We would like to inform you about how we, i.e. Organizační složka Sabbiadoro Gestioni s.r.l unipersonale (hereinafter referred to as “we” or “our company”), process your personal data in connection with the performance of our business activity.
The purpose of this communication is, in particular, to provide you with information about what personal data we collect, how we handle it, what sources we use to obtain it, what purposes we use it for, who we may provide it to, where you can receive information about your personal data, and what individual rights you have in the area of personal data protection. When processing personal data, we comply with generally binding legal regulations, and the processing of personal data is always carried out only to the extent determined by the particular service and/or purpose of the processing.
Please become acquainted with the content of this communication. We will be happy to answer all your questions, if any, at our registered office at Krakovská 1338/10, 110 00 Praha 1, at firstname.lastname@example.org and/or +420 774598866.
You can also contact our Data Protection Officer, Mr Ben Messaud, at email@example.com or at +420 774598866.
Given its business activity, our company is obliged to process certain personal data, especially for the purposes of meeting legal and contractual obligations. In this regard, we could not provide you with our products/services unless you provide us with your personal data.
We also process your personal data beyond our obligations, for the purposes of caring for you and our other clients to ensure that we can further develop our business relationships and to address you with targeted offers of our products/services. In order to do so we need to obtain your consent. With regard to the focus of our products/services, the age maturity limit for giving valid consent to the processing of personal data without the consent of the data subjects’ legal representatives will be respected.
I.1. Principles of the processing of personal data
When processing your personal data, we follow and respect the highest possible standards of personal data protection, and we particularly adhere to the following principles:
(a) we always process your personal data for a purpose that is clearly and comprehensibly determined, using the means determined, in the manner determined, and only for such time as is necessary for the purposes of its processing; we only process accurate personal data of our clients and ensure that the processing of such data complies with the determined purposes and is necessary to meet these purposes;
(b) we protect your personal data as confidential information; therefore, we process our clients’ personal data in a manner that ensures the highest possible security of such data and that prevents any unauthorized or accidental access to, change, destruction or loss, unauthorized transfers, other unauthorized processing and other misuse of clients’ personal data;
(c) we always inform you, in a comprehensible manner, about the processing of your personal data and about your entitlement to accurate and complete information about the circumstances of such processing, as well as about other of your related rights;
(d) we have set and follow appropriate technical and organizational measures in our company to ensure a level of security corresponding to any potential risks; all persons who come into contact with the clients’ personal data are obliged to observe confidentiality about any information obtained in connection with the processing of such data.
II.1. Information about the controller
The controller of your personal data is our company, i.e. Organizační složka Sabbiadoro Gestioni s.r.l unipersonale, with its registered office at Krakovská 1338/10, 110 00 Praha 1, ID 02366801,, a company registered in the Commercial Register kept by the Municipal Court in Prague, File No. A, 76354
II.2. Purposes of processing and the legal basis for processing
II.2.1. Processing of your personal data without your consent
These are usually situations in which you are obliged to give us certain personal data as a condition to be provided with our product/service or, as the case may be, in which we are entitled to process your personal data obtained in another way.
(a) We are entitled by law to process your personal data without your consent for the following purposes to comply with our legal obligations, in particular:
(i) to prevent any damage to our company’s assets;
(ii) to prevent any fraudulent behaviour to which our company may be exposed;
(iii) to meet any potential obligation in identifying and inspecting the client under the Act on Certain Measures against the Legalization of Proceeds from Crime and the Financing of Terrorism;
(iv) to meet the identification obligation in relation to the client under the Aliens Residence Act.
(b) Conclusion or performance of a contract with you:
This particularly concerns the actual implementation of a contractual relationship or other performance of a contract between our company and you. Personal data is needed, inter alia, to enable the contractual relationship to be executed without undue legal risks, including negotiation about the conclusion of or change to the contract with you.
(c) Protection of rights and legitimate interests, in particular for the following:
(i) protecting the rights and legitimate interests of our company, recovering claims, implementing safeguards or other assertion of claims, developing the services provided;
(ii) negotiations with any parties interested in assignment of our company’s claim concerning a client or in any other form of transfer or handover of a claim, including the related implementation, and other follow-up negotiations with third parties, especially informing the providers of related safeguards, etc.;
(iii) dealing with any dispute administration, particularly for the purposes of conducting court or other disputes.
(d) Our legitimate interests:
These are particularly situations in which there is a contractual/customer relationship between you and our company.
II.2.2. Processing of your personal data with your consent
These are usually situations in which you voluntarily agree to our processing of your personal data. Based on your consent, our company processes your personal data for the following purposes:
(a) client care; these are activities which do not constitute performance of a contract or other legal framework for the processing of personal data and which include the following activities:
(i) market research;
(ii) obtaining feedback relating to the controller’s products and services;
(iii) monitoring client behaviour on our company’s website in relation to the services offered (i.e. this purpose is not only related to obtaining information about the behaviour displayed by users visiting our company’s website by using cookies which is described below in the section on electronic communications devices and mobile applications);
(b) offering products and services; this particularly involves disseminating information, offering our company’s products and services by various means (by post, electronic means including email and messages sent to mobile devices, telephone calls and websites).
Providing personal data for the purposes of caring for you is our contractual requirement, and failure to provide it may result in non-conclusion of a contract or non-provision of adequate care.
II.3. The scope of clients’ personal data subject to processing
Our company processes your personal data to the extent necessary to meet the aforementioned purposes. We process contact details (contact addresses, telephone numbers, email and fax addresses, and other similar contact details), identification data(name, surname, date of birth, permanent residence address, type, number and validity of the identity card, as well as ID number and tax ID number in the case of clients-entrepreneurs) and camera recordings.
II.4. The method of processing personal data
The way our company processes your personal data includes both manual and automated processing in our company’s information systems and in physical form.
Your personal data is processed primarily by our employees and, to the extent necessary, also by third parties. Prior to any transfer of your personal data to any third party, we always enter into a written agreement with such a party which contains the same guarantees for the processing of personal data as those adhered to by our company itself in accordance with its legal obligations.
II.5. Recipients of personal data
Your client personal data is particularly disclosed to our employees in connection with the performance of their work duties involving handling of client personal data, but only to the extent necessary and in accordance with all security measures.
In addition, your personal data is transferred to the third parties involved in the processing of personal data of our company’s clients or, as the case may be, such personal data may be disclosed to them for other reasons in accordance with the law.
Data is transferred in particular to:
(a) the law firm led by JUDr. Jan Bouček, attorney-at-law, ID No.: 64 39 15 74;
(b) the provider of accounting services; and
(c) to the processors that provide us with server, web, cloud and IT services.
Prior to any transfer of your personal data to any third party, we always enter into a written agreement with such a party in which we regulate the processing of personal data to contain the same guarantees for the processing of personal data as those adhered to by our company itself in accordance with its legal obligations.
II.7. Transferring personal data abroad
Your personal data is processed in the territory of the Czech Republic and is not transferred to any countries outside the European Union.
II.8. The period of time of the processing of personal data
Our clients’ personal data is only processed by our company for the period of time necessary for the purposes of the processing of such data. We continuously assess whether it is still necessary to process certain personal data needed for a particular purpose. If we find that it is no longer needed for any of the purposes for which it was processed, we destroy such data. However, we have internally determined the usual period of time for the usability of personal data in relation to certain purposes of the processing of personal data after the end of which we most carefully assess the need to process the relevant personal data for the given purpose. In this regard, it also applies that the personal data processed for the purposes of:
(a) performing a contract is processed by our company for the duration of the contractual relationship with the client; the relevant personal data is then usually usable for a period of ten years;
(b) offering products and services is processed by our company for the duration of the contractual relationship; the relevant personal data is then usually usable for a period of ten years;
(c) client care is processed by our company for the duration of the contractual relationship with the client; the relevant personal data is then usually usable for a period of ten years;
(d) protecting rights and legitimate interests in the form of camera recordings; the relevant personal data is then usually usable for 72 hours.
II.9. Right to withdraw consent
In this communication, we have explained to you the reasons why we need your personal data and that we may only process it with your consent for some purposes. You are not obliged to grant us your consent to the processing of your personal data and, in addition, you are entitled to withdraw your consent. Please note that we are also entitled to process certain personal data for certain purposes without your consent. If you withdraw your consent in such cases, we will cease to process the relevant personal data for the purposes requiring such consent, but we may be entitled or even obliged to continue to process the same personal data for other purposes.
If you wish to withdraw your consent to the processing of personal data, please contact us at our registered office at Krakovská 1338/10, 110 00 Praha 1 or by email firstname.lastname@example.org
II.10. Sources of personal data
We obtain our clients’ personal data in particular:
(a) from the clients themselves;
(b) from publicly available sources (public registers, records and lists);
(c) from parties potentially interested in our company’s services as part of our marketing offers and campaigns;
(d) from our own activities, by processing and assessing clients’ other personal data;
(e) from camera recordings.
II.11. Your rights in relation to the processing of your personal data
You may exercise all of your rights at our registered office at Krakovská 1338/10, 110 00 Praha 1 or by email email@example.com, you may also lodge a complaint with the supervisory authority, which is the Office for Personal Data Protection (www.uoou.cz).
II.11.1. The right of access means that you may ask for our confirmation at any time of whether or not the personal data concerning you is processed and, if so, for what purposes, to what extent, to whom it is disclosed, how long we will process it, whether you have the right to rectification, erasure or restriction of processing or the right to object, from where we obtained the personal data and whether automatic decision-making, including profiling, is carried out based on the processing of your personal data. You also have the right to obtain a copy of your personal data; the first provision is free of charge, and any additional provision may be subject to a reasonable compensation of the administrative costs incurred.
II.11.2. The right to rectification means that you may request us at any time to rectify or complete your personal data if it is inaccurate or incomplete.
II.11.3. The right to erasure means that we must erase your personal data if (i) it is no longer necessary for the purposes for which it was collected or otherwise processed, (ii) the processing is unlawful, (iii) you object to the processing and there are no overriding legitimate grounds for the processing, or (iv) we have a legal obligation to do so.
II.11.4. The right to restriction of processing means that until we resolve any controversial issues regarding the processing of your personal data, we must restrict the processing of your personal data so that we may only store it and possibly use it for the establishment, exercise or defence of legal claims.
II.11.5. The right to object means that you may object to the processing of your personal data that we process for direct marketing purposes or based on a legitimate interest. If you object to the processing for direct marketing purposes, your personal data will no longer be processed for this purpose.
Our company uses numerous technologies within it business activity to provide you with the most convenient access to our products/services. These include in particular services related to the use of the internet and to the use of social networks.
III.1. Social networks. You may, inter alia, contact us through different social networks. We mainly use these communication channels as marketing tools, and we currently do not provide our products/services through them.
IV.1. This communication is issued for an indefinite period of time and comes into effect on 1 June 2018.
IV.2. We are entitled to change this communication at any time by issuing a new full wording thereof; its current wording is published on our company’s website and is also available at our registered office.
IV.3. Except as expressly stated otherwise, all information provided herein also applies to the processing of the personal data of potential clients, i.e. persons with whom we have not yet entered into a contractual relationship but with whom we are in contact. The information provided herein also applies, to a reasonable extent, to the processing of personal data of other persons with whom our company is in direct contact although we do not have a contractual relationship with them (e.g. representatives of legal entities).