The Personal Data Processing Policy for the Customers of DoorHan s.r.o. according to GDPR
The aim of this Policy is processing of personal data for the customers of DoorHan s.r.o., in compliance with the GDPR released by DoorHan s.r.o., ID 273 52 820, Tax ID CZ27352820, with the registered office at based Kralovsky vrch 2018, 432 01 Kadan, is to provide information about what personal data DoorHan s.r.o. (as the administrator) processes on natural persons in the provision of services and contacts with potential customers, for what purposes and for how long DoorHan s.r.o. processes such personal information in accordance with the applicable regulations, to whom and for what reason it may pass it, and also to inform what rights natural persons are entitled to in relation to the processing of their personal data.
This Policy relates to the processing of personal data of customers of DoorHan s.r.o. and reasonably also to their representatives or contact persons and applicants for the goods of DoorHan s.r.o. The Policy is effective from 25. 5. 2018 and is released in accordance with the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (the "Regulation” or "GDPR” hereinafter) in order to secure the information obligation of DoorHan s.r.o. as the administrator pursuant to Art. 13 GDPR.
A. Categories of Personal Data
Personal data is any information that relates to a natural person, that DoorHan s.r.o. is able to identify. In connection with the provision of services and sale of goods DoorHan s.r.o. may process the following categories of personal data.
1. Basic personal identification data and address information
That data is necessary for the conclusion and performance of a contract. It includes specifically:
- academic title
- first name and surname
- business name
- personal identification number (in case that none was assigned, the date of birth)
- ID No., Tax ID No.
- permanent address
- registered address or place of business
- billing address
- numbers of presented identification documents and their copies (all data that is not needed to provide the service, are blacked out in the copies of documents)
- identification data of the customer representative or of the contact person who will be named by customer
- identification data of billing payer
- bank details
- signature
In the case of contracts for single sale of disposable products, the scope is limited to the general identification data.
- Contact details
- contact telephone number
- contact e-mail
- social network addresses
- Data about the purchased goods, purchased services, use of services and payment habits
- type and specification of the provided service or goods
- the volume of provided services and their price
- information about the payment habits
4. Data of communication between DoorHan s.r.o. and the customer
This data is generated in the communication relating to the provision of services and goods of DoorHan s.r.o. between DoorHan s.r.o. and the customer. It includes the records of personal communication with the customer or other direct contact with the customer, written and electronic communication with the customer
5. CCTV recordings from the premises of DoorHan s.r.o.
DoorHan s.r.o. installs cameras in the premises of DoorHan s.r.o. in order to protect the legitimate interests of DoorHan s.r.o.
B. Purposes, legal grounds and personal data processing times
The scope of the processed data depends on the purpose of processing. DoorHan s.r.o. processes data directly under a contract, legitimate interest or under the law (without the consent).
1. Processing due to the performance of a contract, the fulfilment of legal obligations and for the legitimate interests of DoorHan s.r.o.
The provision of personal data necessary for the performance of a contract, the fulfilment of legal obligations of DoorHan s.r.o. and the protection of the legitimate interests of DoorHan s.r.o. is obligatory. Without the provision of personal data for the above purposes it would not be possible to provide the services. We do not need permission for the processing of personal data for such purposes. Processing due to the performance of a contract and the fulfilment of legal obligations cannot be refused.
Those include in particular the following sub-purposes:
- providing of electronic communication services, payment transactions, provision of other services (contract fulfilment)
- billing for services (contract fulfilment)
- fulfilment of legal tax obligations (fulfilment of legal obligations)
- purposes established by special laws for the purpose of criminal proceedings and for the fulfilment of the obligations of cooperation with the Police of the Czech Republic and other state authorities (fulfilling of the statutory obligations)
- operation of CCTV and monitoring systems in the premises of DoorHan s.r.o. for damage prevention (legitimate interest of DoorHan s.r.o.)
- to evaluate customer behaviour in the use of services and their payment discipline for the prevention of receivables that may affect the company's decisions on the conditions of entering into other contracts with the customer with the decision on entering or non-entering into other contracts not being made automatically (legitimate interest of DoorHan s.r.o.)
- Recovery of customer’s claims and other customer disputes (legitimate interest)
- processes associated with the identification of the customer (contract fulfilment)
- providing evidence for cases of urgent need for the advocacy of DoorHan s.r.o.’s rights (legitimate interest of DoorHan s.r.o.)
- registry of debtors (legitimate interest of DoorHan s.r.o.)
Personal data for these activities are processed to the extent necessary for the fulfilment of these activities and for the time required for their achievement or for the time directly stipulated by law. After that, personal data is deleted or made anonymous. The general deadlines for processing of personal data are provided below.
As concerns the customers of DoorHan s..r.o. Services, the company is entitled, if they have fulfilled all their obligations to it, to process in the DoorHan s.r.o.’s customer database their general personal, identification, contact information, information on services and data from their communication with DoorHan s.r.o. for a period of 4 years from the date of the termination of the last contract with DoorHan s.r.o.
If goods are purchased from DoorHan s.r.o., DoorHan s.r.o. is entitled to process the general personal, identification and customer contact information, data on goods and data from the communication between the customer and DoorHan s.r.o. for a period of 4 years following the date of the expiration of the warranty on the goods.
If negotiations took place between DoorHan s.r.o. and a potential customer on entering into a contract that have not resulted in the conclusion of one, DoorHan s.r.o. is entitled to process the personal information provided for a period of 3 months from the relevant negotiation.
Invoices issued by DoorHan s.r.o. are, in accordance with § 35 of Act No. 235/2004 Coll., On Value Added Tax, archived for a period of 10 years from their release. Because of the need to prove the legal basis for issuing of the invoices for a period of 10 years from the date of contract termination, even customer contracts are archived.
The identification data necessary for the provision of services from the customer's identity card are processed by DoorHan s.r.o. in accordance with § 16 of Act No. 253/2008 Coll., on selected measures against legitimisation of proceeds of crime and financing of terrorism, for a period of 10 years from the date of the termination of your contract with DoorHan s.r.o. To fulfil the above legal obligation, DoorHan s.r.o. retains a period of 10 years from the date of the completion of the last service of the customer, copies of identity cards with the information required to provide the service, while other data which is not necessary for the provision of the service, is blackened on the copy of the card.
CCTV footages from the premises of DoorHan s.r.o. and the buildings near DoorHan s.r.o. are processed for a maximum period of 90 days from the date of obtaining such CCTV recording.
2. Processing of cookies from websites operated by DoorHan s.r.o.
In the event that the data subject has cookies enabled in its browser, we process the data subject’s behaviour records from the cookies placed on the website operated by DoorHan s.r.o. in order to ensure better traffic of the DoorHan s.r.o.’s websites and for the purpose of the internet advertising of DoorHan s.r.o.
C. Personal data recipients category
In fulfilling of its commitments and obligations under the contracts, DoorHan s.r.o. uses professional and specialised services of other subjects. If those suppliers process personal data provided by DoorHan s.r.o., they have the status of personal data processors and process personal data only within the instructions issued by DoorHan s.r.o. and may not used that otherwise. This particularly involves the recovery of outstanding debts, activities of experts, lawyers, auditors, IT systems management, online advertising or sales representation.
Within the fulfilment of its legal obligations, DoorHan s.r.o. forwards personal data to administration bodies and authorities set out in the applicable legislation.
D. Personal data processing method
DoorHan s.r.o. processes personal data both manually and automatically. DoorHan s.r.o. keeps records of all activities, both manual and automated, in which personal data is processed.
E. Business communication
DoorHan s.r.o. uses appropriate designation for business communication from which it is clear that the said communication is business communication within the meaning of the applicable legislation. As concerns the commercial communications sent by DoorHan s.r.o. it is always clear that the company is the sender of those. Commercial communications can be sent either to the contact information of our customers on the basis of a legitimate interest of DoorHan s.r.o. Until you express your disagreement.
F. Information concerning the rights of data subjects in relation to the processing of personal data valid from 25 5. 2018
Accordingly with the Regulation effective from 25.5. 2018, if data subject is an identifiable natural person for DoorHan s.r.o. and demonstrates its identity to DoorHan s.r.o., it will have the consequential rights.
1. Right of access to personal data
According to Art. 15 GDPR, data subject will have the right to access personal data, which includes the right to obtain from DoorHan s.r.o.:
- a confirmation on whether it processes personal data,
- information about the purposes of the processing, the categories of the personal data concerned, the recipients to whom personal data have been or will be made available, the planned time of processing, the existence of the right to request rectification or erasure of personal data concerning the data subject from the administrator, or limiting of their processing, or to raise objection against that processing, the right to lodge a complaint with a supervisory authority, of any available information about the source of personal data, unless obtained from the data subject, the fact that there is an automated decision-making taking place, including the profiling, of the appropriate safeguards for the transfer of data outside the EU,
- as long as the rights and freedoms of other persons are not adversely affected, also a copy of the personal data.
In the case of repeated request, DoorHan s.r.o. is entitled to charge a reasonable fee for a copy of the personal data.
The right to confirmation of the processing of personal data and to the information can be exercised in writing to the address of the DoorHan s.r.o.’s registered office.
2. Right to the correction of incorrect personal data
Pursuant to Art. 16 GDPR, data subject shall have the right to have corrected the inaccurate personal information of it that DoorHan s.r.o. is going to process. Customer of DoorHan s.r.o. has also a duty to report any changes to its personal data and to demonstrate that such a change occurred. It is also obliged to provide us with assistance upon finding out that the personal data we process is not accurate. We will correct it without an undue delay, but always with regard to the given technical possibilities. Request for the correction of personal data can be applied at the registered office of DoorHan s.r.o. subject to the justification of the request.
3. Right of erasure
According to Art. 17 GDPR, data subject shall have the right to erasure of personal data concerning it. If DoorHan s.r.o. fails to establish legitimate grounds for the processing of that personal data. If the data subject believes that no erasure of its personal data took place, it can contact us in writing at the address of the DoorHan s.r.o.’s registered office.
4. Right to limit the processing
Pursuant to Art. 18 GDPR, data subject shall have until the time to resolving a complaint the right to limit processing if it denies the accuracy of the personal data, the reasons for its processing, or raises a written objection against its processing to the address of the DoorHan s.r.o.‘s registered office.
5. Right to notification of correction, erasure or limiting of processing
According to Art. 19 GDPR, data subject shall have the right to be notified by DoorHan s.r.o. in case of rectification, erasure or limiting of personal data processing. If personal data is corrected or deleted, we will inform each recipient, except where this proves impossible or involves unreasonable effort. Upon the request of the data subject, we may provide information on those recipients.
6. Right to personal data portability
Pursuant to Art. 20 GDPR, data subject will have the the right to the portability of data relating to it that is provided to the administrator in a structured, conventional and machine-readable format, and the right to ask DoorHan s.r.o. to forward such data to another administrator.
If data subject provides us with personal data in relation to a service agreement or upon the consent and the processing of it is done automatically, the data subject has the right to obtain that data from us in a structured, conventional and machine-readable format. If technically feasible, the data can also be passed to an administrator named by you, if the person acting on behalf of a competent administrator is properly identified and can be authorised.
In the event that the exercise of this right might adversely affect the rights and freedoms of third parties, your request cannot be satisfied. The request can be applied at the registered office of DoorHan s.r.o. upon the justification of the request.
7. Right to object to the processing of personal data
Pursuant to Art. 21 GDPR, data subject will have the right to raise an objection against the processing of its personal data due to the legitimate interest of DoorHan s.r.o..
In the event that DoorHan s.r.o. fails to prove that there is a serious legitimate ground for processing, which outweighs the interests or the rights and freedoms of the data subject, DoorHan s.r.o. shall terminate the processing without undue delay based on that objection. Objection can be sent in writing to the address of the DoorHan s.r.o.’s registered office.
8. Right to contact the Office for Personal Data Protection
The data subject has the right to contact the Office for Personal Data Protection (www.uoou.cz).
Mikhail A Kiselev
DoorHan s.r.o., Managing Director.
Czech Republic
What is a cookie
A cookie is a
text file, a code, or a software element that saves information relating the
browsing history and pattern of your terminal on the Internet. It is under the
control of your internet browser, and sometimes carries a unique and random
number. You can read it, destroy it, or modify it.
Why does DoorHan uses cookies?
DoorHan is always seeking new ways to
better it’s or its Internet website(s) and to offer you, the internet user, a
better service and experience. Thus, DoorHan uses different types of cookies as indicated hereafter that can
warrant the preliminary consent of the internet user (commercial type cookies)
before the cookie is installed on its terminal.
How does DoorHan inform you of the cookies that it uses?
When you access
for the first time any of DoorHan web sites, the legal notice of the site will
refer you to a page that will give you all information on the cookies that are
installed and used by this site. In any case, you have the control of these
cookies. Therefore, you have the possibility to refuse or destroy them.
Your cookie seetings
Here is a list of cookies defined as statistical
Name
|
Implemented by
|
Purpose
|
Duration
|
__utma
|
Google Analytics
|
Website Analytics
|
24 months
|
_ga
|
Lemanslive
|
Website Analytics
|
48 hours
|
_gid
|
Analytics
|
Website Analytics
|
48 hours
|
_ym_isad
|
Analytics
|
Website Analytics
|
24 months
|
_ym_uid
|
Analytics
|
Website Analytics
|
24 months
|
ym_visorc
|
Analytics
|
Website Analytics
|
24 hours
|
How to refuse and/or
uninstal these cookies?
a. On computer
You can uninstall these cookies in two ways.
On the one hand, you can consult the cookies
already installed on your terminal through the use of your browser, and delete
them one by one by type of cookies as indicated in the banner or all at once.
·
Apple Safari Browser: "Confidentiality" section in the
« Preferences » menu, provided section for “Cookies and other data of Internet
websites”.
·
Google Chrome Browser: “Confidentiality” section in the «
Parameters» menu, « Content Parameters» subsection, provided section for «
Cookies and website data».
·
Internet Explorer Browser: “Tools” menu, then “Internet Options”
section, then “General” then “Browser history”, then “Parameters”, then open
the “Parameters of temporary internet files and history” window, and finally,
“Display files”.
·
Mozilla Firefox Browser: “Tools” menu, “Options” section,
“Privacy” subsection, “Delete specific cookies” functionality.
Furthermore, you can program your Internet browser to block or
receive a warning for all installations of cookies on your terminal. The steps
to follow differ for each type of browser, but you can find instructions in the
“Help” section of the latter. The programming of your browser can be carried
out independently on each of the terminals that you use in order to access DoorHan web sites.
b. On a smartphone or tablet
You can uninstall these cookies according to the following methods:
·
Android Browser : Open your "Home" screen, Tap your
web browser icon, Tap the "Menu" button, Tap the
"Settings", Your device will either take you to a menu of available
settings OR it will have one of the three following options. Tap on the option
you have: Privacy & Security, Privacy, Security option Tap on "Clear
Cache" ,Tap "OK" to confirm, Tap "Clear all cookie data"
Tap "OK" to confirm, Click the "Home" button to go back to
your "Home" Screen Restart your device by turning it off and then on
again.
·
Google Chrome Browser: On your browser toolbar, click “the
Chrome menu” Click “More tools” and “Clear browsing data” In the box that
appears, click the checkboxes for "Cookies and other site and plug-in
data" and "Cached images and files." Use the menu at the top to
select the amount of data that you want to delete. Choose “beginning of time”
to delete everything. Click “Clear browsing data”.
·
Apple iOS 8: Click the "Home" button, Tap the
"Settings" button, Scroll down to "Safari", Tap on
"Clear History and Website Data". You will receive a warning message.
Tap on "Clear History and Data" to confirm, Click the
"Home" button to go back to your "Home" Screen, Restart
your device by turning it off and then on again.
The uninstalling or the blocking of cookies
used on the DoorHan websites could affect, or even prevent you from using these
websites.
Cookies can be temporary, and only last for
the duration of your browsing session on the website, or can be permanent, i.e.
a longer lifespan according to the span that is attributed and the parameters
of your internet browser. Numerous types of different cookies exist, of which
we can set in four groups defined hereafter.
- Strictly Necessary Cookies
Strictly necessary cookies are cookies that are indispensable due to the fact
that the functionality of the website is contingent on their existence. Their
deactivation will cause important difficulties for using the site, or even the
impossibility to use the services that it proposes. The strictly necessary
cookies do not conserve information once you leave the site. They permit, for
example, to identify the terminals to dispatch the communication, to assign
numbers to the data “packets” in order to dispatch them in the requested order,
and to detect transmission errors or data loss.
- Functional cookies
Functional cookies are used exclusively for providing an electronic
communication service at the request of the internet user. If these cookies are
uninstalled, providing this service will be rendered impossible.
The information is conserved beyond your browsing session on the internet
website, and can be transmitted to partners, uniquely for means of supplying
provisions necessary to the services. These can be, for example, cookies that
save the preferences of the user such as language preference of the user,
cookies that save a “user session”, or cookies that provide a “virtual shopping
basket”.
- Analytics and audience measurement cookies
The audience measurement cookies help to recognize visitors of the website
across their different visits. These cookies only stock an internet user’s ID
(specific to each cookie) and is in no case used to collect nominative
information belonging to the visitors. These cookies save the pages visited by
the user, the duration of each visit, and the error messages encountered; all
of which can help to enables a performance increase of the DoorHan internet websites. The analytics
cookies can be installed and managed by partners; however, DoorHan limits their use to the ends of
the analytical statistics demanded.
- Cookies used for targeted advertising and
social network tracking cookies generated by social network sharing buttons
Targeting and tracking cookies enable third parties to provide services, mainly
advertising, and to improve the effectiveness of such services. These cookies
may remember the web pages and sites that you visit, and may collect personal data,
mainly the IP address of the user’s device. The information collected may be
shared with third parties.
Examples include cookies that enable
advertising agencies to serve ads based on your interests as determined by how
you browse DoorHan’s websites, or that limit their repetition. These cookies
require your permission. In that case, a highly visible banner will appear on
the first page of the site to request your consent to install these cookies.
DoorHan and third-party
providers, including Google, use both first-party cookies and third-party
cookies to collect information and to optimize and serve ads based on visits to
the site. DoorHan and these providers also use these two types of cookies to
determine the ratio of number of site visits to ad impressions, other uses of
advertising services and the interactions with these ad impressions and these
advertising services. Lastly, DoorHan and these providers use these two types of cookies to remember
your interests and demographic data so as to serve you targeted ads.
DoorHan uses so-called social plugins (hereinafter referred to as
buttons) which link to social networks such as Facebook, LinkedIn and YouTube.
When you visit our website, these buttons are disabled by default, which means
they do not send any information to the social networks in question without
action on your part. Before you can use these buttons, you have to click to
enable them. The buttons remain enabled until you disable them again or you
delete your cookies. Once they have been enabled, the system connects directly
to the server of the social network selected. The content of the button is then
transferred directly from the social networks to your web browser, which
incorporates them into the website you are visiting.
As soon as you have enabled a button, the
social network in question can collect data, irrespective of whether or not you
use the button. If you are logged on to a social network, it can link your
visit to this website to your user account. Visits to other DoorHan websites will only be linked if
you have also enabled the corresponding button on these sites.
If you are a member of a social network and you do not want it to link the data
collected from your visit to our website to the information provided when you
joined the network, you must log out of the social network in question before
enabling the buttons.
Please note that we have no influence over the scope of data collected by the
social networks through your buttons. Please refer to the data protection
statement published by the social networks in question for more information
about the scope and purpose of the data collection and how they process and use
such data, as well as the rights and setting options to protect your privacy.
Our website uses the following social network buttons, among others:
· youtube.com, generated by Google Inc., located at 1600
Amphitheatre Parkway, Mountain View, CA 94043, USA. For more information
concerning the protection of personal data, please consult :https://www.youtube.com/static?template=privacy_guidelines
·
Google + generated by Google Inc., located at 1600 Amphitheatre
Parkway, Mountain View, CA 94043, USA. For more information concerning the
protection of personal data, please consult :https://www.google.com/intl/policies/privacy/