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This Directive deals with the topic of personal data protection following the validity of the General Data Protection Regulation (GDPR).
The General Business Principles of IMPROMAT-COMPUTER s.r.o. (hereinafter referred to as the Company) express our commitment to protect the personal data of our customers, suppliers and business partners. These rules state how this commitment will be implemented and the position of the company in the role of controller of personal data.
We consider the protection of your privacy in the processing of personal data to be an important matter and pay special attention to it. Our privacy policy complies with the legal provisions and our rules of conduct, which apply to the entire company IMPROMAT-COMPUTER s.r.o.
We emphasize cooperation with companies that comply with the rules and legal provisions and carry out their activities in accordance with the Regulation (EU) of the European Parliament and of the Council on the Protection of Personal Data. More about the processors and recipients below.
Employees are bound by confidentiality and internal company rules. The company organizes and provides training to employees on rules and other obligations related to data security and protection, as well as internal audits to check compliance with these rules and policies when working with personal data. Access to personal data is controlled and based on the rights of individual employees as strictly necessary for the work.
With regard to the protection of personal data, we limit the processing of personal data to data that is reasonable and relevant for the relevant business purpose. These are personal data for identification and communication with you and special categories of personal data that are required for our business activities in accordance with the relevant legal provisions.
As part of our activities, we collect personal data from customers, business partners or suppliers in order to uniquely identify a person. They are:
- your name,
- your address,
- your e-mail address,
- your phone number,
- your bank account number,
- ID/TIN
We collect personal information about job seekers and employees in accordance with applicable local laws. These are, for example:
- your name,
- your address,
- your e-mail address,
- your phone number,
- your gender,
- your bank account number,
- your date of birth,
- the number of your identification document,
- data on the state of health,
- health insurance company card
- family members
- pension insurance
- life insurance
- photo
We work with your personal data:
- for the period necessary to fulfil the relevant business purpose
- for the period necessary to comply with the statutory regulations (i.e. at least the duration according to the archival act)
- for the determination, exercise or defence of legal claims
After the expiration of the specified period for processing and storage of personal data, your data will be securely deleted or destroyed, anonymized or transferred to an archive.
The data we process is mainly obtained from the personal data subject. However, we can also learn about you from other sources to make sure that what we know about you is true and complete.
We process personal data that are communicated to us at the conclusion of the contract and during its duration directly with you or, with your consent, through our employee. In the case of establishing a new business relationship, we process your personal data communicated when you enter into a contract.
If you are our employee or job seeker, the source of the data may be references from former employers or references from online sources, such as social networks such as LinkedIn or other job portals.
We may obtain your personal data as well as sensitive personal data for the purpose of fulfilling a contractual obligation.
Furthermore, we process personal data lawfully obtained from public registers or in cooperation with government bodies and institutions (within the meaning of Act No. 253/2008 Coll. on certain measures against the legalization of proceeds of crime and terrorist financing).
Personal data may also be processed if your data is provided by a third party to whom you have given consent or directly a power of attorney for this purpose. We may also supplement the information with data published by you from publicly available sources.
The Company processes personal data only to the extent necessary to fulfill the relevant business purpose. Personal data may be processed in one or more of the following circumstances:
If you are dealing with IMPROMAT — COMPUTER s.r.o. as a customer, business partner or supplier, we will ask you to provide personal data for the following purposes:
- conclusion, administration and performance of contracts,
- management of relations, provision of (online) services and contacts,
- compliance with legal and regulatory obligations.
If you are a jobseeker or a former or permanent employee, your personal data will be processed for the following purposes:
- performance of employment contracts, contractual obligations and human resources management,
- internal management, including evaluation of the organization or corporate culture,
- health and satisfaction of employees,
- fraud detection, prevention,
- compliance with legal and regulatory obligations,
- protection of the vital interests of employees,
- analysis of employee profiles,
- acceptance and filling of vacancies, incl. former employees and job seekers.
If it is not one of the variants according to paragraph 4.1 or consent is required by another legal requirement, consent will be obtained from the owner of the personal data before processing it. When granting consent, we will provide you with the following information:
• processing purposes for which consent is required,
• our contact details as the controller of personal data,
• Your rights in connection with the processing of personal data.
If the processing is reasonably necessary to process the request, the consent of the data subject is assumed (for example, the use of the applications of IMPROMAT-COMPUTER s.r.o., personal visit or participation in a social event).
Consent should be the free, specific, informed and unambiguous consent of the data subject to the processing of personal data concerning him, in the form of a written statement, also made electronically, or an oral statement.
The data subject has the right to refuse or withdraw consent to the processing of personal data at any time.
With the entry into force of the General Data Protection Regulation, the owners (subjects) of personal data have the right to:
- information and access to personal data,
- data portability,
- restriction of processing,
- correction and deletion of personal data,
- information regarding the correction or erasure of personal data or restriction of processing,
- raise an objection,
- exclusion from automated decision-making, including profiling.
The roles in which we can record your personal data and identify you uniquely are:
- you are our client — interested in our services,
- you are our supplier — service and technical support provider, sub-process processor,
- you are our employee — permanent and former employee or job seeker.
If you are another natural person whose data has been obtained in the course of our activities, these data are not further processed and we are not able to determine the unambiguous identification of your person based on these personal data. This data is used only for informational purposes of our company and is not further transmitted to other processors or third parties.
Furthermore, we would like to inform you that when exercising your rights in connection with the protection of personal data, there may be some limitation of our activities towards you and our contractual relationship.
To exercise the rights of personal data subjects, we accept requests at our address IMPROMAT-COMPUTER s.r.o., Tomáš Bati class 5267, 760 01 Zlín, or at the electronic address gdpr@impromat.cz.
The application can be accepted in the case of unambiguous identification of the person, both in written and electronic form. Otherwise, we will ask you to provide additional documents for correct identification of your person.
Information and access to personal data
In the event that we obtain your personal data for processing directly from you, we are obliged to inform you of the following:
- identity and contact details of IMPROMAT-COMPUTER s.r.o.,
- the purposes of the processing for which the personal data are collected and the legal basis for the processing,
- the legitimate interests of the controller or of a third party where these interests are superior to the interests and rights of the data subject
- the possible recipients of the personal data and the intention to transfer your personal data to a third country or international organisation,
- the period for which the data will be used or stored,
- an enumeration of your rights, including the right to lodge a complaint,
- whether the provision of personal data is a legal or contractual requirement, i.e. when the data is processed on the basis of the law and when on the basis of your consent
- the fact that automated decision-making takes place, including profiling
In the event that your personal data has not been obtained directly from you, we are also obliged to provide you with information about the category of personal data concerned and the source from which the data was received.
Portability
The owner of the personal data has the right to obtain the personal data that he has provided to us in a structured form in a commonly used and machine-readable format. At the same time, as the owner of personal data, you have the right to transfer this data to another controller. The transfer of personal data is possible only for personal data that are obtained on the basis of consent or contract and are processed automatically.
This right cannot be applied to the processed data for the fulfilment of a task carried out in the public interest or in the exercise of public authority entrusted to the controller.
The transfer of data shall not adversely affect the rights and freedoms of other persons.
Processing Restrictions
As the data owner, you have the right to have us restrict the processing of personal data if:
- deny the accuracy of personal data,
- you suspect the unlawful processing of personal data, but you refuse to delete such personal data and instead request the restriction of its use,
- we no longer need personal data for processing purposes, but you as a data subject require it for the establishment, exercise or defence of legal claims,
- object to processing — the processing will be limited to the time necessary to verify whether the legitimate reasons of the controller outweigh the legitimate reasons of the data subject.
We would like to inform you that in the event of a request to restrict the processing of your personal data, our activities towards you and our contractual relationship may be restricted.
Correction and deletion of personal data
As a data subject, you have the right to correct inaccurate or outdated personal data concerning you.
You can correct your personal data by sending a request to our contact details.
You can exercise the right to erasure, or the right to be forgotten, if:
- personal data are no longer necessary for the purpose for which they were collected and processed,
- you withdraw the consent on the basis of which we process the data and there is no further legal reason for the processing,
- personal data are processed unlawfully,
- personal data were collected under the conditions of granting the consent of the child in connection with the services of the information society
In the event that the right to delete personal data that has been disclosed by us or transferred to third parties is exercised, we will take the necessary steps to contact all recipients of your personal data and communications so that they delete all links.
Your right to erasure can only be exercised after the specified period for the determination, exercise or defence of legal claims has expired.
Information regarding the correction or erasure of personal data or restriction of processing
If you as the data owner so require, we will inform you of the recipients of your personal data as soon as your data has been disclosed to them. In addition, we will inform you of corrections, erasures, or if there is a restriction on the processing of personal data concerning you.
Right to object
You may object only in certain specific cases, in relation to:
- processing of personal data that is necessary for the performance of a task carried out in the public interest or in the exercise of public authority or for the purposes of our legitimate interests or those of a third party (including profiling),
- processing for direct marketing purposes (incl. profiling),
- processing for scientific or historical research purposes or for statistical purposes.
Exclusion from automated decision making, including profiling
As the owner of personal data, you have the right not to be subject to any decision based solely on automated processing. It is about protecting against a potentially adverse decision that could be taken without human intervention.
We hereby confirm that, according to legal definitions, automated decision-making, including profiling, does not take place in our company.
In the case of providing information services to a minor, the child's consent to the processing of his/her personal data is considered lawful if the child has reached the age of at least 13 years. The consent of a child under the age of 13 must be expressed or approved by a legal representative (the person with parental responsibility for the child).
The above does not apply to the general contract law of the Member States, such as the rules concerning the validity, conclusion or effects of a contract in relation to the child.
To exercise the rights of personal data subjects, we accept requests at our address IMPROMAT-COMPUTER s.r.o., Tomáš Bati class 5267, 760 01 Zlín, or at the electronic address gdpr.computer@impromat.cz.
In the event that our contractual relationship is based on an agreement with your employer, we act in this relationship as the processor of your personal data. In order to exercise your rights, you must contact your employer as a personal data controller, who will provide us with any more detailed information about the processing of personal data.
If you are a self-employed person with whom we cooperate on the basis of a contractual relationship, in this case we are the controllers of your personal data and you can exercise your rights with us.
Information and access to personal data
In the event that we obtain your personal data for processing directly from you, we are obliged to inform you of the following:
- identity and contact details of the company IMPROMAT — COMPUTER s.r.o.,
- the purposes of the processing for which the personal data are collected and the legal basis for the processing,
- the legitimate interests of the controller or of a third party where these interests are superior to the interests and rights of the data subject
- the possible recipients of the personal data and the intention to transfer your personal data to a third country or international organization,
- the period for which the data will be used or stored,
- an enumeration of your rights, including the right to lodge a complaint,
- whether the provision of personal data is a legal or contractual requirement, i.e. when the data is processed on the basis of the law and when on the basis of your consent
- the fact that automated decision-making takes place, including profiling
In the event that your personal data has not been obtained directly from you, we are also obliged to provide you with information about the category of personal data concerned and the source from which the data was received.
As our service provider, you have the right to information and access to the data that will be provided to you at the time of the conclusion of the contract when collecting personal data. In the same way, you will be provided with information after the correction, deletion or restriction of processing of personal data. In all and other cases, we will provide you with information no later than one month after the fact.
Portability
The owner of the personal data has the right to obtain the personal data that he has provided to us in a structured form in a commonly used and machine-readable format. At the same time, as the owner of personal data, you have the right to transfer this data to another controller. The transfer of personal data is possible only for personal data that are obtained on the basis of consent or contract and are processed automatically.
This right cannot be applied to the processed data for the fulfilment of a task carried out in the public interest or in the exercise of public authority entrusted to the controller.
The transfer of data shall not adversely affect the rights and freedoms of other persons.
Processing Restrictions
As the data owner, you have the right to have us restrict the processing of personal data if:
- deny the accuracy of personal data,
- you suspect the unlawful processing of personal data, but you refuse to delete such personal data and instead request the restriction of its use,
- we no longer need personal data for processing purposes, but you as a data subject require it for the establishment, exercise or defence of legal claims,
- object to processing — the processing will be limited to the time necessary to verify whether the legitimate reasons of the controller outweigh the legitimate reasons of the data subject.
We would like to inform you that in the event of a request to restrict the processing of your personal data, our activities towards you and our contractual relationship may be restricted.
Correction and deletion of personal data
As a data subject, you have the right to correct inaccurate or outdated personal data concerning you. You can correct your personal data by sending a request to our contact details.
You can exercise the right to erasure, or the right to be forgotten, if:
- personal data are no longer necessary for the purpose for which they were collected and processed,
- you withdraw the consent on the basis of which we process the data and there is no further legal reason for the processing,
- personal data are processed unlawfully,
- personal data were collected under the conditions of granting the consent of the child in connection with the services of the information society
In the event that the right to delete personal data that has been disclosed by us or transferred to third parties is exercised, we will take the necessary steps to contact all recipients of your personal data and communications so that they delete all links.
Your right to erasure can only be exercised after the specified period for the determination, exercise or defence of legal claims has expired.
Information regarding the correction or erasure of personal data or restriction of processing.
If you as the data owner so require, we will inform you of the recipients of your personal data as soon as your data has been disclosed to them. In addition, we will inform you of corrections, erasures, or if there is a restriction on the processing of personal data concerning you.
Right to object
You may object only in certain specific cases, in relation to:
- processing of personal data that is necessary for the performance of a task carried out in the public interest or in the exercise of public authority or for the purposes of our legitimate interests or those of a third party (including profiling),
- processing for direct marketing purposes (incl. profiling),
- processing for scientific or historical research purposes or for statistical purposes.
We will expressly notify you of the right to object (except for the last purpose of processing) at the latest at the moment of the first communication, clearly and separately from other information.
Exclusion from automated decision making, including profiling
As the owner of personal data, you have the right not to be subject to any decision based solely on automated processing. It is about protecting against a potentially adverse decision that could be taken without human intervention.
We hereby confirm that, according to legal definitions, automated decision-making, including profiling, does not take place in our company.
To exercise the rights of personal data subjects, we accept requests at our address IMPROMAT-COMPUTER s.r.o., Tomáš Bati class 5267, 760 01 Zlín, or at the electronic address gdpr.computer@impromat.cz.
In the event that you become our employee, the data of third parties is collected. Third party means family members, such as your children's data for tax credits, contact details, and more.
Information and access to personal data
In the event that we obtain your personal data for processing directly from you, we are obliged to inform you of the following:
- identity and contact details of IMPROMAT-COMPUTER s.r.o.,
- the purposes of the processing for which the personal data are collected and the legal basis for the processing,
- the legitimate interests of the controller or of a third party where these interests are superior to the interests and rights of the data subject,
- the possible recipients of the personal data and the intention to transfer your personal data to a third country or international organisation,
- the period for which the data will be used or stored,
- an enumeration of your rights, including the right to lodge a complaint,
- whether the provision of personal data is a legal or contractual requirement,
- the fact that automated decision-making takes place, including profiling.
In the event that your personal data has not been obtained directly from you, we are also obliged to provide you with information about the category of personal data concerned and the source from which the data was received.
As our permanent employee, you have the right to information and access to such data, which will be provided to you at the time of the validity of the employment contract.
If we register you only as a job seeker, your data is not further processed as structured data after the expiration of your interest in employment (you are a systemically untraceable person). Your personal data and information about you are stored on the job portals through which you responded to our job offer only for a certain period of time.
Portability
The owner of the personal data has the right to obtain the personal data that he has provided to us in a structured form in a commonly used and machine-readable format. At the same time, as the owner of personal data, you have the right to transfer this data to another controller. The transfer of personal data is possible only for personal data that are obtained on the basis of consent or contract and are processed automatically.
This right cannot be applied to the processed data for the fulfilment of a task carried out in the public interest or in the exercise of public authority entrusted to the controller.
The transfer of data shall not adversely affect the rights and freedoms of other persons.
Processing Restrictions
As the data owner, you have the right to have us restrict the processing of personal data if:
- deny the accuracy of personal data,
- you suspect the unlawful processing of personal data, but you refuse to delete such personal data and instead request the restriction of its use,
- we no longer need personal data for processing purposes, but you as a data subject require it for the establishment, exercise or defence of legal claims,
- object to processing — the processing will be limited to the time necessary to verify whether the legitimate reasons of the controller outweigh the legitimate reasons of the data subject.
We would like to inform you that in the event of a request to restrict the processing of your personal data, our activities towards you and our contractual relationship may be restricted.
Correction and deletion of personal data
As a data subject, you have the right to correct inaccurate or outdated personal data concerning you.
Job seekers and former employees may request correction of personal data by contacting the HR Manager at her contact details. As our employee, you have the opportunity to correct your personal data directly in the employee system with the attachment of additional documents, when the data will be updated after approval by the personnel manager. The data can also be updated according to the agreement with the personnel manager in an individual way.
You can exercise the right to erasure, or the right to be forgotten, if:
- personal data are no longer necessary for the purpose for which they were collected and processed,
- you withdraw the consent on the basis of which we process the data and there is no further legal reason for the processing,
- personal data are processed unlawfully,
- personal data were collected under the conditions of granting the consent of the child in connection with the services of the information society
In the event that the right to delete personal data that has been disclosed by us or transferred to third parties is exercised, we will take the necessary steps to contact all recipients of your personal data and communications so that they delete all links.
Your right to erasure can only be exercised after the specified period for the determination, exercise or defence of legal claims has expired.
Information regarding the correction or erasure of personal data or restriction of processing
If you as the data owner so require, we will inform you of the recipients of your personal data as soon as your data has been disclosed to them. In addition, we will inform you of corrections, erasures, or if there is a restriction on the processing of personal data concerning you.
Right to object
You may object only in certain specific cases, in relation to:
- processing of personal data that is necessary for the performance of a task carried out in the public interest or in the exercise of public authority or for the purposes of our legitimate interests or those of a third party (including profiling),
- processing for direct marketing purposes (incl. profiling),
- processing for scientific or historical research purposes or for statistical purposes.
We will expressly notify you of the right to object (except for the last point of processing) at the latest at the moment of the first communication, clearly and separately from other information.
Exclusion from automated decision making, including profiling
As the owner of personal data, you have the right not to be subject to any decision based solely on automated processing. It is about protecting against a potentially adverse decision that could be taken without human intervention.
We hereby confirm that, according to legal definitions, automated decision-making, including profiling, does not take place in our company.
To exercise the rights of personal data subjects, we accept requests at our address IMPROMAT-COMPUTER s.r.o., Tomáš Bati class 5267, 760 01 Zlín, or at the electronic address gdpr.computer@impromat.cz.
The application can be accepted in case of unambiguous identification of the person.
We will process your requests/complaints without undue delay and we will inform you of the processing within 30 days of receiving the request/complaint.
Certain rights and obligations of IMPROMAT-COMPUTER s.r.o., may be superior to the rights of individuals if, under the given specific circumstances, there is a legitimate interest that outweighs the interest of the individual (priority interest). The overriding interest exists if necessary:
- protect the legitimate business interests of IMPROMAT-COMPUTER s.r.o., including:
- prevent or investigate violations of the law, actual or presumed on the basis of reasonable suspicions (including cooperation with e.g. PCR), contracts, or principles of our company,
- otherwise protect or defend the rights of the company, its employees or other persons.
In the course of our activities, your personal data may be provided:
- legal entities, e.g. courts, the Czech National Bank, bailiffs or insolvency administrators,
- other bodies for the protection of rights (e.g. courts, contract doctors, investigators, judicial commissioners, etc. ),
- processors who guarantee the technical and organizational security of the protection of personal data,
- with your consent to cooperating business partners.
Personal data are transferred to third parties only to the extent necessary for the fulfilment of the commercial purpose.
IMPROMAT-COMPUTER s.r.o. cooperates only with processors who provide sufficient guarantees to implement appropriate technical and organizational measures so that the processing meets the legal requirements and to ensure the protection of the rights not only of our clients, but also of employees.
Administrator:
- IMPROMAT-COMPUTER s.r.o., Tomáš Bati 5267, 760 01 Zlín.
Processors:
- Public authorities and courts (especially in compliance with our legal obligations)
- Auditors or other independent persons ensuring compliance with legal obligations
- Information technology providers or operators
- Providers of services necessary for the performance of our activities (administrative activities, archiving, legal advice, debt management, etc.)
- Health service providers (in the investigation of insurance claims)
This Article lays down additional rules for the transfer of personal data to third parties established in a country that is not expected to provide an adequate level of protection of personal data (countries with inappropriate status).
Personal data may be transferred to a third party located in a country with an inappropriate status only if:
- a contract has been concluded between IMPROMAT-COMPUTER s.r.o. and the relevant third party, which provides guarantees that the third party will comply with a similar level of protection as established in our company,
- the third party has been certified under a code of conduct or certification programme recognised under applicable law for providing an “adequate” level of data protection,
- a third party has established binding corporate rules or a similar mechanism to control the transfer of personal data, which provides appropriate safeguards under applicable law,
- the transfer is necessary for the conclusion or performance of a contract concluded in the interests of the individual between IMPROMAT-COMPUTER s.r.o. and a third party,
- the transfer is necessary for the performance of a contract with a customer, supplier or business partner, or at the request of the customer, supplier or business partner prior to the conclusion of the contract,
- the transfer is necessary to protect the vital interest of the individual,
- the transfer is necessary for the establishment, exercise or defence of legal claims,
- the transfer is necessary to satisfy a serious reason in the public interest,
- the transfer is required by any law to which IMPROMAT-COMPUTER s.r.o. is subject
To the extent permitted by law, the last three points above require the prior consent of the management of IMPROMAT-COMPUTER s.r.o.
In our company, internal audits of the processes and procedures that include the processing of personal data are carried out in order to comply with the established principles and rules.