Effective for the websites and services of R1 Systems s. r. o.
(“EASYBOOKING”, “we”, “us”, “our”)

1. INTRODUCTION

1.1. Our services are intended only for individuals aged 16 years or older.

1.2. This Privacy Policy explains how we collect, use, store and protect personal data when acting as:

• a data controller (e.g., for website visitors and Users), and

• a data processor (for the clients of Users of the EasyBooking service).

1.3. When you first visit our website, we ask for your consent to the use of cookies, where required by law.

1.4. In this Privacy Policy, “we”, “us”, and “our” refer to R1 Systems s. r. o. Company details are listed in Section 15.

1.5. This Privacy Policy applies to:

• website visitors,

• registered Users of the EasyBooking service, and

• clients of Users, where we act as a processor.

2. PERSONAL DATA WE PROCESS AND PURPOSES

We process personal data only to the extent necessary and always based on a lawful basis under GDPR or other applicable data protection laws.

2.1. Analytical Data – Google Analytics

Data processed: truncated IP address, browser and device information, session duration, visited pages, navigation paths.
Source: Google Analytics (Google Ireland Limited).
Purpose: traffic analysis, service improvement, performance measurement.
Legal basis: your consent via the cookie banner.
Transfers outside EU: data may be transferred to the USA under Standard Contractual Clauses (SCCs).
More information: Google Privacy Policy.

2.2. Marketing Data – Meta (Facebook) Pixel

Data processed: IP address, device information, visited pages, interactions, conversions, cookies.
Purpose: personalized advertising, optimization, conversion tracking.
Legal basis: your consent (may be withdrawn at any time).
Transfers: may occur to the USA or other third countries under SCCs.
More information: Meta Privacy Policy.

2.3. Registration and Account Data

Data processed: name, business information, email, phone, login credentials, service usage preferences.
Purpose: creation and management of the User Account, access to the Service.
Legal basis: performance of a contract.

2.4. Service Usage Data (Logs and Technical Data)

Data processed: IP address, device type, browser type, system logs, access records, timestamps, actions within the Service.
Purpose: ensuring proper operation, security, fraud detection, troubleshooting, support.
Legal basis: legitimate interest (security and functionality) and/or performance of a contract.

2.5. Communication Data

Data processed: name, email address, phone number, inquiry details, attachments, metadata.
Purpose: customer support, answering questions, service-related communication.
Legal basis: legitimate interest or contract performance.

2.6. Payment and Billing Data

Data processed: billing details, invoice data, tax identifiers, transaction identifiers.
Purpose: processing payments, accounting, invoicing, compliance with financial legislation.
Legal basis: legal obligation.

2.7. Online Payments via GoPay

Data processed: payment status, amount, transaction ID, payer details (name, email).
⚠️ We do not process or store payment card information.
These are processed exclusively by GoPay as an independent controller.
Purpose: enabling payments, reconciliation, preventing fraud.
Legal basis: contract performance and legal obligation.

2.8. Marketing Data (Email, Newsletter)

Data processed: email, name, interaction metrics.
Purpose: sending marketing messages, updates, offers.
Legal basis: your consent.

2.9. Data for Legal Claims

Purpose: establishment, exercise, or defence of legal claims.
Legal basis: legitimate interest.

3. PROCESSING OF PERSONAL DATA AS A PROCESSOR (FOR USERS’ CLIENTS)

3.1. When clients of Users make reservations or payments through EasyBooking, we process their data on behalf of the User.

3.2. In such cases:

• the User is the data controller,

• we are the data processor.

3.3. The data processed include:
name, contact information, reservation details, payment status, communication, and other data entered by the User.

3.4. As a processor, we:

a) process data only according to the User’s instructions,
b) ensure confidentiality,
c) implement appropriate security measures,
d) allow audits where required by GDPR,
e) do not process client data for our own purposes.

3.5. Users are responsible for ensuring that they have a valid legal basis to process the personal data of their clients.

4. DISCLOSURE OF PERSONAL DATA

We may share personal data with:

• hosting and infrastructure providers,

• email and SMS delivery providers,

• payment service providers (GoPay),

• analytics and marketing providers (Google, Meta),

• accounting firms,

• subcontractors assisting with technical maintenance,

• public authorities where required by law.

All third parties who process data on our behalf are bound by Data Processing Agreements.

5. INTERNATIONAL DATA TRANSFERS

When data are transferred outside the EU/EEA, we rely on:

• adequacy decisions of the European Commission, or

• Standard Contractual Clauses (SCCs), or

• other legally recognized safeguards.

For Users outside the EU, additional local privacy requirements may apply.

6. DATA RETENTION

We retain data only as long as necessary:

• Accounting data: 10 years

• Communication data: up to 2 years

• User log data: 12 months

• Clients’ reservation data: as long as the User Account is active + 30 days

• Marketing data: until consent is withdrawn (or 5 years of inactivity)

• Analytics data: up to 26 months

• Cookie data: according to cookie category

Data may be retained longer where required by law or necessary for legal claims.

7. YOUR RIGHTS

You have the right to:

• access your personal data,

• request correction,

• request deletion,

• restrict processing,

• data portability,

• object to processing (including marketing),

• withdraw consent at any time,

• lodge a complaint with a supervisory authority.

Contact for requests: info@easybooking.sk

We respond within 1 month, extendable by 2 months for complex cases.

8. COOKIES

8.1. We use cookies and similar technologies for functionality, analytics, and marketing.

8.2. Cookie categories:

• Necessary cookies – essential for website functionality (no consent required).

• Analytical cookies – measure and analyze traffic (consent required).

• Marketing cookies – personalize ads and track conversions (consent required).

8.3. You can manage your cookie preferences via the Cookie Settings link in the website footer.

9. COOKIES USED BY THIRD PARTIES

Google, Meta and other providers may store cookies while interacting with our Website.
These are used for analytics, measurement and advertising.

10. COOKIE MANAGEMENT

You may refuse or delete cookies through your browser settings.
Blocking cookies may affect website functionality.

11. SECURITY

We implement appropriate technical and organizational measures, including:

• encryption

• secure servers

• access controls

• firewalls and intrusion monitoring

• regular backups

• fraud and abuse detection

• secure data transmission protocols

However, no system is completely secure, and we cannot guarantee absolute protection.

12. LOCAL PRIVACY RIGHTS OUTSIDE THE EU

Depending on your jurisdiction, you may have additional rights:

CCPA / CPRA (California)

If applicable, California residents may request information about categories of data processed, opt-out of “sale” or “sharing”, or exercise deletion rights.

UK GDPR

Transfers, rights and definitions follow the UK Data Protection Act 2018 and UK GDPR.

Other jurisdictions

Local data protection authorities may be contacted according to your country’s legislation.

13. SUPERVISORY AUTHORITIES

For EU residents, the competent supervisory authority is:
Úrad na ochranu osobných údajov SR
Hraničná 12, 820 07 Bratislava, Slovakia

Users may also contact their local supervisory authority.

14. CHANGES TO THIS POLICY

We may update this Privacy Policy occasionally.
We will inform Users of material changes via email or website notification.

15. COMPANY DETAILS

R1 Systems s. r. o.
A. Hlinku 3058/12
926 01 Sereď
Slovakia
ID No.: 52536190

Email: info@easybooking.sk
Tel.: +421 909 109 782
Website: www.easybooking.sk