Privacy Policy
How Agmeno handles personal data
This Privacy Policy explains how FlockHR s. r. o., operating under the Agmeno brand ("Agmeno", "we", "us" or "our") collects, uses, stores and otherwise processes personal data in connection with our website, business development activities, client and supplier relationships, and other interactions described below. We process personal data in accordance with Regulation (EU) 2016/679 (GDPR), applicable Slovak data protection law and other applicable privacy rules.
1. Scope of this Policy
This Policy applies to personal data relating to:
- visitors to agmeno.com and other Agmeno web pages that link to this Policy;
- people who contact us, request information, book a call or discuss potential cooperation;
- employees, representatives and contact persons of clients, prospects, suppliers and partners;
- business contacts identified through professional or publicly available sources for legitimate B2B business development;
- people who apply to work with Agmeno, including independent HR specialists, where the relevant collection form or process refers to this Policy; and
- other individuals whose data we process as an independent controller in connection with our business.
When Agmeno processes personal data strictly on behalf of a client under a data processing agreement, the client may be the controller for that processing and the client's privacy notice may apply. This Policy does not replace project-specific candidate privacy information, data processing agreements or contractual privacy terms where those are required.
2. Personal data we may collect
| Category | Examples |
|---|---|
| Identity and business contact data | Name, surname, job title, employer, business email address, business telephone number, professional profile or account information. |
| Communication and enquiry data | Messages, meeting requests, call notes, information submitted through forms, correspondence and records of our business interactions. |
| Business development and prospecting data | Company affiliation, role, professional experience, publicly available professional information, business contact details, source of the information, outreach history, opt-out status and our internal qualification notes. |
| Website and technical data | IP address, device and browser information, timestamps, page activity, security logs, cookie or similar identifiers and consent preferences. |
| Client, supplier and contractual data | Contact details, role in the relationship, contractual correspondence, billing-related contact information, access permissions and project communications. |
| Talent / HR specialist data | CV or profile information, experience, skills, languages, location, availability, project preferences, professional references, rates or commercial preferences where relevant, project history and quality feedback. |
| Recruitment-related data | Candidate profile and recruitment-process information where Agmeno acts as controller or where this Policy is expressly referenced. Project-specific notices may provide additional information. |
3. Where we obtain personal data
We may obtain personal data:
- directly from you, including through our website, email, meetings, forms or contractual interactions;
- from your employer, colleague, client, referral source or other business contact;
- from publicly available professional sources, company websites, professional networks, public directories, conference or event information, corporate registers and similar legitimate sources;
- from business data providers or service providers used for contact verification, company research or business development, subject to applicable law and contractual restrictions; and
- automatically from our website or IT systems through logs, cookies and similar technologies.
The fact that information is publicly available does not remove our obligations under data protection law. We use public-source data only where we have an appropriate legal basis and for defined business purposes.
4. Why we process personal data and our legal bases
| Purpose | Legal basis under GDPR |
|---|---|
| Responding to enquiries, arranging calls, preparing proposals and taking steps requested before a contract | Article 6(1)(b) where the individual is party to the contract or requested pre-contractual steps; otherwise Article 6(1)(f) - our legitimate interest in responding to business enquiries and developing business relationships. |
| Providing and administering services, managing client/supplier relationships and project communications | Article 6(1)(b) where applicable; Article 6(1)(f) for legitimate business administration; Article 6(1)(c) where processing is necessary to comply with a legal obligation. |
| B2B business development and relevant direct marketing to professional contacts | Article 6(1)(f) - our legitimate interest in identifying and contacting organisations that may reasonably benefit from our services, balanced against the rights of the individual. Where consent is legally required, Article 6(1)(a). |
| Maintaining prospecting records, recording opt-outs and avoiding repeated or irrelevant outreach | Article 6(1)(f) - legitimate interests in efficient business development, accountability and respecting objections. |
| Operating, securing and improving our website and IT systems | Article 6(1)(f) - legitimate interests in security, fraud prevention, service integrity, diagnostics and improvement. |
| Analytics, preference and marketing technologies that are not strictly necessary | Article 6(1)(a) - consent, together with applicable electronic communications rules. You may withdraw consent at any time. |
| Assessing applications from prospective employees or independent HR specialists and managing a professional network | Article 6(1)(b) for requested pre-contractual steps; Article 6(1)(f) for legitimate recruitment and network management interests; consent where we specifically ask to retain a profile for future opportunities. |
| Complying with accounting, tax, legal, regulatory, audit and dispute-related obligations | Article 6(1)(c) - legal obligation; and Article 6(1)(f) - establishment, exercise or defence of legal claims and protection of our rights. |
5. B2B prospecting and direct marketing
Agmeno is a B2B service provider. We may identify professional contacts at organisations that reasonably match our target market and contact them about Agmeno services where permitted by applicable law. We seek to use professional contact details, keep outreach relevant to the recipient's role and organisation, and provide a simple way to object or opt out.
You may object at any time to processing for direct marketing. If you do so, we will stop using your personal data for that purpose. We may retain a minimal suppression record (for example, your business email address and opt-out status) where necessary to ensure that your objection continues to be respected.
6. Is providing personal data mandatory?
You are generally not required to provide personal data merely to browse our website. Certain information may, however, be necessary for us to respond to an enquiry, assess a proposed cooperation, provide services, comply with legal obligations or enter into a contract. If required information is not provided, we may be unable to proceed with the relevant request or relationship.
7. Who may receive personal data
We may disclose personal data only where appropriate and proportionate, including to:
- authorised Agmeno personnel and contractors who need the information for their role;
- hosting, website, cloud, communication, CRM, analytics, security, document management, accounting and other technology or professional service providers;
- clients, potential clients, HR specialists, suppliers or partners where disclosure is necessary for an agreed or requested business purpose and legally permitted;
- professional advisers such as lawyers, accountants, auditors and insurers;
- public authorities, regulators, courts or law-enforcement bodies where required by law or necessary to protect legal rights; and
- a purchaser, investor or successor in connection with a corporate transaction, subject to appropriate confidentiality and legal safeguards.
We do not sell personal data to data brokers or advertisers.
8. International transfers
Some service providers or recipients may process personal data outside the European Economic Area (EEA). Where a transfer is subject to GDPR and the destination is not covered by an adequacy decision, we use an appropriate transfer mechanism where required, such as the European Commission's Standard Contractual Clauses, together with supplementary safeguards where appropriate. You may contact us for information about the safeguards relevant to a particular transfer.
9. How long we keep personal data
We keep personal data only for as long as reasonably necessary for the relevant purpose, taking into account legal, contractual, operational and dispute-related requirements. As a general framework:
| Data / context | Typical retention approach |
|---|---|
| General enquiries and unsuccessful commercial discussions | Up to 24 months after the last meaningful interaction, unless a longer period is justified by an ongoing matter or legal need. |
| B2B prospecting records | Normally reviewed and refreshed periodically and retained for up to 24 months after the last verification or meaningful interaction. Suppression records may be retained longer where needed to honour an objection. |
| Active client, supplier and partner relationships | For the duration of the relationship and afterwards for the period necessary to meet legal, accounting, limitation and dispute-related requirements. |
| Applicant / HR specialist profiles | For the relevant selection or cooperation process. If we wish to retain a profile for future opportunities beyond that process, we will rely on an appropriate legal basis and communicate the applicable period. |
| Security and technical logs | Normally up to 12 months, unless a security incident, investigation or legal requirement justifies longer retention. |
| Cookie data | According to the duration specified in our Cookie Settings and Cookie Policy. |
10. Your rights
Subject to the conditions and limitations in applicable law, you may have the right to:
- Access your data. Obtain confirmation whether we process your personal data and receive access to it.
- Correct your data. Ask us to correct inaccurate or incomplete personal data.
- Erase your data. Ask us to delete personal data in circumstances provided by law.
- Restrict processing. Ask us to restrict processing in certain circumstances.
- Object. Object to processing based on legitimate interests. You have an absolute right to object to processing for direct marketing.
- Data portability. Receive certain data in a structured, commonly used and machine-readable format where the legal requirements are met.
- Withdraw consent. Withdraw consent at any time where processing is based on consent, without affecting processing that was lawful before withdrawal.
- Complain. Lodge a complaint with a competent supervisory authority, in particular the Office for Personal Data Protection of the Slovak Republic.
To exercise your rights, contact us at contact@agmeno.com. We may request information reasonably necessary to verify your identity and protect personal data from unauthorised disclosure.
11. Automated tools and profiling
We may use software or AI-assisted tools to organise information, prioritise business prospects, identify relevant opportunities, support project matching or assist internal decision-making. Unless we inform you otherwise in a specific context, we do not make decisions based solely on automated processing that produce legal effects or similarly significant effects on you. Human review remains part of material business and project decisions where appropriate.
12. Cookies and similar technologies
Our website may use cookies, local storage, pixels or similar technologies. Strictly necessary technologies may be used without consent where permitted by law. Optional analytics, preference or marketing technologies are used only in accordance with applicable consent requirements. Please see our Cookie Policy and the Cookie Settings available on our website.
13. Security
We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. No internet-based system can be guaranteed to be completely secure, and users should also take reasonable precautions when communicating or sharing information online.
14. Children
Our website and B2B services are not directed to children. We do not knowingly use the website to solicit personal data from children. If you believe that a child has provided personal data to us inappropriately, please contact us.
15. Third-party websites
Our website may contain links to third-party websites or services. Their privacy practices are governed by their own policies. Agmeno is not responsible for the privacy or security practices of third parties that we do not control.
16. Changes to this Policy
We may update this Privacy Policy to reflect changes in our services, technology, business practices or legal requirements. The current version will be published on our website with the updated date. Where a change materially affects how we process personal data, we will provide additional notice where required by law.
17. Contact and complaints
Questions, requests or objections relating to privacy can be sent to contact@agmeno.com.
You also have the right to lodge a complaint with the Office for Personal Data Protection of the Slovak Republic (Úrad na ochranu osobných údajov Slovenskej republiky), Galvaniho 7/B, 821 04 Bratislava, Slovak Republic, or with another competent supervisory authority where applicable.