Privacy Policy

Information on the Processing of Personal Data

Dear Customers,

With this document, we would like to inform you on the manner in which we handle the personal information you have communicated to us in connection with the selection of the services provided by First Class Publishing a.s., with its registered office at Prague 1, Washingtonova 5, Postcode: 110 00, registered in the Commercial Register maintained by the Municipal Court in Prague, File Reference B 16356, Company ID: 24713252 (hereinafter referred to as “we” or “our company”).

With this document, we comply with our obligation to provide you with the information required under Articles 12, 13 and 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/ES (General Data Protection Regulation) (hereinafter referred to as the “GDPR”) and the obligations under Act No. 101/2000 Coll., on the protection of personal data, as amended. The content of the GDPR may be consulted at: http://eur-lex.europa.eu/legal-content/CS/TXT/PDF/?uri=CELEX:32016R0679&qid=1503598706724&from=CS.

A.        Who is the controller of the personal data you have provided and how can you contact them?

The controller of the personal data you have provided is First Class Publishing a.s..

You can contact us with queries regarding the processing of your personal data personally by phone at +420 607 975 171 or by e-mail at osobniudaje@firstclass.cz.

You may also appoint a representative to consult us regarding the personal data you have provided, who will produce a written power of attorney when interacting with us.

B.        Data protection officer and how you can contact them?

In accordance with the relevant legislation, our company has appointed an officer who is ready to provide you with details as to why and how we process your personal data, how we handle them, and what actions have been put in place to protect the data from misuse or loss.

You can contact our personal data officer by e-mail at poverenecou@firstclass.cz.

C.        What categories of my personal data do you process?

For data subjects who have entered into a service or goods contract with us via our website or at the company’s headquarters, we generally process the following personal data:

  • name,
  • surname,
  • address,
  • phone number(s),
  • email address(es),
  • account social network account(s),
  • IP address associated with you,
  • cookies.

For data subjects who have not entered into a service contract with us, we generally process the following personal data:

  • name,
  • surname,
  • gender,
  • email address(es),
  • account social network account(s),
  • cookies.

D.        How do we process personal data? For what purposes do we process your personal data and what is our legal basis for processing your personal data? What are our legitimate interests when processing your personal data?

We process your personal data in order to fulfil the purpose of the contract you have entered into with us or under which we are about to provide you with services or goods, and in order for us to be able to provide you with the agreed services or goods (processing under Article 6(1)(b) of the GDPR).

Considering the nature of our services, we cannot provide you with our services unless you transmit the following personal data to us:

(a)        Your name and surname,

(b)        Your permanent residential address.

We further process your personal data on account of the legitimate interests of our company. We define these legitimate interests as (a) protecting our rights inherent in the contract concluded if the same is violated by you or (b) if, in connection with the contract concluded, you apply any of your claims with us. Therefore, we process your personal data for the purpose of using them during court or enforcement proceedings relating to our claims and rights in the event you violate the contract, and for the purposes of our legal defense in the event you apply any claim with us in relation to the contract (processing under Art. 6(1)(f) of the GDPR). As for data subjects who have entered into a service contract with us, we will also use their email address for direct marketing to inform them of our new services they may be interested in, on the discounts offered or other benefits. In this context, please note that under Article 21 of the GPRD you have the right to object to such processing of your personal data on account of our legitimate interests as defined above. You can address the objection to our data protection officer (see section B above).

In addition, we process your personal data on the basis of the consent you have granted to us in writing (if you have indeed done so) (processing under paragraph 1(a) of the GDPR). The scope of the personal data processed in this way is detailed in Part B. of this information. This Part applies primarily to data subjects who have not entered into a service or goods contract with us.

On the basis of your consent (presuming you have granted it) we process your personal data for our company’s marketing purposes in the form of our company’s offers sent to you. You may also request more details from our data protection officer.

Your consent is also provided for profiling purposes so that we could offer you the discounts or other benefits provided by our company that will be most relevant to your customer profile. And again, for more information on profiling, please contact our data protection officer.

E.        Who is the recipient of your personal data?

The primary recipient of your personal data is our company.

Considering the nature of the services and goods that will be provided by us under our contract, we will also transmit your personal data, within the necessary extent, to:

  • operators providing or arranging for postal services,

(b)       our legal counsels for the purpose of collecting our receivables and/or protecting our rights in the event you breach the contract and/or for us to defend ourselves against any claims you may raise,

(c)       entities engaging in and/or mandated to collect any receivables,

(d)       state and administrative authorities, at their request, in connection with the exercise of the powers of such authorities.

F.        Will your personal data be transmitted abroad?

Considering the nature of the services provided by us, your personal data will not be transmitted to other Member States of the European Union or to third countries (i.e., countries outside the European Union).

G.        For how long will your personal data be processed by the company?

As for the personal data regarding which you have granted your consent to the processing (where relevant), as such personal data are described in your consent, these will be processed for as long as for how long your consent has been granted. For information on for how long your consent to the processing of your personal data has been granted, you may contact our data processing officer at poverenecou@firstclass.cz.

As for the personal data we process under the relevant provisions of the GDPR (see Part C above), these will be processed for the period necessary for us to provide you with the agreed services or goods of the company, the period necessary for us to demonstrate having provided the services to competent Czech authorities in accordance with the accounting and tax regulations, and for the period of time necessary for us to protect our rights in the event of your breach of the contract, yet in any case at least for the period of limitation regarding any claims, either yours or ours, inherent in or associated with any contract concluded. The length of the limitation period is set out in the Civil Code (Act No. 89/2012 Coll.).

H.        How will your personal data be processed? How will your personal data be protected?

Your personal data will be processed in electronic format within the company’s electronic system or within the electronic system of the persons to whom the personal data will be transmitted.

Your personal data may also be processed in the form of physical documents (paper documents or similar material carriers) to be kept in the company’s filing cabinet.

Please rest assured we have put in place such controls as are necessary to ensure that your personal data are always protected against misuse or loss to the maximum extent.

All persons on the part of our company who are in contact with the personal data have been instructed and tested for the given purpose. The archive where paper documents are kept is secured against unauthorised access. The archive is secured by locks and other physical security controls. Electronically processed personal data are kept in a secured database.

I.          What are your rights in relation to the processing of personal data?

Your rights in relation to the processing of your personal data are as follows:

(a)       If you have agreed to the processing of your personal data by granting a consent, you have the right to revoke the consent. You may revoke your consent by serving a written notice by post to the address of our headquarters (see Section A above) or electronically to osobniudaje@firstclass.cz, indicating your name, surname, date of birth and your permanent residential address in the letter of revocation. The letter of revocation only needs to state “I hereby revoke my consent granted to First Class Publishing a.s. to processing my personal data.”

            In the context of the revocation of your consent to the processing of your personal data, we would like to inform you that our company is still authorised to process your personal data to the extent that the purpose for the processing is based on a reason foreseen by the GDPR other than your consent.

            At the same time, we would like to remind you that the revocation of your consent is without prejudice to the lawfulness of the processing of your personal data based on the consent you have granted. Therefore, even after you revoke your consent, the processing of your personal data as carried out by us during the term of validity of your consent shall still be regarded as lawful.

(b)       You have the right to request access to your personal data within the scope defined under Article 15 of the GDPR.

(c)        You have the right to rectification of the personal data you have provided as per Article 16 of the GDPR.

(c)        You have the right to request erasure of your personal data as per Article 17 of the GDPR.

(e)       You have the right to request restriction of the processing of your personal data under Article 18 of the GDPR.

(f)        You have the right to portability of your personal data to another controller under Article 20 of the GDPR, i.e. you may ask us to transmit your personal data to another controller.

(g)       You have the right to lodge a complaint against us as the controller of your personal data to a supervisory authority, namely the Office for Personal Data Protection (https://www.uoou.cz/) (Article 77 of the GDPR).

If you decide to apply any of the aforementioned rights, we are obliged to check your identity, i.e. to verify whether the enforcement is requested by a person to whom the personal data we process actually apply.

J.         Do you process my sensitive personal data?

As for sensitive personal data, we only process such data if you have provided us with, or disclosed, such data, or if the processing of such data is necessary to protect your vital interests or vital interests of another individual. We generally do not process sensitive personal data.

In other cases, we process such sensitive personal data only if you have granted your consent to such processing.

K.        Is the provision of your personal data a necessary prerequisite for entering into a contract with our company?

As stated in Part D. above, with regard to the nature of your company’s services and the type of services agreed under the contract, we cannot provide our services to you unless you provide us with the data described in Part D. These data are necessary to enter into a contract with us (identification of the contracting parties, identification of the persons to whom the service is to be provided, actual provision of the service) and the contract cannot be concluded unless the data have been provided.

L.        What does the processing of personal data entail?

Processing of personal data denotes any operation or a set of operations involving personal data or files with personal data, whether by mechanical means or automated means. The processing includes collecting, recording, arranging, structuring, storing, customising or altering, searching, viewing, using, making the data available through transmission, spreading or otherwise making the data available, sorting or combining, restricting, erasing or destroying personal data.

M.        Other information

If we change the purpose of processing your personal data, we will notify you in advance.

If we receive your personal information from a third party, we will inform you thereof.

If anything in this information is unclear to you, we are ready to respond to your concerns. If you have any queries, you can consult our data protection officer. For contact information, see Parts A. and B. above.

We will inform you if we make any changes to this information.

This information is available in physical or electronic form from our headquarters and in electronic form at our website at https://www.improovio.com.

*     *     *

Thank you for the attention you paid to this information.

Prague, 1 May 2018

First Class Publishing a.s.