PERSONAL DATA PROCESSING POLICY DURING BUSINESS ACTIVITY

Transcription

1 PERSONAL DATA PROCESSING POLICY DURING BUSINESS ACTIVITY FOR CUSTOMERS, SUPPLIERS, MARKETING, VISITORS OF WEB SITES At the jint stck cmpany NAM system, a.s. having its registered headquarters at the address: U Pšty 1163/13, Havířv Prstřední Suchá, Czech Republic, business ID N: , entered in the Cmpanies Register kept by the Reginal Curt in Ostrava, sectin B, inset 2365, (hereafter als the "Cmpany"), we pay great attentin t persnal data prtectin. And s, in cmpliance with Regulatin (EU) 2016/679 n the prtectin f natural persns with regard t the prcessing f persnal data (hereafter als the "regulatin" r the "GDPR) we have decided t issue this Persnal Data Prcessing Plicy (hereafter the "Plicy"). The purpse f this dcument is primarily t prvide infrmatin abut what persnal data the Cmpany as the cntrller prcesses abut natural persns during its business activities, in what way and t which purpse and fr hw lng, t whm and fr what reasn it may transfer it, and als t prvide infrmatin abut which rights natural persns have in the cntext f the prcessing f their persnal data. The present Plicy applies t the prcessing f persnal data: f ur custmers and service users, representatives f these custmers r cntact persns f custmers, thse interested in ur services r gds, ur suppliers, representatives f these suppliers r cntact persns f suppliers, persns t whm we send cmmercial messages, visitrs t ur web sites, visitrs t ur premises. Hwever, this Plicy des nt apply t the prcessing f persnal data that the Cmpany carries ut as a prcessr fr ther cntrllers. It invlves the prcessing f persnal data f clients and emplyees f users f the Cmpany's services (crprate custmers f the Cmpany r public entities such as municipalities, plice, etc.) such as ONI system, 1Bx / 1Bx clud, NSG, HelpCare and thers. CONTENT: I Persnal data cntrller... 3 II Categries f persnal data Identificatin and cntact data fr cntractual relatins Data abut gds and services and delivery data Payment data Invicing data... 3

2 5 Data frm cmmunicatin between the Cmpany and the custmer r supplier Camera recrdings frm Cmpany premises Data gained during registratin n web sites Ckies and ther technlgies Database f custmers and suppliers Data fr marketing purpses Data gathered during prviding f services... 4 III Purpse and legal basis fr prcessing... 5 IV Persnal data prcessing and strage perid... 7 V Surces f persnal data... 9 VI Recipients f persnal data... 9 VI Means f persnal data prcessing VII Infrmatin abut rights f data subjects in cntext f prcessing Right t access t persnal data Right t rectificatin f inaccurate data Right t bject t persnal data prcessing Right t restrictin f prcessing Right t erasure Right t persnal data transferability Right t withdraw cnsent t the prcessing f persnal data Autmated individual decisin-making, including prfiling Right t apply t Persnal Data Prtectin Office Right t restrict r cancel marketing messages VIII Data prtectin fficer IX CAMERA SYSTEMS OPERATED BY THE COMPANY RECEIVER / CATEGORY OF RECEIVERS OF RECORDS THE PLACE OF PROCESSING, NUMBER AND LOCATION OF CAMERAS CAMERA MODE AND RECORDING ERASURE

3 I PERSONAL DATA CONTROLLER The persnal data cntrller is the Cmpany (fr the Cmpany's identificatin data, see abve). Cntact data, where yu can ask questins, make cmplaints and requests cncerning persnal data prcessing: pstal address: U Pšty 1163/13, Havířv Prstřední Suchá, Czech Republic gdpr@nam.cz Telephne: (+420) WEB: www. II CATEGORIES OF PERSONAL DATA Any infrmatin related t a natural persn wh the Cmpany is capable f identifying cnstitutes persnal data. In the cntext f trading, the Cmpany handles the fllwing types (categries) f persnal data 1 : 1 IDENTIFICATION AND CONTACT DATA FOR CONTRACTUAL RELATIONS Such data is essential fr the cnclusin and perfrmance f a cntract between the Cmpany and yu r the cmpany which yu represent r fr discussins abut such a cntract. This invlves in particular yur academic title, first name and surname, name, business name, date f birth, Business ID N, Tax ID N, address f permanent residence, address f registered headquarters r place f trading, signature etc. It als invlves the academic title, first name and surname, psitin and signature f yur representatives r entrusted persns. We prcess the cntact data s that we can cntact yu if needs be in cnnectin with the cntract, and this cnsists in particular f yur telephne number and address and that f yur representatives r entrusted persns. 2 DATA ABOUT GOODS AND SERVICES AND DELIVERY DATA We prcess data abut which services r gds yu rder frm us and the address t which the gds shuld be delivered. Similarly, we prcess data abut services r gds which we rder frm yu. 3 PAYMENT DATA We prcess the number f yur bank accunt and data frm yur payment card s that we can identify yur payments and s that we knw t where we shuld make payments in yur favur. 4 INVOICING DATA We prcess data such as yur first name and surname, invicing address, data abut purchased, rdered r delivered gds r services and their price - data that is essential s that we can issue billing fr the gds r services, we can cnfirm the shipping ntes and we can cmply with the duty t keep accunts as impsed n us by law. 5 DATA FROM COMMUNICATION BETWEEN THE COMPANY AND THE CUSTOMER OR SUPPLIER 1 Sme persnal data falls int in several categries and s may be repeated several times in the verview. 3

4 This data arises during cmmunicatin assciated with the prvisin f services and gds between the Cmpany and the custmer r supplier. These are recrds f persnal cmmunicatin with the custmer r supplier, written and electrnic cmmunicatin with the custmer r supplier and phne call recrds. 6 CAMERA RECORDINGS FROM COMPANY PREMISES Fr reasns f security and t prtect the legitimate interests f the Cmpany, the cmplex and premises f the Cmpany are cvered by a camera system. The areas where cameras are lcated are always marked with a warning. Vide recrdings are prcessed using the camera system. 7 DATA GAINED DURING REGISTRATION ON WEB SITES This invlves the data yu enter during registratin n ur web sites, such as academic title, first name and surname, name, business name, date f birth, Business ID N, Tax ID N, address f permanent residence, address f registered headquarters r place f trading. 8 COOKIES AND OTHER TECHNOLOGIES We use ckies and ther technlgies t gain infrmatin when the Cmpany web sites are used. These are recrds abut behaviur n the web sites gained frm ckies and ther technlgies in the case f their permitting int the web brwser. This data is prcessed fr the peratin f the Cmpany web sites, measuring f pages' visitr figures and internet advertising. 9 DATABASES OF CUSTOMERS AND SUPPLIERS If we have already made a business cntact with smene, we retain his/her identificatin and cntact data, such as academic title, first name and surname, business name, Business ID N, address f permanent residence, address f headquarters r place f trading, telephne number and address, in ur database. We use this data fr cmmunicatin, perfrming cntracts, cncluding new cntracts, dealing with claims and servicing. 10 DATA FOR MARKETING PURPOSES Fr marketing purpses, we use the database f ur existing custmers and list f persns wh may becme ur custmers in the future. On this list we have their academic title, first name and surname, name, business name, Business ID N, address f permanent residence, address f registered headquarters r place f trading, telephne number and address. We send ut cmmercial messages in the frm f pstal crrespndence, , internet r mbile messages. With regard t the sending f cmmercial messages by t existing custmers f the Cmpany abut the same r similar prducts r services f the Cmpany, this invlves the use f persnal data fr the use f which we d nt need yur cnsent. In ther cases, this data is used n the basis f yur cnsent t the sending f cmmercial messages. 11 DATA GATHERED DURING PROVISION OF SERVICES This cncerns data that are btained during prvisin f services by the Cmpany t its custmers (states, events and data abut the psitins f tracked bjects) such as: HelpCare - a system fr calling help, ensuring peple's safety and preparatin f staff recrds. The primary functin f the system is t call fr help in the event f a life-threatening r ther dangerus situatin. The system als prvides the custmer with an verview f hw the situatin ccurred, when and where it happened and wh and hw it was reslved. TICK Tracker - a prtable GPS tracker that is especially suitable fr tracking varius bjects (vehicles, children, backpacks, valuable assets, etc.). Thanks t its magnetic fastening system 4

5 and small dimensins, it can be placed virtually anywhere. The tracker can then be easily tracked via a mbile applicatin. III PURPOSE AND LEGAL BASIS FOR PROCESSING We nly prcess yur data in the scpe essential fr the relevant purpse fr example s that we can supply r receive gds r prvide r receive a service. This als invlves cases f negtiating a new cntract. Many laws, such as the Accuntancy Act, the VAT Act, the Incme Tax Act etc., impse an bligatin n us t prcess yur data. The scpe f the prcessed data depends n the purpse f prcessing. Fr certain purpses it is pssible t prcess data directly n the basis f a cntract, the legitimate interest f the Cmpany, r n the basis f a law, but fr ther purpses nly n the basis f yur cnsent. We d nt need yur cnsent fr the prcessing f persnal data fr the purpse f perfrmance f a cntract r fr perfrmance f legal bligatins fr the reasn f the legitimate interests f the Cmpany. Fr this activity the persnal data is prcessed in the scpe necessary t achieve these purpses and fr the perid necessary fr their fulfilment. Then the persnal data is erased r annymised. This invlves, in particular, the fllwing purpse and legal bases, divided up accrding t the individual categries f persnal data: Categries f persnal data 2 Purpse Legal basis fr prcessing 1 Identificatin and cntact data fr cntractual relatins 1 Identificatin and cntact data fr cntractual relatins 2 Data abut gds and services and delivery data 3 Payment data 4 Invicing data prceedings cncerning cnclusin f cntract perfrmance f cncluded cntract delivery r receipt f gds, prvisin r receipt f services, reslving claims, invicing 3 Payment data identificatin and prving f rigin f payments prcessing is essential in rder t perfrm measures adpted befre the cnclusin f the cntract at the request f this data subject prcessing is essential fr perfrmance f a cntract where the data subject is a cntracting party prcessing is essential fr the purpses f the legitimate interests f the Cmpany and fr cmpliance with legal bligatins applying t the Cmpany - the duty t keep accunts. The interventin in the rights f the data subject is cmmensurate with the given purpse. Withut the specified persnal data, the Cmpany wuld be incapable f perfrming business activities in cmpliance with the legal system, and a data subject (custmer) wuld nt be able t receive gds r a service frm the Cmpany. 2 The numbers f the persnal data categries given in this clumn crrespnd t the numbers f the categries given in article II f this Plicy. 5

6 4 Invicing data issue f accunting r tax dcument, keeping f accunts, payment f tax 10 Data fr marketing purpses sending f cmmercial messages by t existing custmers f the Cmpany abut the same r similar prducts r services f the Cmpany 10 Data fr marketing purpses ther than the afrementined marketing f prducts r services 1 Identificatin and cntact data fr cntractual relatins 2 Data abut gds and services and delivery data 3 Payment data 4 Invicing data 5 Data frm cmmunicatin between the Cmpany and the custmer r supplier telemarketing recvery f receivables, prtectin against claims f ther persns prcessing is essential fr cmpliance with legal bligatins applying t the Cmpany - the duty t keep accunts, the duty t pay tax prtectin f the Cmpany's legitimate interests. The legitimate interest f the Cmpany is cnfirmed by the fact that this use f data is permitted by the prvisin f article 16 paragraph 2 f the REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL cncerning the respect fr private life and the prtectin f persnal data in electrnic cmmunicatins the data subject granted their cnsent t the prcessing f their persnal data fr ne r mre specific purpses prtectin f the Cmpany's legitimate interests. The interventin in the rights f the data subject is cmmensurate with the given purpse. Withut the specified persnal data and its handver, fr example t a legal representative and curt, the Cmpany wuld nt be able t assert its claims r defend itself against suits and claims f ther parties. 6 Camera recrdings frm Cmpany premises prtectin f prperty preventing the incidence f damage recvery f receivables, prtectin against claims f ther persns prtectin f the Cmpany's legitimate interests The interventin in the rights f the data subject is cmmensurate with the given purpse. The cameras nly cver cmmn spaces and the recrdings are kept fr 1 week. The camera system als prtects the prperty f data subjects brught nt the Cmpany premises. 7 Data gained during registratin n web sites 8 Ckies infrmatin gained using ckies placed by the Cmpany use f Cmpany web sites implementatin f transfer f electrnic cmmunicatin, r fr prvisin f service via Cmpany web sites, r prcessing is essential in rder t perfrm measures adpted befre the cnclusin f the cntract at the request f this data subject prtectin f the Cmpany's legitimate interests The legitimate interest f the Cmpany is cnfirmed by the fact that this use f data is permitted by the prvisin f article 8 6

7 8 Ckies infrmatin gained using ckies placed by third parties (Ggle etc.) 9 Database f custmers and suppliers 11 Data gathered during prvisin f services fr measuring the traffic n Cmpany web sites internet advertisement cmmunicatin, perfrming cntracts, cncluding new cntracts, dealing with claims and servicing prvisin f services t custmers paragraph 1a), c), d) f the REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL cncerning the respect fr private life and the prtectin f persnal data in electrnic cmmunicatins the data subject granted their cnsent t the prcessing f their persnal data fr ne r mre specific purpses using the internet brwser's settings article 8 paragraph 1b) OF THE REGULATION OF THE EUROPEAN PARLIAMENT AND THE COUNCIL cncerning the respect fr private life and the prtectin f persnal data in electrnic cmmunicatins prtectin f the Cmpany's legitimate interests The interventin in the rights f the data subject is cmmensurate with the given purpse. Withut the specified persnal data, the Cmpany wuld nt be capable f perfrming the business activity and the data subject wuld nt be able t achieve the reslutin f a claim, prvisin f servicing services. prcessing is essential fr perfrmance f a cntract where the data subject is a cntracting party IV PERSONAL DATA PROCESSING AND STORAGE PERIOD We use yur data and keep it nly fr the perid abslutely essentially required f us by legal regulatins r which we need t prtect ur rights. We have internal archiving rules cnfigured that ensure that we d nt hld n t data lnger than we are authrised t. In general terms we are bliged t stre basic data and data abut prducts and services n the basis f legislatin, fr example accuntancy acts r tax acts. Fr example, we keep invices fr 10 years frm the end f the tax perid in which their issue ccurred. Due t the need t prve the legal basis fr the issue f invices, cntracts are als kept fr 10 years frm the end f the cntract. We keep data fr a perid f 3 5 years fr the needs f ur legitimate interests, in particular fr the eventuality that we wuld have t submit evidence in a curt case, this with regard t the perids f limitatin accrding t the current Civil Cde. If we use the data n the basis f yur cnsent, we d s nly fr the perid fr which this cnsent lasts, unless we have ther legal grunds fr it. The table belw cntains the specific perids fr the prcessing f individual categries f persnal data fr individual purpses. 7

8 Categries f persnal data 3 Purpse Perid f prcessing - keeping 1 Identificatin and cntact data fr cntractual relatins prceedings cncerning cnclusin f cntract 3 years frm the end f cntract prceedings 1 Identificatin and cntact data fr cntractual relatins 1 Data abut gds and services and delivery data 2 Payment data 3 Invicing data perfrmance f cncluded cntract delivery f gds, prvisin f services, reslutin f claims, invicing 3 Payment data identificatin and prving f rigin f payments 4 Invicing data issue f accunting r tax dcument, keeping f accunts, payment f tax 10 Data fr marketing purpses sending f cmmercial messages by t existing custmers f the Cmpany abut the same r similar prducts r services f the Cmpany 10 Data fr marketing purpses ther than the afrementined marketing f prducts r services 10 years frm the end f the validity f the cntract, 10 years frm the end f the accunting perid which the dcument cntaining the persnal data cncerns 10 years frm the end f the accunting perid which the dcument cntaining the persnal data cncerns 10 years frm the end f the accunting perid which the dcument cntaining the persnal data cncerns 3 years frm the last prvisin f ur service r purchase f ur gds fr the perid fr which cnsent had been granted t us legitimately - as standard 3 years 1 Identificatin and cntact data fr cntractual relatins 2 Data abut gds and services and delivery data 3 Payment data 4 Invicing data 5 Data frm cmmunicatin between the Cmpany and the custmer recvery f receivables, prtectin against claims f ther persns we keep the actual cnsent and change r withdrawal f cnsent fr the reasn f ur legitimate interests fr the entire duratin f cnsent and fr 5 years after it has expired 10 years frm the end f the accunting perid which the dcument cntaining the persnal data cncerns. If the guarantee perid r claims prceedings are lnger, the Cmpany keeps dcuments and data fr the duratin f this perid r as lng as these prceedings last. If the dcument applies t an as yet unsettled debt r nt 3 The numbers f the persnal data categries given in this clumn crrespnd t the numbers f the categries given in article II f this Plicy. 8

9 6 Camera recrdings frm Cmpany premises 7 Data gained during registratin n web sites 8 Ckies infrmatin gained using ckies placed by the Cmpany 8 Ckies infrmatin gained using ckies placed by third parties (Ggle etc.) preventing the incidence f damage recvery f receivables, prtectin against claims f ther persns use f Cmpany web sites implementatin f transfer f electrnic cmmunicatin, r fr prvisin f service via Cmpany web sites, r fr measuring the traffic t Cmpany web sites internet advertisement perfrmed undertaking, the Cmpany will keep the dcuments and data up t the end f the first accunting perid fllwing the accunting perid in which the debt was settled r the undertaking was perfrmed. fr a maximum f 7 days frm the date f vide recrding. fr duratin f registratin fr perid given in Infrmatin abut use f ckies. fr perid given in Infrmatin abut use f ckies. 9 Database f custmers and suppliers cmmunicatin, perfrming cntracts, cncluding new cntracts, dealing with claims and servicing 10 years frm the end f perfrmance f cntract If the guarantee perid r claims prceedings are lnger, the Cmpany keeps this data fr the duratin f this perid r as lng as these prceedings last. 12 Data gathered during prvisin f services prvisin f services t custmers 10 years frm event lgging V SOURCES OF PERSONAL DATA We prcess data which we have received frm yu and als data frm publicly accessible surces and registers, such as Trade Registers and data frm third parties. VI RECIPIENTS OF PERSONAL DATA The Cmpany may transfer yur persnal data t ther persns (recipients f persnal data) if the Regulatin r ther legislatin permits. These recipients may have dual status: 1. During its activities the Cmpany uses the expert and specialised services f third parties. If these suppliers prcess persnal data fr the Cmpany in the sense f the Regulatin, they have the status f persnal data prcessrs and prcess the persnal data nly n the basis f the cntract and accrding t the instructins frm the Cmpany and they must nt use it in any ther way. 9

10 2. If the recipients prcess persnal data fr themselves (they have designated resurces and purpses f prcessing), they have the status f independent persnal data cntrllers. Yur persnal data may be passed n t these recipients: shippers, cmpanies managing and recvering utstanding receivables, legal representatives, ntaries, bailiffs, auditrs, banks prviding the Cmpany bank accunts, insurance cmpanies that are the Cmpany's insurers, Cmpany sales representatives. IT systems administratrs (K2 admitec s.r., MILK COMPUTERS s.r.., eway System s.r.., RON Sftware, spl. s r..), internet advertising prviders, service prviders, We select each subject carefully. Cmpanies with their registered headquarters in the territry f the Czech Republic r in an EU Member State may be recipients f persnal data. We d nt pass n yur persnal data t recipients and prcessrs utside the territry f the Eurpean Unin. In the cntext f perfrming its statutry bligatins the cmpany als passes n persnal data t administrative bdies and authrities designated by valid legislatin because sme public authrities and ther rganisatins are authrised t require infrmatin abut yu. These are in particular curts, the Plice f the Czech Republic and thers. We therefre nly prvide data if the law permits authrisatin t demand this data. VI MEANS OF PERSONAL DATA PROCESSING The Cmpany prcesses persnal data manually (n paper) and autmatically via IT systems. VII INFORMATION ABOUT RIGHTS OF DATA SUBJECTS IN THE CONTEXT OF PROCESSING We prcess yur data transparently, prperly and in cmpliance with the law. Yu have a right t access t yur data, t explanatins, and ther rights if yu feel that the prcessing is nt crrect. Yu can assert all f yur rights, bjectins and requirements in the methds as shwn belw (naturally with the exceptin f the right t ldge a cmplaint with the Persnal Data Prtectin Office, which yu can nly assert at their ffice): 1. by letter delivered t the address f the Cmpany's registered headquarters 2. by t the address: gdpr@nam.cz 3. via the frm n the internet site f the Cmpany YOU MAY ALSO CONTACT THE COMPANY'S PERSONAL DATA PROTECTION OFFICER REFERRED TO IN PART VIII. OF THIS POLICY. If yu assert any f yur rights, and we have reasnable dubts abut yur identity, we can ask fr the prvisin f additinal infrmatin essential fr identity cnfirmatin. If yu assert a right, request r bjectin and yur request is justified, we will adpt measures cmmensurate with it withut delay and at the latest within ne mnth f the delivery f yur request. 10

11 Otherwise in the same perid we will infrm yu f the reasns fr nt adpting the measure and abut the pssibility t ldge a cmplaint with the supervisry authrity and t apply fr judicial redress. This perid can be extended by a further tw mnths if needs be and with regard t the cmplexity and number f requests. In such a case we will infrm yu f any extensin within ne mnth frm receiving the request alng with the reasns fr this deferral. If yu submit the request in electrnic frm, we will als prvide yu with infrmatin in electrnic frm if pssible, unless yu request anther methd. Infrmatin and all annuncements and acts are prvided and perfrmed free f charge. If yur requests are evidently unjustified r excessive, we may require a cmmensurate fee frm yu reflecting the administrative csts assciated with the prvisin f the required infrmatin r annuncements r perfrmance f required acts, r we may refuse t accede t the request. This cncerns the fllwing rights: 1 RIGHT TO ACCESS TO PERSONAL DATA If yu ask us, yu will receive cnfirmatin frm us abut whether we prcess yur persnal data, and if s, als: - a cpy f yur persnal data that we have, - infrmatin abut: the purpses fr which we prcess it, categries f prcessed persnal data, recipients t whm yur persnal data was r will be made accessible, planned perid f prcessing (keeping) f yur persnal data, the existence f the right t demand f us rectificatin r erasure f yur persnal data, restrictin f its prcessing r t bject t this prcessing, the right t ldge a cmplaint with a supervisry authrity, all available infrmatin and abut the persnal data surce if we did nt btain it frm yu, whether autmatic decisin-making, including prfiling, is taking place, suitable guarantees shuld we send yur persnal data utside the EU (which we d nt hwever d). 2 RIGHT TO RECTIFICATION OF INACCURATE DATA Yu have the right t warn us f inaccurate, utdated r incmplete persnal data. Naturally in such a case we will rectify it. Until we verify the accuracy f yur data, we will restrict its prcessing (see pint 4 belw). With regard t the purpses fr which yur data is prcessed, yu als have the right fr us t cmplete incmplete data. 3 RIGHT TO OBJECT TO PERSONAL DATA PROCESSING Yu may bject at any time t the prcessing f yur persnal data which we use fr the reasn f ur legitimate interest. Until such time as it is verified that we have serius legitimate reasns fr the prcessing f yur persnal data, we restrict its prcessing, unless such prcessing is necessary fr the establishment, exercise r defence f legal claims. If it is seen that we d nt have reasns fr the prcessing f yur persnal data, we will erase yur persnal data, unless yu require its preservatin. 11

12 At any time, yu can bject t the prcessing f yur persnal data which we prcess fr the reasn f direct marketing and we will terminate the use f yur persnal data fr these purpses. 4 RIGHT TO RESTRICTION OF PROCESSING There are sme cases where we are bliged t restrict the prcessing f yur persnal data. This means that yur persnal data will be saved with us and we will nt be able t handle it in any way unless yu give us cnsent t it r it is essential fr the establishment, exercise r defence f legal claims r fr the reasn f prtectin f the rights f anther natural r legal persn. We are bliged t start restricting the prcessing f persnal data if: - yu cntest the accuracy f the persnal data, fr the perid enabling us t verify the accuracy f the persnal data; - it becmes evident that the prcessing f yur persnal data is unlawful, and yu reject its erasure, and instead demand frm us a restrictin f its use; - we n lnger need yur persnal data, but yu ask us t keep it fr the establishment, exercise r defence f legal claims. - yu bject t the prcessing f yur persnal data fr the purpses f ur legitimate interests, until it is verified whether ur legitimate reasns fr the prcessing f yur persnal data verride yur legitimate reasns fr this data t be erased. 5 RIGHT TO ERASURE Yu have the right t erasure f persnal data that applies t yu if: - yur persnal data is n lnger necessary fr the purpses fr which it was gathered r therwise prcessed; - yu withdraw the cnsent n the basis f which the data was prcessed and n ther legal grunds fr prcessing exist; - yu bject t the prcessing f yur persnal data fr the purpses f ur legitimate interests and it becmes evident that ur reasns fr prcessing are nt serius; - yu bject t the prcessing f persnal data fr direct marketing; - the persnal data was prcessed by us unlawfully; - the persnal data must be erased fr cmpliance with a legal bligatin that the law impses n us; - the persnal data was gathered in the cntext f an ffer f infrmatin t scial services pertaining t a child. But we pint ut that there are cases where we d nt have an bligatin t erase yur persnal data (even if ne f the abve cnditins is met), fr example if we need the data fr the establishment, exercise r defence f legal claims. 6 RIGHT TO PERSONAL DATA TRANSFERABILITY If we prcess yur persnal data autmatically (i.e., using infrmatin technlgy) n the basis f a cntract r yur cnsent, and yu ask us fr it, we will transmit, t yu, yur persnal data that yu have prvided t us in a structured, cmmnly-used and machine-readable frmat. If yu want, we will transmit this data t anther cntrller wh yu designate (if technically feasible). If thrugh the exercise f this right there culd be an infringement f the rights and freedms f third parties, it wuld nt be nt pssible t cmply with yur request. 7 RIGHT TO WITHDRAW CONSENT TO THE PROCESSING OF PERSONAL DATA 12

13 In cases where we need yur cnsent fr the prcessing f yur data, yu have the authrity t withdraw this cnsent at any time. Withdrawal f cnsent has n impact n the prcessing f yur data fr the perid fr which this cnsent was validly granted, nr n the prcessing f yur data fr ther legal grunds if they are applied (fr example, cmpliance with legal bligatins r fr the purpses f ur legitimate interests). 8 AUTOMATED INDIVIDUAL DECISION-MAKING, INCLUDING PROFILING Yu have the right nt t be subject t a decisin based slely n autmated prcessing, including prfiling, which wuld prduce legal effects cncerning yu r wuld similarly significantly affect yu. The Cmpany des nt perfrm autmated decisin-making withut the influence f human evaluatin f the legal effects fr data subjects. 9 RIGHT TO APPLY TO PERSONAL DATA PROTECTION OFFICE If yu feel that the regulatin r sme ther law has been breached by the prcessing f yur persnal data, yu have the right t apply t the Persnal Data Prtectin Office ( and ldge a cmplaint with it. 10 RIGHT TO RESTRICT OR CANCEL MARKETING MESSAGES If yu have granted us cnsent fr marketing, r fr sme ther reasn cmmercial ffers are sent t yu frm us, yu can withdraw yur cnsent at any time r unsubscribe frm the sending f ffers in the fllwing ways: ur cmmercial messages include a direct ptin t stp the future sending f them, if yu n lnger wish us t telephne yu, tell us during a call, yu can als infrm us in at ur branch r in writing that yu n lnger wish t receive ffers. We wuld like t pint ut that if yu restrict marketing, we may still cntact yu fr the purpses f servicing, claims and the prvisin f services which yu have rdered. VIII DATA PROTECTION OFFICER The cmpany has appinted a Data Prtectin Officer (the DPO ). DPO s cntact details: Mgr. Richard Dlák tel. (+420) mail: richard.dlak@nam.cz IX CAMERA SYSTEM OPERATED BY THE COMPANY Categries f persnal data prcessed by the Cmpany's camera system, the purpses f this prcessing, time-keeping recrds, cntrller's identificatin and cntact details are listed in the previus articles f this Plicy. Additinal infrmatin abut the Cmpany s camera system: 1 RECEIVERS / CATEGORY OF RECEIVERS OF RECORDS Recrds frm the camera system are nly disclsed in cases where the Cmpany is required t d this by law r n the basis theref (disclsure f data t law enfrcement authrities fr the purpse f infringement prceedings, etc.) r if permitted by law, and at the same time it is necessary t prtect the legitimate interests f the Cmpany. 13

14 2 THE PLACE OF PROCESSING, NUMBER AND LOCATION OF CAMERAS The camera system and recrds taken frm it are lcated and prcessed at the lcatin f the Cmpany's headquarters. A descriptin f camera lcatin is available frm the secretariat at the Cmpany headquarters. 3 CAMERA MODE AND RECORDING ERASURE After the retentin perid has elapsed, the recrds are erased by transcriptin in the lp. Camera Mde: Cntinuus. 14