UBIQ events, s.r.o. Data Privacy Policy

UBIQ events, s.r.o. Data Retention Policy

1.               Introduction

• This Policy sets out the obligations of UBIQ events (“the Organization”) regarding retention of personal data collected, held, and processed by the Organization in accordance with EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

• The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

• The GDPR also addresses “special category” personal data (also known as “sensitive” personal data). Such data includes, but is not necessarily limited to, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation.

• Under the GDPR, personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, or for statistical purposes (subject to the implementation of the appropriate technical and organizational measures required by the GDPR to protect that data).

• In addition, the GDPR includes the right to erasure or “the right to be

forgotten”. Data subjects have the right to have their personal data erased (and to prevent the processing of that personal data) in the following circumstances:

1. Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above);

2. When the data subject withdraws their consent;

3. When the data subject objects to the processing of their personal data and the Organization has no overriding legitimate interest;

4. When the personal data is processed unlawfully (i.e. in breach of the GDPR);

5. When the personal data has to be erased to comply with a legal obligation; or

6. Where the personal data is processed for the provision of information

society services to a child.

This Policy sets out the type(s) of personal data held by the Organization, the period(s) for which that personal data is to be retained, the criteria for establishing and reviewing such period(s), and when and how it is to be deleted or otherwise disposed of.

2.     Aims and Objectives

• The primary aim of this Policy is to set out limits for the retention of personal data and to ensure that those limits, as well as further data subject rights to erasure, are complied with. By extension, this policy aims to ensure that the Organization complies fully with its obligations and the rights of data subjects under the GDPR.

• In addition to safeguarding the rights of data subjects under the GDPR, by ensuring that excessive amounts of data are not retained by the Organization, this Policy also aims to improve the speed and efficiency of managing data.

3.     Scope

• This Policy applies to all personal data held by the Organization and by third- party data processors processing personal data on the Organization’s

• Personal data, as held by the Organization is stored in the following ways and in the following locations:

• The Organization stores electronic data on cloud servers which are GDPR compliant;

• Computers permanently located at the Organization’s business address at Karpatské námestie, 10A, 831 06, Bratislava, Slovakia;

• Laptop computers and other mobile devices provided by the Organization to its employees are stored with and at their homes securely;

• Computers and mobile devices owned by employees, freelances, and external sub-contractors;

• Physical records are stored at the Organization’s business address at Karpatské námestie, 10A, 831 06, Bratislava, Slovakia;

4.     Technical and Organizational Data Security Measures

• The following technical measures are in place within the Organization to protect the security of personal data:

1. All emails containing personal data must be marked “confidential”;

2. Personal data may only be transmitted over secure networks;

3. Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative;

4. Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself and associated temporary files should be deleted;

5. Where personal data is to be transferred in hardcopy form, it should be passed directly to the recipient;

6. All hardcopies of personal data, along with any electronic copies stored on physical media should be stored securely;

7. No personal data may be transferred to any employees, sub-contractors, or other parties, whether such parties are working on behalf of the Organization or not, without authorization;

8. Personal data must be handled with care at all times and should not be left unattended or on view;

9. Computers used to view personal data must always be locked before being left unattended;

10. No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to contractors or other parties working on behalf of the Organization where the party in question has agreed to comply fully with the Organization’s Data Protection Policy and the GDPR;

11. All software should be kept up-to-date. Security-related updates should be installed as soon as reasonably possible after becoming available;

12. No software may be installed on any Organization-owned computer or device without approval;

• The following organizational measures are in place within the Organization to protect the security of personal data:

1. All employees, sub-contractors and other parties working on behalf of the Organization shall be made fully aware of both their individual responsibilities and the Organization’s responsibilities under the GDPR and under the Organization’s Data Protection Policy;

2. Only employees, volunteers and other parties working on behalf of the Organization that need access to, and use of, personal data in order to perform their work shall have access to personal data held by the Organization;

3. All employees and other parties working on behalf of the Organization handling personal data will be appropriately trained to do so;

4. All employees and other parties working on behalf of the Organization handling personal data should exercise care and caution when discussing any work relating to personal data at all times;

5. Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;

6. The performance of those employees and other parties working on behalf of the Organization handling personal data shall be regularly evaluated and reviewed;

7. All employees and other parties working on behalf of the Organization handling personal data will be bound by contract to comply with the GDPR and the Organization’s Data Protection Policy;

8. All sub-contractors, or other parties working on behalf of the Organization handling personal data must ensure that any and all relevant employees are held to the same conditions as those relevant employees of the

Organization arising out of the GDPR and the Organization’s Data Protection Policy;

1. Where any sub-contractor or other party working on behalf of the Organization handling personal data fails in their obligations under the GDPR and/or the Organization’s Data Protection Policy, that party shall

indemnify and hold harmless the Organization against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

5.     Data Disposal

Upon the expiry of the data retention periods set out below in Part 7 of this Policy, or when a data subject exercises their right to have their personal data erased, personal data shall be deleted, destroyed, or otherwise disposed of as follows:

• Personal data stored electronically shall be deleted securely.

• Personal data stored in hardcopy form shall be shredded and securely disposed of;

6.     Data Retention

• As stated above, and as required by law, the Organization shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed.

• Different types of personal data, used for different purposes, will necessarily be retained for different periods (and its retention periodically reviewed), as set out below.

• When establishing and/or reviewing retention periods, the following shall be taken into account:

• The objectives and requirements of the Organization;

• The type of personal data in question;

• The purpose(s) for which the data in question is collected, held, and processed;

• The Organization’s legal basis for collecting, holding, and processing that data;

• The category or categories of data subject to whom the data relates;

7.               Implementation of Policy

• This Policy shall be deemed effective as of 12th Sep No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

8.               Responsible for monitoring GDPR compliance in the Organization

• Vladimíra Roriz – Founder & Global Project Manager at UBIQ webinars

Email: [email protected]

Phone: +421 902 161 667