Operational and Public Conduct Policy

Mekomot Slovakia, o.z.

1. Purpose of this document

This policy sets out the basic rules for the operation and public communication of the civic association Mekomot Slovakia, o.z. The aim is to ensure transparency, legal responsibility, and the protection of personal data in accordance with applicable legislation.

2. Political neutrality

• Mekomot Slovakia, o.z. is a non-political and politically neutral civic association.
• The association does not take part in political campaigns and does not comment on the activities of political parties, movements, or politicians.
• The organisation does not issue statements on international political conflicts or on decisions of foreign governments.
• Cooperation with state institutions, municipalities, or international organisations is limited to cultural, historical, and educational purposes.

3. Transparency

• The association keeps accounts in accordance with applicable legal regulations (including Act No. 431/2002 Coll. on Accounting).
• Financial statements / annual accounts are submitted to the Register of Financial Statements in the manner applicable to the relevant type of non-profit accounting entity.
• The association may voluntarily publish annual summaries of its activities, finances, and the use of donations (e.g., on the website or in public updates).
• Partnerships and cooperation are accepted only in line with the association’s non-political and cultural mission.

4. GDPR and personal data protection

4.1 Data controller

The controller of personal data is Mekomot Slovakia, o.z. (as the organiser of activities, communications, and donor/member records).

4.2 Scope of processed data

• first name and surname,
• contact details (email, phone),
• data related to a donation or participation in activities (e.g., date, amount, note),
• for payments: technical data required to confirm the payment (detailed payment data is primarily processed by the payment service/bank).

4.3 Purpose of processing

• record-keeping of donors and members,
• communication with volunteers and donors,
• fulfilment of legal obligations (accounting, tax duties, reporting, where applicable).

4.4 Legal basis for processing

Processing is lawful under Article 6(1) GDPR if at least one of the following applies:

• (a) consent of the data subject (e.g., newsletter),
• (b) compliance with a legal obligation of the controller (e.g., accounting),
• (c) legitimate interest (e.g., fraud prevention, security, protection of legal claims).

Full text of the GDPR: eur-lex.europa.eu

4.5 Third parties (payments, banks, services)

For processing payments and donations, we may use services such as PayPal, Stripe, Wise, or banking institutions. Depending on the specific service, these entities may act as processors or as independent controllers. We recommend reviewing their privacy policies and processing terms.

4.6 Data retention

• accounting records and donation records: in line with statutory retention periods (typically 10 years),
• email communication: proportionate to the purpose (generally up to 3 years unless needed longer),
• data processed on the basis of consent: until consent is withdrawn.

4.7 Rights of data subjects

Right of access, rectification, erasure, restriction of processing, data portability, objection, and the right to lodge a complaint with the Slovak Data Protection Authority.

5. Public communication

• Public communication (website, social media, media) focuses on cultural, historical, and educational topics.
• The association does not provide political commentary or party-political positions.
• External statements (press, media, official announcements) should be consistent with the association’s mission and this document.

6. Responsibility and oversight

• This policy is binding for members, volunteers, and representatives of the association.
• It is reviewed at least once a year or when relevant changes occur.
• Breaches of this policy may result in termination of membership or cooperation.

7. Effective date

This Operational and Public Conduct Policy takes effect on 27/09/2025 and is publicly available on the association’s website.

Updated: 17.10.2025