Privacy policy — Towardia

What personal data towardia.com processes, why and on what legal basis, who receives it, how long it is kept, your GDPR rights and how to complain.

This policy explains how we process the personal data of visitors to towardia.com under the General Data Protection Regulation — Regulation (EU) 2016/679 (GDPR), in particular Article 13 — and the Slovak Zákon č. 18/2018 Z. z. o ochrane osobných údajov.

1. Who is responsible for your data

The controller of your personal data is:

Clayarena s. r. o., Jenisejská 2441/45A, 040 12 Košice, Slovenská republika

IČO 57 458 821, registered in the Obchodný register Okresného súdu Košice I, oddiel Sro, vložka č. 64983/V.

Contact for all personal data matters: fenix [at] ava.com.ua (temporary address; replace [at] with @).

2. In short

You can read the website without registering; we do not ask for your name or any other details.
We do not show advertising and we do not sell personal data.
We do not make automated decisions about you that have legal effects (Art. 22 GDPR).
Google Analytics 4 is currently used on the website. A consent mechanism (cookie banner) is being prepared. Until it is launched, you can block analytics cookies in your browser (see section 4).

3. What data we process, why, on what legal basis and for how long

Data	Purpose	Legal basis	Retention period
Technical request data in server logs: IP address, date and time, page address, referring page, browser and device type, server response code	to deliver the page, keep the website stable and secure, detect faults and misuse	legitimate interests — Art. 6(1)(f) GDPR; our interest is the secure and reliable operation of the website	no longer than necessary for these purposes; the exact period is to be confirmed
Text you type into the search box, which is sent to our server to display suggestions	to show search suggestions	legitimate interests — Art. 6(1)(f) GDPR; our interest is convenient search on the website	used to display the suggestion; in server logs it is kept as technical request data (row above)
Google Analytics 4 data: identifiers stored in cookies, pages viewed, referring page, approximate location (country, region, city), language, device type, browser and operating system, time on page and interactions	visitor statistics: to understand which pages are useful and to improve the website	consent — Art. 6(1)(a) GDPR and § 109 of Zákon č. 452/2021 Z. z. o elektronických komunikáciách; the consent mechanism is being prepared (see section 4)	cookies — up to 2 years (see Cookies and analytics); the retention period of data in Google Analytics is to be confirmed
Emails you send us: your email address, your name (if you give it), the content of the message	to reply, correct an error, handle a complaint or a request about your rights	legitimate interests — Art. 6(1)(f) GDPR (answering your message); for requests about your rights — compliance with a legal obligation, Art. 6(1)(c) GDPR	as long as needed to handle the message and to establish or defend legal claims; the exact period is to be confirmed

Please do not type unnecessary personal data into the search box or send it to us by email, in particular health data. We do not intentionally collect special categories of personal data (Art. 9 GDPR).

4. Google Analytics: the current situation

The website uses Google Analytics 4 (measurement ID G-59SBVB9RD8), a web analytics service provided by Google. At present the analytics script loads together with the page, and there is not yet a banner for giving or refusing consent. A consent mechanism is being prepared. When it is launched, we will update this page and the Cookies and analytics page.

Until the consent mechanism is launched, you can:

block cookies (all, or only third-party cookies) in your browser settings and delete any stored cookies whose names begin with _ga;
install Google's official opt-out add-on for Google Analytics: tools.google.com/dlpage/gaoptout;
use a browser or an extension that blocks tracking tools.

The website can be read without analytics cookies. You may also object to this processing at any time by writing to us (see section 7).

5. Who receives the data

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland — provides Google Analytics and processes analytics data as a processor on our behalf.
The hosting provider and technical subcontractors that run the website's server — name and country to be confirmed. They process data only on our instructions.
Public authorities — only where required by law.

We do not share personal data for advertising and we do not sell it.

6. Transfers outside the European Economic Area

When Google Analytics is used, data may be transferred to Google LLC in the United States. For companies certified under the EU–US Data Privacy Framework, the European Commission has adopted an adequacy decision (Commission Implementing Decision (EU) 2023/1795 of 10 July 2023). Google also relies on the standard contractual clauses adopted by the European Commission (Art. 46(2)(c) GDPR).

7. Your rights

Under the GDPR you have the right:

of access to your personal data and to receive a copy (Art. 15);
to rectification of inaccurate data (Art. 16);
to erasure ("right to be forgotten") (Art. 17);
to restriction of processing (Art. 18);
to data portability where processing is based on consent or a contract and carried out by automated means (Art. 20);
to object to processing based on legitimate interests (Art. 21);
to withdraw consent at any time, without affecting the lawfulness of processing before the withdrawal (Art. 7(3));
to lodge a complaint with a supervisory authority (Art. 77; see section 8).

To exercise your rights, write to fenix [at] ava.com.ua. We will reply without undue delay and in any event within one month; for complex requests this period may be extended by two further months, and we will tell you if so (Art. 12(3)). Exercising your rights is free of charge. If we have reasonable doubts about your identity, we may ask for additional information to confirm it.

8. Complaints to a supervisory authority

You can lodge a complaint with the Slovak supervisory authority:

Úrad na ochranu osobných údajov Slovenskej republiky, Hraničná 12, 820 07 Bratislava 27, Slovenská republika — dataprotection.gov.sk

or with the supervisory authority of the EU Member State where you live, work or where you believe the infringement took place.

9. Is providing data required?

You are not obliged to provide us with personal data. Technical request data is necessary for your browser to open the page. Consent to analytics is voluntary; the website works fully without it. Whether you email us is up to you.

10. Children

The website is not intended to collect data from children, and we do not knowingly collect it. Content about alcohol is intended for adults only (see Health and alcohol).

11. Changes to this policy

We update this policy when the processing on the website changes, in particular once the consent mechanism is launched. The date of the latest version is shown below; we will announce significant changes on this page.

Updated: 2026-10-23