Privacy policy

1. Who is responsible

The controller under the EU General Data Protection Regulation (GDPR) and the Slovak Act No. 18/2018 Coll. on the protection of personal data is:

AdMax, s. r. o.
Továrenská 7938/14, 811 09 Bratislava, Slovakia
Company ID (IČO): 52283224 · VAT ID: SK2120972843
Registered in the Business Register of the Municipal Court Bratislava III, section Sro, insert no. 136102/B
Email: info@asiarestart.com

We are not required to appoint a data protection officer. For all data protection questions, please write to the email address above.

2. What data we collect

2.1 Free check (quiz and form)

Your answers: destination, who is moving, planned length of stay, work plans, budget range, age range (only for Malaysia, because the MM2H rules depend on age) and timing. Your contact details: name, nationality, country of residence, email address and, if you write one, your question. Nationality and country of residence are needed because the programmes have different rules for different nationalities.

2.2 Contact form and email

Your name, email address, the content of your message and any later correspondence.

2.3 Visiting the website

Technical data that every browser sends: IP address, date and time of access, pages visited, referring page, browser type and operating system (server log files).

2.4 Cookies and similar technologies

Only if you agree: data about your visit and whether you came via one of our Google ads (see section 7).

Please do not send us health information or copies of identity documents. We do not need them for a first recommendation. Documents for an application are exchanged only between you and the licensed agent.

3. Purposes and legal bases

• Preparing and sending your personal recommendation, answering your messages: Art. 6(1)(b) GDPR (steps taken at your request).
• Passing your details to a licensed agent: your consent, Art. 6(1)(a) GDPR, and for the transfer outside the EU Art. 49(1)(a) GDPR (section 4).
• Settling our referral commission with the agent: Art. 6(1)(f) GDPR, our legitimate interest in being paid for our service (section 5).
• Operating a secure website (server log files): Art. 6(1)(f) GDPR, our legitimate interest in a stable and secure website.
• Storing your cookie choice: technically necessary, § 25(2) TDDDG (Germany) and § 109(8) of the Slovak Electronic Communications Act No. 452/2021 Coll.; Art. 6(1)(c) and (f) GDPR.
• Advertising measurement (Google Ads): your consent, Art. 6(1)(a) GDPR, § 25(1) TDDDG and § 109(8) Act No. 452/2021 Coll.
• Keeping accounting records and defending legal claims: Art. 6(1)(c) and (f) GDPR.

We do not use your data for automated decision-making or profiling within the meaning of Art. 22 GDPR, and we do not send newsletters or advertising emails.

4. Passing your details to a licensed agent

If you tick the consent box, we send your quiz answers and contact details to one licensed agent for the country you are interested in, so that the agent can answer your request. Before that, we tell you the agent’s name and licence number by email. For Thailand these are authorised agents of Thailand Privilege Card Co., Ltd.; for Malaysia, companies holding a valid licence from the Ministry of Tourism, Arts and Culture Malaysia (MOTAC).

The agent receives your data as an independent controller and processes it under its own privacy policy, which it will give you.

Transfer to a country outside the EU: Thailand and Malaysia are not covered by an EU adequacy decision, and no other safeguards under Art. 46 GDPR are in place. This means there may be no independent supervisory authority you can turn to, and your rights may be harder to enforce. The transfer is therefore based solely on your explicit consent, Art. 49(1)(a) GDPR.

Your consent is voluntary. Without it, you still receive our recommendation; we simply do not pass on your details. You can withdraw your consent at any time with effect for the future by email to info@asiarestart.com; we will then also ask the agent to delete your data.

5. Commission settlement

Licensed agents pay us a referral commission when a client we introduced takes up their services. To settle it, the agent tells us whether you became a client and which programme you chose. We use this information only for invoicing and accounting. This does not change your price.

6. Hosting, email and fonts

Our website, our forms and our email run on servers of IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany, which processes data on our behalf under a data processing agreement (Art. 28 GDPR). Form entries are sent from our own server straight to our mailbox; we do not use an external form service. All of this stays in the EU.

The fonts on this website are stored on our own server. Your browser does not connect to Google Fonts or other font services.

This website links to official government and programme websites. When you click such a link, the other website’s privacy policy applies.

7. Cookies, Google Ads and consent

Our website works without advertising cookies. Only if you click “Accept” in our cookie banner do we use Google Ads conversion tracking, to measure whether a visit via one of our ads led to an enquiry. We do not use remarketing and do not create user profiles.

The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google may also process data in the USA; Google LLC is certified under the EU-US Data Privacy Framework (adequacy decision of the European Commission of 10 July 2023).

We use Google Consent Mode v2. Until you agree, the signals “ad_storage”, “ad_user_data”, “ad_personalization” and “analytics_storage” are set to “denied”: no advertising cookies are stored and no data is used for ad personalisation. Google then only receives anonymous signals without cookies.

How Google uses data from websites that use its services: policies.google.com/technologies/partner-sites. Google’s privacy policy: policies.google.com/privacy.

8. Your cookie choices

You can change or withdraw your choice at any time with “Cookie settings” at the bottom of every page. Withdrawing does not affect the lawfulness of processing before the withdrawal.

• Necessary: your cookie choice, saved in your browser for 12 months.
• Advertising (only with consent): Google Ads conversion cookies, for up to 90 days.

9. How long we keep your data

• Enquiries and correspondence: 24 months after our last contact with you, then deleted, unless you ask us to delete them sooner.
• Data needed for commission invoices: as long as the law requires accounting records to be kept, in Slovakia 10 years (Act No. 431/2002 Coll. on Accounting).
• Server log files: only as long as needed for security, then deleted by our hosting provider.
• Spam protection: to block mass submissions of our forms, we store a one-way encrypted (hashed) form of your IP address for at most one hour.
• Proof of your consent: as long as we process data based on it, and afterwards for as long as claims can be made.

10. Your rights

You have the right to:

• access the data we hold about you (Art. 15 GDPR)
• have it corrected (Art. 16) or deleted (Art. 17)
• restrict processing (Art. 18)
• receive your data in a common, machine-readable format (Art. 20)
• object at any time to processing based on our legitimate interest, on grounds relating to your particular situation (Art. 21)
• withdraw any consent at any time with effect for the future (Art. 7(3))

Just write to info@asiarestart.com. We answer within one month. To protect your data, we may ask you to confirm your identity.

You also have the right to complain to a data protection authority, in particular in the EU country where you live or work. The authority responsible for us is the Office for Personal Data Protection of the Slovak Republic (Úrad na ochranu osobných údajov SR), Hraničná 12, 820 07 Bratislava, Slovakia, dataprotection.gov.sk.

11. Security

The whole website is served over an encrypted connection (HTTPS/TLS). Only authorised persons in our company have access to your enquiries, and we protect our systems with appropriate technical and organisational measures.

12. Other points

Do you have to give us your data? No. But without your email address and answers we cannot send you a personal recommendation.

Age: our service is meant for adults. We do not knowingly collect data from people under 18.

13. Changes to this policy

We update this policy when our services or the law change. The current version is always on this page, with the date of the last update at the top.