Dear client,
We would like to take this opportunity to inform you about how PSN s.r.o. (hereinafter referred to as „we“ or „our company“) processes your personal data in connection with the performance of our business activities.
The purpose of this notification is to give you information primarily on how we collect the personal data, how we handle it, from which sources we obtain it, for what purposes we use it, to whom we can provide it, where we can obtain information about your personal data and what your individual rights are in the area of the protection of personal data. When processing the personal data we adhere to generally-binding legal regulations and the processing of personal information always takes place solely in the scope of the given specific service and/or purpose for processing.
Please get to know the contents of this notification. We will gladly and willingly answer any questions you may have at our offices at Seifertova 823/9, 130 00 Prague 3, by e-mail at info@psn.cz and/or by phone at + 420 221 088 111.
Our Data Protection Officer, Marek Vavřina is also available to you by email: [marek.vavrina@psn.cz], or by phone at + 420 221 088 111.
I.
General information
With regard to its business activities, our company is obliged to process personal data, particularly for the purposes of fulfilling our legal and contractual obligations. In this regard, we would not be able to provide you with our products/services without the provisioning of your personal data.
Furthermore, we also process your personal data beyond the framework of our obligations, specifically for the purposes of taking care of you and our other clients, to develop our business relations and to contact you with a targeted offer of our products/services. For this we need your agreement. With regard to the orientation of our products/services, the boundary of the age of maturity will be respected for the granting of a valid agreement with the processing of personal data without the agreement of the legal guardians of the subjects of the data.
I.1. Principles of processing personal data
When processing your personal data we honour and respect the highest possible standards of protecting your personal data and especially adhere to the following principles:
- We always process your personal data for a clearly and coherently specified purpose, by the specified means, in the specified manner and only for the period that is necessary with regard to purpose of its processing; we only process the exact personal data of our clients and we ensure that the processing of the data corresponds to the specified purposes and is necessary for the fulfilment of these purposes;
- We protect your personal data as classified information; thus we process the clients’ personal data in a manner that ensures the highest possible security of this data and which prevents any unauthorised or accidental access to the clients’ personal data, or to the changing, destruction of loss of the data, to unauthorised transfers, to its other unauthorised processing or to any other abuse;
- We will always comprehensibly inform you of the processing of your personal data and of your rights to precise and complete information on the circumstances of this processing, as well as your other related rights;
- In our company we have set and adhere to the corresponding technical and organisational measures, in order to ensure a level of security corresponding to all the possible risks; all the people who come into contact with the clients’ personal data are obliged to maintain the confidentiality of the information acquired in connection with the processing of this data.
II.
Information on the processing of personal data
II.1. Information on the controller
We, i.e. PSN s.r.o., with its registered office at Seifertova 823/9, 130 00 Prague 3, Company ID No.: 170 48 869, a company registered in the Commercial Register maintained by the Municipal Court in Prague, file no. C 1671, are the controller of your personal data.
II.2. Purposes of processing and legal foundation for processing
II.2.1. Processing personal data without your agreement
These are generally situations where we are obliged to hand over certain personal data as a condition for offering you our product/service, or when we are entitled to process your personal data obtained in another manner.
-
We are legally entitled to process your data without your agreement for the following purposes of adhering to our legal obligations, primarily
- To avoid the occurrence of damages to our company’s assets;
- To prevent fraudulent behaviour to which our company could be subjected;
- To fulfil any obligations when identifying and checking the client pursuant to the Act on Selected Measures against the Legitimisation of Proceeds of Crime and Financing of Terrorism;
- To fulfil the identification obligation in relation to the client on the basis of the Act on the Residence of Foreign Nationals.
- Concluding or fulfilling a contract with you.
This primarily means the actual realisation of the contractual relationship between our company and you. The personal data is necessary, for example, to realise the contractual relationship without any excessive legal risks, including negotiations on the conclusion or change to contracts with you. -
The protection of rights and interests protected by law, especially for
- The protection of rights and interests protected by law of our company, the enforcement of receivables, the implementation of collateral or the other application of receivables, the evolution and development of the provided services;
- Negotiations with those interested in the transfer of our company’s receivables from the client, or another form of the transfer or assignment of receivables, including the related implementation, and other related negotiations with third parties, especially the information of providers of related collateral, etc.;
- The resolution of all disputes, particularly for the purpose of conducting litigation or other disputes.
- Our justified interests.
These are primarily situations where a contractual/client relationship exists between you and our company.
II.2.2. Processing personal data with your agreement
These are generally situations where you voluntarily agree with us processing your personal data. On the basis of your agreement our company processes your personal data for the following purposes:
-
Client care; these are activities that do not represent the fulfilment of contracts or other legal framework for the processing of personal data and which include the following activities:
- Market research;
- Acquiring feedback regarding the controller’s products and services;
- monitoring the behaviour of clients on our company’s webpages in relation to the offered services (thus, this purpose does not apply to actual acquisition of information on the behaviour of the users of our company’s webpages through cookies, which is described in the section on electronic means of communication and mobile applications below);
- The offer of products and services; this is primarily about the dissemination of information, offering our company’s products and services, and by various means (mail, electronic means, including e-mail and messages sent to mobile devises, telephone calls and through webpages).
The provisioning of personal data for the purpose of caring for you is our contractual requirement and not providing it can lead to not concluding the contract or not providing adequate care.
II.3. Scope of clients’ processed data
Our company processes your personal data in the scope required for the fulfilment of the aforementioned purposes. We process contact data (contact addresses, telephone numbers, e-mail and fax addresses and other similar contact data) and identification data (name, surname, date of birth, address of permanent residence, type, number and validity of identification; for entrepreneurs also the company ID number and tax ID number) and video camera recordings.
II.4. Method of processing personal data
The method by which our company processes your personal data includes manual and automated processing in our company’s information systems and in physical form.
Your personal data is primarily processed by the employees of our company and also third parties to the required extent. Before any handover of your personal data to third parties, we always conclude with this party a written contract, which includes the same guarantees for the processing of personal data as our company is required to adhere to in accordance with its legal obligations.
II.5. Recipients of personal data
Your personal data is primarily accessible to the employees of our company in connection with the fulfilment of their job obligations, during which it is necessary to handle the clients’ personal data, though only to the extent which is required in each particular case and while observing all security measures.
In addition to this, your personal data is passed on to third parties that contribute to the processing of the personal data of our company’s clients, or they can be given access to this personal data for another reason in accordance with the law.
The handover of the data is generally to:
- Our law firm, JUDr. Rostislava Dolečka, Attorney, Company ID No.: 662 13 011;
- Providers of accounting services; and
- Processors that provide us with server, web, cloud and IT services.
Before any handover of your personal data to a third party, we always conclude a written contract with this party, in which we regulate the processing of personal data so that it includes the same guarantees for the processing of personal data as our company adheres to in accordance with its legal obligations.
II.7. Sending personal data abroad
Your personal data is processed within the Czech Republic and is not sent to countries outside of the European Union.
II.8. Period of processing personal data
The clients’ personal data is only processed by our company for the period that is necessary with regard to the purposes of its processing. We continually assess whether the need to process certain personal data necessary for a certain purpose still remains valid. If we ascertain that it is no longer required for any of the purposes for which it was processed, we liquidate the data. Internally, however, we have assessed the normal period of use of personal data in relation to certain purposes, after the expiry of which we assess the need to process the relevant personal data for the given purpose with particular thoroughness. In this context it is also true that the personal data processed for the purpose of:
- The fulfilment of a contract is processed for the duration of the contractual relationship with the client; the relevant personal data is usually useable for a further period of ten years;
- Offering products and services is processed for the duration of the contractual relationship; the relevant personal data is usually useable for a further period of ten years;
- Client care is processed for duration of the contractual relationship with the client; the relevant personal data is usually useable for a further period of ten years;
- The protection of rights and interests protected by law in the form of video camera recordings; the relevant personal data is usually useable for a period of thirty days.
II.9. Right to withdraw agreement
In this notification we have explained to you the reasons that we need your personal data and that we can only process it with your agreement for certain purposes. You are not obliged to grant our company your agreement with the processing of your personal data and you are also entitled to withdraw this agreement. Please keep in mind that we are also entitled to process some personal data for certain purposes without your agreement. If you withdraw your agreement for such a case, we will end the processing of the relevant personal data for the purposes requiring the appropriate agreement, though we may be entitled or even obliged to continue to process this personal data for other purposes.
If you would like to withdraw your agreement with the processing of your personal data, please contact our offices at the address Seifertova 823/9, 130 00 Prague 3 or by email at info@psn.cz.
II.10. Sources of personal data
We particularly obtain the clients’ personal data:
- From the clients themselves;
- From publicly-accessible sources (public registers, records or lists);
- From parties potentially interested in the services of our company as part of marketing events and campaigns;
- From our own activities, specifically by the processing and evaluation of the clients’ other personal data;
- From video camera recordings.
II.11. Your rights in relation to the processing of your personal data
You can apply all of your rights in our offices at Seifertova 823/9, 130 00 Prague 3 or by e-mail at info@psn.czand you can also submit a complaint to the supervisory body, which is the Office for Personal Data Protection (www.uoou.cz).
II.11.1. ight to access
This means that at any time you can ask for our confirmation that the personal data that applies to you is or is not processed, and if it is, then for which purposes, to what extent, to whom it are accessible, how long we will be processing it, whether you have the right to change, delete, limit the processing or raise an objection, from where we obtained the personal data and whether an automatic decision, including profiling, will occur on the basis of the processing of your personal data. You also have the right to obtain a copy of your personal data, with the first copy being provided free of charge, while for other copies we can ask for the appropriate compensation of administration expenses.
II.11.2. The right to correct
This means that you can, at any time, ask for a correction or addition to your personal data, if it is inaccurate or incomplete.
II.11.3. The right to delete
This means that we must delete your personal data if (i) it is no longer required for the purpose for which it was collected or otherwise processed, (ii) the processing is against the law, (iii) you raise objections against the processing and there are no overriding legitimate reasons for the processing, or (iv) we are legally required to do so.
II.11.4. The right to limit the processing
This means that if we do not resolve any disputed issues regarding the processing of your personal data, we have to limit the processing of your personal data so that we can only have the data stored and, if required, we can use to determine, exercise or defend legal claims.
II.11.5. The right to raise an objection
This means that you can raise an objection against the processing of your personal data that we are processing for the purpose of direct marketing or for the reason of justified interests. If you raise an objection against the processing for the purpose of direct marketing, your personal data will no longer be processed for this purpose.
III.
Electronic means of communication
Our company uses multiple technologies as part of its business activities so that you can have the most comfortable access to us and our products/services as possible. These are primarily services connected with the use of the Internet and with the use of social networks.
III.1. Social networks
You can contact us through various social networks, for example. We mainly use these communication channels as a marketing tool; our products/services are not currently provided over these networks.
III.2. Cookies
When providing our products/services, we also use cookies, which are small text files that are stored on the user’s computer when first reading our webpages. Thanks to these files we can more easily identify the method by which the visitors work with the content of our webpages. This helps us to communicate more helpfully with the visitors to our webpages or to more effectively target our marketing. You can find more information about cookies on our webpages.
IV.
Concluding provisions
IV.1.
This notification is issued for an indefinite period and comes into effect on 1 June 2018.
IV.2.
We can, at any time, change this notification by issuing a completely new version; its current version is published on our company’s webpages and is also available at our head office.
IV.3.
Unless explicitly specified otherwise, all of the information given here also applies to the processing of the personal data of potential clients, i.e. entities with which we have not yet entered into a contractual relationship, but we are in contact with them. The information given here also applies to the appropriate extent to the processing of the personal data of other persons with which our company is in direct contact, though does not have a contractual relationship with them (e.g. representatives of legal entities).
Our Data Protection Officer, Marek Vavřina is also available to you by email: [marek.vavrina@psn.cz], or by phone at + 420 221 088.
I.
General information
With regard to its business activities, our company is obliged to process personal data, particularly for the purposes of fulfilling our legal and contractual obligations. In this regard, we would not be able to provide you with our products/services without the provisioning of your personal data.
Furthermore, we also process your personal data beyond the framework of our obligations, specifically for the purposes of taking care of you and our other clients, to develop our business relations and to contact you with a targeted offer of our products/services. For this we need your agreement. With regard to the orientation of our products/services, the boundary of the age of maturity will be respected for the granting of a valid agreement with the processing of personal data without the agreement of the legal guardians of the subjects of the data.
I.1. Principles of processing personal data
When processing your personal data we honour and respect the highest possible standards of protecting your personal data and especially adhere to the following principles:
- We always process your personal data for a clearly and coherently specified purpose, by the specified means, in the specified manner and only for the period that is necessary with regard to purpose of its processing; we only process the exact personal data of our clients and we ensure that the processing of the data corresponds to the specified purposes and is necessary for the fulfilment of these purposes;
- We protect your personal data as classified information; thus we process the clients’ personal data in a manner that ensures the highest possible security of this data and which prevents any unauthorised or accidental access to the clients’ personal data, or to the changing, destruction of loss of the data, to unauthorised transfers, to its other unauthorised processing or to any other abuse;
- We will always comprehensibly inform you of the processing of your personal data and of your rights to precise and complete information on the circumstances of this processing, as well as your other related rights;
- In our company we have set and adhere to the corresponding technical and organisational measures, in order to ensure a level of security corresponding to all the possible risks; all the people who come into contact with the clients’ personal data are obliged to maintain the confidentiality of the information acquired in connection with the processing of this data.
II.
Information on the processing of personal data
II.1. Information on the controller
We, i.e. PSN s.r.o., with its registered office at Seifertova 823/9, 130 00 Prague 3, Company ID No.: 170 48 869, a company registered in the Commercial Register maintained by the Municipal Court in Prague, file no. C 1671, are the controller of your personal data.
II.2. Purposes of processing and legal foundation for processing
II.2.1. Processing personal data without your agreement
These are generally situations where we are obliged to hand over certain personal data as a condition for offering you our product/service, or when we are entitled to process your personal data obtained in another manner.
-
We are legally entitled to process your data without your agreement for the following purposes of adhering to our legal obligations, primarily
- To avoid the occurrence of damages to our company’s assets;
- To prevent fraudulent behaviour to which our company could be subjected;
- To fulfil any obligations when identifying and checking the client pursuant to the Act on Selected Measures against the Legitimisation of Proceeds of Crime and Financing of Terrorism;
- To fulfil the identification obligation in relation to the client on the basis of the Act on the Residence of Foreign Nationals.
- Concluding or fulfilling a contract with you.
This primarily means the actual realisation of the contractual relationship between our company and you. The personal data is necessary, for example, to realise the contractual relationship without any excessive legal risks, including negotiations on the conclusion or change to contracts with you. -
The protection of rights and interests protected by law, especially for
- The protection of rights and interests protected by law of our company, the enforcement of receivables, the implementation of collateral or the other application of receivables, the evolution and development of the provided services;
- Negotiations with those interested in the transfer of our company’s receivables from the client, or another form of the transfer or assignment of receivables, including the related implementation, and other related negotiations with third parties, especially the information of providers of related collateral, etc.;
- The resolution of all disputes, particularly for the purpose of conducting litigation or other disputes.
- Our justified interests.
These are primarily situations where a contractual/client relationship exists between you and our company.
II.2.2. Processing personal data with your agreement
These are generally situations where you voluntarily agree with us processing your personal data. On the basis of your agreement our company processes your personal data for the following purposes:
-
Client care; these are activities that do not represent the fulfilment of contracts or other legal framework for the processing of personal data and which include the following activities:
- Market research;
- Acquiring feedback regarding the controller’s products and services;
- monitoring the behaviour of clients on our company’s webpages in relation to the offered services (thus, this purpose does not apply to actual acquisition of information on the behaviour of the users of our company’s webpages through cookies, which is described in the section on electronic means of communication and mobile applications below);
- The offer of products and services; this is primarily about the dissemination of information, offering our company’s products and services, and by various means (mail, electronic means, including e-mail and messages sent to mobile devises, telephone calls and through webpages).
The provisioning of personal data for the purpose of caring for you is our contractual requirement and not providing it can lead to not concluding the contract or not providing adequate care.
II.3. Scope of clients’ processed data
Our company processes your personal data in the scope required for the fulfilment of the aforementioned purposes. We process contact data (contact addresses, telephone numbers, e-mail and fax addresses and other similar contact data) and identification data (name, surname, date of birth, address of permanent residence, type, number and validity of identification; for entrepreneurs also the company ID number and tax ID number) and video camera recordings.
II.4. Method of processing personal data
The method by which our company processes your personal data includes manual and automated processing in our company’s information systems and in physical form.
Your personal data is primarily processed by the employees of our company and also third parties to the required extent. Before any handover of your personal data to third parties, we always conclude with this party a written contract, which includes the same guarantees for the processing of personal data as our company is required to adhere to in accordance with its legal obligations.
II.5. Recipients of personal data
Your personal data is primarily accessible to the employees of our company in connection with the fulfilment of their job obligations, during which it is necessary to handle the clients’ personal data, though only to the extent which is required in each particular case and while observing all security measures.
In addition to this, your personal data is passed on to third parties that contribute to the processing of the personal data of our company’s clients, or they can be given access to this personal data for another reason in accordance with the law.
The handover of the data is generally to:
- Our law firm, JUDr. Rostislava Dolečka, Attorney, Company ID No.: 662 13 011;
- Providers of accounting services; and
- Processors that provide us with server, web, cloud and IT services.
Before any handover of your personal data to a third party, we always conclude a written contract with this party, in which we regulate the processing of personal data so that it includes the same guarantees for the processing of personal data as our company adheres to in accordance with its legal obligations.
II.7. Sending personal data abroad
Your personal data is processed within the Czech Republic and is not sent to countries outside of the European Union.
II.8. Period of processing personal data
The clients’ personal data is only processed by our company for the period that is necessary with regard to the purposes of its processing. We continually assess whether the need to process certain personal data necessary for a certain purpose still remains valid. If we ascertain that it is no longer required for any of the purposes for which it was processed, we liquidate the data. Internally, however, we have assessed the normal period of use of personal data in relation to certain purposes, after the expiry of which we assess the need to process the relevant personal data for the given purpose with particular thoroughness. In this context it is also true that the personal data processed for the purpose of:
- The fulfilment of a contract is processed for the duration of the contractual relationship with the client; the relevant personal data is usually useable for a further period of ten years;
- Offering products and services is processed for the duration of the contractual relationship; the relevant personal data is usually useable for a further period of ten years;
- Client care is processed for duration of the contractual relationship with the client; the relevant personal data is usually useable for a further period of ten years;
- The protection of rights and interests protected by law in the form of video camera recordings; the relevant personal data is usually useable for a period of thirty days.
II.9. Right to withdraw agreement
In this notification we have explained to you the reasons that we need your personal data and that we can only process it with your agreement for certain purposes. You are not obliged to grant our company your agreement with the processing of your personal data and you are also entitled to withdraw this agreement. Please keep in mind that we are also entitled to process some personal data for certain purposes without your agreement. If you withdraw your agreement for such a case, we will end the processing of the relevant personal data for the purposes requiring the appropriate agreement, though we may be entitled or even obliged to continue to process this personal data for other purposes.
If you would like to withdraw your agreement with the processing of your personal data, please contact our offices at the address Seifertova 823/9, 130 00 Prague 3 or by email at info@psn.cz.
II.10. Sources of personal data
We particularly obtain the clients’ personal data:
- From the clients themselves;
- From publicly-accessible sources (public registers, records or lists);
- From parties potentially interested in the services of our company as part of marketing events and campaigns;
- From our own activities, specifically by the processing and evaluation of the clients’ other personal data;
- From video camera recordings.
II.11. Your rights in relation to the processing of your personal data
You can apply all of your rights in our offices at Seifertova 823/9, 130 00 Prague 3 or by e-mail at info@psn.czand you can also submit a complaint to the supervisory body, which is the Office for Personal Data Protection (www.uoou.cz).
II.11.1. ight to access
This means that at any time you can ask for our confirmation that the personal data that applies to you is or is not processed, and if it is, then for which purposes, to what extent, to whom it are accessible, how long we will be processing it, whether you have the right to change, delete, limit the processing or raise an objection, from where we obtained the personal data and whether an automatic decision, including profiling, will occur on the basis of the processing of your personal data. You also have the right to obtain a copy of your personal data, with the first copy being provided free of charge, while for other copies we can ask for the appropriate compensation of administration expenses.
II.11.2. The right to correct
This means that you can, at any time, ask for a correction or addition to your personal data, if it is inaccurate or incomplete.
II.11.3. The right to delete
This means that we must delete your personal data if (i) it is no longer required for the purpose for which it was collected or otherwise processed, (ii) the processing is against the law, (iii) you raise objections against the processing and there are no overriding legitimate reasons for the processing, or (iv) we are legally required to do so.
II.11.4. The right to limit the processing
This means that if we do not resolve any disputed issues regarding the processing of your personal data, we have to limit the processing of your personal data so that we can only have the data stored and, if required, we can use to determine, exercise or defend legal claims.
II.11.5. The right to raise an objection
This means that you can raise an objection against the processing of your personal data that we are processing for the purpose of direct marketing or for the reason of justified interests. If you raise an objection against the processing for the purpose of direct marketing, your personal data will no longer be processed for this purpose.
III.
Electronic means of communication
Our company uses multiple technologies as part of its business activities so that you can have the most comfortable access to us and our products/services as possible. These are primarily services connected with the use of the Internet and with the use of social networks.
III.1. Social networks
You can contact us through various social networks, for example. We mainly use these communication channels as a marketing tool; our products/services are not currently provided over these networks.
III.2. Cookies
When providing our products/services, we also use cookies, which are small text files that are stored on the user’s computer when first reading our webpages. Thanks to these files we can more easily identify the method by which the visitors work with the content of our webpages. This helps us to communicate more helpfully with the visitors to our webpages or to more effectively target our marketing. You can find more information about cookies on our webpages.
III.3. Types of cookies
With regard to the display of relevant content on our website and the targeting of marketing offers, we use several types of cookies:
- Technical cookies
These are the cookies necessary for the smooth operation of the website and its correct display on all types of devices. Information about the consent to the settings of the website for the users of the given browser is also stored, so that it can be taken into account upon repeated visits. These cookies cannot be rejected as they are necessary to comply with applicable legislation.
- Personalized cookies
Cookies that are used to store selected settings for users of a given browser (eg permanent login, website color theme, preferred products/services, etc.). These cookies only allow us to display content on your website that matches your preferences.
- Analytics cookies
Cookies that are used to store selected settings for users of a given browser (eg permanent login, website color theme, preferred products/services, etc.). These cookies only allow us to display content on your website that matches your preferences.
- Marketing cookies
These are third-party cookies that allow us to address the users of a given browser with targeted offers on the communication platforms used. We use the following platforms and tools for marketing purposes: Facebook and Instagram (Meta), Google Ads, Sklik, Google Tag Manager, Google Analytics, Hotjar.
These cookies allow you to track basic data about a user visit, ie region, type of browser and device, visit metrics - duration, number of pages, etc. Using aggregated data from these cookies, we modify our website so that visitors can easily find it, what they are looking for. The data also helps us identify potential technical issues on the web.
III.4. Cookie control
Based on current legislation, you can adjust your cookie preferences for this website here.
IV.
Concluding provisions
IV.1.
This notification is issued for an indefinite period and comes into effect on 1 June 2018.
IV.2.
We can, at any time, change this notification by issuing a completely new version; its current version is published on our company’s webpages and is also available at our head office.
IV.3.
Unless explicitly specified otherwise, all of the information given here also applies to the processing of the personal data of potential clients, i.e. entities with which we have not yet entered into a contractual relationship, but we are in contact with them. The information given here also applies to the appropriate extent to the processing of the personal data of other persons with which our company is in direct contact, though does not have a contractual relationship with them (e.g. representatives of legal entities).