Personal data hanling policy
- LANDIA Group:
The words „we“ and/or „us“ and/or “our” as used herein refer to Landia Management s.r.o, ID No.: 28510020, with its registered office at Prague 6, Evropská 810/136, entered in the Commercial Register maintained by the Municipal Court in Prague, Section C, Entry No. 146822, including all its subsidiaries, the said companies being part of the LANDIA Group.
- Personal data:
The term “personal data” means any and all information based on which you are identified or identifiable and information relating to you (to you personally, your activities, property, and the like).
Personal data processing means any operation or set of operations which is performed on your personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Processing means processing of your personal data wholly or partly by automated means and processing other than by automated means but only if the personal data form part of a filing system or are intended to form part of a filing system.
- Actual and potential clients:
The words “you” and/or “your” as used herein refer to you as our client and/or potential client interested in our services, especially if you have entered into an agreement with us (reservation agreement, agreement to enter into a contract for purchase, purchase contract, etc.) or you have contacted us when being interested in our services or events.
PERSONAL DATA PROTECTION PILLARS
We regard your personal data as having a major value and treat sensitively them as such. In processing personal data, we observe the fundamental rules as follows:
In relation to you, your personal data are processed fairly, lawfully and transparently. In personal data processing, we act in accordance with applicable legal regulations, in particular with the Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation) and Act No. 253/2008 Sb., on measures against the legalisation of proceeds from crime and terrorism financing.
Any processed personal data are secured. Your personal data are processed in a manner that ensures appropriate security thereof, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using technical and organisational measures. We use sophisticated measures for physical and technical security.
Your personal data are collected solely for specified, explicit and legitimate purposes and are not further processed in a manner that is incompatible with such purposes. We make sure that the data are accurate and updated.
Your personal data are processed and stored only in an adequate, relevant and limited extent, in relation to the purpose for which they are processed, in a form which permits your identification for no longer than necessary for the purposes for which the personal data are processed in the Czech Republic or the European Union.
PERSONAL DATA FOR CONTRACT AND CONTRACTUAL RELATIONSHIP MANAGEMENT
Personal data types
We process personal data given in the contracts that you have made with us and personal data arising in the course of performing the contracts. Such personal data include mainly (but not limited to) contact and identification data, information on the subject-matter of the contract and information on the course of the contractual relationship (invoicing, etc.), including commercial communication with you.
Naturally, we need to process contractual personal data so as to be able to fulfil our contractual obligations and exercise the rights arising therefrom and perform related legal obligations.
Information obtained from you
Personal data intended for contract and contractual relationship management are obtained primarily from you. However, certain personal data can be obtained also as a result of contract performance and related communication with you.
Contracts not yet entered into
Your personal data may be processed also before a contract is entered into so that the contract can be executed in an appropriate way. If the contract is not entered into because an agreement is not reached or for any other reason, we will continue processing your personal data in an extent necessary for resolving any precontractual issues and liability arising from the same, including performance of related legal obligations.
Personal data are processed (kept) for such a period for which they may legally be substantial for the performance of a relevant contractual relationship, i.e., until the expiration of relevant lapse of claim time limits, limitations periods, complaint periods, storage periods and other similar periods arising from legal regulations or contractual parties’ arrangements whichever expires latest. The processing period is dependent on the assessment of the contractual relationship in each specific case; however, as a rule, the period does not exceed 10 years from the performance (termination) of the contractual relationship. In case of contractual relationships which were prepared but not executed, personal data are processed until the expiration of limitation periods relating to precontractual liability.
MARKETING NAD COMMERCIAL PERSONAL DATA
Personal data are processed for marketing and commercial purposes for two reasons:
- Commercial communications
Firstly, to inform our clients and other potentially interested persons about our offer and distribute news among them by way of electronic newsletters and other commercial communications and solicit information from them as to whether they are interested in our offer, such information being obtained by phone, email or in other similar ways as decided in each individual case; and
Secondly, to be able to adapt and personalise our actions taken in relation to you in case of entering into and/or performing a contractual or commercial relationship with you or dealing with you (sales history, etc.).
The personal data cover the following types (not all the personal data types being necessarily processed in each particular case):
- Basic contact data
Identification and contact personal data (name(s) and surname, address, email address, phone number, etc.);
Your profile information in regard of our cooperation (history and course of the commercial relationship, subject of purchase, subject of enquiry, attendance at LANDIA events, etc.); and
Personal data permitting personalisation of our communication with you (communication history, recommendations, etc.).
No personal data revealing your racial or ethnic origin, political opinions, religion, philosophical beliefs or trade union membership, genetic data, biometric personal data and personal data concerning health, sexual life or orientation will ever be processed as marketing and/or commercial data.
Our marketing and commercial personal data sources are as follows:
Our commercial relationship with you and the course of our cooperation;
Your enquiries addressed to us (via online forms, real estate portals, etc.), and
References obtained from parties we cooperate with (typically in cases where you are interested in purchasing real estate and contact a real estate agency that passes your contact information to us).
Based on all or some of the processed data at our disposal, profiles of actual or potential clients are made and used for the purposes described above. Profiles can be imagined as information about you kept in a structured form for simpler communication and cooperation. By no means whatsoever does profiling include methods such as data harvesting, automatic evaluation, etc.
Electronic commercial communications
We respect the rule according to which your email address may be used for delivering commercial communications only if it has been provided by you as our client or provided that you have given us your consent to the same. Your consent may be withdrawn at any time; for information on the forms of withdrawal, see the section “Your rights”. Nevertheless, in each commercial communication sent by email you are given a simple and clear option to refuse receiving further commercial communications by way of an electronic opt out.
Right to object
The legal basis for processing your personal data subsists in our lawful interests in using the data for marketing and commercial purposes in order to maintain and develop business contacts and business activity in general. You can object to the processing of your personal data for marketing and commercial purposes. If you object to the personal data use for the purpose of delivering commercial communications or other direct marketing forms, any further processing for such purposes will be discontinued automatically. If you object to the personal data use for the purpose of personalisation of our dealings with you, we will consider the reasons for your objections (taking into account the particular situation) to determine whether on our part there are serious legitimate reasons for continued processing prevailing over your interests and/or rights and freedoms and inform you that we have accepted or cannot accept your objections and the reasons for the same. For information on how to object, see the section “Your rights”.
Only if you are interested in our offer
Your personal data are processed for contacting you with our offer or other commercial communications only to the extent that you can reasonably be expected to be interested in our offer. This can be expected only if you are or previously were our client. Your personal data are processed for personalisation only if you were in commercial contact with us (for order performance, carrying out a certain action, or if your showed interest in our services).
Your personal data are processed (kept) for the purpose of contacting you with our offer or delivering other commercial communications for as long as you can reasonably be expected to be interested in our offer unless you previously objected to such processing. For personalisation, your personal data are processed for a period of ten years from being in commercial contact with you for the last time.
COOKIES AND WEB BEACONS
Cookies and their use
Web beacons and their use
We may use also web beacons, both on our web pages and in the emails delivered to you. Web beacons are small graphic elements (data files, pixel tags) downloaded from our web server to monitor whether our emails are read or to monitor the number of visits and user behaviour on our web pages and subsequently optimise our user electronic services (including advertising personalisation). No personal data obtained through web beacons are used for your identification.
Our interests and your protection
PERSONAL DATA SHARING AND TRANSMISSION
Your personal data are shared within the LANDIA Group. Such personal data handling policy applies to personal data processed by any company within the LANDIA Group. All of the companies within the LANDIA Group have the same obligations, abide by the provisions of the personal data handling policy and are liable to you jointly and severally.
Your personal data may be transferred to parties that process personal data for us or provide services which necessarily involve personal data disclosure. These are mainly providers of IT services (such as server hosting or webhosting), database services, accounting services, tax advice or legal services. Any cooperation with these parties is of a strictly operational nature. These recipients do not process personal data autonomously, but solely upon our directions. We bear liability for ensuring that no personal data disclosed to them will be misused and that such parties are bound by the obligations of personal data integrity and confidentiality as well as other obligations as need to be agreed on under applicable legal regulations.
Consent to transfer
We are entitled to transfer your personal data to third parties also in case that you give consent to the same, but only under the conditions of such consent. Your consent may be withdrawn at any time. For information on how to withdraw your consent, see the section “Your rights”.
Transfer for the purpose of compliance with a legal obligation; transfers necessary by definition
Your personal data may be transferred to third parties also where necessary for compliance with our legal obligation (particularly in relation to public authorities) or where necessary by definition, especially to perform a contract where you are one of the parties.
- Right to information
You have the right to obtain confirmation from us as to whether your personal data are processed or not. If yes, you have the right of access to the personal data processed and to information on the details and sources of personal data processing. If you have provided your personal data to us based on your consent or in connection with the performance of contractual obligations and such personal data processing is automated, you have the right to receiving such personal data in a structured form, in commonly used and machine-readable format.
- Right to rectification, erasure or restriction of processing.
You have the right to having any inaccurate personal data rectified without undue delay. This applies also to the completion of incomplete personal data. In addition, you have the right to require that we delete your personal data unless we have sufficient legal grounds for processing (e.g., you have objected to personal data processing for the purpose of direct marketing). Your personal data processing will be restricted in lieu of erasure if you so require; that is, your personal data will only be stored without being processed in any other way unless you give consent to the processing.
- Right to object
You have the right to object at any time to personal data processing for the purpose of direct marketing. If you do so, your personal data will no longer be processed for that purpose. If you object to other kinds of personal data processing in cases where the processing is done for our legitimate interests, we will first consider (with regard to the particular situation) where or not there are serious lawful grounds on our part for continued processing prevailing over your interests or rights and freedoms and inform you whether you objections have been or cannot be accepted and on what grounds.
How to exercise your rights
Your rights can be exercised in any form comprehensibly conveying the content of your request, notification or objections, especially in an electronic form on firstname.lastname@example.org. If you require that a certain measure be adopted, we will inform you without undue delay and by any means within one month after delivery of your request, of any measures taken. When necessary, this period can be extended by up to two months of which you must be notified in a due time.
If you feel that your rights are affected in connection with how your personal data are processed, you may contact the Office for Personal Data Protection (www.uoou.cz). In addition, you may file a civil action with a court to seek judicial protection.