Privacy Policy

Personal Data Processing Policy

EFFECTIVE FROM 25 MAY 2018 — IN COMPLIANCE WITH GDPR (EU REGULATION 2016/679)
The protection of your personal data is our priority. This document explains what data we process, why, and what your rights are.

1. Data Controller

FIRST CLASS HOLDING s.r.o.
Hviezdoslavova 4748/1A
031 01 Liptovský Mikuláš, Slovakia
Company ID: 46 056 831
Registration: District Court Žilina, Section: Sro, File No. 54311/L
Contact: firstclass@firstclass.sk | +421 907 579 379

2. What Data We Process

We only process data that is necessary for the provision of our services:

CategoryExamplesPurpose
Contact DataName, email, phoneCommunication, responding to enquiries
Company DataCompany name, registration number, positionPreparation of proposals and contracts
Project DataScope of engagement, deliverablesDelivery of advisory services
Technical DataIP address, cookies, deviceWebsite security and improvement

3. Legal Basis for Processing

We process your personal data on the following legal bases:

Legal BasisWhen
ContractWhen we enter into or fulfil a contractual relationship with you
Legitimate InterestWebsite security, service quality evaluation, legitimate analytical purposes
ConsentOnly when you actively provide it (e.g. newsletter, marketing materials)
Legal ObligationAccounting, tax and regulatory obligations under Slovak and EU law

4. Data Retention Period

We retain data only for the period necessary for the given purpose:

  • Contact enquiries: 2 years from last communication
  • Contractual data: duration of contract + 5 years
  • Accounting documents: 10 years (legal obligation)
  • Marketing consent: until revoked
  • Technical data (cookies): max. 12 months

5. Data Sharing

We share data exclusively with:

  • Hosting provider (EU-based servers)
  • Accounting firm (legal obligation)
  • State authorities (only as required by law)

We never sell data to third parties for marketing purposes.

6. Your Rights

Under GDPR, you have the following rights:

  • Right of Access — obtain information about what data we process about you
  • Right to Rectification — request correction of inaccurate data
  • Right to Erasure — request deletion of your data
  • Right to Restriction — restrict the processing of your data
  • Right to Data Portability — obtain your data in a structured format
  • Right to Object — object to processing based on legitimate interest
  • Right to Withdraw Consent — at any time, without giving a reason

7. Cookies

On our website we use:

  • Essential — ensuring website functionality (session, CSRF)
  • Analytical — Google Analytics (anonymised traffic data, requires consent)

8. Security

We protect personal data with technical and organisational measures corresponding to the current state of technology. Only authorised persons have access to data.

9. Supervisory Authority

If you believe your rights have been violated, you have the right to file a complaint with the Office for Personal Data Protection of the Slovak Republic.

Last updated: April 2026 | FIRST CLASS HOLDING s.r.o.