INFORMATION MEMORANDUM

to process the personal data of users of the portal www.chcipraci.cz valid and effective from 30.4. 2018

Dear client,

We would like to inform you due for your use of the web services of the portal www.chcipraci.cz of the company Business Web Solutions LLC, the State of Delaware, 2711 Centerville Road, STE 400, Wilmington, ZIP code: 19808, USA (hereinafter referred to as the "BWS") that we record your personal data in connection with managing, distributing and advertising our products and services.

The Information Memorandum describes general principles for processing personal data of the users of the web services of the portal www.chcipraci.cz (hereinafter referred to as the "Portal"), types of data we handle and manage, for which purposes we use it, to whom we can provide it, where you can obtain information about your personal data that we process, a short guide for individuals on your data protection rights. BWS acts as the administrator or processor of personal data. BWS collect, process, preserve personal data in accordance with the Act No. 101/2000 Coll., on Personal Data Protection, Act No. 127/2005 Coll. on Electronic Communications, Act No. 480/2004 Coll. on Certain Information Society Services, as amended and other laws and regulations. On May 25, 2018 came into full force Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

  1. General Information

BWS is aware of the legal obligations regarding processing personal data of the users in accordance with the valid legislation of the Czech Republic. In this regard, we could not offer and provide you our services without obtaining your personal data. We also process personal data of the users beyond the statutory obligations in order to provide you our customer care and sending to your address a special offer of our products and services. We need your consent to do so. If you do not grant consent in this case, our product or service range may be limited for you or otherwise modified depending on the extent of personal data we will be authorized to process. We inform all users about any restrictions or modifications. If not explicitly stated otherwise, all information disclosed herein also concerns processing personal data of potential users, i.e. we have not yet concluded contract with them but we are already in contact with these potential or former users.

1.1. Principles relating to processing of personal data

When processing your personal data, we honor and respect all standards of personal data protection, and adhere in particular to the following principles:

(a) We always process your personal data for clear and comprehensible purposes, by agreed means, in the prescribed manner, only for the time necessary to fulfill the purposes for which they were collected; we only process accurate personal data of the users for fulfilling specific purposes;

(b) We process your personal data in a manner to ensure the appropriate security to prevent unauthorized or accidental disclosure or access to personal data, alteration, destruction or accidental loss, unauthorized data transmission or processing, and other misuse;

(c) We always comprehensively inform you about processing your personal data on your request, accurate and complete information about the circumstances of data processing, or your other related rights;

(d) BWS shall comply with appropriate technical and organizational measures to ensure a level of security appropriate to all possible risks; all persons who come into contact with personal data of the users are under an obligation to observe confidentiality of information obtained in connection with the processing of such data.

  1. Information on processing of personal data

2.1. Information about administrator

The administrator of your personal information is the company Business Web Solutions LLC, the State of Delaware, 2711 Centerville Road, STE 400, Wilmington, ZIP code: 19808, USA.

2.2. The purpose of the processing and lawful basis for processing

2.2.1. Processing of personal data without your consent

This is usually the case where you are required to provide certain personal data in order to obtain our products or services, or when we are authorized to process your personal data obtained in another way. We are authorized to process your personal data without your consent for the following purposes:

(i) fullfilling archival obligations;

(ii) concluding or performing a contract with you
(iii) resolving any disputes.

2.2.2.  Processing of personal data with your consent

This is usually a situation where you voluntarily agree to process personal data you have provided or are otherwise obtained. If you do not grant consent, this may be the reason that the Portal will not be able to provide you certain products or services.
Based on your consent, BWS processes your personal data for the following purposes:

(a)  customer care; these are activities that do not constitute performance of any existing contractual duty or other legal framework for processing personal data which include the following activities:

(i)  market research;
(ii) monitoring of behavior of the users on web Portal via cookies;

(b)    providing products or services of the Portal target to very specific group of users across  channels, by post or through electronic devices (including email and text messages sent to mobile phones), by phone calls or through a website.

2.3.   The extend for processing personal data of the users

BWS processes your personal data to the extent necessary to meet the above-mentioned purposes. We mainly process contact information and identification data. Further details on extent the personal data of the users is given in Annex 1 to this Information Memorandum.

2.4. Data processing methods

Data processing methods used by BWS is a combination of automated and manual processing, including algorithmic processing. One of the methods of processing personal data is also automated processing of personal data (profiling) for evaluating personal aspects of the users. We do this especially for the purpose of statistical analysis and subsequent marketing campaigns.

2.5. Recipients of personal data

Your personal data are made available to BWS employees especially in connection with the job performance when it is necessary to use personal data of the users in a certain extent and in compliance with all safety measures.

In addition, your personal data are tranferred to third parties involved in the data processing  of the Portal users or, where appropriate, such personal data are made available for other purposes within the confines of the law. Prior to any transfer of your personal data to a third party, we always enter into a written agreement with that person in which we specify processing of personal data to ensure that BWS complies with their statutory obligations.

2.5.1.  In accordance with the relevant legislation BWS is entitled or directly, without your consent, is obliged to transfer your personal data to:

(a) the competent state administration authorities, courts and law enforcement authorities in criminal proceedings in order to fulfill their duties and for the purposes of enforcement;

(b) other persons to the extent set forth by law, such as third parties for the purpose of our claim recovery against the user.

2.6. The period for processing of personal data

BWS process personal data of the users only for the time necessary to fulfill the purposes for which they were collected. We are continually evaluating whether it is still necessary to process certain personal data needed for specific purposes. If we acknowledge they are no longer needed for any of the purposes, data will be deleted. Processing personal data for the purposes of:

(a)  performance of the contract during the existence of the contractual relationship with the client; the relevant personal data are usually usable for five years;

(b) providing products or services during the existence of the contractual relationship with the client; the relevant personal data are usually usable for five years; the transfer of personal data to third parties, the processing period by third party is determined in accordance with the applicable laws and rules set out in this Information Memorandum;

(c) customer care process during the existence of the contractual relationship with the client; the relevant personal data are usually usable for five years.

2.7.  The right to withdraw consent

Information Memorandum explains why we need to collect your personal data. In addition to the specific purposes we may process personal data with the consent of the individuals concerned. You are not obliged to grant consent to BWS with processing your personal data. You  have the right to withdraw your consent. We may also process certain personal data for specific purposes without your consent. In the case you withdraw your consent, we will cease to process the relevant personal data for specific purposes which require your consent, but we may be authorized or even obliged to continue processing the same personal data for other purposes.

If you do not grant or withdraw your consent, we may:

(a) adequately adjust the availability, terms and conditions and scope of products and services, or

(b) refuse to provide you the products or services if we find that such consent is necessary to do so under these terms and conditions.

In case you wish to withdraw your declared consent and, thus, terminate the processing of personal data partially or completely, please send email on to this address: dpo@chcipraci.cz.

2.8.  The sources of personal data

The personal data of the users are obtained in particular:

(a)  from the users themselves, directly or indirectly. For example, while using the Portal available to the clients providing information about products and services, etc.;

(b)  from publicly available sources (public registers, records or lists);

(c)  from third parties authorized to handle and proces personal data of clients and transfer these data to BWS

(d)  from potential buyers of services with the Portal for marketing events and campaigns;

(e)  from their own activities by processing and evaluating other personal information of users.


2.9. Your right of access the personal data and protection of users' rights

If you ask us for information regarding the processing of your personal data, on your request we shall provide you all information that we record about you without undue delay. We are entitled to demand reimbursement of a reasonable fee incurred in providing such information.

If you discover or suspect BWS or a third party involved in the processing of data, performs processing of your personal data that is inconsistent with the protection of your personal and private life or data in conflict with the law, especially if such data is inaccurate, via e-mail at dpo@chcipraci.cz . you can require:

(a)  the explanation from BWS or a third person involved in the processing of data;

(b)  removal of malfunction of data, in particular, you may request corrections or additions to personal data; if necessary, to temporary block and dispose of such personal data.

In the event of justified request, BWS or a third party involved in the processing of data is obliged to provide a free remedy immediately.

 Annex 1 – Extent the personal data are or will be processed

  1. Identification data– containing personal details such as first name, surname, date of birth, place of birth, birth number, permanent address; for natural person - Company registration number and VAT number for legal person. Other possible identification data is, for example, the IP address assigned to computer being used.
  2. Contact information- contact addresses, phone numbers, email adresses, fax numbers, or other similar contact details.
 
Data Protection Officer contact:
dpo@chcipraci.cz
 
We  kindly  ask you to communicate with DPO in English .