Personal Data Processing Policy of the company POS Media Europe s.r.o.
1. Introduction
1.1. The controller of your personal data is the company POS Media Europe s.r.o., ID No.: 28991575, with its registered office at Budějovická 778/3, 140 00 Prague 4, Czech Republic (hereinafter “POS Media Europe”), which is part of the POS Media Europe.
1.2. POS Media Europe processes personal data exclusively in accordance with national and European Union regulations, in particular Act No. 110/2019 Coll. on the processing of personal data, Regulation (EU) No. 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (GDPR) and other legal regulations governing the protection of personal data, including regulations issued by the relevant supervisory authorities. The following information provides you with an overview of the processing of personal data by the company POS Media Europe s.r.o.
1.3. “Processing” means all activities relating to your personal data, including its collection, handling, storage, sharing, access, use, transfer and disposal.
1.4. “Personal data” are defined as any information relating to an identified or identifiable natural person.
1.5. This Personal Data Processing Policy specifies, among other things, what personal data POS Media Europe processes and how it obtains personal data and for what purposes these personal data are processed, including processing through cookies that occurs when visiting the POS Media Europe website.
2. Collection of information
2.1. POS Media Europe processes personal data obtained mainly in one of the following ways:
i. information provided directly by the data subject, e.g., by filling in a form when accessing the website, placing an order, entering into a contract, submitting a competition entry or otherwise;
ii. obtained through your activity in using the website and individual products and services, such as through cookies and similar technologies. For more information on how POS Media Europe uses cookies, please see the Change cookie settings;
iii. in some cases, the company also obtains personal data from freely accessible public registers (in particular in the preparation of contracts and their drafting)
3. Processed personal data
3.1. The scope of the processed personal data varies depending on the purpose of the processing. The following overview lists the most frequently processed categories of personal data.
3.2. The controller processes the following personal data:
i. identification data, in particular name, surname, identification and document number, date of birth, title, user name, VAT number;
ii. contact data, in particular the electronic address, telephone number, delivery address, billing address, or social media contact;
iii. your settings, in particular profile details, subscription settings for newsletters, catalogues, press releases, membership in loyalty programmes, tracked offers, product and service reviews, completed questionnaires, etc.;
iv. contractual data and information of a commercial nature, such as data about your orders, in particular data about the products and services ordered, how these products and services are provided, payment data, complaints data, etc.;
v. when you visit the company’s website, data about your behaviour on the website, in particular data about the products and services displayed, the links you click on, the way you move around the website, the frequency of visits, the original source (“referral link”) leading to the visit to the website, data about the device used, such as IP address, device location, device identification, etc.; and
vi. details of your complaints, comments, requests, feedback, subscriptions to information, newsletters, etc.
vii. data for the management of the personnel and payroll agenda, e.g., data on marital status and family members, data on educational attainment, data on health status obtained in accordance with the relevant regulations, etc.
4. Purpose and legal basis for the processing of personal data
4.1. The individual purposes of processing personal data and their legal basis are set out in the summary below:
i. Personalisation of contacts, offering suitable products and services, identification of potential customers on the basis of consent given by the data subject
When you visit the website, you can fill in a form (hereinafter the “form”), on the basis of which POS Media Europe may process your personal data for the purpose of better understanding your customer needs and tailoring commercial communications, product and service offers, etc., as well as for the purpose of identifying business opportunities and identifying potential customers.
ii. Performance of contractual obligations
POS Media Europe processes the data of persons who participate in contractual relations with POS Media Europe necessary for the preparation, conclusion and performance of the contract as well as for possible claims, etc. In such cases, the legal basis for the processing is the necessity of the processing for the performance of the contract.
iii. Identifying trends and compiling statistics
After filling in the form, POS Media Europe may process your personal data for the purposes of identifying trends and compiling statistics. For example, the administrator finds out from which regions the website users come from, the original source leading to the website visit (referral link), etc.
iv. Providing of information (e.g., newsletters, catalogues and press releases)
If you subscribe to newsletters, catalogues or press releases of POS Media Europe, or request such materials or information on a one-off basis, POS Media Europe will process your personal data for the purpose of providing them. You can unsubscribe at any time, using the button or link provided in each e-mail containing the above materials or information. The processing of data in these cases is generally based on the data subject’s consent or in connection with the performance of contractual obligations.
v. Handling suggestions, requests, complaints, and providing feedback
Through the website or social media, it is possible to send POS Media Europe various suggestions, requests or complaints, raise questions, etc. POS Media Europe may process your personal data for the purpose of answering questions, handling requests, processing suggestions, and providing feedback. The legal basis here will generally be the legitimate interest of the controller or processing necessary for the performance of a contract.
vi. Processing of personal data of employees and applicants for employment or cooperation
POS Media Europe processes personal data not only of employees and co-workers, but also of applicants for employment or other forms of cooperation. The reason for this is both the fulfilment of the legal obligations of the controller as an employer and in some cases the legitimate interest of the controller.
vii. Compliance with other legal obligations set out in national or European legislation
POS Media Europe is obliged to process data for the purposes required by the applicable legislation, including the legislation of the relevant supervisory authorities (e.g., accounting and tax purposes).
viii. Ensuring the functioning of the website
When visiting the POS Media Europe website, cookies are processed to ensure the correct functioning of the website, to ensure the appropriate user experience, to keep statistics or to target advertising. The legal basis for the processing of personal data within cookies is legitimate interest for necessary cookies and consent for cookies.
ix. Legitimate interests
POS Media Europe has the right to process personal data for its own, subjectively determined interest. In this case, it is obliged to inform you of the right to object to such processing and the right to erasure. The legitimate interest must be necessary to achieve the stated purpose and the processing must not present a disproportionate risk. The legitimate interest of POS Media Europe is, for example, the interest in ensuring order, security and protection of the company’s property.
5. Personal data processed through cookies
5.1. Cookies are small text files consisting of letters and numbers that are sent by the computer running the website to your device (computer, phone) via your browser and stored on your hard drive. These files allow POS Media Europe to distinguish you from other users and to identify the way you interact with our website, to better communicate with you or to target certain marketing activities more effectively. You can restrict or block the use of cookies in your web browser settings.
5.2. For some products, cookies are necessary for the functioning of the website and also for the provision of the service (the so-called essential cookies). In other cases, cookies can only be used with consent (analytical and marketing cookies). You can therefore accept all cookies via the “Yes, I accept” button, accept only essential cookies via the “Use only essential cookies” button or make your own settings via the “Cookie settings” button.
5.3. You can find more details about the cookies used under the link Change cookie settings .
6. Storage and protection of personal data
6.1. POS Media Europe will retain your data for the period necessary to fulfil the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law binding on POS Media Europe.
6.2. The retention period will be determined according to the following criteria as:
i. the duration of your relationship with POS Media Europe;
ii. the period of time required by law binding on POS Media Europe (for example, tax and accounting obligations); and
iii. the period appropriate according to the legal status of POS Media Europe (e.g., applicable statute of limitations).
6.3. POS Media Europe is obliged to ensure, by means of appropriate security measures, that access to your personal data is properly secured, depending on the circumstances, taking into account the state of the art, cost of implementation, nature, scope, context and purpose of the processing as well as the relevant risks In support of this commitment, POS Media Europe is obliged to implement appropriate technical, physical and organisational measures to protect the user’s personal data against unauthorised or accidental destruction, alteration, disclosure, misuse, damage, theft, accidental loss or unauthorised access.
7. Disclosure and transfer of personal data to third parties
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7.1. POS Media Europe may transfer the processed personal data to other companies within the POS Media Europe. In this case, POS Media Europe is obliged to ensure that the same safeguards are applied in relation to your personal data as it provides itself.
7.2. POS Media Europe is also entitled to transfer personal data in accordance with applicable law to such controllers as are provided for by specific legislation – these are usually public authorities (e.g., courts, law enforcement authorities, etc.).
7.3. In justified cases, POS Media Europe may make personal data available to processors who process personal data according to its instructions.
7.4. For the aforementioned purposes, this mainly concerns the processing of personal data by third parties, which are:
i. Suppliers and operators of information systems;
ii. external experts in individual agendas and external consultancy providers (legal, accounting and other consultancy firms);
iii. the provider of Google Analytics and YouTube, Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
7.5. If such disclosure involves the transfer of personal data outside the EU/EEA, POS Media Europe will ensure that a standard data protection agreement is concluded with the processor in accordance with the rules of the European Commission. Alternatively, other safeguards may be provided prior to such a transfer.
8. User rights
8.1. Right of access to personal data
You can request confirmation of whether and to what extent your personal data is processed by POS Media Europe. If so, you can request access to your personal data and other information, such as the purpose of the processing. You are also entitled to a copy of your personal data that is processed.
8.2. Right to rectification and erasure
If you find that any of your personal data is insufficient, incomplete or incorrect, you are entitled to have it rectified. You may have your personal data erased in certain circumstances (e.g., if it is no longer needed for the purposes for which it was collected).
8.3. Right to object to certain processing
You can object to the processing of your personal data processed on the basis of legitimate interest. In the event that it is processed for the purposes of direct marketing activities, POS Media Europe will cease to process your personal data without further action. In other cases, POS Media Europe will do so when there are no compelling reasons justifying its further processing. If you have subscribed to receive information by e-mail, each e-mail will contain an easily accessible unsubscribe function which can be used to cancel the subscription.
8.4. Right to restrict processing
You can request a restriction on the processing of your personal data if:
i. the data processed are inaccurate;
ii. the processing is unlawful;
iii. the processor no longer needs the personal data for the purpose of the processing and the user requires them for the exercise of their legal claims; or
iv. you have objected to processing.
8.5. Right to withdraw consent
You have the right to withdraw your consent to the processing of your personal data at any time, to the extent that such processing is based on your consent.
8.6. Right to data portability
At any time, you may ask POS Media Europe for a machine-readable copy of the personal data the processing of which is based on your consent or contract, as well as those personal data that have been provided to POS Media Europe by automated means, and may request their transfer to another data controller.
8.7. Right to lodge a complaint
If you have any doubts about compliance with the obligations related to the processing of personal data, you have the right to lodge a complaint with the Office for Personal Data Protection.
9. Contact data
9.1. You may send any queries, requests or complaints exercising your rights under this Privacy Notice and under applicable law:
- by e-mail to: info@posmedia.cz; or
- in writing to: Budějovická 778/3, 140 00 Prague 4, Czech Republic.
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