Privacy policy and GDPR

Brief summary of information on personal data protection and consent to personal data processing.
On the basis of the General Data Protection Regulation (hereinafter referred to as “GDPR”), TKSOL s.r.o. located at Gaštanová 21, 010 07 Žilina, has issued Client privacy protection principles (information provided when obtaining personal data from the person concerned pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons in the processing of personal data and the free movement of such data and Act No. 18/ 2018 Coll. on the protection of personal data). In this form, we provide detailed information on the processing of personal data for the purpose of providing services through our mobile platform TiToRi which is available on Google Play store (https://play.google.com/store/apps/details?id=sk.titori.app) and on App Store (https://apps.apple.com/us/app/titori/id6462705683), or from our website (hereinafter referred to as the “Platform”) based on a contract concluded at a distance or a contract concluded outside the seller’s premises and on changes and amendments to some laws, or other services provided by our company. Our mobile platform TiToRi is on Google Play store temporarily published by WAME.sk organization and will be transferred to TKSOL organization after first development phase will end.

USER PRIVACY
While using Our Platform, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

First name and last name
Email address
Phone number
Personal identification number
Date of birth
Address of permanent/temporary residence/postal address
Geolocation (Background location is used to provide features beneficial to the user and relevant to the core functionality of the app. The TiToRi application captures the GPS location of the device, which is active from the time the ride starts and throughout the duration of the ride until it ends. GPS is not in use after driving. Capturing GPS location is absolutely necessary for displaying the location on the map to other users of the TiToRi mobile application and for the proper functionality of the entire system. The acquirer is aware of this technical requirement and the impact on the electricity consumption of the mobile device and the data consumption of its mobile operator.)
Photo
Data of your vehicle
Usage Data

CONTENT

Who is the controller of your personal data?
What personal data do we process?
From which source the personal data originate?
For what purposes (legal basis) did you give your consent?
How long will we process your personal data?
Who has access to your personal data?
What are your rights with data processing?
How can you withdraw your consent to personal data processing?

Who is the controller of your personal data? Data Controller is company, that determines the purposes and means of the processing of personal data. For the above mentioned purpose of providing services is the controller of your personal data TKSOL s.r.o. located at Gaštanová 21, 010 07 Žilina.
What personal data do we process? In order to provide services we may process following categories of personal data:
■ Basic identification data – name, surname, personal identification number, date of birth, address of permanent/temporary residence/postal address, photograph, data of your vehicle.
■ Contact data and other data – phone number, email address.
■ Information about using the services – what services you used.
■ The TiToRi application captures the GPS location of the device, which is active from the time the ride starts and throughout the duration of the ride until it ends. GPS is not in use after driving. Capturing GPS location is absolutely necessary for displaying the location on the map to other users of the TiToRi mobile application and for the proper functionality of the entire system. The acquirer is aware of this technical requirement and the impact on the electricity consumption of the mobile device and the data consumption of its mobile operator.
GPS capture in the background is necessary so that GPS location takes place even if the driver is currently using another application. For example if he is currently on the phone or using a navigation application to navigate to another user’s pick-up/drop-off point. Even if the TiToRi application is in the background, it is necessary to capture the driver’s location and transmit it to other users. After finishing the ride, user location is no longer stored on the server and is deleted. Information about user location is not collected or shared with any third-party services.
■ Information from recording of phone calls or other interactions with you, for example via email or contact or registration form available on our Platform
From which source the personal data originate? Personal data reffered to in the previous point we obtain directly from you. Personal data may come from publicly accessible sources , registers and recordings. Your personal data may come from third persons that are authorised to handle with them.
For what purposes (legal basis) did you give your consent?The purpose for which your consent was given is to carry out our obligations arising from any contracts entered into between you and us or you and our business partners and to provide you with the information and services that you requested (necessary for the performance of our mutual contractual obligations); to send you service-related information by email and/or text message and/or any other communication means (e.g. your booking confirmation) (necessary for the performance of our mutual contractual obligations); to collect payments from you or to transfer to you the payments we collect on your behalf (necessary for the performance of our mutual contractual obligations); to enable you to communicate with other members about our services or about the ride(s) you have/will do with other members and/or to organise such rides (necessary for the performance of our mutual contractual obligations);to give you access to and to enable you to communicate with our community relations service (this processing is (i) necessary for the performance of our mutual contractual obligations, (ii) carried out with your consent or (iii) necessary for the establishment, exercise or defence of legal claims). to enhance our Community Relation service and train our customers agents through the record of your phone conversations with us (this processing is based on our legitimate interest (to provide you a high quality customer support/to enhance our customer support); to ensure compliance with (i) applicable laws, (ii) our Terms and Conditions, and (iii) our Privacy Policy. Certain breaches that we regard as inappropriate may lead to the suspension of your account on our Platform. For these purposes, we may use technologies to automatically analyse your use of the Platform, including the content of your publications, in order to detect any behaviour that may constitute a violation on your part (This processing is necessary (i) for the performance of our mutual contractual obligations, (ii) is based on your consent or (iii) for the establishment, exercise or defence of legal claims) to send you, by email and/or text message and/or any other communication means, in accordance with applicable laws and where required, with your consent, marketing materials and to make you suggestions and recommendations about goods or services related to our services that may interest you. We also use your data to target you in order to serve our ads on social media platforms or third-party sites. You can learn more about how these features work, and the data that we obtain about you, by visiting the relevant sections of the third party social media platforms or sites (this processing is based on your consent where required by law or our legitimate interest (i.e. providing you with meaningful advertising);to notify you, by email and/or text message and/or any other communication means, about changes to our services or accompanying you in the use of our services (this processing is necessary (i) for the performance of our mutual contractual obligations, (ii) for compliance with our legal obligations or (iii) the establishment, exercise or defence of legal claims.)to verify the information contained in your passport, driving licence, ID card and other identity documents that may be collected from you at the time of registration or at any other time during your use of our Platform (this processing is based on (i) your consent, (ii) carried out for the establishment, exercise or defence of legal claims, (iii) for compliance with our legal obligations, or (iv) our legitimate interest (i.e. providing you with meaningful information). In the latter case, you can object to this processing when contacted). to administer our Platforms and for internal operations, including troubleshooting, data analysis, testing, research ( this processing is based on our legitimate interest (i.e. ensuring the security of our Platform and improving its features); to monitor customer relations and in particular to carry out (by email or phone) satisfaction surveys and studies including polls, product tests and statistics (this processing is based on our legitimate interest (i.e. evaluate our Platform and the services we provide in order to improve them). You can object to this processing when contacted; to improve our platform, to ensure that content is presented in the most effective manner for you and for your device (this processing is based on our legitimate interest (i.e. providing you with meaningful content); to allow you to participate in interactive features of our service, when you choose to do so, such as searching for rides around you based on your location (this processing is necessary (i) for the performance of our mutual contractual obligations or (ii) based on your consent, where required by law.) as part of our effort to keep our platform safe and secure, particularly for fighting against the fraud (This processing is necessary (i) for the performance of our mutual contractual obligations or (ii) based on your consent, where required by law.) to measure or understand the effectiveness of advertising we serve, and to deliver relevant advertising to our users (this processing is based on (i) our legitimate interest (i.e. measuring and optimising the efficiency of our advertising campaigns) or (ii) your consent where required by law.)
How long will we process your personal data? You have given your consent to our company for the duration of the contractual relationship and for the following 10 years from the termination of such contractual relationship or until you withdraw your consent. After the relevant time has passed, your personal data will be deleted, but only to the extent and for the purposes for which consent is not required according to legal regulations.
Who has access to your personal data? Other entities that process personal data such as the so-called intermediaries whose task is to provide services to the company. For example, they can be external companies that manage our systems (PC services, accounting services, courier and postal services, ..) or other services that ensure the proper running of the company. At the same time, when you use our services, we share some information about you with members of our communities, either on your public profile or during the booking process (eg we give your phone number to the members with whom you take your ride). We work with third parties who may be recipients of your personal data, such as: I. our business partners who have social media platforms and who can only provide you with those connection services, such as connecting your Platform profile information, from social media platforms to our platform; II. our business partners who may advertise their services on our platform and with whom you may choose to register. Specifically, these services may include: insurance services, banking services, lending services, etc.; III. our business partners who may advertise their services on their websites; IV. our subcontractors, including technical, payment, identity verification and delivery services or analytics providers. As part of our rating system, we publish the rating you write published on the platforms. Ratings, including your name abbreviation and photo, are visible to all visitors to this platform How can we use and moderate messages? We may read messages you exchange with other members of our community through our platform for fraud prevention, service improvement, community member support purposes, enforcement of agreements with our members (such as our Terms of Service). For example, to prevent circumvention of our online booking system, we may scan and analyze messages sent through our platform to verify that they do not contain any contact details or links to other websites and, in relevant cases, messages may be blocked or filtered in whole or in part . We never scan or analyze your messages with other members of our company for business and advertising purposes. We may use automated methods to moderate these messages, but no automated individual decision-making is made in these matters.
What are your rights with data processing? You can excercise following rights: Information include mainly: the identity and the contact details of the controller, the controller’s representative, the contact details of the data protection officer, where applicable the purposes of the processing, the categories of personal data concerned, the recipients or categories of recipients of the personal data, infomration about transfer o f the personla data to third country, the period for which the personal data will be stored, authorised controllers, list of your rights, the right to lodge a complaint with The Office for Personal Data Protection of the Slovak Republic, from which source the personal data originate, information about whether and how the automated decision-making, including profiling is done.

the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed
– the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing
the data subject objects to the processing of personal data and there are no overriding legitimate grounds for the processing,
the personal data have been unlawfully processed
the personal data have to be erased for compliance with Act no. 18/2018 on personal data protection , special legal regulations or international treaty, which is binding upon the Slovak republic.
the personal data have been collected in relation to the offer of information society services. The provisions reffered to above shall not apply to the extent that processing is necessary
for exercising the right of freedom of expression and information
for compliance with Act no. 18/2018 on personal data protection , special legal regulations or international treaty, which is binding upon the Slovak republic,
for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller .
for reasons of public interest in the area of public health in accordance with law
for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in so far as the right to erasure is likely to render impossible or seriously impair the achievement of the objectives of that processing
for excercice of legal claims.
the data subject has objected to processing on grounds relating to his or her particular situation, to processing of personal data concerning him or her for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller or processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child; ; this legal basis shall not apply to processing of personal data carried out by public authorities in the performance of their tasks, including profiling based on those provisions.

How can you withdraw your consent to personal data processing? The consent is based on the voluntary principle, i.e. you may withdraw your consent, at any time, by a handwritten and signed notice of consent withdrawal sent to the address of registered seat of our Company or by e-mail sent to the e-mail address support@titori.com.

Effective date: from 01st October 2023 In Žilina, 01st October 2023 TKSOL s.r.o.

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