(especially as regards product shipping and handling, validity of international product guarantees, financial, process services and audits, certification services, IT services and technology)
Before your personal data are transferred to a third party, we at all times conclude a written contract with that party, containing the same safeguards for the personal data processing as our company itself observes in accordance with its legal obligations, or we verify those parties’ compliance with the GDPR and applicable legal regulations regulating personal data protection.
2.5.1. In accordance with applicable legal regulations, our company is entitled, or directly and without your consent, obliged to transfer your personal data to:
Competent state authorities, courts and law enforcement authorities for the purpose of fulfilment of their obligations and for the purpose of enforcing decisions;
Payment services providers where necessary for the reason of prevention, investigation or detection of frauds in the area of payment transactions;
Providers of consumer and other credits, for the purposes of performance of contracts;
Insurance and reinsurance providers, for the purpose of performance of contracts;
Other persons to the extent required by legal regulations, e.g., third parties for the purpose of recovering our claims from clients.
2.5.2. With your consent, on the basis of which we are entitled to handle your personal data to the respective extent, your personal data may be transferred also to entities for the purpose of compliance with legal regulations of our company, conclusion and performance of contracts, offering products and services, protection of rights and legally protected interests of our company, client care.
2.6. Transfer of personal data abroad
Your personal data are processed in the Czech Republic and in other European Union member states or outside the European Union, where entities such as our suppliers, processors and partners (e.g. Apple) are seated, and which share the same data protection standards as the Czech Republic or members of the European Economic Area.
2.7. Period of the processing of personal data
Our company processes clients’ personal data only for a period necessary with the view of the purposes of the processing of such data. We assess on a continuous basis whether there still exists a need to process certain personal data needed for a certain purpose. Where it is determined by us that the data are no longer necessary for any of the purposes for which they have been processed, the data will be destroyed. However, internally, we have already assessed, in relation to certain purposes of personal data processing, a normal useful life of personal data, at the end of which we evaluate with much care the need to process the relevant data for this purpose. In this connection, personal data processed for the purposes of:
(a) performance of contract are processed for the duration of the contractual relationship with the client; in addition, the relevant personal data are generally usable for a ten-year period;
(b) offering of products and services are processed for the duration of the contractual relationship; in addition, the relevant personal data are generally usable for a ten-year period;
(c) client care are processed for the duration of the contractual relationship with the client; in addition, the relevant personal data are generally usable for a ten-year period.
2.8. The right to withdraw consent
This Policy explains why we need your personal data and that we may process your personal data for certain purposes only with your consent. You are not obliged to give consent for us to process your personal data and you have a right to withdraw your consent. Please remember that we are entitled to process certain personal data for certain purposes also without your consent. If, in such case, you withdraw your consent, we will no longer process the appropriate personal data for the purposes requiring the relevant consent, but we may be entitled or even obliged to continue to process the same personal data for other purposes.
If you do not give your consent or withdraw your consent, we may:
(a) modify the availability, scope or conditions of our products or services accordingly, or
(b)refuse to provide you with our products or services if we find that such consent is necessary for the product or service to be provided under the given circumstances.
If you wish to withdraw your consent to the processing of your personal data, please contact us in writing to the e-mail address firstname.lastname@example.org from the e-mail address registered with us.
2.9. Sources of personal data
we obtain clients’ personal data in the following manners especially:
(a) from clients themselves, i.e. directly, e.g. when concluding contracts related to the products or services provided, or indirectly, e.g., when clients use the products and services as such, or when we make information about the products and services to clients, e.g., on the Company’s website, etc.
(b) from publicly available sources (public registers, records or lists);
(c) from persons potentially interested in our products or services in the context of our marketing events and campaigns;
(d) from own activities, specifically by processing and evaluating other personal data of clients.
2.10. Your right to request access to personal data and protection of clients’ rights
If you ask us for information regarding the processing of your personal data, we will provide you with all information as to what data are processed by us about you. For the provision of such information, we are entitled to request a reasonable reimbursement for costs expended in this connection. If you discover or believe that our company or a third party involved in the data processing performs the processing of your personal data in breach with the protection of your private life or the law, in particular, if your personal data are inaccurate, you may: (a) request an explanation from our company or the third party involved in the data processing;
(b) request that the deficiency be rectified, you may require especially that the personal data be rectified or completed; if necessary, the data will be temporarily blocked or destroyed.
If your request is found to be justified, our company or the third party who is involved in the data processing, will rectify the deficiency immediately.
As a client, you at all times have a right to contact the Office for Personal Data Protection.
3. Electronic means of communication and mobile applications
As part of our client care, our company develops technology to enable you to enjoy modern electronic means of communication and mobile applications when using our products. This in particular includes services related to the use of the Internet, social networks and various mobile applications.
Social networks. You may contact us also via various social networks. We use these communication channels mainly as marketing tools and currently, these networks do not serve for provision of our products and services.
5. The Policy
This Policy is valid and effective as of 23.05.2018. The text of the Policy is posted on our company’s website.
Annex No. 1 – Scope of the personal data processed
Identification data - including in particular, the name, surname, permanent residence address, type, number and validity of identity document; for clients who are business natural persons - also ID No. and Tax ID No. Other possible identification data include for example the IP address of the computer used and sets of specific authentication data that we agree to use.
Contact data – name, surname, contact address, telephone number, e-mail address or other similar contact data. Other possible identification data include for example the IP address of the computer used and sets of specific authentication data that we agree to use.
If you withdraw a submitted request for a product or service, we will process the date of withdrawal of the request in addition to the data provided to you before the withdrawal.
Data arising from the performance of obligations from contracts - depending on the nature of the product or service provided, we process data related to the product or service provided. In this category, processing takes place with respect to such personal data as the duration of the contract, duration of the guarantee, serial number of the equipment.
Personal data obtained in connection with the provision of our products and services - these are personal data collected during our interactions and include especially:
(i) data that serve for ensuring the security of communication,
(ii) records of your preferred language for communication, interest expressed by you in a product or service or data regarding your specific requirements provided to us,
(iii) records of the time of purchases
Personal data generated by our activities - these are especially numbers allocated by us to clients/products, data created by the evaluation of your transaction-based behaviour or data provided by you (e.g. for determining whether the conditions for applying for a fee discount have been met), evaluation of a submitted request for products or services or any evaluation necessary for our decision whether or not to offer you a product or service.