PRIVACY POLICY

Tulip (referred bellow also under terms: “we”, “us”, “our”) is an IT company developing and maintaining a TULIP software which is complex middleware solution covering many areas of HR and finance.

HEADQUARTERS

Tulip Solutions s.r.o.

Pribinova 40, 811 09 Bratislava, Slovakia

ID No.: 46 486 836

Registration: Commercial Register of the Municipal Court Bratislava III, Section: Sro, File No.: 78324/B

E-mail: tulip@tulipize.com

General disclaimer

Tulip provides this website as a service to the public.

Tulip is not responsible for, and expressly disclaims all liability for, damages of any kind arising out of use, reference to, or reliance on any information contained within the site. While the information contained within the site is periodically updated, no guarantee is given that the information provided in this website is correct, complete, and up-to-date. All the information and downloadable materials available via our website have been prepared for general guidance on the matter and it does not represent a customized professional advice. Furthermore, because the legislation is changing continuously, some of the information may have been modified after the material has been released and Tulip does not take any responsibility and is not liable for any potential risks or damages caused by taking actions based on the information provided herein.

Although this may include links providing direct access to other Internet resources, including websites, Tulip is not responsible for the accuracy or content of information contained in these sites.

Links from Tulip to third-party sites do not constitute an endorsement by Tulip of the parties or their products and services. The appearance on the website of advertisements and product or service information does not constitute an endorsement by Tulip, and Tulip has not investigated the claims made by any advertiser. Product information is based solely on material received from suppliers.

What personal information do we collect via our website?

We collect information from you when you subscribe to our newsletter, subscribe to an event, contact us by using any of the available means (forms, e-mail, phone), respond to a survey or apply for a job post.

When using a form on our site, as appropriate, you may be asked to enter your: name, e-mail address, phone number, professional details (company or company details, function, interests), your request in text form, your CV, etc.

Note regarding newsletters: If at any time you would like to unsubscribe from receiving future newsletters, we include detailed unsubscribe instructions at the bottom of each email.

We also use cookies to understand and save your preferences for future visits. Certain cookies are also used to analyse our website traffic and visitor’s interaction and help us offer a better site experience in the future. You may, however, visit our site anonymously.

Cookie Policy

As all professional websites, our website uses cookies to improve user’s experience. If you do not know what a cookie is, how it is used and what you can do about it, then you will find answers to all these matters in the following paragraphs.

What is a “cookie”?

A cookie is a small piece of information sent by a website (through the browser) and stored on a user’s computer while interacting with the website. Cookies were designed to be a reliable mechanism for websites to remember the user’s activity, information that helps the owner(s) of the website make relevant improvements (content, layout) according to the user’s preferences.

Types of cookies

Based on their duration (lifespan)

• session cookies– are deleted when the user closes the browser
• persistent cookies– remain on the user’s device for certain period (a few months to years).

Based on the cookie owner

• first-party cookies– are set by the web server of the visited page and share the same domain
• third-party cookies– stored by a different domain to the visited page’s domain. This can happen when the webpage references a file, such as JavaScript, located outside its domain.

Please note, that as of March 6, 2024 “Google Consent Mode” was implemented by Google to “Google Ads cookies” and “Google Analytics cookies”, which are used on this website if you grant your consent to activate them. You can find more information on all types of cookies implemented to this website in the cookie banner after choosing the option “individual preferences”.

How to manage cookie settings

You may change your cookie preferences or delete them at any time either by reviewing your Individual privacy preferences, or directly in your browser:

Apple Safari
Google Chrome
Microsoft Internet Explorer
Mozilla Firefox
Opera browser

You can even disable/block completely cookies, but you must be aware that this will affect the functionality/features of this and many other websites that you visit.

Third party access

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, as long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or other’s rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Our GDPR statement

The company Tulip Solutions s.r.o., with its registered office at Pribinova 40, 811 09 Bratislava – Ružinov, company ID.: 46 486 836, registered it the Commercial Register at the Municipal Court Bratislava III, Section: Sro, Insert No.: 78324/B (hereinafter as the “Tulip”) processes the following groups of personal data:

• the personal data in relation to which Tulip is the controller as it determines the purpose and means of its processing;
• the personal data in relation to which Tulip is the processor as it processes the respective data on behalf of its clients which determine the purpose and means of its processing.

Tulip processes the personal data in accordance with REGULATION (EU) 2016679 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 as the “Regulation”) and Act No. 18/2018 Coll. on data protection and on amendment of certain acts as amended (hereinafter as the “Act”).

In terms of the Regulation, Tulip has adopted the appropriate technical and organisational measures in order to ensure the protection of the personal data and the rights of the persons, whose personal data is processed (hereinafter as the “Data Subject”). In order to fulfill the obligation laid down by the Regulation, Tulip is obliged to inform the Data Subject about the details of the processing of the personal data.

Tulip as the Controller may collect the Personal Data for the following purposes:

Marketing and Direct marketing

• Purpose of personal data collecting: sending informational newsletters about products and services, updates and new possibilities of using the TULIP portal, as well as about important and interesting business-related news, events invitations and other Tulip materials to clients and potential clients.
• Legal basis: legitimate interest (art. 6 para. 1 f) of the Regulation) which is to provide news about the services we offer to former or current clients, informing about the updates, improvements and new possibilities for using the TULIP portal; or consent (art. 6 para. 1 a) of the Regulation) given by data subjects who are not our clients
• Scope of personal data: name, surname, company, function, e-mail, phone number, interests (countries, business areas, material/communication type), other details that the user is including in the available message box
• Recipients: N/A
• Transfer to third country: N/A
• Storage period: for the period of consent of the data subject (max 5 years if not withdrawn) or for the period of the contractual relationship and 5 years after its termination (for clients/partners/suppliers)
• Data subjects: contact persons of Tulip´s clients, potential clients, individuals interested in receiving the information our company is offering (newsletters, events, informational or promotional materials, career and business opportunities)

Job applicants

• Purpose: keeping records of unsuccessful job applicants of the controller
• Legal basis: consent (art. 6 para. 1 a) of the Regulation)
• Scope of personal data: data stated in curriculum vitae and other accompanying documents
• Recipients: service providers streamlining the recruitment process, only for the purpose of recruitment and maintaining the records of recruitment
• Transfer to third country: N/A
• Storage period: for the period of consent of the data subject (max 2 years if not withdrawn)
• Data subjects: job applicants

Contractual documentation

• Purpose: Administration of evidence of natural persons with whom a contract has been concluded, contact persons / statutory bodies in case of contracts with legal persons and natural persons to whom the Power of Attorney has been granted.
• Legal basis: contract (art. 6 para. 1 b) of the Regulation), legitimate interest (art. 6 para. 1 f) of the Regulation) – processing of contact data of the client´s employee / statutory body for communication purposes related to contractual relationship.
• Scope of personal data: degree, name, surname, maiden name, job position, address of permanent residence, address of temporary residence, phone number and e-mail, date of birth, type and number of identification card, bank account, signature.
• Recipients: tax authorities, courts, Social insurance company, health insurance company, banks, administrative services in the premises of the controller.
• Transfer to third country: N/A
• Storage period: during the contractual relationship and 11 years after its termination, respectively for the period necessary for the purpose for which they were obtained and/or required by law.
• Data subjects: employees / statutory bodies of the controller, natural persons with whom a contract has been concluded or to whom the power of attorney has been granted, contact persons of the client.

Mail

• Purpose: keeping records of recipients and senders of mail.
• Legal basis: legitimate interest (art. 6 para. 1 f) of the Regulation) – to be informed on the date of the sent and received mail including the sender and recipient in order to protect the rights and interests of the controller.
• Scope of personal data: degree, name, surname, signature, address, e-mail.
• Recipients:  administrative services in the premises of the controller.
• Transfer to third country: N/A
• Storage period: 5 years following the closure of the evidence for calendar year.
• Data subjects: natural persons – senders and receivers of mails.

Website

• Purpose: operating a functional website and its content and services.
• Legal basis: legitimate interest (art. 6 para. 1 f) of the Regulation) –the necessity of processing the personal data of the persons concerned for the purposes of operating our website and its proper functioning
• Scope of personal data: personal data that the data subject’s browser automatically transfers to our server and which are temporarily stored in the so-called log file, i.e. the IP address of the computer, the date and time of access, the name and URL of the downloaded file, the website from which the access is made (referring to the URL), the browser used and possibly also the operating system of the computer, as well as the name of the operator of Internet access.
• Recipients:  N/A.
• Transfer to third country: N/A
• Storage period: for the duration of the opening of the website.
• Data subjects: natural persons – website visitors.

Contact form

• Purpose: ensuring the possibility of communication between website visitors and the controller.
• Legal basis: legitimate interest (art. 6 para. 1 f) of the Regulation) – fulfilling the request of the data subject or another reason for which they contacted us
• Scope of personal data: first and last name, telephone number, email, job position, employer / company, content of the message.
• Recipients:  N/A
• Transfer to third country: N/A
• Storage period: for the duration of the processing of the request sent via the contact form, if a longer storage period is not required in accordance with another processing purpose.
• Data subjects: natural persons – website visitors who sent any message via the contact form.

Other communication with the data subject

• Purpose: ensuring the necessary communication with the data subject for the purpose of receiving and handling requests, suggestions and complaints related to the services provided by the controller.
• Legal basis: fulfillment of the contract and pre-contractual relationship (art. 6 para. 1 b) of the Regulation), fulfillment of legal obligations (art. 6 para. 1 c) of the Regulation), especially Act No. 40/1964 Coll. Civil Code as amended, Act no. 513/1991 Coll. Commercial Code as amended, the Regulation and the Act, legitimate interest (art. 6 para. 1 f) of the Regulation), if the communication cannot be subordinated to any of the previous legal bases, which are the proper registration and handling of the request, complaint or initiative of the data subject
• Scope of personal data: first and last name, telephone number, email, job position, employer / company, content of the message or request.
• Recipients: legal representatives
• Transfer to third country: N/A
• Storage period: for the duration of processing a claim, complaint, request or other initiative and 3 years from their processing, unless longer storage is required for reasons of verifiability of the processing of a claim, request or complaint, or due to legal data retention periods.
• Data subjects: natural persons – authorized employees / statutory bodies of clients or potential clients, other senders / recipients of communication with the controller.

Exercising the claims of the controller

• Purpose: the application and enforcement of claims arising to the controller from violation of civil law, commercial law and criminal law regulations by data subject, in proceedings before courts or relevant administrative authorities.
• Legal basis: the purpose of processing is compatible with the above-mentioned purposes of processing
• Scope of personal data: name and surname, address of permanent residence, address of temporary residence, telephone number, email, job position, employer / company, content of mutual communication, circumstances of occurrence of the damage event, or damage to the rights and legitimate interests of the controller.
• Recipients:  legal representatives, courts.
• Transfer to third country: N/A
• Storage period: for the duration of court proceedings and 11 years after its legal end.
• Data subjects: natural persons – authorized employees / statutory bodies of clients or potential clients, other persons involved in the disputed event.

Reporting of crimes

• Purpose: fulfilling the legal obligation to report the commission of a crime and to cooperate with law enforcement authorities.
• Legal basis: the purpose of processing is compatible with the above-mentioned purposes of processing
• Scope of personal data: name and surname, address of permanent residence, address of temporary residence, telephone number, email, job position, employer / company, content of mutual communication, circumstances of committing a crime.
• Recipients:  legal representatives, courts, law enforcement authorities.
• Transfer to third country: N/A
• Storage period: for the duration of criminal proceedings and 11 years after its legal end.
• Data subjects: natural persons – authorized employees / statutory bodies of clients or potential clients, other persons involved in the crime.

The Data Subject shall have the following rights in relation to the personal data processing:

Right of access by the data subject

It does not mean that the data subject should have direct access to the systems, however, the data subject should be informed what, where, for what reason, who is the recipient and period of storage for personal data proceeding and the copy of the personal data.

Right to object

The data subject can object any time the processing of personal data based on the public interest or legitimate interest of the controller, including profiling. Example: personal data processed for marketing purposes – the data subject can unsubscribe from receiving marketing materials.

Right to be forgotten

The data subject shall have the right to obtain from the controller the erasure of personal data in case the personal data is no longer necessary, the data subject withdraws consent, the data subject objects to the processing pursuant to Article 21(A) and there are no overriding legitimate grounds for the processing, the personal data have been unlawfully processed, etc.

Right to restrict the processing

In the regulation, there are four specific situations (art. 18 sec. 1 a) – d). Example: the data subject contested the accuracy of personal data and for a period of verifying, the personal data processing shall be restricted.

Right to data portability

The data subject shall have the right to receive the personal data concerning them, which they have provided to a controller in a structured, commonly used and machine-readable format and transmit the personal data to another controller.

Notification obligation regarding rectification or erasure of personal data or restriction of processing

Example: in case a data subject changes their personal data, the controller (client) is obliged to inform the involved parties.

Right to rectification

In case the personal data is inaccurate or incomplete.

Contact: Tatiana Valentová, Data Protection Officer | GDPR@tulipize.com

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