GDPR Privacy notice: Principles of processing personal data of individuals in DHL Parcel Slovensko

We would like to assure you that DHL Parcel Slovensko sro, registered office at Na pántoch 18, Bratislava, 831 06, entered in the Commercial Register of the District Court Bratislava I, Section Sro, Insert No. 100759/B, Registration No: 47927682, VAT No: SK2024147400 ("DHL Parcel" or "we"), as part of the Deutsche Post DHL group, pays maximum attention to the security of your personal data. In addition to Regulation (EU) 2016/679 (GDPR), we are governed by valid laws of the Slovak Republic, by binding corporate rules approved by leading supervisory authorities within the EU and comply with the standards of ISO 27001.

All data collected by DHL Parcel is processed for justified purposes only, for a limited time and with the maximum possible security.

It is our priority to protect the personal data of our customers, as well as recipients, suppliers, partners and, of course, employees. In connection with GDPR, we provide below the principles of personal data processing. The Data Protection Officer (DPO) of DHL Parcel has extensive knowledge about personal data protection and their role is to monitor compliance with the GDPR. If you have any questions regarding the processing of your personal data, please do not hesitate to contact us at osobne.udaje@dhl.com

In this document you will find information about what personal data we process about our customers, especially senders and recipients of shipments, and users of our website, whether we process the data by consent or other legal reasons, for what purpose we use them, whether we assume the role of an operator or an intermediary in data processing, who we may provide personal data to; and what are your rights as regards the processing of your personal data.

We process the following personal data:

a) Identification data, which include, in particular, your first and last name, your username and password, your ID card number, your registration ID and VAT number, if you are an entrepreneur, and your position in an organization if you represent a legal entity;

b) Contact details, which means personal information that allows us to contact you, in particular e-mail address, phone number, delivery address, billing address;

c) Details of ordered services, which include, in particular, the details of the shipments that you or your company have ordered, the method of payment, including the payment account number, and claim details;

d) Information about your web behaviour, including when browsing through our mobile application, especially the services you view, the links you click on, and information about the device from which you view our website, such as the IP address and derived location, the device ID, its technical parameters as the operating system and its versions, the screen resolution, the used browser and its versions, as well as the data obtained from cookies and similar technologies for device identification;

e) Data related to your using of a call centre or visiting our operation, which include, in particular, recordings of your phone calls with call centres, identification of messages sent to us, including identifiers such as IP addresses, and recordings from camera systems at branches.

As part of our activity, we process personal data for various purposes and to varying extents either:

a) without your consent based on the performance of a contract, our legitimate interest, or the fulfilment of a legal obligation, or

b) based on your consent.

What sort of processing we can do without your consent depends on the purpose of the processing in question and your relation to us - whether you are only a visitor to our website or have a contract with us or you order a service from us. We may also process your data, when you are the recipient of a shipment we were ordered to ship, when you communicate with us, or when you visit our facility.

1. If you order a shipment or conclude a contract with us

If you order a shipment or conclude a contract on service provision or other contract with us, we perform the following data processing:

1.1. Processing based on performance of the contract

If you order shipment as a natural person, we process your personal data for the purpose of shipment and tracking, and in the case of another contract for the purposes of performance of this contract, your identification and contact details, and details of your orders.

In case you order shipment with us as a representative of a legal entity, we shall process, for the purpose of shipment and tracking, and in the case of another contract for the purpose of performance of this contract, your identification and contact details and data about ordered services, based on our legitimate interest related to the conclusion and performance of a contract with the person you represent

The fact that we use these data for the purpose of shipping and tracking a shipment or performance of the contract means that we use them in particular:

  • In order to communicate with you about the shipment, for example to send you a confirmation;
  • For the purpose of payment for shipping or other services or for the performance of services; in this regard, we may also provide your data to other shipping partners as described in "Who processes your personal data and who we provide it to?"
  • In connection with a claim;
  • In connection with other requests you contact us with, for example, through a call centre.

If you order a shipment or conclude a contract with us, we will keep your identification and contact details and data about ordered services based on our legitimate interest (without your consent) in order to protect our legal claims and for our internal records and controls. Our legitimate interests include the protection of legal claims and the control of the proper provision of our services.

For the purposes of protection of legal claims, asset protection and for our internal records and controls, we process your data for the duration of the limitation period of 10 years and one year after its expiration with respect to claims made at the end of the limitation period. In the event of legal, administrative or other proceedings, we process your personal data to the extent necessary for the duration of such proceedings and the remainder of the limitation period after its termination.

Based on our legitimate interest (i.e. without your consent), we also process your identification and contact details and the data of ordered services for the purpose of sending offers via e-mail; our legitimate interest is the promotion of our products and services. For this purpose, we use your personal data for 6 months from the last shipping order or one month after the termination of the shipping agreement.

You have the right to object against such processing based on our legitimate interest.

1.2. Processing based on legal obligations

We must also comply with certain statutory obligations. If we process your personal data for this reason, we do not need to obtain your consent for such processing. Based on this legal basis, we process your identification and contact details, and the data on ordered services, in particular to comply with the following regulations:

  • Act No. 324/2011 Coll. On Postal Services and on Amendments to Certain Acts
  • Act No. 40/1964 Coll. Civil Code,
  • Act No. 250/2007 Coll. On Consumer Protection (if you are shipping as a natural person).
  • Act No. 222/2004 Coll. On Value Added Tax,
  • Act No. 431/2002 Coll. On Accounting,- IATA air cargo rules,
  • EU regulations on counter terrorist financing and anti-money laundering.

For this purpose we use personal data for a maximum of 10 years.

2. If you are the recipient of a shipment ordered with us

If you are the recipient of a shipment ordered with us, we process your identification and contact details:

  • Based on our legitimate interest, for the purposes of shipping and tracking of shipments, making information available on our website and in the Track and Trace system, and communicating with you about the shipment and its delivery, where our legitimate interest is to fulfil the contract with our customer;
  • Based on our legitimate interest to obtaining information that will enable us to improve our services in the future, or information to produce our internal statistics and reports; our legitimate interest is to improve our services for our customers;
  • In order to fulfil legal obligations, in particular according to Act No. 222/2004 Coll. On Value Added Tax and Act No. 431/2002 Coll. On Accounting;
  • In order to protect legal claims and for our internal records and controls; our legitimate interests include the protection of legal claims and the control of the proper provision of our services.

We use your personal data to prepare, conclude, and perform the contract with our customers for the period necessary to transport the shipment. After this time, we will retain the data based on our legitimate interest in order to protect our legal claims and assets and for the purposes of our internal records and controls for the duration of the limitation period of 10 years and one year after its expiration with respect to claims made at the end of the limitation period. In the event of legal, administrative or other proceedings, we process your personal data to the extent necessary for the duration of such proceedings and the remainder of the limitation period after its termination. Our legitimate interests include the protection of legal claims and the control of the proper provision of our services. For the purpose of fulfilling our legal obligations we use personal data for 10 years.

You have the right to object to the processing based on legitimate interest.

3. If you visit our website
3.1. Using cookies and other technology

When you visit our website, we store small files such as cookies on your device and then read them. A cookie is a small set of letters and numbers that we store in your internet browser or on the hard drive of your computer. Some cookies allow us to link your activities while browsing our site from the moment you open the web browser window until you close it. As soon as you close the Internet browser window, these cookies are deleted. Others stay on the device for a set amount of time and activate each time you visit the website that created the cookie. We not only store cookies on your device, but we also read the cookies stored by our website on your device. To make it simple, further in this document, we will only talk about storing.

Some cookies are stored on your device directly by our website. These cookies help us:

  • Identify you when browsing between the individual pages of our website and visiting us again, for example, to save which version of our site you want to see if the site offers multiple variations at a given time;
  • Note that you have given us permission under this document.

Such cookies and other files are necessary for the functioning of our website. If you block these cookies in your browser, our website may not work properly and we may not be able to provide our services.

Into your device we also:

  • Download cookies from our website that allow us:
    • To track traffic to our website, its individual pages, generate statistics and reports, and measure ad performance; to show you different variations of our website as we test new features;
    • Allow third parties to store cookies and use them:
      • To collect data about your behaviour on our site and on other websites;
      • To show personalized offers and targeted advertising within advertising networks on websites other than our.

In order to see customized offers and targeted advertising within advertising and social networks on websites other than our, we also provide information about your web behaviour to advertising and social networks. However, we do not provide your identification details to such partners. For a list of social and advertising networks we use, see Who processes your personal data and who do we share it with?

If you do not disable the use of third-party cookies and the sharing of your data with advertising and social networks in your browser and you remain on our site or click on the "Understand" button that is part of the notification, we will assume that your agree with using these cookies and the sharing of your data with advertising and social networks. You can withdraw your approval at any time by turning off this feature in your browser. A full list of cookies is available on the DHL Parcel Slovensko website in the Privacy & Cookies section.

3.2. Use of personal data of website visitors

If you visit www.dhlparcel.sk, www.balikovapreprava.sk, www.parcelshopy.sk we process data about your web behaviour based on our legitimate interest (i.e. without your consent) for the purposes of:

  • Getting the information that will help us improve our website in the future; our legitimate interest is to improve our services for you;
  • Creating statistics and reports, especially tracking the traffic of our website, its individual pages, and measuring advertising performance; our legitimate interest here is measuring the effectiveness of our website and advertising costs;

We do not obtain data about your web behaviour from cookies only. We also add the following data:

  • the IP address of your device (the address of your device through which you communicate with other devices on the Internet),
  • your device's operating system, versions and language settings;
  • the browser you use on your device, its versions and language settings;
  • The web address (URL) from which you come to our website.

We use personal data for this purpose for 14 months. You have the right to object to this processing.

4. Quality certificate

If you communicate with us through different channels, especially via the Call Centre, e-mail, and social networks, we will process your identification and contact details, and recordings of conversations based on our legitimate interest (i.e. without your consent) for the purpose of

  • Fulfilling your request; if you have ordered us to ship a shipment or have concluded another contract with us and your request relates to this contract, we may carry out this processing on the basis of performance of the contract with you;
  • Recording your request so that we can check that we meet them properly and in a timely manner;
  • Demonstrating that we have accepted and attended your request, when you order goods in this way or make a claim;
  • Their analysis to improve the quality of our services.

For this purpose, we keep your personal data for 3 months. You have the right to object to the processing based on our legitimate interest.

5. If you visit our facility:

If you visit our branch or its surroundings, we will process the recording from the camera system on which you can be captured based on our legitimate interest (i.e. without your consent) in order to protect our and your property and persons moving within the store and its surroundings, which is our legitimate interest.

For this purpose, we keep your personal information for 1 month. You have the right to object to this processing.

6. If you give us your consent:

If you do not use our services yet (you have not concluded a shipping agreement with us, nor have you ordered a shipment) and you give us your consent when providing your data, we may use your identification and contact details to send offers by e- mail or a text message, and to communicate our offers by phone or other electronic means, or send them to you by post.

Your consent is completely voluntary and you can withdraw it at any time. To withdraw your consent, please contact us as described in How to exercise individual rights? The withdrawal of your consent does not affect the lawfulness of the processing until the moment of the withdrawal.

We process all of these personal data as an operator. This means that we determine the above-defined purposes for which we collect your personal data, determine the processing resources and we are responsible for their proper performance.

We may also share your personal data with other entities that are in the role of an operator, namely:

  • If you are the recipient of a service that is ordered with us, we share it with our partners involved in this performance, as listed in the section "If you are the recipient of a service that is ordered with us", specifically with partners executing the transport and delivery of shipments, e.g. our partners abroad during international shipping;
  • When fulfilling our legal obligations we share some personal information with administrative authorities and the state office if we are called upon to do so.
    • Based on your consent, we share it with advertising and social networks, as described in "Using Cookies and Other Technology, Sharing data with advertising and social networks", specifically:

We also share personal data within the DPDHL group. Data transfer within the group occurs especially in the case of products or services that are subject to international shipping and without which services or products cannot be delivered. In particular, this applies to the transfer of contact or identification details to other companies of the Deutsche Post DHL group which carry out the forwarding services for DHL Parcel Slovensko in the destination, on the basis of fulfilment of a contractual obligation or legitimate interest for the administrative needs of the group and, as the case may be, to its sharing with operators within the group for the purposes of shipment delivery. Further, it may apply to processing based on legitimate interest or performing a legal duty to ensure, in particular, security. All companies are bound by the so-called Binding Corporate Rules approved by leading supervisors within EU, providing sufficient safeguards to protect personal data.

For the processing of personal data we also use the services of other intermediaries who process personal data only according to our instructions and for the purposes described in "Why do we process personal data and what entitles us to do so?" Such intermediaries are in particular:

a) Our partners providing transportation under our brand;

b) Cloud service providers and other suppliers of technology, support, and related services for our internal processes;

c) Operators of marketing tools and marketing agencies;

d) Providers of tools for the management and recording of telephone conversations;

e) Providers of SMS, e-mail and other communication tools when processing personal data to mediate our communication with you;

f) Security monitoring providers, in particular, those managing our camera system;

g) Lawyers, tax advisers, auditors, enforcement agencies.

For a list of specific personal data intermediaries that we use, please refer to the list of intermediaries listed on the DHL Parcel Slovensko website.

All our processors are also bound by binding rules of the DPDHL Supplier Code of Conduct.

In most cases, we process personal data that you provide to us when ordering services or communicating with us. If you are the recipient of a shipment we ship, we will collect your details from the person who ordered the shipping. We also collect personal data directly from you by monitoring your behaviour on our website. In some cases, DHL Parcel Slovensko is authorized to obtain personal data from public registers, particularly in situations where DHL Parcel Slovensko exercises its legitimate interests, in particular the interest in acting prudently.

In the context of submitting the data to the recipients listed in "Who processes your personal data and who do we provide it to?", we may also transfer your data to third countries outside the European Economic Area that do not allow for an adequate level of protection of personal data. All such submissions will only be made if the recipient agrees to comply with some of the standard contractual clauses issued by the European Commission and available at http://eur-lex.europa.eu/legal-content/en/TXT/?uri= sektora% 3A32010D0087 or the binding corporate rules of DPDHL, approved by EU leading supervisors; for more information visit https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/binding-corporate-rules_en.

Just as we have our rights and obligations when processing your personal data, you also have certain rights related to the processing of your personal data. These rights include:

1. Right of access

Simply put, you have the right to know what data we process about you, for what purpose, for what time, where we collect your personal data, who we share it with, who except us processes it and what are your other rights related to the processing of your personal data. You can find all this information in "Principles of Processing Personal Data of Individuals in DHL Parcel Slovensko". However, if you are unsure of which personal data we process about you, you may ask us to confirm if we process the personal data concerning you or not, and if so, you have the right to access these personal data. As part of your right of access, you can ask for a copy of the processed personal data, with the first copy provided free of charge and additional copies with a fee.

2. Right to correct

To err is human. If you find that the personal data we process about you are inaccurate or incomplete, you have the right to correct or supplement them without undue delay.

3. Right of deletion

In some cases, you have the right to have your personal data deleted. We will delete your personal data without undue delay if any of the following applies:

  • We no longer need your personal data for the purposes we have processed them for;
  • You withdraw your consent to the processing of your personal data, where your consent is necessary to process these data, and at the same time we have no other reasons to further process these data.
  • You exercise your right to object to processing (see section "Right to object to processing") for personal data we process based on our legitimate interests, and we will find that we have no such legitimate interests as would justify such processing, or
  • We believe that our processing of your personal data has ceased to comply with generally binding regulations.

But please keep in mind that even if one of these reasons is met, it does not mean that we will immediately delete all your personal data. This right is not granted, when the processing of your personal data continues to be necessary to fulfil our legal obligations or to determine, exercise or defend our legal rights (see Why do we process personal data and what entitles us to do so)?

4. Right to Restrict Processing

In addition to the right to delete, in some cases you may have the right to restrict the processing of personal data. This right allows you, in certain cases, to require that your personal data be tagged and this data is not subject to any further processing operations in this case not forever (as in the case of the right to delete) but for a limited time. The processing of personal data must be limited when:

  • You deny the accuracy of your personal data, as we agree, what data is correct;
  • We process your personal data without a sufficient legal basis (for example, beyond what we need to process), but you will only prefer the limitations of such data to its deletion (for example, if you expect you will provide such data to us in the future);
  • We no longer need your personal data for the specified processing purposes, but you require them to determine, exercise or defend your legal claims, or
  • You submit an objection to the processing. The right of objection is described in more detail below in chapter "Right to object to processing"). For the period of investigation, if your objection is legitimate, we are obliged to limit the processing of your personal data.
5. Right of portability

You have the right to receive from us all of your personal data that you have provided to us and which we process under your consent (see section If you give us your consent) and based on the performance of the contract. We will provide your personal data in a structured, commonly used and machine readable format. In order to easily transfer your data upon your request, it may only concern data subject to automated processing in our electronic databases.

6. Right to object to processing

You have a right to object to the processing of your personal data that occurs based on our legitimate interest. (See Why do we process personal data and what entitles us to do so?) In the case of marketing activities, we will no longer process your personal data; otherwise we will do so unless we have serious legitimate reasons for continuing such processing.

7. Right to file a complaint

Exercising your rights in the manner described above shall not affect your right to file a complaint with the relevant supervisory authority. You may exercise this right in particular if you believe that your personal data is being processed unlawfully or in violation of generally binding regulations. You may file a complaint against our processing of your personal data with the Office for Personal Data Protection, located at Hraničná 12, 820 07, Bratislava 27.

In all matters relating to the processing of your personal data, whether it be a matter of law, complaints, or anything else, you can contact us at osobne.udaje@dhl.com. At the same time, our responsible Data Protection Officer (DPO) is at your disposal.

We will address your request without undue delay, and within a maximum of one month. In exceptional cases, especially due to the complexity of your request, we are entitled to extend this period for further two months. We will, of course, inform you of any possible extension and its justification.

Date of last revision: 11.5.2018