Protection of personal data of our clients and other natural persons is important to us. This Privacy Policy provides an explanation on how we process personal data of data subjects within our company GoHealth, s. r. o., with registered seat at: Nivy Tower, Mlynské Nivy 5, 821 09 Bratislava, Company ID No. (IČO): 48 108 308 (hereinafter “We” or “GoHealth”). In this regard, the foregoing relates to the processing of personal data of
As for the processing of personal data of data subjects, the company GoHealth processes the personal data directly and for the purposes of the legal regulation stated hereunder that regulates the protection of personal data it is therefore considered to be the controller. If, in special cases, personal data is provided to and processed by our subcontractors, in the position of Representatives of our company (e.g. for purposes of provision of services to our clients), such activities are performed at the request of the company GoHealth and to the extent specified by it. For this reason, our subcontractors are considered processors for the purposes the legal regulation stated hereunder. The mutual relationship between the company GoHealth and our subcontractors in the processing of personal data is regulated by special contracts on processing of personal data that are based on and fully in compliance with the applicable legal regulation, by which it is ensured that all rights of data subjects to which we refer hereunder are duly preserved.
In the processing of personal data, we primarily follow
If you have any questions regarding the processing of personal data by the company GoHealth or in case your wish to file an application or other requests under the provisions of GDPR and under the provisions of Personal Data Protection Act, you can contact the company GoHealth by telephone at the following phone number: 0907/774990, by email at pkrauspe2@gohealth.com or by post to the following address: Nivy Tower, Mlynské Nivy 5, 821 09 Bratislava.
Processing of personal data by the company GoHealth is necessary for us to be able to:
Collecting and processing of personal data may be in the light of the foregoing under certain circumstances a requirement arising under the respective legal regulation (e.g. special accounting and tax laws, etc.), as well as a requirement necessary to conclude a contract with a business partner or a job seeker, or to duly fulfil the obligations resulting therefrom, or, as the case may be, to duly assess the applications and requests of the persons exercising their rights under the GDPR and the recipients and senders of correspondence.
Providing your personal data to our company is primarily voluntary. However, failure to provide your personal data to the appropriate extent may make it impossible to enter into a respective contract with our company, or a proper evaluation and resolution of your request. Depending on the specific case, the failure to provide personal data may establish the right of our company to refuse to enter into a contract with a business partner or a job seeker, or to refuse the applications of persons exercising their rights under the GDPR, or the recipients and senders of correspondence.
As for our business partners, we process their personal data as follows:
Purposes of the processing | Legal basis for the processing | Categories of the personal data | Period for which the personal data will be stored |
---|---|---|---|
Performance of business activities | Compliance with legal obligations pursuant to Article 6 (1) (c) of GDPR, performance of a contract pursuant to Article 6 (1) (b) GDPR. | Ordinary personal data including identification data (e.g. name, surname, title, address of permanent residence, date of birth, work or other position, etc.) (hereinafter also referred to as the “identification data”), contact information (e.g. postal address, e-mail address, phone number, etc.) (hereinafter also referred to as the “contact information”) and other personal data in the extent necessary for the provision or receiving of services. | Depending on the applicable legal basis, we store personal data until the material and accounting expiration of the respective contractual relationship, or as the case may be, until the expiration of the limitation periods relating to individual claims arising from the contractual relationship with our business partner in question. |
Accounting and tax purposes | Compliance with legal obligations pursuant to Article 6 (1) (c) of GDPR. | Ordinary personal data including identification data, contact information and respective financial data pursuant to applicable legislation. | We store the personal data to the extent and for the period stipulated in the special accounting and tax legislation. |
Ensuring compliance with the laws applicable to our company | Compliance with legal obligations pursuant to Article 6 (1) (c) of GDPR. | Ordinary personal data including identification data, contact information and other personal data to the extent set forth in respective laws applicable to our company (e.g. laws in the area of prevention and detection of money laundering and terrorist financing). | We store the personal data to the extent and for the period specified in the respective laws (e.g. laws in the area of prevention and detection of money laundering and terrorist financing). |
Promotional and communication purposes of our company to introduce our company and its results (including its work and activities) | Performance of pre-contractual measures at the request of the potential business partner prior to entering into a contract under Article 6 (1) (b) GDPR, legitimate interests pursuant to Article 6 (1) (f) of GDPR. The legitimate interest of our company is, in this regard, particularly the performance of marketing activities of our company with the intention to expand the range of our business partners, maintain contractual relations with our business partners, or to extend the range of services provided to our business partners. | Ordinary personal data including identification data and contact information. | We store the personal data until the end of the pre-contractual relationship with a potential business partner or for a period of 3 years from the end of cooperation with our business partner. |
As for job seekers, we process the personal data of these persons in the following manner:
Purposes of the processing | Legal basis for the processing | Categories of the personal data | Period for which the personal data will be stored |
---|---|---|---|
Evaluation of abilities, skills and personal qualities of the job seeker and the performance of a selection process for a designated job or other position and re-addressing the unsuccessful job seeker with a job offer or an offer for mutual cooperation and performance of a selection process for a new job or other position | Compliance with legal obligations pursuant to Article 6 (1) (c) of GDPR, performance of pre-contractual measures at the request of the job seeker prior to entering into a contract under Article 6 (1) (b) GDPR, jobseeker's consent under Article 6 (1) (a) GDPR. | Ordinary personal data including identification data, contact information and other personal data in the extent that the job seeker has provided in the CV, during the selection process, or has provided otherwise (e.g. via email, contact form on the company's GoHealth website or by other electronic means) to the company GoHealth in applying for a job or other cooperation. | We store the personal data of job seekers who have been successful in the selection process only for the necessary time, i.e. during the selection process. We store the personal data of job seekers who have not been successful in the selection process only until the selection process is completed. In case we are provided with a written consent, we store the personal data of unsuccessful job seekers for the duration of such consent (typically, for a period of 1 year from the date of its granting). |
As for persons exercising their rights under GDPR, we process the personal data of these persons in the following manner:
Purposes of the processing | Legal basis for the processing | Categories of the personal data | Period for which the personal data will be stored |
---|---|---|---|
Ensuring compliance with personal data protection legislation | Compliance with legal obligations pursuant to Article 6 (1) (c) of GDPR. | Ordinary personal data including identification data, contact information and other personal data to the extent set forth in the applicable legal regulation, particularly in GDPR and in Personal Data Protection Act, or stated in the applications of persons exercising their rights under GDPR. | We store the personal data for a period of 5 years from the processing of the data subject's application under GDPR, the fulfilment of the respective obligation arising from GDPR or Personal Data Protection Act, or other legally relevant fact. |
As for recipients and senders of correspondence, we process the personal data of these persons in the following manner:
Purposes of the processing | Legal basis for the processing | Categories of the personal data | Period for which the personal data will be stored |
---|---|---|---|
Recording of incoming and outgoing correspondence | Compliance with legal obligations pursuant to Article 6 (1) (c) of GDPR, legitimate interests pursuant to Article 6 (1) (f) of GDPR. The legitimate interest of our company is, in this regard, particularly to ensure the proper maintenance of evidence of the incoming and outgoing correspondence, as well as to ensure the provision of a qualified response and reply to the correspondence received by our company. | Ordinary personal data including identification data, contact information and other personal data constituting the contents of correspondence or our electronic mailbox. | We store the personal data to the extent and for the period stipulated in relevant legal regulations on registry. |
Ensuring communication with persons who contact our company through its contact details, website or social networks | Performance of pre-contractual measures at the request of the potential business partner or other person prior to entering into a contract under Article 6 (1) (b) GDPR, legitimate interests pursuant to Article 6 (1) (f) of GDPR. The legitimate interest of our company is, in this regard, particularly the necessity to establish a communication channel between a potential business partner or other persons and our company, or, alternatively, the provision of a reply to requests of other third persons addressed to our company. | Ordinary personal data including identification data, contact information and other and other data that persons concerned provide in the course of communication addressed to our company or share with it through its contact details, website or social networks, as well as social netwroks features (e.g. Like button and Share button on Facebook). | We store the personal data until the end of the pre-contractual relationship with a potential business partner or other person, or for the period necessary to provide a response to other third persons, or duration of sharing communication with such a person on social networks. |
As for the Representatives of our company, we process the personal data of these persons in the manner set forth in internal regulation of our company, of which Representatives of our company have been duly informed.
We store the personal data only to the extent necessary and as long as is necessary for the purposes for which the personal data are processed. When storing personal data, we ensure the compliance with the relevant legal regulations (e.g. special accounting and tax legislation, etc.), internal regulations adopted by our company.
For more information about the processing and storage of personal data please see the Section 3 above and, if needed, we will provide you with additional information or explanations based on your inquiry.
We disclose personal data of data subjects only to the extent necessary and always while maintaining the confidentiality of the data recipients, e.g. to Representatives of our company, persons stated in point 6 below, our accountants and tax advisors, legal advisors, or the software and IT support providers of our company. Personal data of data subjects can also be, in specific cases, provided to translators, notaries, companies providing email services, social networks or postal and delivery services.
Specific cases of disclosure of your personal data may occur in cases of disclosure of such data to the competent public authorities, e.g. in cases prescribed by law, in the case of exercising your or our rights and claims in accordance with applicable law (e.g. exercising rights in court proceedings, in proceedings before the Office for Personal Data Protection of the Slovak Republic, etc.), etc..
Generally, we do not in intend to transfer your personal data to third countries outside the European Economic Area (EU, Iceland, Norway and Liechtenstein). If the transfer of data outside the EU or the European Economic Area is necessary, the company GoHealth will ensure that the country to which the data will be transferred is approved by the European Commission as a country with a sufficient level of privacy protection or that privacy is ensured by standard contractual terms approved by the European Commission.
However, the cross-border transfer of personal data occurs in the case of jobseekers by providing them to the following recipient: the company GoHealth US with its registered office at 214 West Huron St., Chicago, Illinois, which participates in the selection process of these data subjects through its representatives. The transfer of personal data takes place while ensuring adequate safeguards in the form of standard contractual clauses on the protection of personal data approved by the European Commission concluded with this company established in a third country outside the EU.
We do not perform automated decision-making, nor profiling.
Mostly, we obtain your personal data directly from you. In that case, obtaining your personal data is voluntary. We may also obtain personal data from publicly available sources (e.g. the Commercial registry), public authorities or other third persons.
GDPR regulates several rights of data subjects whose personal data are processed. These rights among others include the right to withdraw the consent to the processing of personal data, the right of access to personal data, the right to rectification of personal data, the right to erasure of personal data (‘right to be forgotten’), the right to restriction of the processing of personal data, the right to data portability, the right to object the processing of personal data and the right to lodge a complaint with the supervisory authority.
As a data subject, you may exercise your rights as specified below through the contact information of the company GoHealth referred to in Section 1 above.
If we process your personal data based on your consent to the processing of personal data (within the meaning of Article 6 (1) (a) of GDPR), you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of the processing based on the consent before its withdrawal. You can withdraw your consent to the processing of personal data given to the company GoHealth by email at pkrauspe2@gohealth.com or in writing to the address of the registered seat of the company GoHealth.
You have the right to obtain from the company GoHealth a confirmation as to whether or not we process your personal data. If we do process your personal data, you have the right to access such personal data and information about (i) the purpose of processing, (ii) the categories of your personal data concerned, (iii) the recipients or category of recipients to whom your personal data have been or will be provided; (iv) the period for which we will store your personal data; (v) the right to rectification and erasure of the personal data processed by the company GoHealth, the right to restriction or to object to the processing of personal data, (vi) the right to file a complaint with the supervisory authority (Personal Data Protection Office of the Slovak republic); (vii) the source of the personal data if we had not obtained them from you; (viii) the existence of automated decision-making, including profiling pursuant to Article 22 (1) and (4) of GDPR; and (ix) the appropriate safeguards established under Article 46 of GDPR, should we transfer personal data to a third country or an international organization.
You also have the right to be provided with a copy of the personal data undergoing processing. The company GoHealth may charge a reasonable fee corresponding to administrative costs for any additional copy that will be requested from your part.
If we process your personal data, you have the right to obtain from the company GoHealth without undue delay the rectification of inaccurate personal data concerning you. With respect to the purpose of processing personal data, you also have the right to have incomplete personal data concerning you completed, including by means of providing a supplementary statement.
You have the right to obtain from the company GoHealth the erasure of your personal data which are processed if (i) your personal data are no longer necessary in relation to the purposes for which we collected or otherwise processed them (ii) you have withdrawn your consent to the processing of your personal data (if applicable) and there is no other legal ground for the processing of your personal data; (iii) you have exercised your right to object to the processing of your personal data (such as described in Section 9 (g) below) and at the same time there are no overriding legitimate grounds for the processing of your personal data, (iv) your personal data has been processed unlawfully, or (v) your personal data must be erased in order to comply with any obligation applicable to the company GoHealth.
However, your right to erasure of the personal data is not an absolute right and the company GoHealth is entitled to reject your application if any of the reasons set forth in Article 17 (3) of GDPR apply, e.g. (i) the processing of your personal data is necessary to fulfil our legal obligation (e.g. the period of storage of personal data under applicable legal regulation still lasts), (ii) the processing of your personal data is required for the purposes of archiving in the public interest; and/ or (iii) the processing of your personal data is necessary to establish, exercise or defend any legal claims of the company GoHealth.
If we process your personal data, you have the right to obtain from the company GoHealth the restriction of processing if any of following applies: (i) you contest the accuracy of the personal data for a period enabling us to verify the accuracy of the personal data, (ii) the processing of your personal data is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead, (iii) your personal data are no longer needed for the purposes of the processing, but you require them to establish, exercise or defend your legal claims or (iv) you have exercised your right to object to the processing of your personal data (as described in Section 9 (g) below) pending the verification whether the legitimate grounds of the company GoHealth override the legitimate grounds of yours.
If, after exercising your right to restriction of the processing of your personal data in the above cases the processing of your personal data has been restricted, the company GoHealth may, with the exception of storage of such personal data, process such personal data only with your consent or for the establishment, exercise of defence of legal claims of the company GoHealth or for the protection of the rights of another natural or legal person or for important public interest of the European Union or a member state of the European Economic Area Agreement.
If we process your personal data, you have the right to receive your personal data which you have provided to us in a structured, commonly used and machine-readable format and to transmit this data to another controller, or the right to transfer this personal data directly to the other controller, if (i) we process your personal data based on your consent or based on a contract and (ii) the processing is carried out by automated means (i.e. electronically).
However, the aforementioned rights do not apply to personal data that we process on a legal basis other than the consent or performance of the contract (e.g. compliance with legal obligations). Further, the exercise of your rights as described above shall not adversely affect the rights and freedoms of others.
You have the right to object the processing of your personal data that is based on the legal grounds of public or our legitimate interest, including profiling based on legitimate interest.
After exercising this right, the company GoHealth will no longer process your personal data processed on the given legal grounds unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or the reasons for the establishment, exercise or defence of legal claims.
If we process your personal data for direct marketing purposes, you also have the right to object at any time to the processing of your personal data for the purpose of such marketing, which includes profiling to the extent that it is related to such direct marketing. After exercising this right, the company GoHealth will no longer process your personal data for such purposes.
If you believe that your rights under GDPR or Personal Data Protection Act have been violated within the processing of your personal data by the company GoHealth, you have the right to lodge a complaint (motion for personal data protection proceedings) with the supervisory authority, in particular in the Member State of your habitual residence, place of work or place of alleged infringement. The supervisory authority in Slovak Republic is the Office for Personal Data Protection of the Slovak Republic, Hraničná 12, 820 07 Bratislava.
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Protection of your data is not a one-time issue for us. The information we give you with regard to processing of personal data may change or cease to be up to date. For these reasons, we may change this Privacy Policy at any time and to any extent. If we change this Privacy Policy substantially, we will bring such changes to your attention, for example through a general notice posted on this website or by explicit notice delivered by email.
Yours sincerely,
the company GoHealth, s. r. o.