Privacy Policy for the Provio Service
Controller: VisionEdge s. r. o., 29. augusta 1503/1A, 958 01 Partizánske, Slovak Republic Company ID (IČO): 51962161, Tax ID (DIČ): 2120848521 (not a VAT payer) Registration: Commercial Register of the District Court Trenčín, Section Sro, Insert No. 37109/R Data protection contact: info@visionedge.sk
Version: 1.0 · Effective date: 21 June 2026
1. Introduction
This policy explains how VisionEdge s. r. o. ("we") process personal data in connection with Provio — an accounting bridge for crypto transactions (importing and valuing on-chain transactions, evidence packages, sanctions screening and accounting exports). Processing is carried out in accordance with Regulation (EU) 2016/679 (GDPR) and Act No. 18/2018 Coll.
2. Dual role in processing
2.1 Controller: With respect to data about user accounts, billing and operation of the Service, we are the controller. This is governed by this policy.
2.2 Processor: With respect to personal data contained in the Customer Content (in particular data of clients, counterparties and persons associable with transactions and addresses), we are a processor. The controller is the customer; where the customer (an accountant) processes data on behalf of its own clients, it acts as a processor and we as a sub-processor. The processing is governed by the Data Processing Agreement (DPA).
2.3 Wallet addresses and transaction data may, in certain circumstances, constitute personal data (where they can be linked to a specific person). Special categories of data under Art. 9 GDPR are not to be entered into the Service.
3. What data we process (as controller)
- Account and user data: first name and surname, email, password (in secured form), role (including read-only access), sign-in identifiers.
- Billing and identification data: business name, registered office, Company ID, Tax ID, VAT ID and data needed to issue documents and manage the subscription.
- Technical and operational data: IP address, device and browser data, logs, audit records of actions.
- Communication: the content of communications during support.
4. Purposes and legal bases (as controller)
| Purpose | Legal basis (GDPR) |
|---|---|
| Provision and administration of the Service, account management | Art. 6(1)(b) — performance of a contract |
| Billing and bookkeeping | Art. 6(1)(c) — legal obligation |
| Security, abuse prevention, logs and audit | Art. 6(1)(f) — legitimate interest |
| Improving and supporting the Service | Art. 6(1)(f) — legitimate interest |
We do not carry out marketing communications without a legal basis.
5. Retention period
- Account data and Customer Content: for the duration of the agreement and a reasonable period after termination (export for 30 days — see Terms Art. 11.4).
- Accounting and tax documents on the Provider's side: for the period required by law (usually 10 years).
- Logs and audit records: usually 12 months, unless needed longer for security or evidentiary purposes.
6. Recipients and processors
To provide the Service we use processors with whom we have concluded processing agreements:
| Processor | Purpose | Location |
|---|---|---|
| Hosting provider | hosting of the application and database | [fill in — EU] |
| Email provider | sending transactional emails | [fill in] |
| On-chain and market data source | importing blockchain data and prices (if a third party) | [fill in] |
| Sanctions list provider | inputs for sanctions screening (if a third party) | [fill in] |
Operational note: I have deliberately not named the specific processors (hosting, email, on-chain/price data source, sanctions list source) — before publishing, fill them in according to the actual technical solution, including the region and any SCC. If part of the processing takes place within our own infrastructure, state that.
7. Transfers to third countries
If any processor processes data outside the EEA, we will safeguard the transfer with appropriate safeguards under the GDPR, in particular standard contractual clauses (SCC).
8. Rights of data subjects
You have the right to access, rectification, erasure, restriction of processing, portability, to object to processing based on a legitimate interest, and to withdraw consent. Exercise them at info@visionedge.sk. If your data is processed as part of a customer's Content, please exercise your rights with the relevant customer (the controller). You have the right to lodge a complaint with the supervisory authority:
Office for Personal Data Protection of the Slovak Republic
Hraničná 12, 820 07 Bratislava 27
https://dataprotection.gov.sk
9. Cookies
We use only strictly necessary cookies. Details are set out in the separate Cookie Policy.
10. Security of processing
We apply appropriate technical and organisational measures: encrypted transmission (HTTPS/TLS), secure password storage, security HTTP headers, logical isolation of individual customers' data, access and role management, a content checksum (SHA-256) for the integrity of evidence packages, audit logging, regular encrypted backups, and monitoring.
11. Changes to this policy
We may update this policy when the Service, processors or legislation change. We will inform you of material changes in an appropriate manner.
12. Contact
VisionEdge s. r. o., 29. augusta 1503/1A, 958 01 Partizánske, info@visionedge.sk, https://visionedge.sk