Cookie policy
All cookies and similar tools integrated on the websites i) https://huglo.com/ ii) https://huglo.sk/ iii) https://www.trovi.sk/ iv) https://foaf.sk/ v) https://softygon.com/ (hereinafter collectively referred to as the “Websites” or separately as the “Website”) are operated by the Company:
Foaf s.r.o., limited liability company
registered at Pribinova 30
821 09 Bratislava – mestská časť Ružinov
Slovak Republic
VAT ID: 36 774 421
(hereinafter referred to as “we”, “FOAF”, or “Operator”). You can contact our responsible person at any time about cookies, either:
- by e-mail to: dpo@foaf.sk, or
- by mail to: Foaf, s.r.o. registered at Pribinova 30, 821 09 Bratislava – mestská časť Ružinov.
This document is primarily intended for visitors to Websites. It provides information on how we use cookies and similar tools in the connection with the use of Website. Furthermore it provides information how we further use such data collected.
This document supplements and specifies the general information on the processing of personal data available in Privacy Policy.
As a data subject, you have the right to revoke your consent at any time, whereby based on the consent given prior to its revocation, the revocation of the consent does not affect the lawfulness of processing personal data. At the same time, for the reasons related to your specific situation, you have the right, as a data subject, to object to the processing of personal data determined by to:
- the legal basis of legitimate interests; and
- direct marketing purposes;
including related profiling. Such an objection shall have the same effect as revoking a consent.
Information contained in this document is a subject to changes and updates.
Foaf, s.r.o.
28 March 2024
1. What types of cookies do we use?
Cookies are files that are stored in your internet browser used by your device when browsing our Websites sending us information about your activity. It is a technology, that helps us to better control and configure our Websites, understand your behavior during the usage, but it also targets our online advertising and campaigns more specifically.
We use the following basic types of cookies on our Websites:
- Necessary cookies – Necessary cookies are used for anonymous identification of the user, enabling basic functions such as site navigation and access to protected areas of websites, but also very basic traffic measurement without sharing data with a third party. The Website cannot function properly without these cookies. We process necessary cookies for the purpose of the operations, security and optimization of the functioning of our Websites without the need for obtaining your consent.
- Statistical cookies – In the context of the usage of specialized tools (e.g. Google Analytics) and in order to better understand and interpret data about the users of our Websites and how they are using our services, this involves the processing of statistical cookies, which we are using for marketing analytics or for advertising campaigns. We are using this then data to target advertising. Prior to using statistical cookies for the purpose of targeting and personalizing the advertising content for you, we require a consent.
- Marketing-analytical cookies – This includes the processing of marketing-analytical cookies and tools of third-party cookies (such as Meta and Adform in particular) for targeting our advertising campaigns and displaying ads on our Websites, on your social networks profiles and during the regular use of the Internet. They further serve to raise the awareness of us in the online environment by using analytical cookies and third-party tools (in particular Facebook, Google or Adform) in order to display personalized content on our Websites and social networks, enabling you a better interaction with our content on social networks via third-party plug-ins (e.g. Facebook, LinkedIn). In accordance with legal regulations and prior to using any analytical cookies, we require your consent, which you can revoke at any time.
Synchronously, we also distinguish between so-called “1st party” cookies – which are stored directly by us or by our servers – and so-called “3rd party” cookies – which are stored by our external service providers / third parties such as e.g. Google Analytics, Adform, Meta, Gemius.
2. For what purposes and on what basis do we use cookies?
| Purpose of processing | Cookie type | Legal basis |
|---|---|---|
| Operations, security and optimization of websites | Necessary cookies | Legitimate interest |
| Using the website for analytical and statistical purposes | Statistical cookies, Marketing-analytical cookies | Consent of the subject concerned |
| Targeting and personalization of advertising content | Marketing-analytical cookies | Consent of the subject concerned |
These unifying purposes however involve a number of processing operations, which we describe in more detail below:
| Purpose of processing | Further explanation |
|---|---|
| Operations, security and performance optimization of websites | This includes processing of necessary cookies that allow us to use cookies you have chosen in the settings of the website, such as storing granted consent or non-consent to cookies, utilization of our client portal or other ways of using our Webpages. It also includes processing of necessary cookies that contribute to protection against attacks Cross-Site Request Forgery (CSRF) and anti-spam robots or otherwise support a correct and safe operation of the Website. |
| Using the website for analytical and statistical purposes | This includes processing of marketing-analytical cookies during the usage of specialized tools (e.g. Google Analytics, Gemius or Adform) in order to better understand and interpret data about users of our Websites, about the way in which our services are used and also the monitoring of advertising campaigns. Subsequently they are used in targeting advertising and as a part of it, there may also be segmenting customers into different groups for which then the advertising, campaigns or Website content is adjusted. |
| Targeting and personalization of advertising content | This concerns processing of marketing-analytical cookies and third-party tools (such as Meta and Google in particular) to target our advertising campaigns and displaying advertisements on our website, on your social networks profiles. It enables you to better interact with our content through third-party plugin modules (eg Meta). |
3. What specific cookies do we use and for how long (what is their lifespan)?
Below, there is a list of all the cookies we currently use on the Website.
The given list also contains other necessary information, including the lifetime of cookies or the length of their functionality. Depending on the storage time of cookies in your device or internet browser, cookies can be divide into short-term cookies (so-called session cookies – duration while browsing the web), deleted after closing the session or after closing the browser, and long-term cookies (also so-called persistent cookies), that remain stored in your device. Long-term cookies are only deleted after a certain period of time or by actively deleting cookies, which you can perform at any time.
Google reCAPTCHA (Functional)
Name | Expiration | Function |
| _grecaptcha | 6 months | Provide spam protection |
WordPress (Functional)
Name | Expiration | Function |
| wpEmojiSettingsSupports | session | Store browser details |
Complianz (Functional)
Name | Expiration | Function |
| cmplz_id | 160 days | Store cookie consent preferences |
| cmplz_user_data | 160 days | Read to determine which cookie banner to show |
| cmplz_saved_services | 160 days | Store cookie consent preferences |
| cmplz_saved_categories | 160 days | Store cookie consent preferences |
Google Analytics (Statistics)
Name | Expiration | Function |
| _ga | 2 years | Store and count pageviews |
| __utmc | 30 minutes | Store time of visit |
| __utma | persistent | Store the calculation of days and time to purchase |
| __utmz | 6 months | Store used keyword and search engine |
| __utmb | session | Store time of visit |
| _ga_* | 1 year | Store and count pageviews |
Polylang (Functional)
Name | Expiration | Function |
| pll_language | persistent | Store language settings |
4. How do you revoke your consent to cookies?
By interacting with the active element “Customize”, you will be shown the cookie bar again, where you just need to disable cookies (see image below). Changes to the settings will take effect immediately.
You can also revoke your consent by submitting a data subject request to our responsible person, however this process is not automatic and does not have any immediate effect. We therefore recommend that you change your settings directly on the Website in the manner described above.
5. How do you prevent cookies from being stored on your device?
If you do not grant the consent through our cookie bar (unless they are necessary cookies), these cookies will not be stored to your device. Not giving the consent to marketing or/and statistical cookies has no impact on the Website functionality. You can delete all types of cookies (both necessary and analytical) at any time through the settings of your internet browser. In case of a deletion of necessary cookies, some settings and functions of our Website may not work optimally.
In relation to specific analytical cookies of third parties, it is also possible to use so-called opt-out mechanisms, which prevent the use of specific third-party cookies. Not only in relation to our Website, but overall, using any other websites or social networks, where you have your own account.
| Google Analytics | You can prevent saving cookies from Google Analytics service on our website (but also on any other website) by installing an add-on in your internet browser. The add-on is available here: https://tools.google.com/dlpage/gaoptout |
| Facebook (Meta) / Google and many ising on the Internet | If you don’t want to display personalized ads, you can use initiative www.youronlinechoices.com. Through control preferences you can turn off several cookies on imaging of these advertisements in relation to the involved companies that use cookies. Turning cookies off do not mean, that you will no longer be shown advertising, but the advertising will not be based on your behavior. |
| Facebook (Meta) and Instagram | If you have your own Facebook account, you can also use the controls for managing cookies integrated directly into this social network, available here: https://www.facebook.com/settings/cookie |
| Adform | The tool is designed for recording and evaluating customer behavior on the Web. Adform evaluates it only based on Cookies, and the company does not share or send any other customer data. If you do not want to use this tool, so-called opt-out function is available here: https://site.adform.com/privacy-center/website-privacy/opt-out/ |
| Gemius Direct Effect | If you don’t want to display personalized ads, you can use function “I don’t want you to collect my data” button on the Gemius Privacy Tool Page, available here: http://privacypolicy.gemius.com/ |
At the same time, through the settings of your Internet browser, it is possible to delete the cookies that are stored in your browser. Follow the information below, depending on which browser you use:
If you want to increase your protection against unauthorized monitoring of your device and behavior on internet through cookies (especially third-party cookies), use the “Do Not Track” function (or block third-party cookies pages), which you can turn on, depending on the type of browser used, according to the following instructions:
6. Do we transfer your data to third countries outside of EU/EEA?
To a necessary and minimal extent, yes. Some of our suppliers, or their group subsidiaries, which we use for cookies or various plug-ins integrated into our website, are based in the United States of America, which do not have the status as a whole adequate third country. According to the recent decision of the Commission American companies can again apply through certification for adequacy status. For now, we provide the legality of transfers to the United States of America through standard contract clauses approved by the Commission (text available here). However, it is possible that over time our partners will acquire the status of adequacy and transmissions will be again taken in place, directly on the basis of the Commission’s decision. Up to this point, we provide the following information about adequate guarantees used, according to Art. 46 and Art. 47 GDPR:
| Supplier / Third Party | Reasonable Warranties and Additional Precautions |
|---|---|
| Google Cloud EMEA Ltd. with registered office at 70 Sir John Rogerson’s Quay, Dublin 2, Ireland for Google Services / Google Ireland Ltd. with registered office at Gordon house, Barrow Street, Dublin 4, Ireland for YouTube services (Google Analytics, YouTube Feed plugin) | Approved guarantees – self-certification Information about processing of personal data – Google New type standard contractual clauses approved by the relevant decision of the European Commission (module 1 and module 2) and adequate additional measures with closer by explaining the setting |
| Meta Platforms Ireland Ltd. with registered office at 4 Grand Canal Square Grand Canal Harbor Dublin 2, Ireland (Page Insights, Custom audiences, Measurements and analytics) | Approved guarantees – self-certification Information about processing Information about personal data processing – WhatsApp (at transmission data outside the EEA) Standard contractual clauses are used, specifically a combination of old ones (standard contractual clauses for the transfer of personal data by intermediaries from third countries approved by the European Commission 2010/87/EC of February 5, 2010) and new clauses (module 3) inserted form of the amendment to the general conditions of personal data processing and reasonable additional measures explained here: |
7. Is storing cookies on my device a contractual or legal requirement and what are the consequences if I prevent them from being stored?
Granting any cookies is not a legal requirement and therefore the failure to provide them has no negative consequences of legal significance for you. However, it is possible to consider, that the processing of necessary cookies is necessary to ensure and provide f the services you are interested in. It also may be a contractual requirement. In the case of statistical and marketing-analytical cookies, providing them is solely voluntary and is governed by whether or not you grant your consent. Failure to grant this consent does not have any negative effect neither any consequences.
8. How do we use cookies to manage our social media profiles?
Simple links (links) may also be available on our Websites that immediately enable the link between our Website and our profile established on a social network or another platform (including Facebook, Instagram, LinkedIn). In these cases they are not active plug-in modules (plugins) processing data, which would require a consent from users of these social networks, either logged or not logged in.
However, in the case of a user interaction with icons displaying individual social networks, cookies and personal data may be processed by these social networks, for which we do not posses any control. In this case, we are not responsible for the use of cookies. For more information about processing cookies, it is therefore necessary to familiarize yourself with the rules of their processing, which social network providers have published and are easily accessible through the following links:
In Foaf, s.r.o. we are responsible for processing your data only to a certain extent, for example if you visit our profile, if we communicate with each other on a social network or if we target you with advertising on social networks. We can process your personal data and cookies on our profiles on social networks for marketing or statistical purposes together with the relevant controllers of social networks as so-called “joint controllers” in accordance with GDPR. Based on this foundation, we are obliged to to inform you about the basic parts of the agreements that we concluded according to Art. 26 GDPR:
9. Do we use third-party plugin modules on our websites?
Some websites also include an authentication module from Google, via which you can register and log in to our client portals on our websites. It may result in the processing of personal data during the usage of this method of registration and login by the company Google for its own processing purposes, which it informs in Privacy Policy privacy of Google. As a data subject (concerned person), you can defend yourself against this processing. It is necessary for you to apply and excersise this right directly to Google. Foaf, s.r.o. does not influence neither the extent and scope, nor the method of processing such data.
Google Analytics
This service from Google Inc. is an analytical tool that stores information into cookie files and creates traffic statistics of our Websites. This function is not necessary for browsing and serves to monitor and to improve the performance of the Website. When using Google Analytics service, we do not process any personal data or other indirect identifiers which can be used for identification (e.g. IP address) of persons concerned (data subjects). However, this does not mean that Google Inc. as the operator of the Google Analytics service does not process your personal data. The main cookie used by Google Analytics is _ga file. You can find more information about cookie types used by Google Inc. here: https://policies.google.com/technologies/types?hl=en_US or in the information provided above.
In addition to reporting statistics about the usage of our website, Google Analytics together with some advertising cookies may be used to display more relevant ads from Google Inc. (based on your search history and activities on our websites), as well as for measuring interactions with displayed advertisements from Google Inc. Google Analytics service also uses cookies, stored on the end user’s device (computer, tablet, smartphone, …) to analyze your behavior on our Websites. As a part of increasing the protection of your privacy, Google company anonymizes part of the IP address of the end user, immediately after obtaining it. Google Inc. uses information obtained during the use of the Website to evaluate your use of the Website, to provide activity reports on Websites and to provide other services related to the use of Websites and use of the internet.
You can prevent this data processing by Google Analytics with appropriate settings of your internet browser, in which you can install the browser plug-in (available on the following link):
https://tools.google.com/dlpage/gaoptout?hl=en. Clicking this link will cause your Internet browser to save a cookie with the possibility of opting out preventing the future access to data when visiting Websites. You can read further information on the processing of your personal data when using Google Analytics by Google Inc. company in its privacy policy of protecting personal data available at: https://policies.google.com/technologies/partner-sites?hl=en_US.
Apple
Some Websites also include an authentication module from Apple Inc., via which you can register and log in to our client portals on our websites. It may result in the processing of personal data during the usage of this method of registration and login by the company Apple for its own processing purposes, which it informs in Customer Privacy Policy Apple. As a data subject (concerned person), you can defend yourself against this processing. It is necessary for you to apply and excercise this right directly to Apple. Foaf, s.r.o. does not influence neither the extent and scope, nor the method of processing such data.
