The main data controller is:
Smartwings, a.s., ID: 256 63 135, registered office: Praha, K Letišti 1068/30, postal code: 16008 (hereinafter referred to as “SW CZ”)
Contact details: email@example.com
Data protection officer: KUBEČKA & PROKOP, advokátní kancelář s.r.o., firstname.lastname@example.org
Other general information:
SW CZ is a company established under the law of the Czech Republic, which established its Slovak subsidiary Smartwings Slovakia, s.r.o., registered office Ivanská cesta 30/B, Bratislava 821 04, registered office Ivanská cesta 30/B, Bratislava 821 04 (hereinafter referred to as “SW SK”), its Hungarian subsidiary Smartwings Hungary Kft., registered office Wesselényi u. 16/A, Budapest, 1077, Hungary (hereinafter referred to as “SW HU”), its Polish subsidiary Smartwings Poland Sp. z o.o., registered office ul. Gordona Bennetta 2B, Warszawa, 02-159, Poland (hereinafter referred to as “SW PL”) and its German subsidiary Smartwings Germany Gmbh, registered office Theatinerstraße 23, 80333 München, Gemany (hereinafter referred to as “SW DE”) (all of them hereinafter jointly referred to as “SW”).
All the above stated companies use their joint website www.smartwings.com – however, the important difference is that SW CZ provides services in the field of civil air transport directly to passengers in the form of regular transport, while SW SK, SW PL, SW HU and SW DE provide aviation services especially through travel agencies in the form of charter flights. Most of the visitors of the websites, i.e. data subjects according to GDPR, are likely to be the customers of SW CZ, so the main controller within this company group is SW CZ. Together with the other aforesaid companies, they are all joint controllers. Joint management of cookies is given by economic reasons – administrative streamlining.
What are cookies – what is the purpose of their collection?
- to secure correct functionality of our website, so that it is possible to complete the buying process as smoothly possible;
- to facilitate business setting; when you return, they help with logging in or remind you of our offer in advertising spaces of other websites as well;
- to remember login data, so that you do not have to enter them each time;
- to secure correct functioning, so that your cart is not emptied accidentally or so that you remain logged in;
- to ascertain which pages and functions are most used by the visitors, so that we are able to adjust our offer to your requirements in the best possible way;
- to ascertain which advertisements are most viewed by the visitors and to optimize the offer for customers and approach them in advertising spaces, so that not the same advertisement is displayed over and over again or that advertisements of goods in which the visitors are not interested are not displayed. Further general information about cookies is available e.g. here
What cookies do we use?
The cookies used on our website can be divided by the duration and by the purpose into two types. Short-term cookies, which are called “session cookies”, are used for the duration of your visit and are erased several minutes after you leave the website. Long-term cookies called “persistent cookies” stay saved in your device much longer, generally until you delete them.
In terms of the purpose fulfilled, the cookies are classified as:
- conversion cookies – they make it possible for us to analyse the efficiency of advertising and the performance of various sales channels
- tracking cookies – these cookies, in combination with conversion ones, help us to analyse the performance of various sales channels and, basically, help us to optimize our offer
- remarketing cookies – they are used for the personalization of advertising contents and their correct targeting
- analytical cookies – they help us to increase the comfort of use of our website through understanding how the website is used by users, and to facilitate access to the required contents
- essential alias key or functional – they are important for the basic functionality of the website.
Some cookies may collect information that is subsequently used by third parties and that e.g. directly support our advertising activities (third party cookies). However, you are not identifiable from such data.
What is the legal ground for the processing of cookies?
Cookies are processed on the grounds of our legitimate interest associated with the enhancement of the quality of our web presentations, analytical purposes and personalization of advertising – this relates to SW CZ, SW SK, SW PL and SW DE. As far as the Hungarian legislation is concerned, we have received recommendation to process the cookies used for the personalization of advertising only with your consent. So if you are a visitor of our website, and the analysis shows that you are located in Hungary, we will process the concerned cookies only with your consent for the time until you withdraw your consent or prohibit the cookies in your browser. In any case, we will process the cookies only until you prohibit them in your browser.
Who is the recipient of personal data?
We are the recipients. Some cookies may collect information that is subsequently used by third parties and that e.g. directly support our advertising activities (third party cookies). However, you are not identifiable from such data.
What are your rights
I. Right to obtain basic information about processing – We are obliged to provide you with such information when obtaining personal data if we have them directly from you, and if the data were not obtained directly from you, then at the latest within one month after obtaining the personal data, or at the moment of mutual communication if the personal data are used for the purposes of such communication, or at the latest at the time of the first disclosure if we are going to disclose the data to a third party.
II. Right to access to personal data – At your request, we are obliged to confirm to you whether we process your personal data and to inform you in accordance with GDPR e.g. about the purpose, period of processing, right to erasure, etc. We will also provide you with a copy of the personal data undergoing processing, provided that this does not result in adverse interference with the rights and freedoms of other persons.
III. Right to rectification – If we have inaccurate personal data, we are obliged to rectify or complete them at your request.
IV. Right to erasure – At your request, we are obliged to erasure personal data without undue delay especially if:
- you have withdrawn your consent, and we do not have any other legal ground for the processing,
- we do not need the data any longer for the specified purpose for which they were processed,
- we have processed the personal data unlawfully,
- we fulfil a legal obligation laid down in legal regulations by doing so,
- you object to the personal data processing on the grounds of legitimate interests, and there are no overriding legitimate grounds,
- you object to the personal data processing for the purposes of direct marketing, including profiling.
If you request erasure, we are not obliged to erase personal data where the following reasons, in particular, are concerned:
- the establishment, exercise or defence of legal claims,
- the compliance with a legal obligation laid down in legal regulations,
- the exercise of the right of freedom of expression and information.
V. Right to restriction of processing – We are obliged to restrict the processing of your personal data if:
- you contest the accuracy of the personal data,
- SW group companies (hereinafter jointly referred to as “SW”) process personal data unlawfully, but you do not want the group companies to erase them,
- SW no longer needs the personal data for any of the specified purposes, but you require SW to maintain them for the establishment, exercise or defence of legal claims,
- you have objected to the processing on the grounds of a legitimate interest, and we are waiting for the verification whether the interests of SW override your legitimate grounds.
Where personal data processing has been restricted, SW may only process such data by storing them, except for the situation when you give us consent, or for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural person or legal entity, or on the grounds of important public interest of the Union or of a Member State.
SW will inform you beforehand if the restriction of processing is lifted.
VI. Right to data portability – If we process personal data on the basis of consent or a contract, and the processing is carried out fully automatically, you can request SW to:
- provide you with the personal data in a structured, commonly used and machine-readable format,
- transmit such data to another controller where technically feasible.
VII. Right to object – If we process your personal data on the grounds of a legitimate interest or carry out profiling (for the definition of profiling see art. 9), you may object to such processing at any time. We will restrict the processing until everything is clarified, and if we do not demonstrate compelling legitimate grounds for the processing, we will no longer process the personal data. If we use the data for direct marketing purposes, we will no longer process them without further notice after you lodge your objection.
VIII. Right to protection by national authorities – You have the right to lodge a complaint with the supervisory authority for personal data protection, which is:
For SW CZ: Úřad pro ochranu osobních údajů, registered office Pplk. Sochora 27 170 00 Praha 7, website: https://www.uoou.cz/, telephone: fixed landline: +420 234 665 111 (telephone exchange). In addition, you have the right to judicial redress. You may lodge a complaint to the supervisory authority and an action to a court if you believe that your rights protected by GDPR were infringed in the consequence of the processing by SW.
- For SW PL: Biuro Generalnego Inspektora Ochrony Danych Osobowych, website: http://www.giodo.gov.pl
- For SW SK: Úrad na ochranu osobných údajov Slovenskej republiky, website: http://www.dataprotection.gov.sk
- For SW HU: Nemzeti Adatvédelmi és Infotmációszabadság Hatóság, website: http://www.naih.hu/
- For SW DE: Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit, website: http://www.bfdi.bund.de
EXERCISE OF RIGHTS AGAINST SW
You may exercise your rights against SW electronically, in particular, by sending an e-mail to the address email@example.com or a letter to the address Na bojišti 1473/18, Nové Město, 120 00 Praha 2, or a letter to the registered offices of the companies SW SK, SW HU and SW DE. If you contact us electronically, SW will also reply electronically. However, you may also request a different method of communication.
We will handle your requests and reply to them as soon as possible, depending on our capacities and capabilities; according to GDPR we are obliged to reply at the latest within 1 month from the receipt of the request. This period may be extended by further two months where necessary, taking into account the complexity and number of requests. However, we will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.
If we have any doubts concerning you, we will ask you to provide us with further information necessary to confirm your identity. This is done in order to protect your personal data, i.e. to prevent transfer of personal data to a person who is not who they say they are.
We handle requests free of charge, but there are certain exceptions:
- your request is unfounded,
- your request is excessive.