pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (the Regulation)

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Introduction

Company FibreNet, s.r.o., with registered office at: Tomasikova 64, 831 04 Bratislava, Company ID: 36 747 572, registered in the Commercial Register of the City Court Bratislava III, section Sro, insert no. 194363/B as Operator (hereinafter referred to as “the operator”) hereby informs visitors of this website about the collection and processing of their personal data.

This information is intended primarily for our customers, business partners (both customers and suppliers) and their employees entrusted to individual areas of communication relating to the supply of products and services in the framework of contractual relations.

The information is also intended for you if you are a developer, builder, investor, architect, designer and request a statement or opinion through the online forms placed on our website.

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Privacy Policy

We process your personal data only on the basis of legal conditions, which are specified in the regulation or in the law. As a controller, we are responsible for the protection of your personal data that we have obtained or obtain from you in accordance with the regulation and the law to the extent and in the manner according to the information provided in this statement.

Your personal data will be stored and backed up securely, in accordance with our security policy and only for the period specified below.

Access to your personal data will be granted to recipients and persons authorized by us, who process them on the basis of our instructions.

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Source of collection of personal data

We collect your personal data primarily directly from you, when you voluntarily provide it to us in connection with an inquiry or request for our services, which you address to us personally, by phone, in writing by mail or electronically through electronic forms available on our website www.fibrenet.sk.

If you are an employee of our business partner, who is a legal entity, or a self-employed person who has designated you as his authorized person for individual areas of communication related to the supply of products and services within the framework of contractual relations, we collect personal data from your employer.

We also collect your personal data from our contractual partners or other authorized persons in connection with the performance of contracts or other contractual, pre-contractual or other obligations of ours, or from publicly available sources: Commercial register, register of associations, websites, professional networks (LinkedIn), public telephone directories, etc.

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Categories of personal data

Data that we normally process about applicants, customers, business partners, including personal data of their employees:

Identification and contact details: i particular your name, surname, contact and delivery postal address, telephone contacts, e-mail contacts and, if you are a business natural person, also your business name, address of the place of business or registered office, identification number and tax identification number.

Details of the subject of the order/request: information about the subject of your order or request.

‍Banking, financial and transaction data: credit card number, bank account details, payment details.

Information about our mutual communication or other contact related to the conclusion and performance of the contract: in particular the communication channel used, the date and content of the communication.

Information relating to your complaint, claim or appeal: in particular the identification and contact details of the complainant, claimant or appellant, the reason for the complaint, claim, appeal, method of resolving the complaint, complaint, appeal or dispute.

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Necessity of providing personal data

We absolutely need your personal data from you, because in case of non-provision of them, a contractual relationship between the supplier and the customer cannot arise, since in accordance with the Law of the NR SR No. 513/1991 Coll. The Commercial Code, as amended, is your identification as a party to the contract one of the essential requirements of the contract.

However, if you choose not to provide us with your phone number or e-mail address, this does not prevent the formation of a contractual relationship, but our communication with each other will not be as effective as if you had provided them to us. If you do not provide your e-mail address, we will not be able to send you electronic billing invoices, which we will issue to you on the basis of the Contract and we will only be able to send them to you by post. Furthermore, in case of non-provision of your personal data, the performance of the contracts may be significantly difficult or even impossible, or this may result in the communication of the parties to the contract difficult.

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Recipients of personal data

All your personal data will be stored in our internal systems and will be further provided by us to various cooperating entities. Recipients of personal data may be:

• control, supervisory and other state bodies in the exercise of their activities within the meaning of specific legislation e.g. Local authorities (Municipalities, District Offices), Office for Regulation of Electronic Communications and Postal Services, Slovak Trade Inspection, Office for Personal Data Protection, Tax Office, etc.,
• courts and law enforcement agencies at their request or within the legitimate interests of the controller in establishing, exercising and defending legal claims,
• contracted service providers who:
• provide us with IT administration and maintenance services, hosting and servicing of software applications used by us,
• provide us with accounting management services,
• participate in the processing of your requests (service companies carrying out statements, designations and consultations on network transshipments),
• provide us with legal services, in particular ensuring for us the protection of our legally protected interests and representing us in determining, defending and enforcing our legal claims (lawyers, bailiffs).
• other recipients to whom the controller is obliged to provide personal data pursuant to a special law or legitimate interest, such as auditors, legal advisers, tax and accounting advisors, insurance companies, banks, credit registers, persons who are in an employment or similar relationship with us, to the extent that is strictly necessary for the performance of their work or rights, and which at the same time, in relation to the personal data provided or made available, will have to the extent and under the conditions agreed in a written contract that we conclude with them or provided for by generally binding legislation, the obligation to keep such information confidential.
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We have duly concluded contracts with all processors, on the basis of which we have ensured the protection of your personal data. We ensure that these processors ensure an adequate level of protection of personal data, in accordance with applicable data protection legislation.

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Purpose and duration of the processing of personal data

We will collect and further process your personal data for the following purposes:

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Completing the application

In order to provide a statement on the basis of your request for comment on the existence of telecommunications equipment of the optical network or for territorial and construction proceedings, as well as obligations related to the administration of requests and representations and the possible future exercise and defense of the rights and obligations of the parties, by keeping related documentation and records.

The legal basis for the processing of your personal data for this purpose is Art. 6 (1) (b) and (c) of the Regulation, i.e. performance of the contract and fulfillment of the controller's legal obligations arising in particular from Act 452/2021 Coll. on Electronic Communications and Act No. 200/2022 Coll. on Spatial Planning, Act No. 25/2025 Z.z. Building Code as amended.

The provision of personal data by the data subject in this case is necessary for the processing of your request. Your personal data will be stored for a period of 10 years after the application has been properly processed.

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Provision of services

To perform contractual obligations or to carry out actions at your request before we conclude a contract with you, in particular for the purposes of processing and sending quotations, preparing and concluding contracts, recording contracts including all changes to them in our internal system, checking the performance of contracts and obligations of the parties, in particular within the framework of supply contracts services, as well as other obligations related to the administration of contracts, delivery, handling of claims and complaints, invoicing in connection with the provision of services, keeping related documentation and records.

The legal basis for the processing of your personal data for this purpose is Art. 6 (1) (b) and (c) of the Regulation, i.e. performance of the contract and fulfillment of the controller's legal obligations arising in particular from Act NR SR No. 513/1991 Coll. Commercial Code as amended and Act No. 452/2021 Coll. on electronic communications as amended.

The provision of personal data by the data subject in this case is a contractual requirement. In case of non-provision of personal data, it will not be possible to conclude a contractual relationship with the data subject. After the termination of the contractual relationship, your personal data will only be stored, for a period of 10 years from the end of the contract, because the obligation to keep the contract and the accounting and tax documents related to the contract that contain your personal data arises from generally binding regulations, in particular from the Accounting Act.

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Networking

As part of the acquisition activity aimed at expanding the network, we process personal data in order to contact potential business partners, suppliers, merger/acquisition companies and conduct pre-contractual negotiations and subsequently for the preparation and conclusion of purchase contracts, registration of contracts including all their changes in our internal system, control of compliance with the contract. the contracts and obligations of the parties, in particular in the context of purchase contracts, as well as other obligations related to the administration of contracts, the keeping of related documentation and records.

The legal basis for the processing of your personal data for this purpose is Art. 6 (1) (f) of the Regulation, i.e. the legitimate interest of the controller (consisting in the development and expansion of business, business relations and identification of suitable business opportunities.

In the event that the contract is concluded, the legal basis is Art. 6 (1) (b) and (c) of the Regulation, i.e. performance of the contract and fulfillment of legal obligations of the operator arising in particular from Act NR SR No. 513/1991 Coll. Commercial Code as amended and Act No. 452/2021 Coll. on electronic communications as amended. The provision of personal data by the data subject in this case is a contractual requirement. In case of non-provision of personal data, it will not be possible to conclude a contractual relationship with the data subject.

We store your personal data only for the necessary time, namely:

• For the duration and evaluation of the acquisition opportunity and/or the conduct of pre-contractual negotiations.

• For a maximum period of 3 years from the last contact, if the contract is not concluded. After this period, the data will be deleted.

• If a contract is concluded, your data becomes part of the categories of processed data for the performance of the contract. After the termination of the contractual relationship, your personal data will only be stored, for a period of 10 years from the end of the contract, because the obligation to keep the contract and the accounting and tax documents related to the contract that contain your personal data arises from generally binding regulations, in particular from the Accounting Act.

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Exercise of the rights of data subjects

It is the legal obligation of the operator to ensure the proper handling of requests by which data subjects exercise their rights in accordance with the Regulation.

Your personal data processed for the purpose of proper processing of the rights of the data subjects may be processed for a period of 5 years if you exercise the right of the data subject.

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Application of the company's claims

The Company processes the following data for the purpose of asserting the Company's claims: data specified in contracts with customers and suppliers, data specified in claims, complaints, data required for filing a claim by the Company, data specified in the action against the Company, data contained in records of thefts, data kept in accounting and other data necessary in connection with the possible exercise of claims or defense of interests of the company. The purpose of the processing of these personal data is the legitimate interest of the controller and the legal basis for the processing is Article 6 (1) (f)

GDPR regulations. The processing of personal data by the company is necessary for the purposes of the legitimate interests of the company. The legitimate interest of the company is the protection of its assets as well as protection against unjustified assertion of claims against the company.

In the event that we assert legal claims against you and conduct legal or administrative proceedings, or if you assert legal claims against us and bring legal or administrative proceedings against us, the personal data will be processed for the establishment, exercise or defence of legal claims until the legal termination of such proceedings.

In the event that you have not fulfilled your obligation to our company, that damage has been caused to us for reasons on your part, or if, on the contrary, you assert your claims against our company by certain legal means, or there is a real risk that the above situations will occur in the future, we

To process your personal data to the extent set out above on the basis of our company's legitimate interest in recovering our claims and/or protecting the rights and legally protected interests of our company (e.g. determination, defence or enforcement of legal claims in court). For this purpose, we store your personal data after the statutory limitation period.

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Transfer to third countries or to an international organisation

FibreNet, s.r.o. is a subsidiary of DRFG Fiber Infrastructure s.r.o. - an entity of DRFG Group. Data transfer takes place between FibreNet, s.r.o. and DRFG Group in order to enable the parties to operate as a group of companies. To provide services within Microsoft 365 (including email, data storage, and online tools), we use cloud services from Microsoft Corporation, based in the United States of America (USA). Customer data is stored primarily in data centers within the European Union. Transfers to third countries take place in particular in the context of operational support and administrative data. The transfer of personal data to the United States takes place on the basis of the European Commission's adequacy decision in relation to

The EU-US Framework for the Protection of Personal Data (EU-U.S. Data Privacy Framework (DPF) (Commission Decision 2023/1795). Microsoft Corporation is certified under this framework, ensuring that the level of privacy protection is comparable to that in the EU. For more information about Microsoft's DPF certification, visit www.dataprivacyframework.gov/list.

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Revocation of consent

In the event that we process your personal data also on the basis of consent, you have the right to revoke this consent to the processing of personal data at any time. Withdrawal of consent does not affect the lawfulness of the processing of personal data based on consent prior to its withdrawal. You can revoke the consent given in the same way as the consent was granted.

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Protection of privacy on our website

Data provided voluntarily by you

You may voluntarily provide certain information on our website for a specific purpose, e.g. any information you enter when you express your interest in being contacted. Such data may include personal contact information such as name, surname, email address and any other information you provide.

We use this collected data to contact you. For this reason, we may share the data with an external partner if this is necessary to answer your questions.

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Cookies

When you visit our website, we collect certain information, such as cookies, by automated means. Our site uses only necessary cookies, without which the website could not function properly or it would not be possible to provide the service expressly requested by the user. They are therefore technically necessary to ensure the basic functionality and security of the website.

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Linked pages

We may provide links from our website to third party websites (“Linked Sites”) such as www.google.com/maps. Linked sites do not necessarily have to be checked or researched by us. Each linked site has its own terms of use and privacy information. We are not responsible for the policies and practices of any linked sites and other links contained therein, so we encourage users to read the terms and notices of those linked sites before using them.

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Children

Our websites are not directed at children and we do not use them to knowingly solicit personal information from children or market it to children. If we learn that a child has provided a personal through one of our websites, we will remove that information from our systems.

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Your other rights in relation to the protection of personal data

In connection with the processing of your personal data, in addition to the above rights, you have in particular the following rights:

Right of access to personal data(Art. 15 of the Regulation); you have the right to obtain confirmation from us as to whether we are processing your personal data and, if so, you have the right to access such personal data (copies thereof), as well as the right to additional information to the extent provided for in Article 15 of the Regulation. In most cases, we will provide you with these copies of your personal data and additional information in written form, unless you request another method of providing them. If you have requested the provision of this information by electronic means, it will be provided to you electronically, if technically feasible.

If your image is recorded on a camera system, you also have the right to request and have at your disposal a copy of your personal data from the recording. On the basis of a written request, which contains the specification of the required record — date, time range, spatial designation, we can provide you with a record in justified cases. If any other persons are visible in the records, the record will be modified, e.g. by blurring, before it is provided.

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Right to rectification of personal data (Art. 16 of the Regulation); we take reasonable steps to ensure the accuracy, completeness and timeliness of the information we hold about you. However, this right allows you to request us to correct your incorrect personal data without undue delay or to supplement your personal data if it is inaccurate, incomplete or out of date.

Please note that you are only required to provide us with personal data that is complete and correct, and you are responsible for the veracity of the personal data you have provided to us.

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How to delete personal data (right to be forgotten) (Art. 17 of the Regulation), without undue delay after the exercise of this right, for example if your personal data are no longer necessary for the purpose for which we collected or processed them, if you have withdrawn your consent to the processing of personal data on the basis of which we carry out the processing of your personal data, and there is no other legal basis for the processing personal data (for example, the contract (or other contracts) that we have concluded with you), if you object to the processing of personal data pursuant to Art. 21 (1) of the Regulation or if your personal data we process it in violation of the regulation and the law.

However, this right of yours must be assessed in the light of all relevant circumstances. For example, we may have certain legal and regulatory obligations, which means that we will not be able to comply with your request.

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Restriction of the processing of personal data (Art. 18 of the Regulation), you have the right to ask us to stop processing your personal data, e.g. if you object to the accuracy of the personal data we hold about you, but only for a period allowing us to verify the accuracy of your personal data, you object to the processing of personal data by automated decision-making or the processing of your personal data is contrary to the regulation and you object to the erasure of your personal data, requesting instead the restriction of their use or objecting to the deletion of your personal data which we, as a supplier, no longer need and want to delete, but you need them, for example in an ongoing legal proceeding,

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Right to portability of personal data (Art. 20 of the Regulation), that is, the right to obtain from us your personal data previously provided to us in a structured, commonly used and machine-readable format and the right to request that we transfer your personal data to another controller in compliance with legal conditions; the exercise of this right does not affect your right to erasure of personal data by the supplier. However, the right to portability only applies to personal data that we have obtained from you on the basis of your consent or on the basis of a contract to which you are a party.

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You can object to the processing of personal data (Art. 21 of the Regulation) if the processing of your personal data is based on our legitimate legitimate interest or if we process your personal data for the purpose of direct marketing of our services and products, including profiling in such processing. In the event that you object and we do not demonstrate a compelling legitimate legitimate reason for the processing of your personal data, or if you object to the processing of your personal data for the purpose of direct marketing of our services and products, we will not further process your personal data for these purposes.

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Make sure that the decision does not apply to you, which is based solely on automated processing of personal data, including profiling if such automated decision-making and profiling would have legal effects in relation to you or significantly affect you (Art. 22 of the Regulation); however, as we have stated, there is no automated decision-making or profiling when processing your personal data by us,

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You can file a complaint with a supervisory authority(Art. 77 of the Regulation); if you believe that the processing of your personal data is contrary to the regulation or the law, you can file a complaint with the Office for Personal Data Protection of the Slovak Republic (https://dataprotection.gov.sk/).

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Final provisions

If you have any questions regarding the processing of your personal data, you can contact us personally and in writing at the address of our registered office or you can contact our Data Protection Coordinator directly by e-mail: gdpr@fibrenet.sk. This information is current and valid from 01.01.2026. We reserve the right to change, modify and update this privacy information at any time. Please check back regularly to see if you are aware of our most current notice.

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