its legal claims.

Consent to the Personal Data Processing is not required in this case.

6.6. Registry of Postal Communication

The purpose of Personal Data processing is to keep records of incoming and outgoing mail.

The legal basis for processing is the legitimate interest of Transportly as the Controller, by which it monitors the initial and general registry of mail for the purpose of keeping a clear list thereof provided that the principle of minimization is observed.

Data Subjects are obliged to provide their Personal Data; otherwise, there may be no full- fledged postal communication and its registry. The Personal Data of the Data Subjects are not provided to other Recipients.

Consent to the Personal Data processing is not required.

6.7. Registry Management

The purpose of Personal Data processing is the proper management and administration of registers. The legal basis for the Personal Data processing is the fulfillment of a legal obligation pursuant to the Act No. 395/2002 Coll. on Archives and Registries, and on amendments to certain acts, as amended, and/or other related specific legislation.

The provision of Personal Data of the Data Subject is a legal requirement; in case of non- provision thereof, Transportly cannot fulfill its legal obligations arising out of the relevant legislation.

Consent to the Personal Data Processing is not required in this case.

6.8. Providing of value-added service

Value-added service is any service which requires the processing of Personal data including Location data beyond that which is necessary for fulfilling the Contract, transmission of necessary communication or the billing in respect of that communication. This may include, for example, a call service that locates the driver of a broken-down vehicle, or using location data to target location-specific content.

This processing is optional and voluntary for the Data Subjects and may be terminated at any time at the request of the Data Subject.

7. Recipients of Personal Data

Transportly processes Personal Data of Data Subjects through its professionally trained employees, persons, with whom Transportly cooperates upon other contractual relationships, or through external service providers.

In addition to the Transportly, the Personal Data of the Data Subjects may also be processed by the Recipients, i.e. the categories of Recipients, which may include, in particular:

Contractual partners of Transportly, who provide administrative services and other related activities for Transportly upon the special contractual relationships;
Payroll and financial accounting companies;
Companies providing the intellectual property protection agenda and performing Due
Diligence of Transportly;
Investors and advisers of Transportly;
Providers of IT services, or companies providing security within Transportly’s premises.

In the event that the Personal Data of the Data Subjects are processed by a contractual partner of Transportly in the name and on behalf of Transportly, Transportly enters into a contract with such contractual partner on the Personal Data processing pursuant to the applicable legislation in the field of Personal Data protection, and such a contractual partner becomes entitled to process Personal Data exclusively on the basis of the documented instructions of Transportly and such a partner alone, as well as its employees, are bound by the duty of confidentiality in relation to the Personal Data of the Data Subjects to be processed.

8. Security of Personal Data Processing

In the interest of protecting the rights and freedoms of natural persons in the Personal Data processing, Transportly has taken appropriate technical and organizational measures in order to ensure compliance with the requirements of the GDPR and the Data protection act.

Transportly emphasizes the security of the Personal Data processing and makes constant efforts to prevent any security incidents that could lead to a risk of threat to the rights and freedoms of the Data Subjects. The security of the Personal Data processing is regularly assessed with regard to the latest knowledge and the nature of the Personal Data processing.

All Personal Data obtained from the Data Subjects by Transportly are processed with a high level of organizational and technological security. Transportly regularly reviews and, where possible, applies reasonable safeguards for, the security of Personal Data, which may include encryption or Pseudonymization.

The compliance of the Personal Data processing by Transportly with the GDPR and the Data protection act, as well as with any other applicable legal regulations of the European Union and the internal rules of the Transportly, is monitored by the relevant persons authorized by Transportly as the Controller to supervise the protection of Personal Data.

9. Rights of Data Subjects

It is important for Transportly that Data Subjects have control over their Personal Data and that the Personal Data of each Data Subject are processed lawfully.

It is in the interest of Transportly to enable any Data Subject to exercise their rights in connection with the protection of their Personal Data as easily as possible. If the Data Subjects wish to exercise any of their rights granted to them by the GDPR and the Data protection act, they may do so electronically to the e-mail address info@transportly.eu, by post by sending a written request to Transportly’s address: Transportly s. r. o., Tolstého 22, Košice 040 01, Slovak Republic, by telephone at the telephone number +421 911 271 969, or in person at the registered office of Transportly, by demanding a meeting with a person authorized to handle the Personal Data processing.

The Data Subjects have the right to request access to their Personal Data from Transportly. The Data Subjects have the right to correct, delete, or restrict the Personal Data processing, as well as the right to object to the Personal Data processing, and the right to the portability of Personal Data. The Data Subjects also have the right to withdraw their consent to the Personal Data processing, as well as the right to lodge a complaint with the Supervisory Authority.

Transportly shall, without undue delay, provide the Data Subject with the information on the measures taken on upon the Data Subject’s request under this Article hereof, no later than one (1) month from the receipt of the request. That period may be extended by further two (2) months, if necessary. Transportly shall inform the Data Subject of any such extension within one (1) month of receipt of the request, by stating the reasons for the delay. If the Data Subjects have submitted the request by electronic means, the information shall be provided, as far as possible, by electronic means, unless the Data Subjects have requested otherwise.

If Transportly does not take action at the request of the Data Subject, it shall inform the Data Subject, without delay and at the latest within one (1) month from the receipt of the request, of the reasons for the failure to act and of the possibility to lodge a complaint with the Supervisory Authority and apply a judicial remedy.

9.1. The Right of the Data Subject to Access the Personal Data

The Data Subjects have the right to obtain confirmation from Transportly as to whether Personal Data relating to the Data Subject are being processed. If such data are processed, they have the right to access them. In this connection, the Data Subject also has the right to obtain information on the purposes of Personal Data processing, the categories of Personal Data concerned, Recipients or categories of Recipients, the expected storage period of Personal Data, the existence of the Data Subject’s rights in connection with Personal Data processing, the information on the source of Personal Data, if these have not been obtained from the Data Subject, and/or the existence of automated decision-making, including Profiling.

Information on the Personal Data processing is adequately supplemented and updated whenever the facts listed above change.

9.2. The Right of the Data Subject to Correct Personal Data

Transportly is interested in processing only the current and accurate Personal Data of/about the Data Subject. In this connection, the Data Subjects have the right to have Transportly, without undue delay, correct any incorrect Personal Data of/about the Data Subject processed, or to supplement incomplete Personal Data. In this context, the Data Subjects shall be adequately informed of the right of rectification at each contact and shall be invited to make active use of it.

9.3. Right of the Data Subject to Delete Personal Data

The Data Subjects have the right to demand that their Personal Data processed by Transportly be immediately deleted, if any of the following reasons has been met:

a) Personal Data are no longer needed for the purposes, for which they were obtained or otherwise processed;

b) The Data Subject withdraws his/her consent, on the basis of which the Personal Data have been processed;

c) The Data Subject objects to the Personal Data processing;

d) Personal Data are processed illegally;

e) Personal Data must be deleted in order to comply with legal obligation.

In connection with the fulfillment of obligations related to the Data Subject’s right to deletion, Transportly is able to identify relevant Personal Data within its systems and ensure their subsequent deletion to meet the requirements of the GDPR and the Data protection act.

However, the Personal Data of the Data Subject will not be deleted if the processing is necessary to:

a) Exercise the right to freedom of expression and information;

b) Fulfill a legal obligation;

c) Fulfill a task carried out in the public interest or in the exercise of public authority entrusted to Transportly;

d) To archive in the public interest, for the scientific or historical research purposes or for statistical purposes;

e) Prove, assert or defend the legal claims of Transportly.

If Personal Data are deleted, each Recipient will be duly informed by Transportly.

9.4. The Right of the Data Subject to Restrict the Personal Data Processing

The Data Subject has the right to demand from Transportly to restrict the processing of the Personal Data about/of the Data Subject in cases, where:

a) The Data Subject challenges the accuracy of the Personal Data;

b) The Personal Data processing is illegal and the Data Subject objects to their deletion and requests their processing to be restricted;

c) Transportly no longer needs Personal Data for the processing purposes, but the Data Subject does need them to prove, assert or defend legal claims;

d) The Data Subject objects to the Personal Data processing. In this case, Transportly will limit the Personal Data processing until the end of the proportionality test, i.e. until it is verified whether the legitimate reasons on the part of Transportly outweigh the legitimate reasons of the Data Subject.

If there is a Restriction on the Personal Data processing, Transportly will adequately inform each Recipient.

Methods for restricting the Personal Data processing may include, depending on the specific situation, inter alia, any temporarily transfer of the selected data to another processing system, preventing the users from accessing selected Personal Data, or temporarily deleting of the published data from the Transportly Website or Transportly Driver App.

Any further Personal Data processing should be ensured in such a way that the Personal Data are not the subject to any further processing operations and cannot be changed.

9.5. The Right of the Data Subject to the Portability of Personal Data

If the Personal Data processing is performed by any automated means and the legal basis for the Personal Data processing is the Consent of the Data Subject or the performance of the Contract, the Data Subjects have the right to obtain their Personal Data provided to Transportly in a structured, commonly used and machine-readable format, and the right to transfer these data to another Controller. In the interest of the Data Subject and as far as technically possible, Transportly will transfer the relevant Personal Data directly to another Controller.

9.6. The Right of the Data Subject to object to the Personal Data Processing and Automated Individual Decision-Making

The Data Subjects have the right to object to the Personal Data processing, which is necessary for the performance of a task carried out in the public interest, or in the exercise of public power entrusted to Transportly, or which is necessary for the purposes of the legitimate interests of Transportly, and which concerns them. The Data Subjects also have the right at any time to object to the Personal Data processing for the direct marketing purposes. In connection with the Personal Data processing pursuant to the first and second sentence above, the Data Subjects may also object to the Profiling based on such processing.

If exercising the right to object, Transportly will not further process the Personal Data of the Data Subjects, unless it demonstrates the legitimate reasons necessary for processing the Personal Data, which outweigh the interests, rights and freedoms of the Data Subjects or the reasons for proving, asserting or defending legal claims.

The Data Subjects have the right not to be subject to a decision of Transportly, which is based exclusively on automated processing, including Profiling, and which has legal effects concerning, or similarly significantly affecting, them.

9.7. The Right of the Data Subjects to Lodge a Complaint with the Supervisory Authority

If the Data Subjects suspect that Transportly processes their Personal Data illegally, they are entitled to file a complaint with the Supervisory Authority. The Supervisory Body competent in the territory of the Slovak Republic is the Office for Personal Data Protection of the Slovak Republic. If a complaint was lodged by the Data Subject, the relevant representatives and agents of Transportly involved in the processing of the Personal Data concerned shall provide the cooperation necessary to settle the proceedings in question.

9.8. The Right to Revoke the Consent of the Data Subject

If Personal Data are processed, for which the Consent of the Data Subject is required pursuant to the GDPR and the Data protection act, Transportly requires the Data Subjects to grant consent for the relevant purpose of Personal Data processing to the processing of their Personal Data, which is a clear expression of will and a free, specific, informed and unambiguous expression of consent to the processing of their Personal Data. If the Data Subjects have consented to the processing of their Personal Data for a specific purpose, they have the right to revoke their consent at any time, without prejudice to the lawfulness of the processing based on the consent given prior to its revocation.

10. Storage Period of Personal Data

Transportly stores the Personal Data of the Data Subjects for the duration of their processing, i.e. for various lengths of time, depending on the reason and purpose of their processing. In general, Transportly processes Personal Data of Data Subjects:

For a period required by the relevant generally binding legal regulation, if Transportly processes Personal Data for the purpose of fulfilling its legal obligations;
For a duration of the contractual relationship established by the Contract, or the duration of the pre-contractual relationships, if it processes Personal Data due to the performance of the Contract;
For the duration of the legitimate interest pursued by Transportly, if the Personal Data processing is necessary for this purpose;
For a period expressly stated in the Consent of the Data Subject, or until the revocation thereof, if it processes Personal Data upon the Consent of the Data Subject.

In order to ensure that Personal Data are not kept longer than necessary, Transportly sets deadlines for the deletion or regular review of Personal Data. Personal Data may only be processed for as long as the purpose of the processing persists. After this period, the Personal Data shall be disposed of without delay in accordance with the principle of minimized storage of Personal Data and, after the purpose of processing the Personal Data ended, these shall be destroyed in all forms, in which they were processed. The Data Subjects may, at any time, ask Transportly to indicate, how long their Personal Data will be kept by Transportly.

Upon expiration of the relevant storage periods, Transportly is entitled to process the Personal Data of the Data Subject only for compatible purposes or for special purposes, such as archiving or statistics.

11. Transfer of Personal Data to Third Countries

Personal Data of the Data Subjects may be the subject of cross-border transfers to Third Countries, which guarantee adequate protection of Personal Data.

In the event of a possible transfer of Personal Data to Third Countries, Transportly always undertakes to ensure that a sufficient level of protection of the Personal Data of the Data Subjects is ensured during the transfer of Personal Data to Third Countries.

Transportly does not transfer Personal Data to any Third Countries that do not guarantee adequate protection of Personal Data.

In the event that Transportly will carry out the transfer of Personal Data to Third Countries in the future, which do not guarantee an adequate level of protection, it undertakes to comply with the GDPR and the Data protection act, as well as other generally binding legal regulations.

12. Processors

Transportly may also use Processors to process Personal Data. In such a case, the relationship between the Processors and Transportly is governed by a contractual relationship.

In connection with the performance of the Contract, the Processors are mainly persons, who provide services to Transportly upon a special contractual relationship.

Transportly undertakes to cooperate only with such Processors, who contractually undertake to take appropriate technical and organizational measures so that the Personal Data processing meets the requirements of the GDPR and the Data protection act, and to ensure the protection of the rights of the Data Subjects. In addition to Partners, Processors can also include:

Providers of cloud solutions and services and other suppliers of technology and support for the functionality of the Transportly Website or Transportly Driver App;
Contractual partners providing various administrative services and other activities for Transportly;
Contractual partners providing archiving services for Transportly;
Marketing companies and operators of marketing tools providing data-analytical activities for Transportly statistical and reporting purposes for needs of Transportly;
Companies providing legal, accounting and tax advice to Transportly.

13. Automated Personal Data Processing, Individual Decision-Making, Including Profiling

The performance of the Contract may also include automated Personal Data processing. In the automated Personal Data processing, the automatic information systems are used, e.g. software, IT applications, and other support systems. The goal of the automated Personal Data processing is the effective fulfillment of the Contract.

In connection with the processing of the Personal Data of the Data Subjects, Transportly does not apply decision-making, which is based exclusively on automated processing, including Profiling, and which has legal effects concerning or similarly significantly affecting the Data Subjects.

14. Processing of Personal Data Through Cloud Solutions

Transportly also uses cloud solutions for the internal communication or communication with business partners. In order to protect the Personal Data shared within such cloud solutions, Transportly uses the state-of-the-art technical and software tools to encrypt data so that the protection and integrity of the shared data, which may also be Personal Data, is maintained.

15. Cookies and Web Beacons

The Transportly Website uses the cookies. Cookies are small text files that are stored on the Data Subject’s computer in a special Internet browser clipboard. Thanks to their use, which is, however, anonymous, it is possible to make full use of all the functions of the Transportly Website. Cookies thus facilitate the use of the Transportly Website and improve its functionality. Cookies are also used to monitor the behavior of the visitors to the Transportly Website as Data Subjects and subsequently adapt the content of the Transportly Website interface, simplify the use of individual subpages/log in options of the Transportly Website, and customize and restrict advertising campaigns and similar functionalities that would not be possible without cookies. The Data Subjects have the right to prohibit the use of cookies by changing the settings in their Internet browser. If the Data Subjects do not accept any cookies, they will not be able to use the full functionality and all the options of the Transportly Website.

The Transportly Websit emay also contain Web Beacons (internet tools that help detect interactions with the Transportly Website, set cookies, track a traffic on the Transportly Website, detect the number of open messages out of the total number sent, etc.). Web beacons or specially coded links may be incorporated in the Transportly’s flyers and marketing e-mails to determine, whether these messages have been read and whether the links containing these messages have been clicked on.

IP addresses are in no case provided to third parties and Transportly uses all necessary security measures to secure them. The Data Subjects have the right to receive the information about the use of their IP address.

16. Transportly WebsiteTraffic Analytics through Google Universal Analytics

The Transportly Website uses, or may use in the future, Google Universal Analytics, i.e. the Web Analytics Service provided by Google, Inc. (hereinafter referred to as “Google”). Google Universal Analytics uses cookies, which are text files placed in the computer of the Data Subjects, to assist in analyzing how visitors to the Transportly Website use it. The information generated by the cookies about your use of the Transportly Website (including the IP address of the Data Subject) is generally sent to, and stored by Google on, the servers in the United States (USA). However, if an anonymized IP address is activated on the Transportly Website, Google will first shorten the IP address of the Data Subject in the Member States of the European Union or other countries of the Agreement on the European Economic Area. Google will use this information for the purpose of evaluating the use of the Transportly Website by its visitors, producing reports on the activities on the Transportly Website, and providing other services relating to the use of the Transportly Website. The full IP address is sent to, and shortened by Google’s servers in, the USA only in exceptional cases. Google will not associate the IP address of visitors of the Transportly Website with other information held by Google. Data Subjects may refuse the use of cookies by selecting the appropriate settings in their Internet browser. However, if refusing to use cookies, the Data Subjects will not be able to use the full functionality of the Transportly Website. Users of the Transportly Websiteas Data Subjects may also prevent Google from collecting and using data (cookies and IP addresses) by downloading and installing a browser add-on available at https://tools.google.com/dlpage/gaoptout?hl=sk. Further information regarding Google’s Terms of Use and Privacy Policy can be found at https://www.google.com/Analytics/terms/gb.html, or on the website https://policies.google.com/technologies/cookies?hl=sk.

In case Data Subjects have any questions related to the protection of Personal Data, Transportly hereby invites them to contact Transportly in any form according to the preference of each Data Subject.

Transportly is entitled to modify, supplement or change this Privacy policy, in particular in order to incorporate legislative changes, update the purposes/means of Personal Data processing and the like. Transportly will not restrict the rights of the Data Subjects arising from the GDPR or the Data protection act by any change made in this Privacy policy. If the Privacy policy is amended, Transportly will notify the Data Subjects in an appropriate manner by publishing the changes in question on the Transportly Website or Transportly Driver App.