PRIVACY POLICY

Adam Technology s.r.o., ID Number (IČO): 09360735, having its registered office at Evropská 2758/11, 160 00 Prague 6, Czech Republic, operating the Adam web application at painteradam.ie (hereinafter referred to as “Adam”), as the controller, would like to hereby notify users of the web application and professionals (hereinafter also referred to as “you” or the “Data Subject”) of the method and scope of personal data processing conducted by Adam, including the scope of the Data Subject rights associated with the processing of their personal data by Adam.

1. WHICH PERSONAL DATA DO WE PROCESS?

Adam processes, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation; hereinafter referred to as the “GDPR”) and in accordance with relevant national data protection legislation, the following personal data:

(a) Identification details such as first name, last name, name of your company, date of birth, ID number;

(b) Contact details such as e-mail address, phone number, contact address;

(c) Payment and tax information such as name and surname or company name, permanent address or address of the registered office, place of birth, date of birth, taxpayer identification number, country of residence, VAT number, bank account identification number, account holder, price of the requested and offered services;

(d) Details of the service requested such as the location in which the Data Subject (user) is requesting the service, technical information, information on the number of rooms, type of property, additional service requirements, price of services and any other information the Data Subject provides to Adam in connection with the request;

(e) Information related to the service offered, such as the location in which the Data Subject (professional) offers the service, its experience, photo of the professional, information about the additional services offered, the price of the services, copies of identification card, licenses and other documents related to provision of Professional Services and other information that the Data Subject (professional) provides to Adam in connection with the offer and its work;

(f) Data contained in communication such as content of contact forms and information from the communication between the Data Subject and Adam, via telephone, e-mail, chat, etc;

(g) Photos of work such as photographs of the work taken before and after the Professional Services are provided and other photographs that show the professional's work.

(h) Information collected automatically, such as your IP address, browser type, operating system, application version, and geographical location. We also collect information about your use of Adam website, such as the pages you have visited or the search terms you use. We collect this information by setting cookies.

Adam processes the personal details solely for the purposes stated below and to the extent and for the time necessary to achieve such purposes.

2. FOR WHICH PURPOSES AND ON WHICH LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA?

(a) To fulfil contractual obligations and ensure the provision of the service
- Adam processes Identification details, Contact details, Payment and tax information, Details of the service requested, Information related to the service offered and Data contained in communication for the purpose of providing the services offered through the Adam website, for the performance of the contract concluded between Adam and the Data Subject, and for the purpose of providing the services requested and mediation of the services offered.
- The legal basis for this processing is the performance of the contract between the Data Subject and Adam and the need to take steps before entering the contract. Adam processes the Data Subject's personal data for the duration of the contractual relationship and for 5 years after the termination thereof.

(b) To mediate communication between independent professionals and users
- The processing of personal data to this extent – Identification details, Contact details, Payment and tax information, Details of the service requested, Information related to the service offered and Data contained in communication – is necessary in order to mediate communication between independent professionals of painting and other craft and household services and users and to subsequently fulfil the rights and obligations arising from the provision of the service by Adam, including keeping records of such relationships and the related communication between you and Adam through the web application.
- The legal basis for this processing is the performance of a contract between the Data Subject and Adam or legitimate interest of Adam to mediate communication. The data is processed for the duration of the contractual relationship created by the conclusion of the contract but always for a minimum of five years after the personal data has been obtained.

(c) To protect legal interests (claims)
- Personal data processing to a limited extent as necessary for Adam’s legitimate interests which include enforcing claims of Adam against third parties and providing protecting against claims made against Adam.
- The legal basis for this processing is legitimate interest of Adam in protecting its rights. Adam processes the data for the duration of the time limits within which the data Subject can exercise its rights. Typically, personal data will be stored until 10 years after the end of the concluded contract or the termination of the cooperation (or even longer in the event of a dispute).

(d) To market and promote Adam and the web application services via promotional e-mails and other electronic commercial communication
- Adam collects and processes the Data Subjects’ personal data within the scope of Contact Details (specifically email address).
- The legal basis for this processing is legitimate interest of Adam in supporting and promoting its products and services. The data is processed until a maximum of 5 years after the last e-mail sent by Adam. You can opt out of receiving promotional e-mails at any time by clicking the unsubscribe link in each e-mail.

(e) For reporting necessary information in accordance with legal regulations for tax purposes (particularly DAC7 directive)
- The processing of personal data, including Identification details, Contact details and Payment and tax information is necessary for reporting required information in accordance with legal regulations for tax purposes (particularly the DAC7 directive).
- The legal basis for this processing is the fulfilment of legal obligations of Adam. The data is processed for the period required by law.

(f) Processing related to mechanisms for taking action on illegal content
- In accordance with Regulation (EU) 2022/2065 of the European Parliament and of the Council (the DSA regulation), Adam, as the provider of the online platform, is required to implement mechanisms to allow entities to report the appearance of information that may be considered illegal content. At the same time, Adam must take measures to remove the illegal content and hand over the requested information when requested by the administrative authorities. For this purpose, Adam processes Identification details, Contact details, Payment and tax information, Details of the service requested, Information related to the service offered (including copies of identification card, licenses and other documents related to provision of Professional Services) and Data contained in communication.
- The legal basis for this processing is the fulfilment of legal obligations of Adam. The data is processed for the period required by law. However, the personal data will also be processed for the performance of tasks carried out in the public interest, to the extent that the DSA regulation does not specify what personal data are to be processed, in particular in connection with the evaluation of the illegality of content, the transmission of information to the administrative authorities, and other activities that are related to the performance of obligations under the DSA regulation.

(g) Adam promotion and marketing
- Adam may process personal data for the purpose of promoting Adam, its website and the services provided by Adam and professionals. As part of this, Adam may, for example, share Photos of work on social media, on the website and on other promotional materials and platforms.
- The legal basis for this processing is the consent of the Data Subject. The personal data is processed until the consent is withdrawn, but in any case until a maximum of 10 year has elapsed since publishing of the photo.

(h) Ensuring website operation and security (necessity)
- Adam processes personal data of Data Subjects for the operation of the website and its security, i.e. for the presentation of information on the website, the internal functioning of the website, and for ensuring security. For this purpose,
- Adam processes Information collected automatically (necessary cookies).
- The legal basis for this processing is Adam's legitimate interest in the proper functioning and secure operation of the website. The data is processed for the duration of the visit to the website, for a maximum of 1 year after the data has been collected.

(i) Collection of statistical data on website traffic (statistics)
- Adam processes personal data to understand how Data Subjects use the website. As part of this purpose, Adam may collect statistical data, monitor website traffic, optimize the website and generally make the website visit more user-friendly. With Data Subjects`s consent, Adam may process Information collected automatically (statistical cookies) for this purpose. While doing so, personal data may also be transferred to third parties.
- The legal basis for the processing is the consent of the Data Subject, which the Data Subject has given via the cookie bar. The personal data is processed until the consent is withdrawn, but in any case until a maximum of 1 year has elapsed since last visit of the website. The specific storage period may vary according to the different types of tools and cookies that are deployed on the website.

(j) Support and promotion on the website (marketing)
- Adam also processes personal data to obtain information about personal preferences and to display and target relevant advertising. For this purpose, Adam processes Information collected automatically (marketing cookies), based on the consent of the Data Subject. In doing so, personal data may also be transferred to third parties.
- The legal basis for processing here is thus the consent of the Data Subject granted via the cookie bar. The personal data is processed until the consent is withdrawn, but in any case until a maximum of 1 year after the visit to the website. The specific storage period may vary according to the different types of tools and cookies that are deployed on the website.

3. WHO ARE THE RECIPIENTS OF YOUR PERSONAL DATA?

In order to reach the aforedescribed purposes, personal data may be also processed, in addition to Adam and its employees, by Adam’s partners. Adam carefully selects its third-party partners, who may process your personal data as processors, and entrusts personal data only to entities that provide a sufficient guarantee of its appropriate technical and organisational measures implemented to prevent primarily any accidental or illegal destruction, loss, alteration, unauthorised disclosure of transferred, saved personal data or personal data processed using other means or unauthorised access thereto.

Other entities that may have access to your personal data are or may be in the future:

- persons who assist Adam with the administration of the platform and with its services and who work with Adam under a collaboration agreement or similar arrangement;
- professionals who provide the services requested by Data Subjects (users);
- persons who run the technical aspects of a certain service or operators of technology used by Adam for such services (such as software and IT system suppliers; communication service providers, marketing and promotion service providers);
- public, who can see through the platform the public personal data of professionals and photos of the work that Adam shares publicly.
- persons providing consulting services to Adam (such as a law firm, tax advisor, etc.);
- company which provides Adam with tools for sending SMS messages;
- company which provides Adam with cookie bar and tools for website functionality;
- Celonis, Inc., which provides Adam with tools to manage its business. This company is registered under the Data Privacy Framework;
- Google Ireland Limited, which provides Adam with software workspace and tools for website functionality, usage statistics and marketing. Even if the data are shared with Google LLC, the company is registered under the Data Privacy Framework;
- Kliken GmbH which provides Adam with tools for website functionality. The company is seated in the Switzerland and there is adequacy decision for such sharing of personal data;
- Meta Platforms, Inc., which provides Adam with marketing tools;
- Microsoft Ireland Operations Limited, which provides Adam with tools for usage statistics and marketing. Even if the data are shared with Microsoft Corporation, the company is registered under the Data Privacy Framework;
- Slack Technologies, LLC, which provides Adam with communication tool. This company is registered under the Salesforce, Inc., under the Data Privacy Framework;
- WhatsApp LLC, which provides Adam with communication tool. This company is registered under the Data Privacy Framework;
- Wix.com Inc., which provides Adam with web development tool and tools for website functionality and usage statistics. This company is registered under the Data Privacy Framework.

Adam is also required to disclose some of your personal data under applicable legislation, for example, to administrative authorities, courts or law enforcement authorities in connection with administrative, criminal or civil proceedings. Similarly, Adam may be required to share the Data Subject's personal data with persons who claim to have been harmed by the Data Subject's conduct.

Where Adam shares the Data Subject's personal data with controllers and processors in third countries (outside the EEA), Adam only do so where there is a decision by the European Commission that a particular country outside the EEA provides an adequate level of data protection, including where controllers or processors have adopted additional data protection measures such as Binding Corporate Rules (BCR) or Standard Contractual Clauses (SCC).

4. WHAT ARE YOUR RIGHTS IN RELATION TO PERSONAL DATA PROCESSING BY ADAM?

In relation to your personal data, you, as a Data Subject, have the following rights:

- Right to revoke your consent to the processing of personal data at any time (where the processing is based on your consent);
- Right of access to personal data (the right to request information as to whether or not personal data concerning you are being processed by Adam or not, and, where that is the case, access to the personal data and other information listed in Art. 15 GDPR);
- Right to data portability (the right to obtain any personal data that concern you in a structured, commonly used and machine readable format and the right to transmit such data to another controller; and the right to have the personal data transmitted directly from one controller to another, where technically feasible);
- Right to rectification (the right to request that Adam rectifies inaccurate personal data concerning you without undue delay);
- Right to limitation on processing (the right to request that Adam limits the processing, including but not limited to where Adam verifies the accuracy of data; or if Adam processes the personal data illegally but you do not wish to have them erased);
- Right of erasure (the right to request that Adam erases your personal data without undue delay, such as when the personal data are no longer necessary for the purposes, for which they were collected, or you have withdrawn your consent, on the basis of which the personal data were processed by Adam and there is no other legal basis for the processing or if Adam processed the personal data illegally);
- Right to file a complaint to the competent Office for Personal Data Protection or other data protection authority.

5. HOW CAN YOU CONTACT ADAM?

Should you have any questions regarding the processing of your personal data or the exercise of the aforementioned rights, you can contact Adam by post at Evropská 2758/11, 160 00 Prague 6, Czech Republic, or by e-mail at adam@painteradam.ie.

PRIVACY POLICY

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