Privacy Policy and Information on Personal Data Protection Rights

We care about protecting your privacy. Please read this Privacy Policy carefully.

This Privacy Policy describes in detail how we collect, use, store and, where applicable, publish your Personal Data in the course of the individual activities carried out by the Controller. If you have any questions or requests concerning the protection of your privacy, please contact us at podpora@terminovka.sk.

I. Definitions

For the purposes of this Privacy Policy, the following terms have the following meanings:

“Website” means the website and its parts located on the domain www.terminovka.sk, operated by the Controller, and, where applicable, a web or mobile application, if created, including the administration portal of the Website.

“Regulation” means 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, “GDPR”).

“Organiser” means a person or entity that holds, operates or organises a Sporting Event, or mediates the holding of a Sporting Event, and that has a contractual relationship with Stella Digit enabling Stella Digit to provide participant registration and the sale of entry fees for the Sporting Event and related activities.

“Personal Data” means any personal data relating to a specific living natural person who is identifiable or could be identified by means of such data, and which we process for any of the purposes set out in this Privacy Policy.

“Controller” means the specific person who determines the purpose of the processing of Personal Data, namely Stella Digit.

“Pseudonymised Data” means information and data about data subjects that have been processed in such a way that a specific natural person can no longer be identified without the use of additional information.

“Processor” means a person other than the Controller who, in a specific case, processes Personal Data on behalf of the Controller.

“Stella Digit” means Stella Digit s.r.o., with its registered office at Terasová 627/15, 059 21 Svit, Slovak Republic, Company ID (IČO): 48 110 787, registered in the Commercial Register of the District Court of Prešov, Section Sro, Insert No. 41749/P.

“Sporting Event” means a public event of a sporting nature organised or held by an Organiser, for which you can register via the user area of the Website. Sporting Events are services related to leisure activities which their Organisers undertake to provide at an agreed time and place.

“Artificial Intelligence” or “AI” means software tools and systems (for example, language models) that, based on input data, generate content, suggestions, recommendations, predictions or other outputs, including AI systems within the meaning of Regulation (EU) 2024/1689 of the European Parliament and of the Council (the AI Act).

“Authority” means the Office for Personal Data Protection of the Slovak Republic (Úrad na ochranu osobných údajov Slovenskej republiky), Hraničná 12, 820 07 Bratislava 27.

“User Profile” means a user’s profile on the Website, which can be created by completing and submitting the registration form on the Website.

“T&C” means the Controller’s General Terms and Conditions published on the Website.

“Privacy Policy” or “Policy” means this privacy policy and the information on personal data protection rights contained herein.

“Personal Data Protection Act” means Slovak Act No. 18/2018 Coll. on the Protection of Personal Data and on Amendments to Certain Acts.

Terms not defined in this Privacy Policy have the meaning given to them in the T&C.

We process your Personal Data in accordance with the Regulation and the Personal Data Protection Act.

II. Conditions for the Processing of Personal Data for the Website

In this part of the Privacy Policy, we inform you how we handle the Personal Data you provide to us when using the Website.

1. Categories of Personal Data We Process

The privacy of users visiting the Website is extremely important to Stella Digit. Users’ Personal Data are processed and used only for the purposes set out in this Privacy Policy.

a) Personal Data you provide to us yourself

You provide us with Personal Data yourself when you:

• enter your Personal Data (first name, surname, e-mail address) in the registration form for creating a User Profile and submit this data;
• enter your Personal Data (first name, surname, date of birth, gender, e-mail address, telephone number, nationality, residential address/billing details, name of the sports club in which you are registered, and information about your health insurance company) in the registration form for a Sporting Event and submit this data;
• decide to give us your consent to publish your Personal Data (first name, surname, bib number, sports club) in the list of registered participants of a Sporting Event in the User Profile;
• decide to give your consent to receiving direct marketing messages (newsletter);
• decide to contact us via the Website’s communication features – contact form, e-mail address, telephone number;
• give us your consent to contact you by e-mail to rate a Sporting Event in which you participated;
• give us your consent to store your Personal Data (first name, surname, photograph, placing at the Sporting Event and the time and place it was held) in our database and to publish this data on terminovka.sk;
• give us your consent to the processing of Personal Data in connection with a consumer competition (first name, surname, e-mail address, and, where applicable, the profile name/nickname used on social networks);
• give us your consent to the placement and storage of cookies;
• pair the STRAVA application with your User Profile on the Terminovka Website and log in to your profile even faster. We process only the following personal data: first name, surname and e-mail address. (We do not process data about your training sessions, routes run, health status, heart rate information or any other data.)

You provide the above Personal Data voluntarily, and it is up to you to decide to what extent you provide such Personal Data. However, without certain Personal Data it may not be possible to complete the registration of your User Profile or the registration for a Sporting Event, to pay the entry fee, or to conclude the contract establishing the registration for a Sporting Event. Without certain Personal Data, we are also unable to respond to your query or request.

You are responsible for the accuracy, completeness and truthfulness of the Personal Data provided, and Stella Digit will rely on the accuracy, completeness and truthfulness of the Personal Data provided. Stella Digit is not liable for any damage that may arise to you or any third party in connection with the provision of incorrect, incomplete or untrue Personal Data.

b) Personal Data we obtain from your use of the Website

We may also indirectly obtain certain Personal Data enabling your identification from your use of the Website, whether as a holder of a User Profile or merely as a visitor to the Website. This mainly concerns the following data:

• information and data from the devices you use to access the Website, which may include general information about your device;
• log data, i.e. data and information automatically stored by our servers whenever you access the Website (in particular the location of your access, time of access, details of the hardware and software you use, the type of browser you use, the type of device you use to access the Website, number of clicks, the page you visited before the Website, gender, age, nationality, interests);
• data about your use of the Website;
• information obtained through cookies and other user-monitoring programs, including cookies and monitoring programs of our partners, to the extent permitted by your settings;
• information obtained by monitoring user activity after clicking on specific Sporting Events;
• information we obtain through social plugins operated by third parties, e.g. the Facebook “Like” button, Google and similar.

The above data do not by themselves enable the identification of a specific living natural person. The above data become Personal Data at the moment we assign them to a specific identified or identifiable living natural person, for example when the Website is used while logged in to a User Profile.

c) Personal Data obtained during sporting events

Our company organises or provides information about and registration for various Sporting Events. At these Sporting Events, we or the Organisers take photographs or audiovisual recordings intended to inform about and promote the Sporting Event.

2. Purposes of Processing Personal Data

Our company focuses on providing registration and entry fee payments for various sporting events via the Website. We process most Personal Data on the basis of the performance of a contract or of steps preceding the performance of a contract (pre-contractual relations). We also process Personal Data to comply with a legal obligation or on the basis of our legitimate interest. Where necessary, we process your Personal Data only with your consent. When processing Personal Data for some of the purposes listed below, the Controller may also use Artificial Intelligence tools under the conditions set out in Part III of this Policy. Stella Digit processes Personal Data for the following purposes:

3. Retention Period of Personal Data

4. Disclosure of Personal Data to Third Parties

The Controller processes your Personal Data through members of its statutory body and persons who have signed a confidentiality and non-disclosure agreement. We disclose your Personal Data to third parties in the following cases:

• If you register via the Website for a Sporting Event organised by an Organiser and pay the entry fee, your Personal Data, to the extent you provided them to us, will also be provided to the Organiser with whom you conclude the contract for registration for the Sporting Event and payment of the entry fee. We will also provide the Organiser with the Personal Data you enter in the registration form for the Sporting Event. The conditions of the processing of Personal Data by the Organiser are always available to you when registering for a specific Sporting Event;
• if we take photographs or audiovisual recordings at a Sporting Event, these will also be provided to the Organisers of the Sporting Event;
• where we are required to do so by applicable law, in particular at the request of law enforcement authorities, courts, other public authorities or other authorised persons;
• where necessary for the fulfilment of our obligations and the protection of our legitimate interests, in particular to our lawyers, advisers, auditors, IT service providers, providers of Artificial Intelligence tools, marketing and advertising agencies, cloud services and the like;
• to ensure high-quality operation and an enhanced experience when visiting the Website, Stella Digit cooperates with Websupport s.r.o., with its registered office at Karadžičova 7608/12, 821 08 Bratislava – Ružinov, Slovak Republic, Company ID (IČO): 36 421 928, registered in the Commercial Register of the District Court of Bratislava I, Section Sro, Insert No. 63270/B.

With persons acting as Processors, we conclude data processing agreements in accordance with the Regulation, and Processors always process Personal Data on the instructions and on behalf of Stella Digit. All our Processors process Personal Data in accordance with this Privacy Policy.

As the Controller, Stella Digit ensures that everyone to whom your Personal Data are transferred maintains a high standard of protection. Under no circumstances do we provide your Personal Data to an entity where this standard is not ensured.

As a rule, we do not transfer Personal Data to third countries (outside the EU and the EEA). If any of the Processors (for example, a provider of cloud services or Artificial Intelligence tools) processes Personal Data outside the EU and the EEA, the transfer will take place only under the conditions of Chapter V of the Regulation, in particular on the basis of an adequacy decision of the European Commission or standard contractual clauses approved by the European Commission.

5. Role of the Organiser of Sporting Events in the Processing of Your Personal Data

With regard to the processing of your Personal Data that you provide to us for the purpose of registering for a Sporting Event, the Organiser acts as an independent controller of Personal Data, and the processing of Personal Data by the Organiser is subject to the specific data protection terms set by the Organiser.

We provide the Personal Data obtained from you during registration for a Sporting Event to the Organiser in order to fulfil the obligation to ensure registration for the Sporting Event and payment of the entry fee. The legal basis for the processing of Personal Data by the Organiser is usually the necessity of processing your Personal Data for the performance of the contract concluded between you and the Organiser by registering for the Sporting Event and paying the entry fee (ground under Art. 6(1)(b) GDPR).

On the basis of your registration and payment of the entry fee for a Sporting Event it organises, the Organiser may be entitled/obliged to contact you in the event of cancellation of the Sporting Event, to inform you about weather conditions and risks, or to offer you another Sporting Event that may interest you. In some cases, however, the Organiser may also require your consent to the processing of your Personal Data [ground under Art. 6(1)(a) or Art. 9(2)(a) GDPR], in particular where your participation in the Sporting Event requires the processing of special categories of your Personal Data (e.g. your health declaration, health insurance company, etc.). Where such Personal Data are processed, the Organiser alone will be their controller (unless expressly stated otherwise). For more information on the scope and manner of the processing of Personal Data by the Organiser, please contact the Organiser of the Sporting Event for which you registered.

6. Processing Conditions for Our Facebook Pages and the Use of Google Analytics

As we may come into contact with data about you obtained through your interaction on our Facebook and/or Instagram pages, in the interest of transparency of the processing of Personal Data we would like to inform you how we obtain and handle such data.

When you visit our Facebook and/or Instagram page, we do not directly collect any Personal Data about you other than Pseudonymised Data provided by Meta Platforms Ireland Ltd., which include metrics such as the number of visits, clicks, views, “Likes”, shares and comments, as well as data on your location, nationality, gender, age, interests, the type of device you connect with, the type of your browser, your activity and the last website visited, and the like.

We may also collect data on the use of our tabs or applications, which may include basic web analytics, the type of browser used and your likely country of origin. This information is Pseudonymised and cannot be attributed to an individual user or to specific information from public or private profiles on Facebook and/or Instagram. We process the data obtained to analyse usage patterns, improve the overall performance of the Facebook page and provide information that is relevant and useful to you.

We may disclose data obtained in this way to third parties where we are required to do so by applicable law, in particular at the request of law enforcement authorities, courts, other public authorities or other authorised persons. We will also disclose this data where necessary for the fulfilment of our obligations and the protection of our legitimate interests, in particular to our lawyers, advisers, auditors, IT service providers, marketing and advertising agencies and the like.

The Website also uses Google Analytics, which records the above-mentioned Personal Data about Website visitors and their behaviour. Google Analytics anonymises the relevant data. We also use insights from analytics cookies for advertising purposes, whereby, on the basis of this data, we may display advertisements to you on third-party websites that we consider relevant to you. If you want to control which of your analytics cookies we process, you can use the following link: https://tools.google.com/dlpage/gaoptout

For more information about privacy and Google’s principles for processing Personal Data, please click on this link: https://policies.google.com/privacy

7. Processing of Personal Data Received from Third Parties

If, as a third party, you provide us with Personal Data of other persons, such as your employees or contractual partners, you are responsible for ensuring that:

• you process such Personal Data in accordance with the Regulation and the Personal Data Protection Act and are entitled to provide such Personal Data to us;
• you provide the Personal Data to us on the basis of a specific legal basis under the Personal Data Protection Act and the Regulation and, where necessary, you have obtained the consent of the data subjects to such provision;
• you fulfil your information obligation towards the data subject under the Personal Data Protection Act and the Regulation;
• you take appropriate measures and provide the data subject with information on the right of access, rectification, erasure and portability of Personal Data, information on the right to restriction of processing and the right to object to the processing of Personal Data, as well as information on automated individual decision-making, including profiling (where applicable);
• you will cooperate with us in fulfilling our obligations in the field of Personal Data protection under the Personal Data Protection Act and the Regulation.

The legal basis for the processing of Personal Data of third parties that you provide to us as a person without any contractual relationship with Stella Digit for the purpose of establishing cooperation is the taking of steps prior to entering into a contract at your request (expressed by your contacting us), and in other cases our legitimate interest in retaining them for future communication or for the establishment or defence of our rights. If you decide to contact us because of your interest in cooperating with us or for any other reason, we are entitled to process the Personal Data you provide to us in our mutual communication, in particular your first name and surname, telephone number, e-mail and correspondence address. The legal basis for such processing of Personal Data, if you decide to contact us for the purpose of establishing cooperation, is the taking of steps prior to entering into a contract at your request (expressed by your contacting us), and in other cases our legitimate interest in retaining them for future communication or for the establishment or defence of our rights. We will retain Personal Data provided under this part of the Policy for the period necessary to fulfil the purpose for which you provided them to us and subsequently for 3 years from the fulfilment of that purpose, unless we are required by generally binding legal regulations to retain such Personal Data for longer. The conditions set out in point 4 of this part of the Policy apply to the transfer of Personal Data obtained under this part of the Policy outside the EU and the EEA.

8. Automated Processing and Profiling

The Controller strives to provide individually tailored offers of Sporting Events. For this reason, it profiles the Personal Data obtained. For this purpose, it uses automated information systems, web applications, calculators and, where applicable, Artificial Intelligence tools. On this basis, it sends you individualised offers of Sporting Events. Automated evaluation (profiling) of Personal Data helps to better understand needs, predict future behaviour and adapt the offer of products and services accordingly.

The Controller also processes your Personal Data (age) to automatically assign you to a specific category of participants in a Sporting Event, which is determined by the Organiser and is automatically processed for this purpose.

The Controller does not take decisions concerning you based solely on automated processing, including profiling, which would produce legal effects concerning you or similarly significantly affect you within the meaning of Art. 22 GDPR.

9. Users’ Rights

As data subjects, users have the following rights:

• Right to withdraw consent – where Stella Digit processes Personal Data on the basis of consent, the user has the right to withdraw such consent at any time, either electronically at podpora@terminovka.sk, by written notice of withdrawal of consent sent to the registered office of Stella Digit, or in person at the Controller. Withdrawal of consent does not affect the lawfulness of the processing of Personal Data carried out by the Controller on the basis of that consent.
• Right of access – the user has the right to obtain a copy of the Personal Data about them held by the Controller, as well as information on how the user’s Personal Data are used.
• Right to rectification – at the user’s request, the Controller will update the Personal Data processed.
• Right to erasure (right to be forgotten) – if the Personal Data that Stella Digit has obtained about the user are no longer necessary for the original purpose of processing, the user has the right to request the erasure of the Personal Data.
• Right to restriction of processing – in certain circumstances, the user is entitled to request that the Controller stop using the user’s Personal Data, e.g. where the user considers that the Personal Data processed by Stella Digit are inaccurate or Stella Digit no longer needs them.
• Right to data portability – in certain circumstances, the user is entitled to request the transfer of the Personal Data they have provided to another third party. However, this right applies only to Personal Data obtained on the basis of consent or a contract.
• Right to object – the user has the right to object to the processing of Personal Data based on legitimate interests, including processing by means of Artificial Intelligence tools. If the user considers that Stella Digit has no compelling legitimate grounds for the processing, they may lodge an objection; if it is shown that the legitimate interest concerned does not override the interests of the user, Stella Digit will no longer process the user’s Personal Data.
• Right to lodge a complaint – the user may lodge a complaint with the supervisory authority, which is the Office for Personal Data Protection of the Slovak Republic (Úrad na ochranu osobných údajov Slovenskej republiky), Hraničná 12, 820 07 Bratislava 27, if they consider that their Personal Data are being processed unfairly or unlawfully. If the complaint is submitted electronically, it must meet the requirements of Section 19(1) of Slovak Act No. 71/1967 Coll. on Administrative Proceedings (Administrative Procedure Code). More information is available at https://dataprotection.gov.sk. The user may also contact the data protection supervisory authority of the EU Member State of their habitual residence.

10. Processing of Automatically Stored Data (“Cookies”)

When a user visits the Website, Stella Digit may collect personal data of Website visitors from the user’s device (called “cookies”). The information stored in cookies can be read by the Stella Digit server when it reconnects with that computer. Every user can disable cookies and configure their browser accordingly.

Cookies contain, among other things, the following data:

• the public IP address of the computer from which the request was sent;
• information about the type of the user’s operating system;
• information about the user’s browser;
• the pages visited by the user and the time spent on each of them.

Cookies do not contain any identification data of the person visiting the Website or any other information collected from users.

Use of cookies

Stella Digit stores the cookies collected for a maximum of 14 months solely for auxiliary purposes serving the administration of the Website. Their information is made available only to persons authorised to administer the Website. Stella Digit uses cookies for strictly necessary functional purposes, analytical purposes, statistical purposes and marketing purposes in order to adapt the content and structure of the Website to the needs of the users who visit it.

More information on the use of cookies can be found at this link: https://www.terminovka.sk/legal/cookies

Links to other websites

The Website also contains links to other websites. The terms of use of those websites and the rules for protecting the privacy of their users, to which the user is redirected via a link, are set out on those websites. Stella Digit has no control over these websites and services. These websites may use their own tools to collect information and data about you, including your Personal Data.

III. Use of Artificial Intelligence

1. General

In the course of its activities, the Controller uses and is gradually introducing Artificial Intelligence tools in order to streamline and optimise its processes and improve the quality of the services provided. Artificial Intelligence tools are used mainly in the administration portal of the Website, which serves the Controller and the Organisers for managing Sporting Events and related data. They may gradually be introduced into other processes and parts of the Website as well.

2. Areas of use

Artificial Intelligence tools may be used in particular for:

• creating, editing, translating and checking texts (e.g. descriptions of Sporting Events, race information, announcements);
• processing, sorting, checking and evaluating data;
• communicating with users and Organisers and handling their questions and requests;
• automating administrative and repetitive tasks;
• analysing the use of the Website and improving its functions and services.

This list is not exhaustive. We will inform you by updating this Policy if Artificial Intelligence is introduced into a process that would substantially change the way your Personal Data are processed.

3. Scope of processing and legal basis

Artificial Intelligence tools are a technical means of processing and do not create new purposes of processing. We use them to process Personal Data only for the purposes and on the legal bases set out in Part II, point 2 of this Policy, and only to the extent necessary to perform the specific task. Where Artificial Intelligence is used to streamline internal processes, the legal basis is the legitimate interest of the Controller pursuant to Art. 6(1)(f) GDPR. Wherever possible, we work with anonymised or Pseudonymised Data.

4. Human oversight

The outputs of Artificial Intelligence tools serve as an aid and are subject to review by authorised persons of the Controller. The Controller does not use Artificial Intelligence tools to take decisions based solely on automated processing which would produce legal effects concerning you or similarly significantly affect you within the meaning of Art. 22 GDPR.

5. Providers of Artificial Intelligence tools

Artificial Intelligence tools may be provided by third parties acting as Processors in the processing of Personal Data. We conclude data processing agreements with such providers in accordance with the Regulation. The Controller selects providers that offer sufficient guarantees for the protection of Personal Data and that do not use Personal Data provided by the Controller to train their models. In the event of a transfer of Personal Data outside the EU and the EEA, the conditions set out in Part II, point 4 of this Policy apply.

6. Transparency

If you interact directly with an Artificial Intelligence system (e.g. a chatbot or automatically generated replies), you will be informed of this in advance.

7. Security and your rights

When using Artificial Intelligence tools, we apply the same technical and organisational measures to protect Personal Data as in other processing. In connection with the processing of Personal Data by means of Artificial Intelligence tools, you may exercise all your rights set out in Part II, point 9 of this Policy.

IV. Strava API Integration

1. Purpose of data processing (authentication)

On our portal Terminovka.sk, we offer users a simplified registration and login process via the Strava service (Strava API). The purpose of this processing is to increase user convenience (Single Sign-On), so that the user does not have to create a new username and password but can use their existing Strava authentication.

2. Scope of data processed

If you choose the “Log in with Strava” option, our platform will request from Strava Inc. and process only the following basic data:

• first name and surname (to create your profile in our system),
• e-mail address (to communicate about your race registrations and to send race information for races you have registered for).

Important notice: The Terminovka.sk portal does not request, store or have access to your sports activities, GPS routes, biometric data, friends list or any other private statistics stored in the Strava application. Our integration is limited exclusively to identifying the user.

The Strava application may monitor and collect data on the use of the API.

3. Legal basis

The legal basis for processing this data is your voluntary consent, which you give by clicking the “Connect with Strava” button and subsequently confirming the authorisation in the Strava interface.

4. Withdrawal of consent and deletion of data

You can withdraw your consent to linking your profile with Strava at any time directly in your account settings on Strava.com (under “My Apps”), where you revoke access for the Terminovka.sk application, or in your account on Terminovka.sk in the profile/personal data settings by clicking the “disconnect” link.

After the connection is removed, we will no longer have access to updates of your identification data; however, your profile created on our portal will remain unless you request its complete deletion in accordance with your rights under the Regulation.

V. Final Provisions

Information security

Stella Digit uses appropriate technical and organisational means to keep users’ Personal Data secure, including protecting Personal Data against misuse, loss and destruction. To ensure the security of users’ Personal Data, appropriate personnel, organisational and technical measures have been put in place (Personal Data are transmitted via an encrypted protocol with certification and are pseudonymised). These measures also apply to the processing of Personal Data by means of Artificial Intelligence tools. In the event of a security incident, we will promptly take the necessary technical measures, assess its severity and, if the severity is high, notify the Authority.

Changes to the Privacy Policy

The Controller may amend this Privacy Policy, in particular to adapt it to the requirements of applicable legislation or in connection with the introduction of new technologies, including Artificial Intelligence tools. The Controller will publish information about any changes on the Website.

Contact details

You can exercise your rights with the Controller by telephone at +421 951 007 126, by e-mail at podpora@terminovka.sk, or by written request sent to the registered office of Stella Digit: Stella Digit s.r.o., Terasová 627/15, 059 21 Svit, Slovak Republic.