PERSONAL DATA PROCESSING POLICY

We are SAPELI, a.s., ID: 46982086, with place of business at Pávovská 3104/15a, 586 01 Jihlava, and registered with the Regional Court in Brno, section B, insert 4323 (hereafter ‘we’ or ‘our company’).

 

We are also an administrator of your personal data and are responsible for its processing. 

You can contact us as follows:

 

Email: sidlak@sapeli.cz
Telephone: +420 731 663 889
Address: Pávovská 3104/15a, 586 01 Jihlava

This personal data processing policy (hereafter ‘the policy’) has been created in accordance with the General Data Protection Regulation (hereafter ‘GDPR’) and describes the ways in which we process and protect your personal data. 
 

 

What personal data from you do we process? 

When we sell you our produces and provide our services to you, we come into contact with people and thus also with their personal data. In order to perform these activities diligently and professionally, we must obtain certain personal data from you. In order for you to better understand not only the scope of the processing of your personal data but also the reasons for it, we have divided this data into the following categories:

•    Identification and address information – information that allows us to identify you for purposes of concluding a purchase contract with you and providing our products to you without undue legal and/or material risks, e.g. name, surname, delivery or other contact address, billing address, end-user address, place of business, ID;

•    Data relating to the provision of services – data arising in relation to the performance of a contract, e.g. the date of contract conclusion, contract duration, date, and reason for termination, payment date, order history, data essential for the due performance of the contract, including prices, bank account number, and payment date;

•    Electronic data – data arising in relation to your visit to our website, e.g. the IP/MAC address of your device, cookies, social media identifiers, localization data of devices used by a customer, etc;

•    Geolocation data – data on your geographic location;

•    Contact information – data that allows us to establish contact with you and communicate with you, e.g. email address, telephone number.

•  

• How do we acquire your personal data? 

• We acquire your personal data in the following ways:
  •    when you provide it to us in mutual communication by means of telephone, email, post, registration, online contact form, website interface, etc.;
  •    from publicly accessible sources (e.g. public registers of persons, public listings, professional social networks); 
  •    in the performance of our legal obligations; 
  •    when you visit our website, for instance from cookies – you can read more about cookies in Information on Processing Cookies.

 

What are the purposes, legal basis, and duration of the data processing? 

The tables below list the purposes and legal basis for processing your personal data and also show how long we will store your personal data.

In this policy, the purpose of processing your personal data is any activity undertaken by us in relation to the sale of our products that requires us to work with your personal data (namely the conclusion and performance of a purchase contract, performance of our legal obligations, newsletter distribution, etc.).

In this policy, the legal basis for processing your personal data is one of the four reasons described below for the legal processing of personal data according to GDPR:

 

Legal basis	Explanation	Example of processing
Consent	We process your personal data only after receiving your consent.	Distribution of newsletters because you provided your email address to us in our online contact form.
Contract performance	We process your personal data if it is essential to the performance of a contract.	If we conclude a contract with you, we will process your identification, address, and contact information in order to fulfil our commitments and verify that you are fulfilling yours.
Performance of legal obligations	We process your personal data if it is essential to the performance of legal obligations.	In order to fulfil our legal obligations, we must archive tax documents for a period of 10 years. These documents contain your name, surname, address, etc.
Legitimate interest	We process your personal data if our legitimate interest in doing so outweighs your rights and freedoms.	When you visit our website, we process statistical website traffic data.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Purpose No. 1 - CONCLUSION AND PERFORMANCE OF A CONTRACT

We primarily process your personal data so that you can purchase our products and services. You are not obligated to provide your personal data to us for this purpose; however, without your personal data, we are not able to sell you our products, which in turn means we cannot conclude a purchase contract with you. 

We also process your personal data in handling your questions, suggestions, and complaints. If you opt to communicate with us by means of a social network, you must keep in mind that the processing of the data you provide is also subject to the terms and conditions of the given social network, over which we have no control. The processing of personal data for this purpose is based on our legitimate interest in communicating with our customers or your consent depending on which of the parties initiates the communication. In this case, the provision of personal data is not a legal or contractual requirement. You are not obligated to provide your personal data to us for this purpose. If you decide to publish a review, you do so voluntarily, and we process your personal data on the basis of your consent. You can withdraw your consent at any time. In this case, the provision of personal data is not a legal or contractual requirement. You are not obligated to provide your personal data to us for this purpose. 

 

Operation	Scope of data processing	Legal basis	Processing period
Negotiations on the conclusion, amendment, or termination of a purchase contract or its performance	Identification and address information; information relating to a contract and its performance; contact information, information that characterizes you	Contract performance	For the duration of the contractual relationship
Communication, satisfaction surveys, publication of reviews, handling of suggestions, complaints, and product claims	Identification and address information; information relating to a contract and its performance; contact information	Legitimate interest         Consent	For a period of 4 years after the dissolution of our contractual relationships and/or for a period of 4 years after obtaining your personal data      Until withdrawal of your consent

 

Purpose No. 2 - FULFILMENT OF LEGAL OBLIGATIONS

We also process certain personal data about you for the purpose of fulfilling our legal obligations, namely in the areas of accounting and taxes. The processing of personal data for this purpose is based on the fulfilment of legal obligations. We are required to process this personal data. 

 

Operation	Scope of data processing	Legal basis	Processing period
Fulfilment of legal obligations in the areas of accounting and taxes	Identification and address information; contact information (namely  information required on accounting and tax documents)	Fulfilment of legal obligations in the areas of accounting and taxes, namely per Act No. 235/2004 Coll. on Value Added Tax and Act No. 563/1991 Coll. on Accounting	For a period stipulated by relevant laws, namely Act No. 235/2004 Coll. on Value Added Tax and Act No. 563/1991 Coll. on Accounting;   Accounting data is processed for a period of 5 years, tax documents for a period of 10 years

 

Purpose No. 3 – DISTRIBUTION OF PROMOTIONAL MESSAGES

We also process some of your personal data (namely your email address and/or telephone number) for the purpose of sending you promotional messages, such as newsletters and offers of services or job openings that you may be interested in. We send promotional messages to users on the basis of our legitimate interest or to those who have consented to it (i.e. by means of an online form). 

We are entitled to use the information you provide to us and the information we obtain through other means in relation to our services, such as data on how you use our website, data on orders for services, or information about your participation in events and competitions, to personalize our promotional messages. 

The processing of personal data for the purpose of sending promotional messages is based on your consent and/or our legitimate interest in direct marketing. In this case, the provision of personal data on the basis of your consent is voluntary; however, without it, we cannot send you promotional messages. You can withdraw your consent at any time. You can object to our distribution of promotional messages based on our legitimate interest. If you notify us that you no longer wish to receive promotional messages, we will immediately discontinue their distribution to you. To do so, please use the above contact information. 

In this case, the provision of personal data is not a legal or contractual requirement, thus you are not obligated to provide your personal data to us for this purpose.  

 

Operation	Scope of data processing	Legal basis	Processing period
Distribution of promotional messages	Identification and address information; information relating to a purchase contract and its performance; electronic data; contact information (namely email address and telephone number)	Legitimate interest in sending our customers promotional messages per Act No. 480/2004 Coll. on Certain Information Society Services             Consent	Until you notify us that you no longer wish to receive promotional messages; no longer than 3 years after you cease to be our customer       Until you notify us that you no longer wish to receive promotional messages; until you withdraw your consent for the processing of personal data and distribution of promotional messages

 

 

Purpose No. 4 – PROTECTION OF OUR RIGHTS  

Upon termination of our contractual relationship, we store your personal data for a reasonable period as stipulated by statutory limitations for the purpose of protecting our rights, property, and security or the rights, property, and security of third parties. The processing of your personal data for this purpose is based on our legitimate interest in the protection of our rights, property, and security or the rights, property, and security of third parties. In this case, we can use your personal data to, among other things, prevent or uncover fraud or misuse, unlawful use, and/or violation of our terms and conditions and to comply with court decisions or those issued by other bodies involved in criminal proceedings or public administration bodies as well as all relevant legal provisions. 

In this case, the provision of personal data is not a legal or contractual requirement, thus you are not obligated to provide us with your personal data for this purpose; however, we will process your personal data for this purpose in situations where you have already provided it to us. 

 

Operation	Scope of data processing	Legal basis	Processing period
Protection of our rights	Identification and address information; information relating to a purchase contract and its performance; contact information	Legitimate interest	For a period of 4 years after termination of our contractual relationships, or for a period of 4 years after obtaining the personal data

 

 

Purpose No. 5 – ADMINISTRATION OF CUSTOMER ACCOUNTS

If we allow it on our website, you can register and create a customer account in which you can manage your personal preferences, etc. In this case, we must process your email address, name, surname, mailing address, and/or telephone number. This information serves to facilitate the provision of our services.  

The processing of personal data for this purpose is based on your consent. In this case, the provision of your personal data on the basis of your consent is voluntary; however, without it we cannot create a customer account for you or provide you with the majority of the services we offer. You can withdraw your consent and delete your account at any time. If you notify us that your no longer wish to use to your customer account, we will immediately delete it. To do so, please use the above contact information or the corresponding link from within your account. 

In this case, the provision of personal data is not a legal or contractual requirement, thus you are not obligated to provide us with your personal data for this purpose.
 

Operation	Rozsah zpracovávaných údajů	Právní důvod	Doba zpracování
Administration of customer accounts	Identification and address information; contact information	Consent	For the duration of your consent for the processing of personal data for this purpose

 

Purpose No. 6 – DIRECT MARKETING AND PROMOTIONAL ACTIVITIES

The technology of creating personalized content and advertising allows us to present our advertisements on partner websites to visitors who have already expressed interest in our website or services. We work to ensure you are only presented with advertising that you are genuinely interested in and not advertising without any relevance to you and your interests. Your history of job inquiries, interests, and habits on websites can be used to create personalized content and offers for you on our website as well as on third-party websites and applications, including social networks. This is primarily made possible thanks to cookies. You can learn more about managing your preferences relating to the processing of cookies in  Information on the Processing of Cookies.

The processing of personal data for the purpose of direct marketing and the creation of personalized content and advertising is based on your consent and/or our legitimate interest in direct marketing. In this case, the provision of personal data based on your consent is voluntary; however, without it you cannot be presented with personalized content and advertising. You can withdraw your consent at any time. In this case, the provision of personal data is not a legal or contractual requirement, thus you are not obligated to provide us with your personal data for this purpose.

 

Operation	Scope of data processing	Legal basis	Processing period
Browsing our website and offers of relevant content depending on your geographic location	Geolocation data	Consent	Until you withdraw your consent
Displaying personalized content and advertising (direct marketing)	Electronic data (namely cookies), contact information (namely email address and telephone number)	Consent	Until you withdraw your consent

 

Purpose No. 7 – CUSTOMER COMPETITIONS AND DELIVERY OF PRIZES

From time to time, we may organize customer competitions or events, during which we process your personal data according to the parameters of the given competition. This data will typically comprise your email address, name, and delivery address, though it may vary from one case to the next.  

The processing of personal data for the purpose of organizing customer competitions and delivering prizes is based on your consent. In this case, the provision of personal data is voluntary; however, without it you cannot participate in customer competitions. You can withdraw your consent at any time, though this will typically result in you being disqualified from the competition.  

 

Operation	Scope of data processing	Legal basis	Processing period
Organization of customer competitions and delivery of prizes	Identification and address information; contact information	Consent	For the duration of the customer competition

 

Purpose No. 8 - VISITING OUR WEBSITE

When you visit our website, we automatically process your personal data according to the scope, purpose, and legal title described in the table below. You can find more information on cookie files and how we use them in Information on the Processing of Cookies.

Who do we disclose your personal data to? 
In order to ensure the security of your personal data while also offering and selling you our products, we rely on the following groups of recipients and processors to help us process personal data:
 

 

Recipients	Reasons for disclosure
Accountants, tax advisors, auditors, legal representatives, notaries public	We entrust matters that we do not understand to specialists. We disclose your personal data only in an essential scope for processing by accountants, tax advisors, and/or auditors. In the vast majority of cases, this involves data on accounting and tax documents only.
Entities administrating our website and software	In order to offer and sell you our products and deliver our services to you at the highest possible level, we must work with a wide range of providers of information and communication services (e.g. providers of IT services and hosting, including cloud storage, security and integrity specialists for our services and website, providers of billing and accounting systems, etc.).
Entities providing marketing and graphic design services, event organizers	Marketing agencies, marketing specialists, and graphic designers may help us prepare and execute marketing campaigns.
Entities distributing our promotional materials	We may entrust the distribution of promotional materials to third parties, to whom we provide your personal data in the scope established for the purpose of sending you promotional messages (typically your email address and/or telephone number).
Entities providing payment services (operators of payment gateways, banks, etc.)	In order to provide convenient payment methods, we must disclose your personal data to the entities who provide payment services.
Public regulatory bodies (courts, public prosecutor’s offices, public administration and self-government bodies, the Czech Police, etc.)	We provide public regulatory bodies with access to your personal data in cases when we are obligated to do so based on a purchase contract (typically in the filing of lawsuits, petitions, motions, etc.) or if we are required to do so by law. The provision of personal data to these entities occurs only in special cases, not on a regular basis.
Operators of social networks	On the basis of your order history, interests, and habits on our website, you may be presented with personalized content and offers on social networks. This is made possible namely by cookies, which are used by so-called widgets embedded in our website. You can learn more about how your cookie processing preferences are administrated in the document entitled Information on the Processing of Cookies.
Sales partners	In providing our services and selling our products, we use a network of sales partners. In order to properly execute your order, we occasional have to share your personal data with one of our sales partners.

 

Is your personal data also transferred outside the EU?

If we transfer your personal data for processing to a third country (outside the European Economic Area, which includes the non-EU members Iceland, Lichtenstein, and Norway) or to an international organization, we will do so only if the European Commission has decided that the given country or international organization provides a sufficient level of protection or has provided appropriate data protection guarantees and that the rights of the data subject are enforceable in the target country and there is effective legal protection for data subjects in place. 

 

How is your personal data processed? 

Personal data is processed manually and automatedly. In compliance with relevant laws, we keep proper records on all of our data processing activities. 

 

What are your rights as a data subject?

To exercise your rights, please contact us using the information listed at the top of this policy. We reserve the right to verify in an appropriate manner the identity of the person requesting the rights in question. If such requests are repeated and/or clearly unfounded or excessive, we reserve the right to impose an reasonable fee or reject the requests. 

•    Right to access
If you want to know whether we are processing your personal data, you have the right to request information from us on whether or not your personal data is being processed, and if it is, you have the right to obtain access to that personal data. In the event of repeated requests, we are entitled to charge a reasonable fee to cover the administrative cost of providing you with multiple copies of your personal data.  

•    Right to rectification of inaccurate or incomplete personal data
If you believe that the personal data we are processing about you is inaccurate or even false, you have the right to request its rectification. You also have the right to completion of any incomplete personal data. We will rectify or complete your data without undue delay, but always with consideration for our technical and time constraints. 

•    Right to erasure
You have the right to request the erasure of your personal data that we are processing in the following cases:
a)    your personal is no longer necessary in relation to the purposes for which it was collected or otherwise processed; 
b)    we are processing your personal data unlawfully;
c)    you withdraw your consent on the basis of which your personal data was being processed, and we have no other legal basis on which to continue processing it;
d)    you raise an objection to the processing of your personal data in the event that your personal data is being processed for marketing purposes (e.g. distribution of our newsletters);
e)    you raise an objection to the processing of your personal data that we are processing on the basis of our legitimate interest and we are not able to demonstrate that our legitimate interest outweighs your right to erasure;
f)    there exist legal grounds requiring the erasure of this personal data;
g)    we are processing personal data of a child despite no parental consent having been granted for such processing. 

•    Right to restriction of personal data processing
If you do not want the complete erasure of your personal data but instead want to temporarily restrict the processing of your personal data, you have the right to ask us to restrict the processing of your personal data.

•    Right to data portability
If you want us to transfer your personal data to a third party, you can exercise your right to data portability; however, if such an operation could negatively impact the rights and freedoms of third parties, we will not be able to grant your request. 

•    Right to object
You have the right to raise an objection at any time to the processing of your personal that is being processed for purposes of performing a task in the public interest or in the performance of public authority or for purposes of protecting our legitimate interests. If we cannot demonstrate that there are substantial legitimate grounds for processing that outweigh your interests or rights and freedoms, without undue delay we will discontinue the processing of your personal data on the basis of your objection. 

•    Right to withdraw consent at any time
If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time.  

In cases where your personal data is being processed for purposes of distribution of promotional messages, you can withdraw your consent to the processing of personal data and consent to the distribution of promotional messages simply by replying ‘No’ to the given email or in any other way in your reply to express your wish to withdraw your consent. You can also click on the relevant link at the end of the promotional message if one is provided. 

 

•    Right to information on automated individual decision-making, including profiling
You are not the subject of any decision based exclusively on automated processing, including profiling, that would have legal bearing on you or would affect you in a similar way.

 

•    Right to file a complaint with the Office for Personal Data Protection
You have the right to file a complaint at any time with the supervisory Office for Personal Data Protection. Complaints can be filed using the contact information listed here.
 

Is personal data on children also processed? 

Our products, services, and website are not primarily intended for persons under 16 years of age; therefore, we do not intentionally collect their personal data. If we provide products or services to persons under 16 years of age, we request consent from the child’s legal guardian. If we discover that through some oversight we have inadvertently obtained the personal data of persons under the age of 16, we will take steps to immediately erase such data with the exception of cases in which we are bound by relevant laws to keep it. 

 

What regulations govern the processing of personal data and the protection of privacy? 

The processing of personal data in the Czech Republic is primarily governed by the following regulations:
•    Regulation (EU) 2016/679 of the European Parliament and of the Council 2016/679, General Data Protection Regulation; 
•    Act No. 110/2019 Coll. on Personal Data Processing;
•    Act No. 89/2012 Coll. of the Czech Civil Code.

 

Conclusion

Regulations and our business strategy and related methods of processing your personal data are subject to change. If we decide to update this policy, we will post the changes on our website in order to inform you of them. In cases of more fundamental changes to this policy, or if we are required to do so by law, we will inform you in advance. We kindly ask you to thoroughly read this policy and to review it in subsequent communication with us or when using our website.