Personal data processing principles

04.03.2019
Other

Personal data processing principles

1. WHO ARE WE?

We are the company TREVOS, a.s., with registered office at Nová Ves, 34, 511 01 Turnov, registered under file No. B 3650, registered at the Regional Court in Hradec Králové, ID No. 078 29 965.

We are a purely Czech manufacturer and seller of lighting fixtures, providing a wide range of industrial and interior lighting fixtures. In connection with our business, we may come into contact with your personal data and thus become a so-called data controller (hereinafter referred to as "Controller" or "we").

2. WHAT KIND OF DOCUMENT IS THIS?

As mentioned above, in the course of our business, we may need your personal data (for example, to communicate or further engage with you). In view of this, we, as the Data Controller, are obliged to provide you with certain information in accordance with Article 13 of Regulation (EU) No 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter referred to as "GDPR").

In this document, you will find information on how we process your personal data, in particular for what purposes, on what legal basis and for how long. You will also find in this document information on what rights you have in relation to this and how you can exercise these rights.

3. WHERE CAN YOU CONTACT US?

If you have any questions or wish to request the exercise of any of the rights set out below, you may contact us at our registered office address listed above, or by email at gdpr@trevos.cz or by telephone at 481 363 375.

4. WHAT IS PERSONAL DATA?

Personal data is information that is processed about an identified or identifiable person. Simply put, personal data is information that you have provided to us and that we subsequently process about you.

Personal data can be further divided into categories, and we often process the following in the course of our business:

Categories of personal data

Example

Identification data

Name, surname, title, job title, etc.

Contact details

Telephone number or e-mail, etc.

Address data

Registered office address or any other address you provide to us.

Payment details

Account number, bank name, etc.

Product data

The very information about what you buy from us can be your personal data.

Order history and related information

Information about products purchased or requested, etc.

Content of communication

Information relating to our joint communications, in particular the content of Your messages, etc.

 The above personal data and their categories are only indicative, the specific scope of categories that we may process in the context of our cooperation can be found below.

 5. ON WHAT BASIS CAN WE PROCESS YOUR PERSONAL DATA?

First of all, we only process your personal data when it is strictly necessary. However, we must always comply with the conditions required by the GDPR to do so. Thus, we can only process your personal data if:

  • such processing is necessary for the conclusion and performance of our contract or for processing related to the conclusion of such contract;
  • such processing is directly required by law and such processing is necessary for compliance with a specific legal obligation;
  • the processing is necessary for the purposes of our legitimate interests, which take precedence over your rights in the specific case;
  • you have given us your express and free consent to such

The GDPR provides for other legal titles where your personal data can be processed, but these are not applicable to our cooperation.

Specific information on the basis of which we process your personal data can be found below.

6. HOW DO YOU PROCESS PERSONAL DATA ABOUT ME AND FOR HOW LONG?

The actual scope of the categories of personal data processed, the purpose for which they are processed and the legal title vary depending on the situation. The specific situations are listed below in this paragraph, while it is understood that in your case not all of the processing may occur.

Conclusion and performance of the contract between us

If you cooperate with us and enter into a contract with us, we need your personal data in order to enter into and subsequently perform the contract together. Without the information provided below, it would be impossible for us to conclude the contract at all (as we would not know with whom we are concluding it) or to perform it (as we would not be able to process your address data, for example, and would not know where the goods are to be delivered).

In the above case, we process your personal data for the following purposes:

Purpose of processing

Categories of personal data

Legal title

Processing time

Conclusion and performance of the contract, including related communication regarding performance

Identification details; Contact details; Product details; Payment details; Order history and related information;

Necessary for the performance of the        contract (or, where applicable the legitimate interest of the controller in the case of cooperation with a legal person)

For the duration of the cooperation (contractual relationship) and subsequently 3 years after the end of the cooperation (basic data on this relationship after a period of 10 years)

Reaching out with offers of services and products, including discount promotions that relate to of the goods received

Identification data; Contact data; Address data; Order history and related information;

Legitimate interest (or customer exception)

For the duration of the cooperation (contractual relationship) and subsequently for 3 years after termination of cooperation

If you withdraw goods from us, we are entitled to use your e-mail (but not your telephone number) to contact you with an offer of a similar product or service that you have withdrawn from us on the basis of the so-called customer exception. Section 7(3) of Act No. 480/2004 Coll., on certain information society services, as amended, allows us to do this. If you do not wish to receive these messages, you can certainly exclude this when negotiating a contract, or you can find a link at the end of each commercial communication, after clicking which we will not send you such communications until you give us your consent to do so again.

For more information on how to opt out of receiving commercial communications that relate to a similar product or service that you have subscribed to with us, please see below.

Contact and enquiry form

On our website, you have the opportunity to leave us a message and your contact details for the purpose of further communication, especially regarding our products. In this context, you can contact us for help with lighting calculations, consultancy or technical support. Even in this case, personal data is processed by us and you are not obliged to provide us with your personal data if you do not wish to do so. However, without it we are unable to write to you or respond to your enquiry.

In the above case, we process your personal data for the following purposes:

Purpose of processing

Categories of personal data

Legal title

Processing time

Inquiry handling and related communication

Identification details; Contact details; Content of communication;

Necessity for the performance of the contract or the implementation of measures taken prior to its conclusion contracts on the basis of Your requests

For a period of 1 year from the last communications, or for the duration of the contract

Marketing communication

We are happy to share our news with you. To do this, you can write to us or fill in a form and agree that we can contact you with our product and service offerings or news about us (either by email, phone or in writing). In the event that you wish to receive such news from us, we need to know your contact details as well as your order history and related information so that we can send you news of interest to you. All activity is voluntary on your part and you are under no obligation to subscribe to our newsletter.

In the above case, we process your personal data for the following purposes:

Purpose of processing

Categories of personal data

Legal title

Processing time

Reaching out with offers of services and products, including discounts and news

Identification data; Contact data Address data; Order history andrelated information;

Consent

Pending withdrawal of consent

In any case, the provision of the personal data in question is entirely voluntary on your part and you can always withdraw your consent by following the procedure set out below. If you have concluded a contract with us in the past and have not opted out of receiving commercial communications relating to similar products and services that you have received from us in the past, we may also send you commercial communications without your consent (see above for the conclusion and performance of the contract).

7. WHO HAS ACCESS TO PERSONAL DATA?

We do not disclose your personal data to anyone unless absolutely necessary. In some cases, we use suppliers who are then in the position of personal data processors. We have entered into appropriate contracts with these parties in accordance with Article 28(3) of the GDPR.

We refer to all these persons as beneficiaries and list them below:

Recipient

Reason for disclosure

Operator websites

This person manages the website for us and may randomly have access to personal data.

Providers- mailing tool

For the purpose of sending commercial communications, we use a service that helps us send e-mails.

Carriers and logistics companies

These persons assist us with the dispatch of goods in the performance of the contract and may have access to personal data in connection therewith.

 

8. WHAT RIGHTS YOU HAVE IN RELATION TO THE PROCESSING OF PERSONAL DATA

At this point, we would like to inform you about what rights you have in relation to the possible processing of personal data and how you can subsequently exercise these rights.

8. 3. Right to erasure (right to be forgotten)

If we do not need your personal data, we delete it immediately. However, this does not change the fact that you have the right to have us delete (or anonymise) your personal data without delay, provided that one of the following reasons applies:

  • the personal data is no longer needed for the above purposes;
  • withdraw your consent to the processing of personal data;
  • you object to a legitimate interest and we assess that this legitimate interest does not override your rights (in the case of marketing purposes based on legitimate interest, we will delete the data immediately);
  • processing was unlawful;
  • deletion is required by Czech or EU law.

However, this right is not absolute, as sometimes we may not be able to delete your personal data, this is in those cases where the processing is necessary:

  • for the exercise of the right to freedom of expression and information;
  • to fulfil a legal obligation;
  • for reasons of public interest in the field of public health;
  • for archiving purposes in the public interest, for scientific or historical research or for statistical purposes;
  • for the establishment, exercise or defence of legal

However, it is quite possible that none of the above cases will occur at all, so you do not need to worry that we will not delete your personal data.

8.4. Right to restriction of processing

You also have the right to have us restrict the processing of your personal data in one of the following cases:

  • you deny the accuracy of the personal data for the time necessary to verify its accuracy;
  • the processing is unlawful, you will refuse to erase the personal data and you will require the restriction of its use;
  • we no longer need the personal data for processing purposes, but you require us to retain it for the establishment, exercise or defence of legal claims;
  • you raise an objection against a legitimate interest, pending an assessment of its

8.5. Right to portability

Although it sounds strange, if we process your personal data by automated means and the processing is based on consent or necessity for the performance of a contract, you have the right to so-called portability. The right to portability guarantees that we will transmit the data you have provided to us in a commonly used and machine-readable format, or that we will transmit the data to another controller that you identify to us.

8.6. Right to object to processing on the basis of legitimate interest (and the exclusion of the so-called customer exception)

Where we process your personal data on the basis of a legitimate interest, you have the right to object to this processing on the basis of a reasoned objection. In the case of such processing for direct marketing purposes, you do not have to justify the request and we will immediately stop processing your personal data in accordance with the GDPR.

This is the case, for example, when we send you commercial communications about similar products or services that you have purchased from us, i.e. on the basis of the so-called customer exception. If you do not wish to do this, please let us know by sending us an e-mail or by telling us at the appropriate point when you negotiate the contract and we will not do so or will stop doing so. Similarly, you can use the unsubscribe link at the bottom of the email within our commercial communications.

In other cases, we have the right to review your objection and assess whether your rights take precedence over our legitimate interests.

8.7. Right to withdraw consent

If we process your personal data on the basis of consent, you are of course entitled to refuse and withdraw your consent at any time. In this case, we will not continue with further processing and, unless we are prevented by law from doing so, we will delete your personal data.

However, if we also process your personal data on the basis of another legal title, we are not obliged (sometimes not even allowed) to delete the personal data.

8.8. Right to lodge a complaint with the Office for Personal Data Protection

If you believe that we are processing your personal data unlawfully, you are of course entitled to lodge a complaint with the supervisory authority, which is the Office for Personal Data Protection (www.uoou.cz).

9. HOW TO EXERCISE THE ABOVE RIGHTS?

You can exercise your rights easily by emailing gdpr@trevos.cz. Once we have checked your identity, we will be happy to help you with your rights.

10. IS PERSONAL DATA TRANSFERRED OUTSIDE THE EU?

No, it's not.

11. IS AUTOMATED INDIVIDUAL DECISION-MAKING USED IN THE PROCESSING OF PERSONAL DATA?

No, it's not.

12. SINCE WHEN IS THIS DOCUMENT BINDING?

9. February 2019