Information on Personal Data Processing
GLS General Logistics Systems Slovakia s.r.o., registered seat Budča 1039, 962 33 Budča, Slovak Republic, Business Identification Number: 36 624 942, listed in the Business Register of the District Court Banská Bystrica (hereinafter „GLS SK“) as a service provider processing the personal data of the data subjects, hereby informs about the system, purposes and scope of personal data processing by GLS SK, including the scope of the rights of the data subjects related to the processing of their personal data.
GLS SK processes personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data repealing Directive 95/46 / EC (General Data Protection Regulation) and in accordance with the relevant national regulations (hereinafter referred to as “Personal Data Protection Law”).
Purposes and Scope of Processing Personal Data
GLS SK processes only exact personal data that were obtained in accordance with the Personal Data Protection Law, while GLS SK collects and processes this personal data only for the specified purpose, to the extent specified below, for the duration of the contractual relationship, or for the time strictly necessary.
In general, GLS SK processes personal data for the following purpose:
contract fulfillment and service providing;
- operational activities;
- accounting and tax purposes;
- debt collection;
- compliance with a legal obligation;
- direct marketing (information and product campaigns);
- assets protection.
GLS SK processes the personal data of the data subjects to the extent that they have been provided to GLS SK, in order to achieve the purpose for which they have been processed.
Categories of Data Subjects:
1. Sender (consignor), recipient (consignee)
a) Purpose of personal data processing: fulfillment of a legal obligation (e.g. in relation to the bookkeeping), fulfillment of contractual obligations (e.g. in relation to the delivery of a parcel), legitimate interests of GLS SK (eg. in relation to a complaint procedure, legal enforcement of receivables etc.). In certain cases, if required by the consignee or recipient, the purpose of personal data processing may be to fulfill the customs obligations, where the reason for personal data processing is in particular the legal fulfillment of the contract on the customs clearance procurement.
b) Scope of personal data processing: name, surname, title, identification number, tax identification number, e-mail, telephone, contact person, place of business (registered office), delivery address and, in the case of customs clearance, also ID card or travel document number and country of issue of identity card or travel document, identification number.
For details and further information in this category of persons, see:
2. Suppliers of goods and services, persons who charge GLS SK and persons who are charged by
GLS SK and their representatives
a) Purpose of personal data processing: fulfillment of a legal obligation (e.g. in relation to the bookkeeping), fulfillment of contractual obligations, legitimate interests of GLS SK (e.g. in relation to a complaint procedure, legal enforcement of receivables or during the business meetings (business offer, business correspondence).
b) Scope of personal data processing: name, surname, title, identification number, tax identification number, e-mail, telephone, contact person, place of business (registered office), delivery address, bank account number.
3. Agency staff, eventually employees of other employers
a) Purpose of personal data processing: fulfillment of legal obligations (e.g. in relation to human resources management, payroll, fulfillment of obligations in health and safety protection at work), fulfillment of contractual obligations, legitimate interests of GLS SK, in the form of property protection, eventually an act in connection to the fulfillment of work tasks, etc.
b) Scope of personal data processing: name, surname, title, residence, e-mail, telephone, camera recordings.
4. Addresses of the services offers
a) Purpose of personal data processing: legitimate interest of GLS SK in the form of services offers or other business communication (correspondence), providing important information, GLS SK business performance.
b) Scope of personal data processing: name, surname, title, residence, e-mail, telephone within the internal system.
5. Unclassified natural persons who are monitored by camera system in the premises of GLS SK
a) Purpose of personal data processing: legitimate interest of GLS SK, consisting in the protection of GLS SK property and property of business partners, customers, GLS SK consignees from theft, damage or destruction of higher value items located in the GLS SK building, as well as other illegal activity, eventually other criminal offense. The lawfulness of the processing of personal data using a camera system is a necessity for the purposes of the legitimate interests of GLS SK or a third party (business partners, customers, consignees).
b) Scope of personal data processing: capture of images of natural persons.
6. Couriers delivering parcels (subcontractors, subcontractor employees or other sub-subcontractors)
a) Purpose of personal data processing: legitimate interest of GLS SK in the form of quality control of provided delivery and transport services – mainly but not exclusively – in order to determine the route of the courier, including his stops, to prevent the breach of couriers’ working routes and in order to collect the data in relation to the complaints or other comments from the recipients of parcels (consignees).
b) Scope of personal data processing: name, surname, title, job position, achieved job qualification (driving license authorization in individual groups of motor vehicles), data on motor vehicle and data from GPS coordinates to identify the position and movement of the motor vehicle.
Sources of Personal Data:
GLS SK obtains personal data mainly from the person related to the negotiation of the contract, or from third parties, as well as from contractual partners (clients) in connection with delivery services provided by GLS SK. GLS SK also obtains personal data from publicly available records and registers and other public sources on the Internet in order to search for new (potential) clients.
GLS SK also obtains personal data from camera system records. The persons concerned are always informed about the location of the camera systems by means of the information boards and pictograms placed at the entrance to the monitored areas. Recordings from camera systems are archived for the necessary time and only for the specified purpose and outside the specified purpose they are not further processed.
GLS SK informs the data subjects when the provision of personal data is necessary for the provision of a specific service and when it is voluntary, but the provision of such personal data facilitates mutual communication between the data subject and GLS SK and also significantly streamlines the provision of services.
In order to increase the quality of services, objectivity, provability and security, GLS SK monitors and records communication with the data subjects concerned (especially telephone calls to the customer line).
Protection of Personal Data
GLS SK ensures the security of personal data depending on the assessment of specific risks. GLS SK has taken such measures to prevent unauthorized or accidental access to personal data, their change, destruction or loss, unauthorized transfer, processing, as well as other misuse.
If it results from the nature of the data subject, the personal data is stored on special servers, which are located in a special (separate) room, which is used exclusively for the purpose of locating the servers. The room is then properly locked and secured.
The camera system as such is operated within a closed system circuit, i.e. data cannot be accessed via the internet. The camera system is protected by anti-virus protection.
Access to personal data and its processing is allowed only to authorized persons who hold an authorization (permission) to work with personal data.
Employees and other authorized persons are trained in the personal data handling and the personal data processing and are subject to an internal control system.
Data subjects who enter into contractual relations with GLS SK are duly informed about the nature of personal data and, if they handle personal data, they are also contractually obliged to process personal data in accordance with the Personal Data Protection Law.
Personal Data Processors (Intermediaries) and Personal Data Recipients
The priority of GLS SK is to non-provide the personal data to any other party for any purposes that would not be related to the delivery services.
However, in addition to GLS SK and its employees, personal data may also be provided to other entities in order to ensure the purposes described above:
1) entities that exercise their power – personal data are provided by GLS SK for the purpose of fulfilling legal obligations;
2) law enforcement entities and law enforcement agencies or other authorities and bodies in the application of the legislation in order to protect national security interests or as part of a legal procedure to protect property or to detect violations of GLS rules and policies, unauthorized access or use of GLS assets or other illegal activity;
3) personal data processors (intermediaries) – entities that have a contractual relationship with GLS SK, whereby they provide services for GLS SK, and for the purpose of providing their services they process personal data on the basis of a contract on personal data processing and protection; these are in particular the following entities:
- GLS subsidiaries and subcontractors in other EU countries or outside the EU for the purpose of the contract fulfillment (delivery of the parcels from the sender to the addressee);
- affiliated or non-affiliated third parties who are in a contractual relationship for the provision of services for GLS SK or on behalf of GLS SK (intermediaries), in particular regional depot operators, as well as third parties with whom GLS SK has concluded relevant contracts for personal data protection and processing;
- other persons or organizations that have the right to collect and process personal data in accordance with applicable law;
4) other operators to whom personal data are provided for the purpose of fulfillment of the contractual obligations (insurance companies, banks, communication service providers, etc.);
Personal data are transferred abroad only for the purpose of providing delivery and transport services (delivery of parcels), for the purpose of archiving, for the purpose of compiling statistics and for the purpose of fulfilling legal obligations (international sanctions, embargoes, etc.).
Data Subjects Rights
The data subject has the right to:
- be informed and have access to their processed personal data (right to be informed and right to access according to Article 15 of the GDPR),
- obtain the correction of inaccurate personal data (right for the correction according to the Article 16 of the GDPR),
- obtain the deletion of their personal data (right for the deletion according to the Article 17 of the GDPR),
- obtain a restriction of data processing (right for the restriction of data processing according to the Article 18 of the GDPR),
- receive their personal data which were already provided (right for the data transfer according to the Article 20 of the GDPR),
- object the processing of personal data, due to the specific situation carried out on the basis of a legitimate interest or on the basis of a public interest task fulfillment (right for the opposition according to the Article 21 of the GDPR).
The above mentioned rights may be exercised by the data subject provided that the legal conditions are met.
Provided that personal data have been processed with the consent of the data subject, the data subject shall have the right to withdraw that consent at any time, without the withdrawal of consent affecting the lawfulness of the personal data processing prior to the withdrawal of the consent.
Exercise the Data Subjects Rights
If the data subject is interested in exercising the right or withdrawing the explicit consent, he/she shall send a request to GLS SK stating the subject of his/her request, in particular which right he/she wishes to exercise, so that GLS SK can take the necessary steps to respect this right.
Please note that if GLS SK is contacted via unencrypted e-mail, the confidentiality of the transmitted information may not be guaranteed and unencrypted e-mails may be read by unauthorized third parties.
The request of the data subject can be delivered to GLS SK by the following means:
- in writing to the registered office address
- by e-mail to email@example.com
In the case that GLS SK shall disclose information concerning the processing of personal data of a particular person, GLS SK is entitled to request confirmation of the identity of the data subject/applicant, so that GLS SK can assess the legitimacy of the request and ensure personal data protection and privacy.
The data subject has the right to lodge a complaint at the Office for Personal Data Protection of the Slovak Republic if he or she is convinced that his or her rights have been violated. (https://dataprotection.gov.sk/uoou/sk).