PERSONAL DATA PROTECTION PRINCIPLES OF

ITERA TECHNOLOGIES A.S.

 

  1. PURPOSE

    1. The purpose of this document is namely to declare the principles of the Company in regards to the protection of Personal Data and inform natural persons about the information related to the protection of personal data, to which they have a right based on legal provisions or which could be the subject of their interest.

 

  1. APPLICATION

    1. The principles are applicable to any case of processing of personal data, which is done in the Company and any Employee of the Company is required to abide by these principles when processing Personal Data or when fulfilling other obligations stemming from the General Data Protection Regulation.

 

  1. TERMS, DEFINITIONS, ABBREVIATIONS

    1. Supervisory Authority – The Office of Personal Data Protection (in Czech: Úřad pro ochranu osobních údajů), unless a different law or regulation of the same or higher legal power does not state that the authority will be another entity;

    2. GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation);

    3. Personal Data – Any information relating to an identified or identifiable natural person; an identifiable natural person is one, who can be identified, directly or indirectly, in particular by reference to an identifier such as name, an identification number, location data, an online identifier or to one or more factors specific to the physical, genetic, mental, economic, cultural or social identity of that natural person;

    4. Employee – Any person, including natural and legal persons, who exercises any activity for the Company, namely an employee, natural persons working for the Company based on agreements on work performed outside the employment relationship, an external partner, a supplier, etc.

    5. Company – The company Itera Technologies a.s., with its registered office in Thámova 181/20, Karlín, 186 00, Prague 8, Id. No.: 06704026, registered
      in the commercial register maintained by the Municipal Court in Prague under file
      No. B 23152.

    6. Data Subject – Any natural person including self-employed persons;

    7. Processing (of personal data)  – Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

 

  1. PERSONAL DATA, THEIR COLLECTION AND PROCESSING

    1. Generally can be stated that the Company processes Personal Data which are obtained directly from the Data Subjects or which are provided to Company by its contractual partner to fulfill their contractual obligations.

    2. The Company undertakes to process the personal data for the purpose for which the personal data has been provided and in the scope which is necessary for such purpose.

    3. Personal Data provided to the Company will be processed solely by the Company; however, to fulfill contractual or legal obligations the Company can hand over Personal Data to its suppliers, provided that it enters into a personal data processing agreement with such a supplier and supplier will undertake to protect the Personal Data on the same level as or higher level than the Company itself. Personal Data can be handed over namely to external accounting providers and tax advisors, external legal counselors, processors, which provide to the Company server, web, cloud or IT services, or which are their business partners.

    4. The Employees of the Company are obliged to maintain confidentiality regarding all Personal Data they become familiar with during the performance of their work for Company and this obligation of confidentiality survives termination of their employment or other relationship with the Company.

    5. The Company will retain the Personal Data during a period necessary to fulfill her obligations or for a period during which the consent for receiving marketing notices will last or until the Data Subject rejects the receiving of marketing notices.

 

  1. PURPOSE OF PERSONAL DATA PROCESSING AND MARKETING

    1. The Company processes Personal Data of Data Subjects to fulfill its contractual obligations or to efficiently communicate with Data Subjects or the Company processes Personal Data to fulfill the purpose for which the Data Subjects have explicitly stated their consent.

    2. The Company processes Personal Data also for so called restricted direct marketing, which means that the Company, in the sense of Act No. 480/2004 Coll., about certain services of an information company and changes of certain laws, as subsequently amended, has the right to send to her clients commercial communication related to the products or services the client has ordered from the Company.

    3. Sending of such commercial messages can be rejected at any time by either a direct link, which is found in the body of such marketing e-mail message, or by sending such request to an e-mail address info@itera.io.

 

  1. DATA SUBJECT RIGHTS

In regards to the processing of your Personal Data, you have the following rights:

  1. Right to access the Personal Data;

  2. Right to rectification;

  3. Right to erasure (“right to be forgotten”)

  4. Right to restriction of processing;

  5. Right to object processing; and

  6. Right to lodge a complaint against Personal Data processing;

 

Your rights are explained below so you can understand more clearly about their content.

Ad 6.1.            All your rights can be exercised by contacting us at Pobřežní 620/3, 186 00, Prague 8 or emailing us at info@itera.io.

Ad 6.2.            You can submit a complaint to the Supervisory Authority – The Office of Personal Data Protection (in Czech: Úřad pro ochranu osobních údajů -  www.uoou.cz)

Ad 6.3.            Right to access means that at any time you can request a confirmation from us, whether or not the Personal Data related to you are or are not processed and if they are, then for which purpose, in what scope, who has access, and for how long we will process them, if you have a right for rectification, erasure, restriction of processing or lodging a complaint, where we received the Personal Data from and if automated individual decision-making or profiling takes place based on processing of your Personal data. You have a right to receive a copy of your Personal Data with the first copy being free; the Company can request appropriate fee for administrative costs related to providing subsequent copies.

Ad 6.4.            Right to rectification means that you can request at any time rectification of inaccurate Personal Data or completion of incomplete Personal Data if they were inaccurate or incomplete.

Ad 6.5.            Right to erasure means that we have to erase your Personal Data if (i) they are not necessary anymore for the purpose for which they have been gathered or otherwise processed, (ii) the processing is illegal, (iii) you object against the processing and there are no prevailing justified reasons for processing, or (iv) there is a legal obligation we have to fulfill.

Ad 6.6.            The right to restriction of processing means that until any disputes regarding the processing of your Personal Data are solved, we have to restrict the processing of your Personal Data in a way as to only store them or use them to determine, exercise or defend legal claims.

Ad 6.7.            Right to lodge a complaint means that you can lodge a complaint against the processing of your Personal Data which we process for the purpose of direct marketing or for the reason of legitimate interest. If you lodge a complaint against the processing for the purpose of direct marketing, your Personal Data will not be processed for that purpose anymore.