Information on processing for Marketing purposes – Email Campaign

When Photoneo s.r.o. processes personal data for marketing purposes, it complies with applicable data security and privacy laws, including applicable U.S. federal and state laws, Regulation (EU) 2016/679 on the protection of natural persons in the processing of personal data and on the free movement of such data, which repeals Directive 95/46/EC (general regulation on data protection) (hereinafter referred to as “GDPR”), and Act no. 18/2018 Coll. on the protection of personal data and on the amendment and supplementation of some laws.

Information on the processing of personal data

  1. The Controller of personal data is Photoneo s.r.o., with its registered office at Plynárenská 6, Bratislava 821 09, Slovakia, ID number: 47 353 309, a company registered in the commercial register of the District Court Bratislava I, section Sro, insert no. 91452/B (hereinafter also “Controller” or “Photoneo“).
  2. The processed personal data are all data that can directly or indirectly identify a natural person. Controller processes the following identifiers and employment-related information: name, surname, title (if any), work-related email address, work-related phone number, job position, and the company on behalf of which you act. We source your personal data from you directly, or from paid or publicly available databases. We always make sure that we receive personal data only from those databases which declare compliance with applicable laws and regulations governing personal data privacy and protection.
  3. The Controller will stop processing personal data in the event that the purpose of processing ceases, at the latest within a period of 6 months from the delivery of the marketing campaign email communication. The Controller will retain personal data only for as long as is necessary to fulfill the purposes disclosed in this notice.
  4. The purpose of processing your personal data in Photoneo’s system is the marketing and promotional activity of the Controller in the form of an email campaign.
  5. The Controller may use, store, copy, print your personal data in paper form and perform other processing operations in order to achieve the purpose of processing. The Controller may use marketing platforms and customer relationship management (“CRM”) systems, currently including Hubspot. The Controller has and will enter into a Data Processing Agreement with Hubspot and any similarly situated service provider as a subprocessor.
  6. Where applicable, the processing of personal data in Photoneo’s system takes place on the basis of Article 6, paragraph 1(f) of the GDPR, and we process your personal data on the basis of our legitimate interest. Our legitimate interest is marketing and promotional activity which allows us to offer our products electronically in a more effective way. We do not expect any harm or threat to harm your rights and interests by sending you promotional information.
  7. We share your personal data, including identifiers and employment-related information, with authorized personnel of the Controller and of our affiliated company Photoneo Inc. We also share such data with Hubspot (or a comparable service provider), which may, in connection with operating its CRM system, process your personal data on behalf of and at the direction of the Controller. Hubspot tracks all customer emails in order to confirm their receipt. For more information on Hubspot data protection, please see https://www.hubspot.com/data-privacy/gdpr.

    HubSpot tracking can be deactivated in one of the following situations:
    – You format your email in plain text, or
    – Your email doesn’t automatically download images, or
    – You incorporate a filter which strips away all images for incoming emails.

  8. As a data subject, you may have certain rights regarding your personal information. Where the GDPR is applicable to our processing of your personal data, or where applicable laws or regulations. you have the right to request access to your personal data, its correction, erasure or limitation of personal data processing, and data accuracy. Your right to object to processing can be exercised by clicking the “unsubscribe” link at the bottom of each email communication sent pursuant to this notice. If you are a California resident, you have the right to access the categories of (or specific detail about) your personal information that we process, the right of portability to enable you to receive your personal information in portable and readily usable format, the right to correct inaccurate personal information, the right to delete your personal information, and the right to be free from discrimination by us for exercising any of these rights. You can exercise these rights by emailing info@brightpick.ai or calling (513) 507 4121. We can provide you with a more detailed description on the processing of personal data and your rights, if you send your request to email: info@brightpick.ai.
  9. If you are a data subject under the GDPR, you also have the right to submit a proposal to the competent supervisory authority to initiate proceedings on the protection of personal data in the event that your rights according to this notice have been violated during the processing of personal data. The submission of the proposal must be preceded by the exercise of the right with the Controller, except where there is a reason worthy of special consideration for not exercising the right in question directly.
  10. Personal data may be transferred to third countries if we share data with our affiliated company Photoneo Inc.
  11. Cookies – We do not use cookies in our marketing campaign email communication.

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