We attach great importance to the protection of the personal data of data subjects. We are therefore committed to protecting all personal data that we process and to taking all measures necessary to fulfil this commitment.

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This Privacy Policy (the Policy) sets out, among other matters, who we are, what personal data we process, the purposes for which we process such data, the legal bases on which we rely, and your rights and obligations as a data subject.

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The Cookie Statement concerning our use of cookies (the Cookie Statement), which is available at this link, forms an integral part of this Policy.

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It is important to us that you feel safe and properly informed when using our website at www.joinbfg.com (the Website). We therefore ask that you read this Policy and the Cookie Statement carefully and ensure that you understand their contents.

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If you have any questions concerning this Policy and/or the Cookie Statement, you may contact us by email at legal@joinbfg.com.

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By browsing the Website or otherwise interacting with its content and/or functionality, you acknowledge that you have read and agree to this Policy and the Cookie Statement.

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1. Definitions

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For the purposes of this Policy:

1.1 Organization means United Resources Group s. r. o., with its registered office at Račianska 9705/96, 831 02 Bratislava, Slovak Republic, Company ID No. 50 866 222, registered in the Commercial Register maintained by the Municipal Court Bratislava III, Section Sro, Insert No. 119547/B. References in this Policy to we, us and our are references to the Organization;

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1.2 Regulation means 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);

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1.3 Act means Act No. 18/2018 Coll. on Personal Data Protection and on Amendments to Certain Acts, as amended.

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2. Controller

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2.1 The controller within the meaning of Article 4(7) of the Regulation is United Resources Group s. r. o., with its registered office at Račianska 9705/96, 831 02 Bratislava, Slovak Republic, Company ID No. 50 866 222, registered in the Commercial Register maintained by the Municipal Court Bratislava III, Section Sro, Insert No. 119547/B (the Controller).

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2.2 You may contact us, among other means, by post at the registered office of the Organization and/or by email at info@joinbfg.com.

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3. Purposes and Legal Bases of Processing

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3.1 We value your trust and therefore process all personal data lawfully, fairly and transparently. In our capacity as Controller, we process the personal data of data subjects for our own purposes. In practical terms, this means that we determine the purposes for which personal data are processed, determine the means of such processing and are responsible for ensuring that the processing is carried out properly.

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3.2 The purposes for which we process personal data and the legal bases on which we rely are set out below.

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3.2.1 Processing Personal Data for the Admission of New Members

(A) The Organization seeks to admit new members who meet the membership profile and have the capacity to participate actively in the establishment and development of business ventures.

 

An individual may apply for membership in the Organization, in particular, by submitting the electronic form available on the Website at https://www.joinbfg.com/membership.

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The admission of new members includes a selection process in which the Organization reviews the application, communicates with the applicant for membership (the Applicant), conducts one or more in-person or online interviews, assesses the Applicant's profile against the membership conditions and criteria, reasonably verifies the information provided by the Applicant, and decides on the outcome of the selection process. If the Applicant is successful, the admission process also includes the steps necessary to prepare and enter into a membership agreement.

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(B) The legal basis for processing personal data provided by an Applicant for this purpose is the taking of steps, at the Applicant's request, prior to entering into a contract, pursuant to Article 6(1)(b) of the Regulation.

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To the extent that the Organization reasonably verifies material information provided by the Applicant, assesses potential conflicts of interest, or obtains relevant data concerning the Applicant from publicly available sources or from referees identified by the Applicant or whose contact the Applicant has approved in advance, the legal basis for the processing is the legitimate interests pursued by the Organization pursuant to Article 6(1)(f) of the Regulation. The Organization's legitimate interests consist in verifying the trustworthiness and relevant suitability of Applicants, preventing conflicts of interest, and safeguarding the security and proper functioning of the membership environment.

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3.2.2 Processing Personal Data for Direct Marketing

(A) In the course of its activities, the Organization may contact prospective members and provide them with information concerning membership opportunities and the Organization's activities, projects and events.

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For this purpose, the Organization may process, for example, identification, contact and professional data obtained from relevant publicly available sources.

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Prospective members may be contacted, in particular, by email, by telephone or by direct message through social media, in each case in accordance with applicable law.

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(B) The legal basis for such processing is the legitimate interests pursued by the Organization pursuant to Article 6(1)(f) of the Regulation. The Organization's legitimate interests consist in presenting membership opportunities and information about the Organization's activities, projects and events to persons who, in view of their professional or business activities, may reasonably be interested in them, and in developing the Organization's membership base.

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A data subject has the right to object at any time to the processing of his or her personal data for direct marketing purposes. Once an objection has been made, the Organization will no longer process that data subject's personal data for such purposes.

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4. Categories of Personal Data Processed

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4.1 We obtain personal data directly from data subjects, from relevant publicly available sources, in particular professional or business sources, and, in the circumstances specified in this Policy, from referees.

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We determine the categories and extent of personal data processed by reference to the specific purpose of the processing, so that the personal data are adequate, relevant and limited to what is necessary in relation to that purpose.

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4.2 The categories of personal data processed for each purpose are as follows.

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4.2.1 Admission of New Members

For the purpose of admitting new members under Section 3.2.1 of this Policy, we process, in particular:

a) the Applicant's identification and contact details and the location from which the Applicant operates;

b) information concerning the Applicant's professional and business activities, expertise, education, experience, track record, projects and scope of responsibility;

c) information concerning the Applicant's motivation, expectations of membership, anticipated contribution, preferred project role, time availability, project interests and resources that the Applicant may be able to mobilize for a suitable project;

d) information concerning the Applicant's financial preparedness and any proposed investment parameters;

e) information concerning potential conflicts of interest, non-compete or contractual restrictions and confidentiality obligations;

f) the content of communications with the Applicant, interview notes, references provided, the results of reasonable verification of information, the assessment of the Applicant, and the decision on the outcome of the selection process; and

g) where the Applicant is admitted, the information necessary to prepare and enter into the membership agreement.

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If an Applicant identifies a referee, we also process that referee's identification and contact details, information concerning the referee's relationship with the Applicant, and the content of the reference provided.

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4.2.2 Direct Marketing

For the purposes of direct marketing under Section 3.2.2 of this Policy, we process, in particular, the prospective member's identification data; contact details, including a telephone number, email address or social media profile identifier; relevant information concerning his or her professional or business activities; records of communications; and information concerning any request not to be contacted further.

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5. Categories of Recipients

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5.1 We make personal data available only to persons whose involvement is necessary to achieve the relevant purpose of the processing and only to the extent necessary for that purpose.

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Within the Organization, access to personal data is limited to persons who require such access to perform their duties and who are authorized to process personal data in accordance with the Organization's instructions.

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5.2 Where we engage a processor to process personal data, we use only processors providing sufficient guarantees that appropriate technical and organizational measures will be implemented. Processing by a processor is governed by a contract or other legal act in accordance with Article 28 of the Regulation. A processor may process personal data only on the basis of the Organization's documented instructions, unless the processor is required to process such data by applicable law.

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5.3 The following categories of recipients may, in particular, be involved in the processing of personal data under this Policy:

•  providers of hosting services and services supporting the operation of the Website;

•  providers of electronic forms and related software solutions;

•  providers of cloud storage, email and other communication tools; and

•  providers of information-system maintenance, support and security services.

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5.4 To the extent necessary, personal data may also be made available to the following categories of recipients:

•  referees, where it is necessary to verify information provided by an Applicant and the Applicant has approved contact with the relevant referee;

•  operators of social media networks and communication platforms, where their services are used to communicate with the data subject; and

•  courts, public authorities and other authorized entities, where the disclosure of personal data is required or permitted by law.

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Depending on the nature of the relevant processing, certain service providers may act as independent controllers of personal data.

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6. Processing and Retention Periods

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6.1 We retain personal data only for as long as necessary to achieve the purpose for which they are processed and, in any event, no longer than the periods specified in this Section.

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6.2 Personal data processed for the admission of new members under Section 3.2.1 of this Policy are retained while the application is being assessed and throughout the selection process, but no longer than 30 days following the date on which the final decision is communicated to the Applicant.

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If an Applicant is placed on a list of candidates for possible admission at a later date, we retain the Applicant's personal data while the application remains under consideration, but no longer than 12 (twelve) months following the date on which that decision is communicated to the Applicant. The Applicant may request at any time that the further consideration of his or her application be discontinued.

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If a membership agreement is entered into with the Applicant, the personal data necessary for the establishment and duration of the membership will continue to be processed in accordance with the information on personal data processing applicable to members of the Organization.

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6.3 Personal data processed for direct marketing purposes under Section 3.2.2 of this Policy are retained for no longer than 2 (two) years from the date on which they are obtained and, in any event, only until the data subject objects to their processing for that purpose.

Following an objection, we will no longer process the personal data for direct marketing purposes. To the extent necessary, we may retain identification or contact details and a record of the objection in order to ensure that the data subject is not contacted again for direct marketing purposes.

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6.4 Upon expiry of the applicable retention period, we will erase, anonymize or physically destroy the personal data, unless their continued retention is required by law.

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7. Personal Data Are Not Made Public

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The Controller does not make public any personal data of data subjects processed for the purposes set out in this Policy.

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8. Voluntary Provision of Personal Data

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8.1 The provision of personal data for the purposes set out in this Policy is voluntary. A data subject is not required to provide personal data.

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8.2 If, however, a data subject chooses to apply for membership, the Controller will be unable to assess the application or conduct the selection process unless the personal data necessary for the assessment of the application are provided.

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8.3 The processing of personal data for direct marketing purposes under Section 3.2.2 of this Policy is not a condition for the assessment of a membership application or for entering into a membership agreement. A data subject has the right to object to such processing at any time.

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9. Transfers of Personal Data

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9.1 Unless otherwise stated, the personal data of data subjects are processed within the territory of the European Union or the European Economic Area. European Union law recognizes this territory as providing a secure and guaranteed level of protection.

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9.2 Personal data are transferred to third countries only where the safeguards necessary to ensure the appropriate protection of the personal data of data subjects have been implemented and subject to the conditions laid down in the Regulation and the Act.

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10. Website Security

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Our Website at https://www.joinbfg.com uses an encrypted SSL (Secure Sockets Layer) connection whenever a connection is established or data are transmitted. This prevents unauthorized third parties from accessing and/or altering data in transit.

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11. Rights and Obligations of Data Subjects

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11.1 As a data subject, you have the rights and obligations set out below. The full scope of those rights and the conditions governing their exercise are laid down in the Regulation and the Act.

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11.2 A data subject undertakes, in particular, to:

•  provide only complete and accurate personal data;

•  update the personal data provided without undue delay following any change; and

•  provide only his or her own personal data.

 

Where a person provides the personal data of a third party, that person represents that the data are provided with the third party's consent and that the third party has been duly informed of this Policy and the Cookie Statement.

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11.3 A data subject has the following rights:

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11.3.1 Right of Access

A data subject has the right to obtain confirmation as to whether his or her personal data are being processed and, where that is the case, the right to access such personal data and certain additional information in accordance with Article 15 of the Regulation and Section 21 of the Act.

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11.3.2 Right to Rectification and Completion of Incomplete Personal Data

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A data subject has the right to obtain the rectification of inaccurate personal data concerning him or her and, having regard to the purposes of the processing, to have incomplete personal data completed.

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To ensure that the personal data we process remain accurate and up to date, you should notify us of any change without undue delay. If we process inaccurate personal data, the data subject has the right to have such data rectified.

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11.3.3 Right to Erasure

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A data subject has the right to obtain the erasure of his or her personal data where the conditions laid down in Article 17 of the Regulation or Section 23 of the Act are met.

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11.3.4 Right to Restriction of Processing

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A data subject has the right to obtain restriction of the processing of his or her personal data where the conditions laid down in Article 18 of the Regulation or Section 24 of the Act are met.

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11.3.5 Right to Data Portability

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Where personal data are processed on the basis of the data subject's consent or for the performance of a contract to which the data subject is a party, and the processing is carried out by automated means, the data subject has the right to receive his or her personal data in a commonly used and machine-readable format and to have those personal data transmitted to another controller, where technically feasible.

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11.3.6 Right to Object to Processing

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A data subject has the right to object to the processing of his or her personal data where such data are processed pursuant to Article 6(1)(e) or (f) of the Regulation, including profiling based on those provisions.

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The Controller is not required to cease such processing where it demonstrates compelling legitimate grounds for the processing that override the interests, rights and freedoms of the data subject, or grounds for the establishment, exercise or defence of legal claims.

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This exception does not apply where personal data are processed for direct marketing purposes, including profiling related to such direct marketing, and the data subject objects to that processing. In such circumstances, the Controller must cease processing the personal data for that purpose.

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11.3.7 Right to Lodge a Complaint

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If a data subject considers that the processing of his or her personal data infringes the Regulation or the Act, he or she has the right to lodge a complaint with the Controller by email at legal@joinbfg.com and/or with the competent supervisory authority. The supervisory authority in the Slovak Republic is the Office for Personal Data Protection of the Slovak Republic, Galvaniho 7/B, 821 04 Bratislava, Slovak Republic.

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11.3.8 Right to Withdraw Consent

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A data subject has the right to withdraw any consent given to the processing of personal data at any time, with effect for the future.

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12. Automated Individual Decision Making

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We do not engage on our Website in automated individual decision-making, including profiling, that produces legal effects concerning a data subject within the meaning of Article 22(1) and (4) of the Regulation.