What is personal data and who is the data subject?
The law defines personal data as any information about an identified or identifiable natural person; an identifiable natural person is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, a network identifier or to one or more specific elements of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (hereinafter also referred to as "data"). If you enter into a contract with us, you are a data subject within the meaning of applicable law and the data we process about you is personal data.
Personal data is not anonymous and/or aggregated data, i.e. data that cannot be linked to a specific person from the outset or by virtue of the processing, but is the result of the aggregation of a number of individual pieces of information.
When you become a customer using our services, we will ask you to disclose your personal data.
The data we process about you depends on the products and services you have ordered from us, the way you use those products and services and your interaction with us, or depending on the data we have received from third parties, and only on your consent for third parties to share.
Personal Information
Our company processes personal data generally referred to as personally identifiable information. The list of data we provide here does not imply that our company processes data about everyone to that extent. It is only to fulfil an information obligation, with the understanding that the scope of the data is always individualised to the specific customer, except for data that our company is required by law to process.
At the same time, for the sake of completeness, we also list data relating to legal entities, which are not personal data within the meaning of the law.
Personal and identification data means, in particular: name, surname, address, date of birth, birth number/national identifier, age, address (gender), business name, registered office/place of business, registered office of the organisational unit, name, surname and residence of persons authorised to act for the legal entity identification number, tax identification number, contact telephone number, billing data (e.g. Type, method and volume of services used), e-mail address, bank account and other data legitimately obtained about the customer.
Only personal data of natural persons are protected under the applicable data protection legislation.
Operational data
Operational data is defined by the Electronic Communications Act as any data processed for the purpose of transmitting a message over electronic communications networks or for billing purposes.
So what is traffic data? Operational data is everything that is needed for the customer to send emails, SMS text messages or use other services provided by our company. It is therefore, for example, the e-mail addresses of the addressees, the telephone numbers of the addressees and the sender, the address of the data connection (e.g. IP address), the address of the data connection, including the traffic location data, which is the necessary information about from and to which location in the network the message was transmitted, while it is data generated only for the transmission of messages.
Location data
Location data is defined by the Act as any data processed on an electronic communications network or electronic communications service that identifies the geographic location of a telecommunications terminal equipment of a user of a publicly available electronic communications service.
Location data means any data processed on an electronic communications network and identifying a geographical area. Thus, location data is data about the location of the customer's terminal equipment, i.e. data about the network to which the customer is connected.
Other processed data
At the same time, we collect written or telephone communications between you and our company regarding your complaints about products or services, your inquiries about our services, etc. We also keep your contact up to date with the services you have ordered and are using. If you provide us with your personal data when ordering products or services, when speaking to sales representatives or in connection with a marketing event or offer from our company, you can be sure that we will only use it in accordance with the law to ensure and maintain contact between you and our company.
Without disclosing any personal information to us, you can look at our website (except for cookies to keep our site running properly), talk to help desk operators or sales representatives.
Why, on what basis, for how long and what personal data do we process?
Performance of the contract
If you choose to use our services or products and enter into a contract with us, whether under our GTC by way of registration or other similar contract, our company is obliged to obtain your personal or identification data for the purpose of fulfilling our contractual obligations.
We process this data in full for a period of 6 months after the termination of the contract and then in a limited form for the general limitation period, i.e. 3 years.
Performance of legal obligations
On the basis of applicable law, we are obliged to process some of your personal data, such as data that arises in the context of the provision of electronic communications services, the so-called operational and location data, as well as other data - mainly personal, contact, identification, payment, data on the services used, billing and, which are used for the purposes of providing electronic communications services, related services, payment transactions, providing interconnection and access to the network, billing and carrying out related actions, accounting and tax purposes, identification of abuse of the network or services, debt recovery, sale of third party products or services through our network or their billing, to identify the owners of the campaign in case of a request from the Office of the OCC;
The time period for processing this personal data varies according to the individual laws under which the processing occurs, e.g. for tax purposes it is 11 years, for location and traffic data it is 6 months from the moment the data is generated. However, we only process your personal data for the necessary period of time required by law.
Legitimate interest of the controller
The legal title of legitimate interest of the controller applies to such processing of personal data where the legitimate interests or rights of the controller (our company) and/or third parties outweigh the interests or rights of the data subject (our customers, taking into account the reasonable expectations of the data subject based on his/her relationship with the controller. This includes, for example, the protection of the controller's property, the life and health of employees, persons entering the controller's premises, the recovery of debts, etc. Depending on the purpose, this may include your personal, contact or identification data, data on invoices paid, data on the services and products you use and how you use them, data obtained from publicly available sources (registers and databases) and possibly other data.
We only process this data for the duration of the purpose, e.g. for the period of debt recovery.
Consent given for marketing and commercial purposes
If you give us consent to process your personal data, including traffic and location data, for marketing and business purposes, we will be able to offer you a targeted offer of new services, products, discounts or other attractions tailored to you. Similarly, if you give us your consent to receive commercial offers from third parties, we will be able to offer you from time to time advantageous offers for services or goods from our business partners.
Your provision of the above consents is voluntary, free and unconditional. You can learn more about the processing of your personal data based on consent in the Consent Process section.
We only process personal data provided on the basis of consent until you withdraw your consent, it is strictly necessary for the purpose of the processing or unless otherwise specified in the text of the consent.
How we process your personal data
Data may be processed automatically or manually.
We collect your personal data when you purchase a product or service from us (including sales via the internet, telephone, in-store or any other sales channel), register for a product or service, order information materials, brochures, magazines and similar services, that you ask for more information about a product or service or contact us with any other query and request clarification, that you participate in any game or contest run by our company, that you use our services or products or visit our website.
We may also collect your data from other sources (known as indirect collection), such as the commercial register, trade register and other business register, debtors' registers, etc., all in accordance with the law.
Consent process
As part of the contract process or at any time thereafter, you have the right not to consent to our processing of your personal data, for processing that is voluntary, or to withdraw consent at any time.
You always consent to the processing of data for a specific purpose, namely
Consent to receive commercial offers from third parties, which means that our company also offers third party products that may be of interest to you, such offers may be tailored to you; the third party never has access to your personal data.
We will be happy to provide you with information on what consents you have given at any time upon request.
Marketing and tailoring our services to your needs
Direct marketing and marketing
As our customer, we will inform you about new products and services, send you newsletters or official communications, invite you to participate in surveys or inform you about offers, promotions, draws or competitions. We customize these messages based on the type of products and services you have purchased from us and how you use our services.
We may further customize these messages based on your use of our services, location data and web browsing history, provided that we have your consent to process this data for this purpose.
If you give your consent, we will also inform you about products and services from other companies that we think may be of interest to you. However, in this case we do not pass on your data.
We will contact you, for example, by post, online, by telephone (to the telephone numbers you and you provide) or by notifications via our apps.
You can change your consent settings for receiving marketing communications and for using your data to tailor these communications at any time.
Option to share your data
Customer (natural person)
We always disclose information regarding your personal data to you, the customer, only after sufficient identity verification. Therefore, our staff have mandated procedures to credibly verify the interviewer and without this, they are not authorized to provide you with the information.
Third parties
We may only disclose your personal data and/or account information to third parties under the terms of the law and in accordance with the Terms and Conditions, this Policy and any other documents we agree directly with you.
Our Company will not, of course, pass your personal data to third parties (other than those listed below) unless (a) you give us your consent to do so, (b) it is necessary to provide the services or products you have ordered or use, (c) it is required by law, or (d) our Company is authorized by law to do so.
Your personal information may only be disclosed to the following:
Companies that provide electronic communications services (Spam filters, Blacklist administrators, mail servers, etc.);
Processors, i.e. an entity that processes personal data on the basis of a specific law or a mandate from the controller (e.g. marketing agencies, call centres, debt collection agencies, etc.);
If we process your personal data outside the Czech Republic, we will comply with all legal regulations and fulfil all obligations imposed on us by law.
Recipients / Processors / Partners
Recipient means any person to whom the data is disclosed, either on the basis of (a) the law or (b) a contract for the processing of personal data (processors).
Where data is transferred to processors, these persons are obliged to comply not only with the applicable law but also with the data processing contract, including the so-called minimum security requirements.
Our suppliers and partners must also comply with the regulations and arrangements set out, especially for working with information that is personal data.
See the List of processors to whom data is transferred. This list is subject to change as the business relationship between our company and its suppliers changes.
Right to rectification of personal data
If your data is not accurate, you have the right to have it corrected. Therefore, if the data we hold about you requires updating or if, in your opinion, it is inaccurate, you can contact us and we will make the necessary corrections.
Right of access to personal data
You have the right to know what data we process about you and to request a copy of your personal data that our company holds. The request can only be made in your capacity as a natural person, where we are absolutely certain that you are the right person. We may charge a reasonable fee for additional copies based on the administrative costs incurred.
Right to data portability
You have the right to obtain the data you have provided in certain circumstances.
Right to object to the use of personal data
In certain circumstances, you also have the right to object to our processing of your personal data.
This includes where we process your data on the basis of our legitimate interest. You can also object to direct marketing or satisfaction surveys.
Right to restrict the use of your data
You can exercise this right if you believe that the personal data we hold about you is inaccurate or that we should not process it in your opinion. You have the right to request restriction of processing in certain circumstances.
Right to erasure
Our company aims to ensure that your data is only processed and retained for as long as necessary. In certain circumstances, you have the right to request the erasure of your personal data that we hold. If you believe that we are keeping your data for longer than is strictly necessary, we recommend that you first check whether your contract with our company has been terminated, which you can do by contacting our customer service helpdesk. Even if your contract with our company has been terminated, we may still have legitimate reasons for processing your personal data.
How to make a complaint or exercise your rights
To contact us about any of your rights or to complain about how we use your data, please email the Data Protection Officer at dpo@emailkampane.cz or visit us during normal business hours at our registered office. We aim to do our best to accommodate you, but if you are still not satisfied you can contact the Data Protection Authority, for more information visit: https://www.uoou.cz/.
Identification of the data subject
In order for us to be able to comply with some of your requests to exercise your rights, we need to be absolutely sure that it is you, the relevant data subject, who is exercising those rights. We have set up our rights processes to ensure that someone other than you does not exercise your right or that someone other than you has access to your data. Identifying the data subject therefore protects you, but it also protects us.
Contacts for exercising rights and other data protection related questions
We will be happy to answer your questions about personal data protection at dpo@emailkampane.cz or at our headquarters at Lovosická 711/30, Prague 9, 190 00 during normal business hours and by prior arrangement.