Information about the processing of personal data through social media platforms
In accordance with Articles 13 and 14 of 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 (hereinafter referred to as the "Regulation"), United Rental Group, s. r. o., Ivanská cesta 4358/43, 821 04 Bratislava, ID No.: 44560940 (hereinafter referred to as the "United Rental Group") hereby provides information on the processing of personal data by the company's abbreviated company name via social media platforms:
FACEBOOK: www.facebook.com
INSTAGRAM: www.instagram.com
YOUTUBE: www.youtube.com
LINKEDIN: www.linkedin.com
Taking into account the services provided by United Rental Group, the sites and media channels operated within the respective social media platform are intended exclusively for persons over 18 years of age. Where the functionality of the social media platform permits, access to a specific page and/or media channel is also only granted to registered persons over 18 years of age.
WHICH CATEGORIES OF DATA SUBJECTS ARE AFFECTED BY THE PROCESSING?
For the purposes of this information, a data subject is an identified or identifiable natural person whose personal data is processed by United Rental Group through social media platforms ("Data Subject"). Generally, this includes visitors to sites/media channels set up and operated by United Rental Group, in particular:
persons not registered on the relevant social media platform who visit the site (e.g. by searching via a publicly available search engine),
persons registered on the social media platform FACEBOOK / INSTAGRAM who have set up a profile / account and who visit the site and freely express their interest in receiving information and news (following the site) or express their opinion with the content of the site via the "Like" / "Follow" / "Follow" button or by recommending the site to others,
persons registered on the YOUTUBE social media platform who are logged in via a service account provided by Google LLC and who, by free choice, become subscribers to the content of the media channel via the "Subscribe" button,
persons registered on the LINKEDIN social media platform, who have set up a profile/account and who visit the site or freely express their interest in subscribing to information and news (following the site) via the "Follow" button,
The data subjects may also be other persons whose data is published by the data subject referred to above during his/her activity on the social media platform, which the United Rental Group cannot define in advance. A Data Subject who discloses personal data about another person acknowledges that he or she may only do so in accordance with the Regulation and the applicable policies and terms of use of the relevant social media platform published by its operators.
WHAT PERSONAL DATA IS BEING PROCESSED?
For the purposes of this information, personal data means any information relating to a data subject 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 by reference to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the data subject. Data Subjects are under no obligation to provide their personal data to United Rental Group for the purposes set out in this information (where the social media platform allows).
In particular, the following personal data about registered data subjects may be processed by United Rental Group on the relevant social media platforms:
the name (username or, where applicable, the name of the data subject provided by the data subject when registering) and nickname of the data subject,
profile and cover photograph (a photograph of the data subject or another photograph, which may also include images of other natural persons, locations or interests of the data subjects),
contact details: e-mail address, telephone number and residence details,
data on the age, hometown and gender of the data subject,
information about relationships with other natural persons, including information about family members,
information about the school attended (primary, secondary, higher education) and information about employment (work),
information on the languages the data subject indicates that he/she can communicate in,
information on life events which the data subject indicates,
places where the data subject has been and has indicated his/her presence in a particular place,
the information about the data subject that he or she includes and discloses in the profile, including opinions, statements and other information and data from posts (statuses, photos, videos, comments, etc.), participation in votes, events and polls, etc., on the social media platform,
name (username or name of the data subject, as the case may be, which the data subject specifies when registering),
profile photograph (a photograph of the data subject or another photograph, which may also include images of other natural persons, locations or interests of the data subjects),
contact details: e-mail address, telephone number, details of residence or any other place of address provided by the data subject,
data relating to the sex of the data subject,
the information about the data subject that he or she includes in the profile and discloses, including opinions, statements and other information and data from the posts (statuses, photos, videos, comments, etc.) that he or she publishes on the social media platform,
YOUTUBE
name (username or name of the data subject, as the case may be, which the data subject indicates when registering),
profile photograph (a photograph of the data subject or another photograph, which may also include images of other natural persons, locations or interests of the data subjects),
contact details: e-mail address, telephone number,
gender data,
the information about the data subject that he or she includes in the profile and discloses about him or herself, including opinions, statements and other information and data from the posts (videos, comments, etc.) that he or she publishes on the social media platform,
name (username or name of the data subject, as the case may be, which the data subject provides when registering),
profile photograph (a photograph of the data subject or another photograph, which may also include images of other natural persons, locations or interests of the data subjects),
contact details: e-mail address, telephone number,
gender data,
details of whereabouts or current work,
references from other persons to the data subject (references, confirmation of knowledge, skills and knowledge, etc.),
and other information that the data subject discloses within his or her profile (in particular, data on education, interests, employment, experience and skills, etc.), including opinions, statements and other information and data disclosed by the data subject on social media platforms,
and any other non-predefinable data of the data subject provided by the data subject:
during communication with United Rental Group on the relevant social media platform (e.g. in comments on posts published on the Pages/Channels, in private or group communications called "squads", etc.),
during the publication of posts within their own profiles/accounts, which are marked as publicly accessible by the registered data subject.
The scope of personal data available about the data subject to other persons and entities within social media platforms is entirely dependent on the level of privacy, public or accessibility settings of the data subject's account/profile, which are made directly by the data subject, possibly also through the setting of cookies, the processing of which can be freely decided by the data subject.
FOR WHAT PURPOSES WILL PERSONAL DATA BE PROCESSED?
United Rental Group, when operating the pages and media channels within the respective social media platforms, processes personal data primarily for the following purposes:
Providing targeted and non-targeted sales and marketing information related to the promotion of the sale of goods and services provided by United Rental Group, including the promotion of sales promotions, events, events and the organisation of competitions and surveys,
providing information related to United Rental Group (e.g. information about job offers, company achievements and related major events, etc.),
informing about the participants and winners of competitions organised by United Rental Group and their progress, in accordance with the published terms and conditions and/or the statutes of the competitions,
communicating with the persons concerned in relation to comments and contributions published by them (reactions to contributions and comments published by United Rental Group or others, positive or negative reactions and references, etc.),
communications with data subjects in messages sent to United Rental Group or in group conversations ("group chats"),
the effective management of the website or media channel by processing the personal data collected in connection with the visit or interaction of the data subjects and their content.
The publication of comments and contributions is generally subject to the approval of United Rental Group or its duly authorised administrators, but this is not the rule. United Rental Group reserves the right to delete the content of these posts and comments, especially those with inappropriate or prohibited content.
The legal basis for the processing of personal data on the sites and media channels operated by United Rental Group on social media platforms (for the purposes set out above) is the legitimate interest of the company in building its reputation and relationships with data subjects (Article 6(1)(f) of the Regulation).
Any data subject shall have the right to object at any time, on grounds relating to his or her particular situation, to processing of personal data concerning him or her which is carried out on the basis of a legitimate interest of United Rental Group, including to object to profiling. United Rental Group shall no longer process the personal data unless it demonstrates to the data subject compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
In light of the above, United Rental Group respectfully requests that data subjects do not include any of their personal data or the personal data of other natural persons in the comments and posts they wish to publish on the social media platform, as United Rental Group does not have the power to ensure the protection and security of such data and to verify the legitimacy of the processing of the data concerned. The personal data so disclosed may be misused by third parties (other than United Rental Group) for purposes other than those for which it was disclosed by the data subject, which may be detrimental to the rights and freedoms of the data subject.
HOW WILL THE PERSONAL DATA BE PROCESSED?
Disclosure of data subjects' personal data to other recipients: personal data processed to the extent and for the purposes set out above are not disclosed by United Rental Group to other recipients for the purposes of further processing, unless:
the disclosure of personal data is necessary for the fulfilment of a legal obligation of United Rental Group (as defined by specific legislation),
the disclosure of personal data is necessary to protect the legitimate interests of United Rental Group,
the personal data is provided to entities that process personal data on behalf of United Rental Group (authorised processors), a current list of which is available at https://www.avis.sk/
Disclosure of personal data of data subjects: personal data processed to the extent and for the purposes set out above:
which are part of private messages and the content of other private or group communications, are not further disclosed by United Rental Group,
which are expressions of interest in the content of the Sites or media channels, or which are part of posts and comments made by the data subject, or opinions and statements made by the data subject through organised polls, votes and events presented on the Sites and media channels operated by United Rental Group are disclosed directly by the data subject. The data subject hereby acknowledges that his or her opinions and the content referred to in this paragraph may also be published on websites operated by United Rental Group or on websites presenting goods and services provided by United Rental Group.
Retention periods of personal data of data subjects: personal data processed to the extent and for the purposes set out above shall be retained as follows:
personal data that are part of private messages and the content of other private or group communications are retained for the necessary periods, depending on the content of the communication and whether the data subject uses the official contact details to notify United Rental Group for subsequent communications, as set out at the beginning of this information (if he/she exercises his/her rights regarding the processing of his/her personal data in accordance with the Regulation), or uses the contact details provided by the company for subsequent communications related to the subject matter of the communication (mainly to speed up the processing of the data subject's request that is not related to the exercise of his/her rights under the Regulation, such as the following complaints, suggestions, requests and other requests). Where the situation permits (taking into account the above), private messages and the content of other private or group communications are retained for a period of 60 days.
Personal data that are part of the posts and comments made by the data subject on the sites and media channels operated by United Rental Group are retained (disclosed) for the period of publication of the post in question by the data subject (if the publication of posts is allowed) or for the period of publication of the post to which the data subject has posted his or her comment, opinion, statement, etc.The period of retention of a post or comment published by the data subject may be shortened by the data subject directly by deleting the post or comment (if the functionality of the social media platform allows it) or by requesting United Rental Group to delete the post or comment in question.
Personal data that is part of published polls, votes and events in which the data subject has participated or is participating on the sites and media channels operated by United Rental Group is retained (published) for the period of publication of the poll, vote or event in question. The data subject may request that the retention period for such personal data be shortened by requesting United Rental Group to delete the personal data in question.
Personal data that is an expression of interest in the content of the pages or media channels (Likes" / "Follow" / "Follow" / "Subscribe") is retained within the social media platform of the pages and media channels operated by the short name company for the duration of the existence of the respective page or media channel, where applicable, until the data subject directly cancels his or her interest personally (unsubscribes from the media channel, or unsubscribes from following the page, or cancels interest in the page - e.g. or unlikes it, or unlikes it, or unlikes it, or unlikes it, or unlikes it).
personal data stored in connection with the organisation of competitions are stored for the periods specified in the published competition statutes and/or published competition terms and conditions,
personal data processed by United Rental Group on the basis of the consent to the processing of personal data given by the data subject are kept within the time limits specified in the relevant consent.
PROCESSING OF PERSONAL DATA JOINTLY WITH OPERATORS OF SOCIAL MEDIA PLATFORMS.
United Rental Group and the operator of the relevant social media platform may also partially process the personal data of data subjects as joint controllers (in accordance with Article 26 of the Regulation). When setting up pages and media channels on the relevant social media platform, United Rental Group accepts the terms and conditions of operation of these pages and has no influence (or only minimal influence) on changing these terms and conditions.
The operators of social media platforms also offer other tools and services to effectively target marketing communications (e.g. displaying advertising content to selected individuals, sending out messages with advertising content, etc.). The profiling of individuals is carried out by the respective operator of the social media platform under its own responsibility and on its own behalf, and United Rental Group does not have access to the data of these individuals and does not have the possibility to influence the processing of such personal data. Depending on the operator of the social media platform, different functionalities and tools are made available to the data subjects to manage, for example, preferences for displaying advertisements and sending messages with advertising content, or to request the exercise of any right guaranteed by the Regulation and related to the processing of the data subject's personal data.
Such personal data about the data subject is also collected by the operators of social media platforms on the sites and media channels operated by United Rental Group within the respective platform. They are primarily used for the purposes of:
profiling of the data subject, which may be carried out by the relevant social media platform operator (see above) to the extent of the data subject's privacy settings and preferences. United Rental Group has no influence on such processing (it cannot prohibit or not allow such profiling in the operation of its sites or media channels).
the creation of site or media channel statistics by the relevant social media platform operator (see above) for the purposes of United Rental Group. Site statistics are generally based on personal data collected in connection with the visit or interaction of data subjects with the site or media channel and its content. United Rental Group has no control over such processing (it cannot prohibit or disable such profiling in the operation of its sites or media channels), but it has the possibility to consult and handle these statistics within the functionality of the sites and media channels.
Further information on the joint processing of personal data as well as the conditions for such processing are published by the operator of the social media platform on its website as follows:
FACEBOOK: Information on the joint responsibilities and obligations of the individual controllers
Further information on the processing of personal data by the operators of social media platforms as well as information on the possibility for data subjects to exercise their rights within the scope of the Regulation is published by the respective operator separately within the social media platforms operated by it (it is also generally available in the profile/account settings of registered users or in the main menu or footer of the website):
FACEBOOK: Data Use Policy
INSTAGRAM: Instagram Data UsePolicy
YOUTUBE: PrivacyPolicy
LINKEDIN: PrivacyPolicy
WHAT RIGHTS DOES THE DATA SUBJECT HAVE WHEN THEIR PERSONAL DATA IS PROCESSED?
The data subject has the right to:
To be informed about the processing of his or her personal data,
to have access to the personal data processed and stored about him or her,
to request the rectification of his or her personal data that are incorrect, inaccurate or incomplete,
to request the erasure of their personal data when they are no longer necessary or if the processing is unlawful,
object to the processing of your personal data for marketing purposes or on grounds relating to a particular situation,
request the restriction of the processing of your personal data in specific cases,
receive your personal data in a machine-readable format and/or request its transfer to another controller,
withdraw his or her consent at any time without affecting the lawfulness of processing based on consent given prior to its withdrawal, where such consent has been given by the data subject,
to request that decisions based on automated processing which concern or significantly affect him or her, based on his or her personal data, be carried out by natural persons and not by automated technical means, where personal data are so processed. The data subject shall have the right to express his or her point of view and contest the decision of United Rental Group,
lodge a complaint with a supervisory authority, in particular in the Member State of his/her habitual residence, place of work or place of alleged infringement, and the right to an effective judicial remedy if he/she considers that the processing of his/her personal data is in breach of the law.
The supervisory authority in the territory of the Slovak Republic is:
The Office for Personal Data Protection of the Slovak Republic
Hraničná 12
820 07 Bratislava 27
Slovak Republic;
submit a request or complaint to United Rental Group in connection with the protection and processing of your personal data. Any data subject who wishes to make a request or complaint and exercise his or her rights may do so:
in writing at United Rental Group, s.r.o., Ivanská cesta 4358/43, 821 04 Bratislava
electronically at: info@avis.sk
by telephone at the following telephone number: +421 2 2030 2100
Validity of information on the processing of personal data as of: 25.05.2018