MultiSport - personal data protection

Personal Data Protection

  1. GENERAL INFORMATION

INFORMATION ABOUT US

The company Benefit Systems Slovakia s.r.o., with the registered office Ružová dolina 6, Bratislava, Post Code 821 08, Company ID: 48 059 528, registered in the Commercial Register administered by the District Court Bratislava I, Section: Sro, Insert No. 102826/B (hereinafter "Benefit Systems" or "we" or "us") takes personal data protection very seriously. We therefore take all care to ensure that your personal data is processed in accordance with the applicable law, in particular by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and on repealing Directive 95/46/EC (General Regulation on the protection of personal data) (hereinafter "Directive") and by Act No. 18/2018 Coll., on the Protection of Personal Data, as amended (the " Act").

WHAT IS THE PURPOSE OF THIS DOCUMENT?

This document (hereinafter the "Privacy Policy") provides the legal basis for our processing of personal data, rules on the collection, use and other processing operations performed. The intent of the Privacy Policy is also to inform you of your rights in relation to the personal data we process. Benefit Systems uses your personal data for the purposes set out in this Privacy Policy and, if applicable, for other purposes not listed here, which will be disclosed to you in individual cases.

WHOM IS THE INFORMATION CONTAINED IN THIS DOCUMENT PROVIDED?

This document is determined for the following persons:

  • Our clients, partners and other natural or legal persons cooperating with us, including cases when cooperation has not yet been formally established (potential clients, partners and other collaborators) and in the event when cooperation has already been terminated (former clients, partners and other cooperating persons), as well as for members of the statutory bodies, employees and other representatives of these persons;
  • Job applicants in our company;
  • MultiSport card users;
  • Visitors to our websites;
  • Other persons not listed above whose personal data will be processed by our company.

WHAT ARE PERSONAL DATA?

Personal data means any information about an identified or identifiable natural person (e.g., name and surname, address, e-mail address, MultiSport card number and data related to its usage, IP address of visitors to our websites). Benefit Systems processes personal data for various purposes. The legal basis for the processing of personal data, the processing time and the retention of personal data may vary depending on the purpose of the transactions.

WHAT IS PERSONAL DATA PROCESSING?

Processing is any operation or set of operations with personal data (e.g., collection, storage, use, analysis, transfer, deletion). Our intention is to maintain transparency as regards the legal basis and the method of the personal data processing. In accordance with our policies, we collect and process personal data only when it is necessary for specific purposes and for the required time, and we ask you to provide us with your personal data only in the necessary cases.

WHO IS THE CONTROLLER OF YOUR PERSONAL DATA AND WHAT DOES IT MEAN FOR YOU?

Benefit Systems itself determines the purposes and means of your personal data processing, and therefore it is the controller of your personal data in the relationship with you. So, we decide what type of your personal data will be processed, what means will be used and why do we process your personal data (for what purposes).

Within the extent of our processing, we are therefore responsible for the legality of your personal data processing and you may contact us regarding the exercise of your rights in this area.

HOW IS YOUR PERSONAL DATA PROCESSED?

All personal data is processed by Benefit Systems in an automated or manual manner. Automated processing takes place in our information systems, or in the information systems of our processors, i.e. third parties, which we have entrusted with specific processing operations.

Our company has taken steps to ensure that only our employees and processors with whom we have concluded a written agreement on the processing of personal data have access to your personal data. These persons are bound by the obligation of confidentiality in relation to all personal data they have come into contact with when performing their activities.

BASED ON YOUR PERSONAL DATA, IS AUTOMATED DECISION TAKEN OR PROFILING MADE IN A WAY THAT AFFECTS YOUR RIGHTS?

There is no automated decision making in our company, i.e. no decision-making is based solely on automated processing (including profiling) that would have legal effects for you, or otherwise have a significant impact on you.

WHAT DOES SECURITY OF PERSONAL DATA MEAN FOR US?

Benefit Systems approaches security of the data it retains, very conscientiously and seriously. To that end, we have put in place the appropriate organizational and technical procedures, and we train our staff to protect privacy, confidentiality and security of personal data. In addition, we conduct regular inspections of established security procedures as to their sufficiency in relation to the nature and extent of personal data we process.

WHOM DO WE SHARE YOUR PERSONAL DATA WITH?

Benefit Systems may share your personal data with third parties as recipients or may transfer them to such third parties if any of the legal bases under Directive is given for such disclosure (transfer). These recipients also include processors who carry out processing operations with your personal data on behalf of our company.

Specifically, our company may share your personal data with the following recipients (the recipients of the following categories):

  • Our partnerswho are operators of sports and relax facilities, which can be found on https://multi-sport.sk in the part Locations and whose services are used on the basis of the MultiSport card. Partners, according to terms of using of the MultiSport Card, especially verify if you are legitimate holder of MultiSport card through the seeing of you personal document and via our devices (or written forms) register the data related to the use of your MultiSport card. We use these data primarily for billing purposes.
  • Our clientswho are your employers (or the employers of a person who, in agreement with you, has joined you in the MultiSport program). We share data with our clients about who of their specific employees and potentially other persons are supposed to be members of the MultiSport Program. We do not share with our clients the details about the use of your MultiSport card.
  • External consultantswhich are companies providing us with legal, consulting, auditing and other similar services.
  • External supplierswho, based on our mandate, carry out processing operations with your personal data. Specifically, these are companies that provide accounting, debt management, marketing and IT services. Furthermore, companies that print MultiSport cards, providers of other services available under the MultiSport Program, entities providing electronic payment services, companies providing user support services and promoting our marketing activities.
  • State administration bodies and other public authoritieswith whom we may share your personal data under certain circumstances stipulated by the legal regulations (e.g. tax offices, police).

As we act as one group, your personal data may be transferred to the following companies:

The direct business partners, which are: MultiSport Benefit, s.r.o., so sídlom Lomnického 1705/9, 140 00 Praha 4, Czech republic, Benefit Systems International spółka z ograniczoną odpowiedzialnością, 00-844 Warsaw, Ul. Młynarska 8/12, POLAND, Benefit Systems S.A., 00-844 Warszaw, Plac Europejski 2, Poland,

Pre-approved sub-processors, which are: BMS sp. z o.o., Al. Słowiańska 10B, 01-695 Warsaw, Poland, Primaris Sp. z o.o. Sp. k., ul. Bukowińska 22B, 02-703 Warsaw, POLAND, Betacom S.A., ul. Połczyńska 31 A, 01-377 Warsaw, Poland, Microsoft Ireland Operations, Ltd., One Microsoft Place, South County Business Park, Leopardstown, Dublin 18 D18 P521, IRELAND, Sii Sp. z o.o., Al. Niepodległości 69, 02-626 Warsaw, Poland

Transfers of the personal data to countries third countries in some cases for which the Commision decided that ensures an adequate level of protection:
-  Twilio Inc., 375 Beale Street, Suite 300, San Francisco, CA 94105, United States of America (EU-U.S. Privacy Shield Framework: https://www.privacyshield.gov/participant?id=a2zt0000000TNLbAAO)

- Formstack, LLC, 11671 Lantern Road, Suite 300 Fishers, IN 46038, United States of America (EU-U.S. Privacy Shield Framework: https://www.privacyshield.gov/participant?id=a2zt0000000TVUtAAO

 HOW CAN YOU CONTACT US TO GET MORE INFORMATION ABOUT YOUR PERSONAL DATA PROCESSING?

If this Privacy Policy does not provide answers to your questions about the protection of your personal data, you may contact us using any of the following ways:

  • By a letter sent to the address Benefit Systems Slovakia s.r.o., Ružová dolina 6, 821 08 Bratislava, mark an envelope with “Personal Data”
  • By e-mail sent to the address dpo@multi-sport.sk
  • By phone +421 949 516 152

The above contact details can also be used for the potential exercise of your rights as a personal data subject vis-à-vis our company and further if you wish to withdraw your consent to the processing of your personal data granted to our company.

  1. SPECIFIC INFORMATION ON PROCESSED PERSONAL DATA FOR CLIENTS, PARTNERS AND OTHER COOPERATING PERSONS

Benefit Systems hereby informs you as clients, partners and other cooperating persons about the processing of your personal data by us as a controller.

IN PRIVACY POLICY, WE FURTHER WORK WITH THE FOLLOWING TERMS:

  • “MultiSport Program“ meansa summary of products and services provided by third parties - Partners that Benefit Systems enables card users to use for the duration of a contract with the Client. The current review of products and services included in the MultiSport program can be found on the website https://www.multi-sport.sk in the part Locations.
  • “Card“ means a MultiSport card issued by Benefit Systems company authorizing users to use MultiSport products and services.
  • “Client“means a company that provides its employees with benefits in the form of using products and services within the MultiSport Program via Cards.
  • “Partner“means a person operating sports and relax facilities that cooperate with Benefit Systems and provides the said facilities for the agreed scope of services or enables Card users to use these services.

HOW HAVE WE OBTAINED YOUR PERSONAL DATA?

We have obtained your personal data through various communication channels, depending on the type of cooperation with our Benefit Systems company. If you have not provided us with your personal data directly, we have received it in one of the following ways:

  • From the Partner, the Client, and other cooperating persons (hereinafter referred to as “Business partners”) for whom you are active (i.e. you are a statutory body, employee or a different representative);
  • From the websites of the Business partner for whom you are active and from other publicly available sources (e.g. the Commercial Register, ARES application).

WHAT PERSONAL DATA DO WE PROCESS? WHAT IS THE PURPOSE AND LEGAL BASIS OF SUCH PROCESSING AND THE PERIOD OF RETENTION OF PERSONAL DATA?

Identification and contact details and business data, which are name and surname, name and seat/workplace of the Business partner, position within the Business partner, telephone contact and e-mail address, information on existing business cooperation and communication. Legal base for the purpose of conclusion and performance of the contract is Article 6 par.1 b) Directive (processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract). If you are act as the representative or contact person of the Business partner, the legal base for above stated purpose is Article 6 par. 1 f) Directive (processing is necessary for the purposes of the legitimate interests pursued by the controller, which consist in identification and authorization of communicating party, mutual communication, giving instructions). Data are processed for the period necessary for negotiation of the contract, for the period of duration of the contract and or until the replacement of contact person of the Business partner (what happens first), but no later than 6 months after the termination of the contract.

If it is necessary for the purpose of recovery of claims and the defense of our rights, we can further process the data after the stated period, until it is necessary for the achieving of the purpose (for the duration of the applicable limitation period or during the civil or administrative proceeding and then for one year after its ending) based on Article 6 par.1 f) Directive (processing is necessary for the purposes of the legitimate interests pursued by the controller, which consist in the recovery of claims and the defence of our rights.

We process above stated data further for the purpose of archiving based on Article 6 par.1 c) Directive (processing is necessary for compliance with a legal obligation to which the controller is subject) for the period provided for by the relevant legislation.

Further we process personal data name, surname, position within the Business partner, telephone number, e-mail address for the purposes of direct marketing, which consist in promoting and offering new products or services of our company, sending information about new services and products, improving service quality by conducting user satisfaction surveys, where the legal base is Article 6 par.1 f) Directive (processing is necessary for the purposes of the legitimate interests pursued by the controller, which consist in achieving of the purpose of the processing). Such data are processed for the duration of mutual cooperation with our Business partner, or unless you object such processing (for more information see part 6 below).

In some cases we process data in the scope of name and surname, name and seat/workplace of the Business partner, position within the Business partner, telephone contact and e-mail address, if you provided us with the consent (legal base is Article 6 par. 1 a) Directive) for the purpose of maintaining the obtained basic identification and contact information for contacting potential Business partner in order to establish cooperation or repeat cooperation in the future, for the period for which the consent was given otherwise three years from obtaining the data or termination of cooperation, or until it is revoked. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

  1. SPECIFIC INFORMATION FOR JOB APPLICANTS ON PERSONAL DATA PROCESSING

Benefit Systems hereby informs you as a person applying for a job in our company about the processing of your personal data by us as a controller.

HOW HAVE WE OBTAINED YOUR PERSONAL DATA?

We have obtained your personal data through various communication channels, depending on the type of contact with our company. If you have not provided us with your personal data directly (for example, by sending a CV, filling in the form on our website), we have received it through the personnel agency to which you provided your personal data.

WHAT PERSONAL DATA DO WE PROCESS? WHAT IS THE PURPOSE AND LEGAL BASIS OF SUCH PROCESSING AND THE PERIOD OF RETENTION OF PERSONAL DATA?

Identification and contact details (name and surname, date of birth if sated, address of residence, telephone number and e-mail), data about the applicant listed in the CV, cover letter or other document provided to our company, data about the applicant communicated by the applicant during a job interview or by other means (mainly achieved education, work experience and further information about the applicant’s qualification), and basic information on assessing the suitability of an applicant for a given job position. We do not process and do not require from you special categories of personal data nor the personal identification number. Legal base for data processing is for the purpose of recruitment procedure Article 6 par. 1 b) Directive (processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract). We process data for the duration of recruitment procedure.
Legal base for processing the data is your consent, if you granted it us voluntarily not only for the purpose of specific recruitment procedure, but also for contacting you in the future in order to take part in recruitment procedure for another suitable work position. In such case we process data until the consent is revoked, but no longer than three years from its granting. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

  1. SPECIFIC INFORMATION FOR MULTISPORT CARD USERS ON PERSONAL DATA PROCESSING

Benefit Systems hereby informs you as a user of the MultiSport card about the processing of your personal data by us as a controller.

IN THE PRIVACY POLICY, WE ALSO WORK WITH THE FOLLOWING TERMS:

  • “Partner Facilities“ means sports and relax facilities operated by a Partner whose services the User is entitled to use by means of the Card. The current review of Partner Facilities can be found on the website https://www.multi-sport.sk in the part Locations.
  • “List“ means the list of names of the Users delivered to the Benefit Systems by the Client.
  • “User“means an Employee, Accompanying Person, or a Child using the Card who are authorized to use Benefit Systems products and services.
  • “Employee“means a natural person performing works for the Client on the basis of employment relationship or an agreement on work done outside the employment relationship or under another similar contract, in particular a contract for the provision of services.
  • Employee Card“means the MultiSport Card issued to the Employee.
  • “Accompanying Person“ means a close person of an Employee within the meaning of the definition contained in Act No. 40/1964 Coll., the Civil Code, listed on the List, and a partner of the Employee included in the list is also considered the Accompanying Person.
  • “Card of the Accompanying Person“means a MultiSport Card issued to the Accompanying Person.
  • “Child“means a child of the Employee of less than 15 years of age listed on the List; and a "Children's card" means the MultiSport Card issued to the Child.
  • „Test Card“means the MultiSport Card issued either directly to the User as part of a Benefit Systems promotional event or to a potential Client for the purpose of its acquisition.

HOW HAVE WE OBTAINED YOUR PERSONAL DATA?

We have obtained your personal data through various communication channels, depending on the type of cooperation with our Benefit Systems company. We have received your personal data in one of the following ways:

  • From the Client who has concluded a contract with us on the basis of which his employees are entitled to participate in the MultiSport Program through Cards or has expressed an interest in joining the program through Test Cards. If you are an Employee Card holder, your personal data has been provided to us by your employer who has agreed with you on your participation in the Multisport Program. If you are the Accompanying Person Card holder, your personal data has been given to us by the employer of the person who has agreed with you on your participation in the Multisport Program. If you hold a Children's Card, your personal data has been given to us by your parent's employer or other legal representative.
  • You have provided us with your personal data directly or it has been provided by a person who agreed with you on your participation in the MultiSport Program (in the case of the Accompanying Card) or your parent or other legal guardian (in the case of a Child Card) through the IT systems proposed (for example, Formstack) in connection with a contract concluded with us by the Client on the basis of which its employees are entitled to participate in the MultiSport Program or the Client has expressed an interest to test this program through Test Cards.
  • You have provided us with your personal data directly upon agreement between you and us about your participation in the Multisport Program via the Test Card.

WHAT PERSONAL DATA DO WE PROCESS? WHAT IS THE PURPOSE AND LEGAL BASIS OF SUCH PROCESSING AND THE PERIOD OF RETENTION OF PERSONAL DATA?

Identification and contact details, data for indirect identification (name, surname, month and year of birth of child, name of the Client - employer and data related to the use of the Card (number of the Card, frequency of use of the Card – time and date of use, visited Partner facilities, selected services). Legal base of processing for the purpose of enable the implementation of the MultiSport Program, including issuing of the Card and its lifecycle management, the using of negotiated non-monetary sports benefits through the MultiSport Card including the services provided exclusively to the MultiSport Card Users, the fulfilment of billing and statistical duties of Company, is Article 6 par. 1 f) Directive (processing is necessary for the purposes of the legitimate interests pursued by the controller to achieve above stated purpose. We process data for the duration of the membership in the MultiSport Program. Further processing will only be undertaken for the purposes fulfilling the statutory obligations of the Company required by a valid and effective statutory regulation or if required for the purposes of the Company's legitimate interests (such as claiming, dispute resolution with your employer or with other Business partners of the Company), and always in the scope and for the time necessary to achieve these purposes.

If you granted us your specific consent, your data based on this legal base are processed in the scope of name, surname, name of your employer, e-mail, for the marketing purposes (organization of competitions and promotional campaigns you can take part in, information about the events we organize, offer of other services, reminding you of important information that affects the provision of our services (e.g. newsletters). In such case we process data for the period the consent was granted, but no more than one year after termination of the membership or until the consent is revoked. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

  1. SPECIFIC INFORMATION FOR VISITORS OF OUR WEB SITES ON PERSONAL DATA PROCESSING

Benefit Systems hereby informs you as visitors of our websites at https://www.multi-sport.sk about processing of your personal data performed by us as a controller.

HOW DO WE COLLECT YOUR PERSONAL DATA?

We collect your personal data through our websites (e.g. through tracking pixels) and cookies stored in your devices (especially computers and mobile phones). Benefit Systems cookies are subject to the privacy policy available on our websites at www.multi-sport.sk/zasady-cookies.

WHAT PERSONAL DATA DO WE PROCESS? WHAT IS THE PURPOSE AND LEGAL BASIS OF SUCH PROCESSING AND THE PERIOD OF RETENTION OF PERSONAL DATA?

Information about visits of our websites (visitor's IP address of the device, visitor's mobile devices IDs, personal data contained in cookies stored in end-user devices (visitors) intended to use our website) are processed for the purpose of obtaining information about visitors to our websites to improve and optimize and customize content by user preferences, obtaining information about visitors to our websites to improve our services, records of visits to our websites for statistical and analytical purposes, promotion of our services, upon legal base legitimate interest according to Article 6 par. 1 f) Directive which consist in achieving above stated purpose. We process data for the period of one year from its obtaining.

Legal base for the processing of data for the above stated purpose is your consent, if you granted it to as. In such case we process data for the period for which the consent was granted, but no longer than three years from its granting or until the consent is revoked. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

  1. COMMON INFORMATION ON YOUR RIGHTS IN RELATION TO PERSONAL DATA PROCESSING

WHAT RIGHTS DO YOU HAVE IN RELATION TO YOUR PERSONAL DATA WE PROCESS?

The processing of your personal data is governed by the following rights of data subject under the applicable legal regulations (Directive and Act) that you may exercise under the determined terms and conditions at any time by contacting us in any of the ways listed in Part 1 (General Information) of this Privacy Policy. The specific conditions under which the following rights may be exercised are further set out in Directive and Act.

We will respond to your requests for the exercise of the rights listed below within the statutory time limits.

THE RIGHT TO CLEAR, TRANSPARENT AND COMPREHENSIBLE INFORMATION ON HOW YOUR PERSONAL DATA IS USED AND WHAT YOUR RIGHTS ARE

Obligations corresponding to your rights are performed through this Privacy Policy, or through other information and communication channels.

RIGHT TO ACCESS THE PERSONAL DATA

You have the right to access your personal data that we retain as a data controller.

You have the right to ask our company to inform you whether it processes your personal data. If our company processes your personal data, you have the right to obtain the following information about its processing in particular: the categories of processed personal data, the purpose of the processing, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period,  the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations.

Upon your request, we will provide you with a copy of the processed personal data.

THE RIGHT TO REQUEST CORRECTION OF THE PERSONAL DATA

You have the right to request the correction and completion of your personal data if our company processes incorrect or incomplete personal data about you.

You can update the personal data you have provided us at any time. Depending on the purpose of the processing, the changes may be made in accordance with the terms of the services you use or the method outlined above.

If we receive a notification from you that some of your personal data we process is no longer up to date, we will correct your personal data based on your information, provided that the change can be made. Data update can take up to 48 hours, what is connected with the technical conditions of our systems.

RIGHT TO WITHDRAW CONSENT TO THE PROCESSING OF PERSONAL DATA

If your personal data is processed upon your consent, you have the right to withdraw this consent at any time. If you want to withdraw your consent to the processing of your personal data, simply contact us in one of the ways listed in the Privacy Policy above.

To unsubscribe from the newsletter, click on the unsubscribe link in the e-mail message we sent to you. Withdrawal of consent is without prejudice to the lawfulness of processing of your personal data prior to such withdrawal. 

RIGHT TO OBJECT TO THE PROCESSING OF PERSONAL DATA. IN WHICH CASES YOU MAY OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA?

You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on the legal ground, which is the legitimate interest of the controller. The controller shall no longer process the personal data unless he demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.

  • You have the right to object the processing of personal data for direct marketing purposes. If you object to processing for direct marketing purposes, we shall no longer process your data for such purposes.

RIGHT TO LIMIT PROCESSING

You have the right to request from our company that we restrict the processing of your personal data where one of the following applies:

  • the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
  • you object that the processing is unlawful and oppose the erasure of the personal data and requests the restriction of their use instead;
  • we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims;
  • you object to processing based on legitimate interest until we verify that the legitimate reasons on our side as the controller outweigh your legitimate reasons.

In this case, we will no longer process your personal data or restrict our processing until we are able to demonstrate reasonable grounds for processing or the necessity of processing for the purpose of exercise or defense of legal claims, protection of human or general public interest.

RIGHT TO DATA PORTABILITY

If our company processes your personal data under your consent or for the purpose of performing the contract, and if the processing is automated you are entitled to obtain our personal data in a structured, commonly used and machine-readable format. You may also transfer your personal data to a different data controller or request that we transfer it to a different data controller. However, we can only do so if the transfer of data is technically feasible and the other controller agrees to accept it. Exercise of right to data portability shall not affect the right to deletion of personal data.

RIGHT TO DELETION OF PERSONAL DATA

We will delete your personal data upon request without undue delay if:

  • Personal data are no longer needed for the purposes for which they were collected or otherwise processed;
  • You withdraw your consent under which we process personal data and there is no other legal ground for processing;
  • You make a legitimate objection to the processing based on a legitimate interest of our company;
  • Personal data was processed unlawfully or
  • Personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

RIGHT TO FILE A COMPLAINT WITH THE OFFICE FOR PERSONAL DATA PROTECTION

You have the right to lodge a complaint, if you believe that during the personal data processing there has been a breach of the obligations set by the legislation on the protection of personal data (in particular Directive and Act).

The authority performing supervision of the personal data processing carried out by Benefit Systems is the Office for Personal Data Protection of Slovak republic with the registered office at Hraničná 12, 820 07 Bratislava, https://www.dataprotection.gov.sk. Act in its par. 100 stipulates the essentials of such complaint and the procedure of the Office for the Personal Data Protection in its investigation.

  1. AMENDMENTS TO THIS PRIVACY POLICY

We will periodically review and update this Privacy Policy in connection with amendments to the applicable legal regulations, changes in the scope of our processing of personal data, and our efforts to improve the level of security of your personal data and the quality of our services.

The latest update of this documents was on November 21, 2019.