This policy explains how we process the personal data of visitors to discomort.com and of people who contact us or work with us — artists, bands, media, promoters and collaborators. The Slovak version is legally binding; this is a translation.
Controller
- Company: DANUBE DIGITAL s. r. o. (operator of the Discomort Studios brand)
- Registered office: Cintorínska 12, 811 08 Bratislava – Staré Mesto, Slovakia
- Company ID (IČO): 54 818 486
- Registration: Municipal Court Bratislava III, section Sro, file no. 163518/B
- Phone: +421 915 042 006
- E-mail: contact@discomort.com
Legal framework
This policy is issued in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data (“GDPR”) and Slovak Act No. 18/2018 Coll. on the protection of personal data, as amended. The controller declares that it complies with all rules under these regulations.
What personal data we process
We process personal data only to the extent necessary. The site has no registration, forms or payments. We mainly process:
- Contact details and the content of communication if you e-mail us (for example about a release, recording, visuals or a show): name, e-mail address, possibly phone number and company name, and the content of the message.
- Data of artists and collaborators that we publish on the site with their consent: names, artistic names, roles, photographs and links (see below).
- Data about use of the site through cookies, only to the extent you have consented to (see Cookies).
- Technical data needed to deliver the site (for example IP address and browser type), processed by the hosting provider when you visit.
Where we get personal data from
We obtain personal data directly from you — when you contact us, work with us, or visit the site and consent to cookies.
Purposes of processing
Communication and answering your questions
If you contact us, we process your data on the basis of legitimate interest so that we can reply and keep a record of sent and received mail. You have the right to object to processing based on legitimate interest. We keep the data only as long as necessary, at most five (5) years.
Preparing and performing a contract (release, production, show)
If you negotiate with us about releasing a recording, music or visual production, a show or other collaboration, we process identification and contact details of you or your representatives in order to prepare, conclude and properly perform the contract. The data are necessary for this purpose; otherwise the contract cannot be concluded or performed. We process them for the duration of the contractual relationship and then archive them as required by law.
Presenting artists, releases and collaborators
We publish names, artistic names, roles, photographs and links of artists and collaborators on the site by agreement with them, in order to present releases, projects and the people behind them. We publish them for the duration of the collaboration or until the person concerned asks for removal.
Accounting
Accounting and tax laws (in particular Act No. 431/2002 Coll. on accounting, Act No. 595/2003 Coll. on income tax and Act No. 222/2004 Coll. on value added tax) require us to keep accounts. We keep accounting records under § 35 of the Accounting Act for ten (10) years following the year to which they relate.
Measuring visits and marketing (only with consent)
If you consent in the cookie settings, we use analytics and marketing cookies deployed through Google Tag Manager to understand how the site is used and to measure campaigns. The legal basis is your consent, which you can withdraw at any time via “Cookie settings” in the footer. Withdrawal does not affect the lawfulness of processing before it.
Handling data subject requests under GDPR
We process your data to fulfil the legal obligation to handle requests under Articles 12 to 21, 33 and 34 GDPR. We keep requests, how they were handled and related communication on the basis of legitimate interest (defence of legal claims in case of an inspection by the supervisory authority or a court dispute) for at most five (5) years after the request was handled, but at least until any related proceedings are finally concluded.
Cookies
Cookies are small text files that a website stores in your browser. We use necessary cookies without consent because the site cannot work without them. Everything else only with your consent.
- Necessary:
discomort_consentstores your cookie choice (180 days),discomort-langyour manual language choice (1 year). - Analytics (only with consent): measuring visits, for example Google Analytics, deployed through Google Tag Manager.
- Marketing (only with consent): measuring and tailoring ads, for example Google Ads or Meta, deployed through Google Tag Manager.
Until you consent to analytics or marketing cookies, Google Tag Manager is not loaded on the site at all. You can change or withdraw your consent at any time via “Cookie settings” in the footer.
If you switch the site language manually (SK / EN), we remember the choice in a necessary cookie discomort-lang (1 year) and in your browser's local storage. It only makes the site open in your chosen language next time. Without a manual choice we pick the language from your browser's language setting; nothing is stored.
YouTube videos load only after you press play, from youtube-nocookie.com. Only then does the YouTube (Google) player process playback data under its own terms.
Recipients of personal data
We do not disseminate, publish or sell personal data to third parties unless there is a legal or contractual reason. We share it only to the extent necessary with:
- service providers: the website and e-mail hosting provider, Google (Google Tag Manager and tools deployed through it, only with your consent; the YouTube player after you press play);
- collaborators on a specific project (for example a studio, photographer, manufacturer or distribution partner), only to the extent the project requires;
- our accounting and tax advisor;
- public authorities.
Transfers to third countries
Your personal data are not primarily transferred to third countries. Such transfers may occur when cookies and services of providers established outside the European Economic Area (for example Google) are used, to the United States. These providers offer appropriate safeguards in the form of standard contractual clauses adopted by Commission Implementing Decision (EU) 2021/914 of 4 June 2021.
The controller does not carry out automated decision-making or profiling.
Security
We protect personal data with appropriate technical and organisational measures against unauthorised or unlawful processing, accidental loss, destruction or damage. Only authorised persons have access, to the extent necessary for their work.
Your rights
As a data subject you have in particular the right:
- of access to personal data (Article 15 GDPR), including confirmation whether we process data about you and a copy of it;
- to rectification and completion of personal data (Article 16 GDPR);
- to erasure of personal data (Article 17 GDPR);
- to restriction of processing (Article 18 GDPR);
- to data portability (Article 20 GDPR) where processing is based on consent or on a contract;
- to object (Article 21 GDPR) where processing is based on legitimate or public interest, or where it concerns direct marketing;
- to object to automated individual decision-making (Article 22 GDPR);
- to lodge a complaint at any time with the Office for Personal Data Protection of the Slovak Republic, or to file a motion under § 100 of the Personal Data Protection Act.
Where we process data on the basis of your consent, you can withdraw it at any time. Withdrawal does not affect the lawfulness of processing before it. You can exercise your rights using the controller's contact details above.
Data protection officer
The controller has not appointed a data protection officer, as one is not required under the Personal Data Protection Act.