Privacy Policy
1. Data controller
The controller of your personal data is Axora Group s. r. o., company ID (IČO) 57746401, registered office: Tomášikova 1498/30, 821 01 Bratislava, Slovak Republic. Smart Study is the AXORA group's division for admission to Slovak schools and universities.
Contact for data protection matters: e-mail smart.study.slovakia@gmail.com, phone +421 952 380 383.
2. What data we process and why
- Consultation request (website form): name, phone number or messenger handle (Telegram, WhatsApp, Viber), country, and the page and language the request was sent from. Purpose: to contact you, hold a consultation and, if you decide to work with us, prepare a contract. Legal basis: your consent (Art. 6(1)(a) GDPR) and steps prior to entering into a contract (Art. 6(1)(b) GDPR).
- Chat assistant: the text of your questions and, if you ask to be contacted by a manager, the same contact details as in the form. Purpose: to answer your question and pass the enquiry to a manager. Legal basis: consent and pre-contractual steps. The chat session ID is stored in your browser (localStorage) so that you can continue the conversation.
- Analytics: we use Umami, a cookie-free visitor counter that does not build user profiles or share data with third parties. It collects anonymised data: page, country, device and browser type, referrer. Legal basis: our legitimate interest in improving the website (Art. 6(1)(f) GDPR).
- Server logs (IP address, request time, page address) — for security and availability of the site; legal basis: legitimate interest.
3. Who receives the data
Requests and chat messages go to the AXORA group CRM (a service on the axora-legal.com domain, hosted in the EU) and to the Smart Study managers' working group. If you choose to be contacted via Telegram, WhatsApp or Viber, the conversation takes place in those services — their operators (Telegram FZ-LLC, Meta Platforms Ireland Ltd., Rakuten Viber) may store data outside the EU under their own terms. We do not sell or pass your data to any other third parties; documents are shared with Slovak schools, universities and public authorities only after a contract is signed and on your instruction.
The website and the CRM are hosted on servers in the European Union. Data is not transferred outside the EU/EEA, except when you use a messenger of your choice.
4. How long we keep the data
- Requests and chat conversations that do not lead to a contract — up to 12 months after the last contact, then deleted.
- Client data under a contract — for the term of the contract and thereafter within the periods required by Slovak law (accounting and tax obligations — up to 10 years).
- Anonymised Umami statistics — no time limit (contains no personal data).
- Server logs — up to 30 days.
5. Your rights
You have the right to request access to your data, its rectification, erasure, restriction of processing and portability, to object to processing, and to withdraw your consent at any time (this does not affect the lawfulness of processing before withdrawal). To do so, write to smart.study.slovakia@gmail.com — we will reply within 30 days. You may also lodge a complaint with the supervisory authority: Úrad na ochranu osobných údajov Slovenskej republiky (Office for Personal Data Protection of the Slovak Republic), Hraničná 12, 820 07 Bratislava, dataprotection.gov.sk.
We do not use automated decision-making or profiling. The website does not use advertising or tracking cookies.
6. Changes to this policy
The current version is always available at smartstudy.sk/en/privacy/. If we make material changes, we will update the version date at the top of this document.
