Personal data processing directive

Introduction

During cooperation with KOPOS KOLÍN, a.s., ICO 61672971, registered address at Kolín IV, Havlíčkova 432, PSC 28002, the company registered in the Companies Register administered by the Municipal Court in Prague and filed in Section B, File 3689 (“Company”), you entrust us with your personal data. We do our best not to let down your trust. We would like to explain how we handle personal data for you.

This directive applies to all clients, suppliers and customers of the Company, as well as to any other subjects the Company contacts or to which the Company sends any information in any other way (if not stated otherwise below). This includes all subjects that use services of the Company or provide the Company with services, sub-deliveries or are in any other contractual relation with the Company.

Personal data controller

The Company is the controller of personal data. Should you want to contact us or ask anything related to the personal data processing, please use the following contact information:

E-mail: GDPR@kopos.cz
Mail address: Havlíčkova 432, Kolín IV, 280 02 Kolín

Web address: https://www.kopos.com/

The controller collects and processes personal data exclusively in accordance with the rules and in accordance with the legal regulations, which are in particular 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, as amended on 25 May 2018 (hereinafter referred to as the "GDPR") and the Act on the processing of personal data No 110/2019 Coll., as amended. The Controller processes the personal data of the subjects in a lawful and transparent manner while complying with the condition of minimizing personal data to the extent necessary in relation to the purpose for which they are processed.

What kind of data we collect

The Company collects the following personal data categories:

1. Data you provide
   
   Information provided at these occasions:

• when a contractual relation is closed with us;
• visit of our website;
• data you provide us for completing an order;
• registration and maintenance of a user account on our website
• by signing up for the e-mail business communication (newsletter);
• when you contact the Company and remand or offer deliveries of your services or goods.

2. Information from other sources
   
   This kind of sources includes:

• publicly accessible sources, including public registers and the Internet network as long as we do necessarily need this data for e.g. issuing an accounting document, or as long as you publish your business contact data on the Internet and we would like to offer you a cooperation;
• information we have received from third persons, such as your employers or collaborators or business partners, we necessarily need for completing orders.

3. Automatically obtained information
   
   Information obtained by visiting and browsing the Company's website is one of these sources:

• cookies
• the website from which you came to our website
• IP address
• date and duration of access
• search queries
• http and https response code
• transmitted data groups
• information about the browser and computer operating system

The Company may combine information collected from these sources with other information available to it.

How we use your personal data

The Company uses the collected data for the following purposes:

1. Property and third person rights protection
   We are interested in protecting property and rights of the Company and third persons. For this reason the plants and the headquarters of the Company are secured with a camera surveillance system.
   
   If you come to visit us, you will be identified for the same reason.
   
   We use your personal data exclusively for the above-stated reason and process it in no other way.

2. Closing, amending and terminating contracts
   We use data for preparing contractual documents and amending or terminating contracts.
   
   For this reason we do necessarily need your personal data to comply with legal requirements for closing, amending and terminating contracts.

3. Addressing for cooperation
   We us data for demanding services and products from various suppliers as long as your personal data is published on the Internet or as long as you provide us voluntarily with your data e.g. at fairs, meetings or on similar occasions. We believe we do not interfere with your privacy by doing that. However, if you still feel hassled by that, let us know as soon as possible. You can use the E-mail address of GDPR@kopos.cz for that.
    
4. Business operation
   We use data for the very completing and recording of orders and services, for communication with clients, suppliers and customers.
   
   For this reason we do necessarily need your personal data to complete orders or services as well as for complying with all valid legal regulations.
    
5. Keeping accounts
   We use data for issuing invoices and keeping accounts.
   
   For this reason we do necessarily need your personal data to comply with legal requirements for keeping accounts.
    
6. Marketing
   We further use your data for the purpose of sending business communications as long as you have provided us with your voluntary consent. However, if you no longer wish to receive business communication, you may withdraw your consent at any time by making a declaration in person at our registered office by prior agreement, in paper form by notice delivered to our registered office, by declaration sent to the e-mail address GDPR@kopos.cz for that. If you withdraw your consent, we will assume that you no longer wish us to process your personal data for the above marketing purposes.
   
   If you take part in an event of the Company, we can take photographic or video recordings from the event and publish these recordings on our websites, social networks of the Company or in other marketing materials. These recordings are not taken with the intention to process your personal data; however, if you feel uncomfortable with that, let us know as soon as possible and we will remove the recordings if possible.
    
7. New employees recruitment
   If you send us your curriculum vitae, we will use your data for filling a new job position.
   
   We will keep processing your personal data during the whole selection process unless you provide us with your consent allowing us to save your data for the period of additional two years for the case that a new job position will get opened in the future.
    
8. Court proceedings and legal claims defence
   We can use the collected data for investigating or resolving disputes or legal claims related to the business cooperation with the Company, or in other cases allowed by valid laws.

How are cookies processed?

Our website, email messages, online services, advertisements, and interactive applications may use "cookies" to optimise the service. A cookie is a file that we send to your browser via our web server. The purpose of cookies is to enable our web server to provide the user with a website that adapts its use to the user's habits.

At the same time, the Company's website can be viewed in a mode where the behaviour of the visitor is not monitored. It is possible to activate this mode by setting the so-called cookie bar, which will be displayed to the visitor when visiting our website, or by sending an objection pursuant to Article 21 GDPR to the Company's (controller's) e-mail. If cookies necessary for the proper functioning of the website are blocked, the functionality of the website may be impaired.

On the website https://www.kopos.com/ we use the following cookies:

• technical (essential) that are necessary for the functionality of our website and all the features it offers. They are responsible for, among other things, storing products in the basket, displaying the list of favourites, the operation of filters, the shopping process and storing privacy settings.
  We do not require your consent to use technical cookies on our website. For this reason, technical cookies cannot be individually deactivated or activated.
• analytical, which allow us to measure the performance of our website and our advertising campaigns. We use them to determine the number of visits and sources of visits to our website. We process the data obtained through these cookies in aggregate, without using identifiers that point to specific users of our website. If you disable the use of analytics cookies in relation to your visit, we lose the ability to analyse performance and optimise our measures. These cookies are not strictly necessary for the functioning of our website, but they enhance the functionality and practicality of its use.
• advertising, which we or our partners use to show you relevant content or advertisements on our site or on third party sites. This enables us to create profiles based on your interests, so-called pseudonymised profiles. Based on this information, it is generally not possible to directly identify you as a person, as only pseudonymised data is used. Unless you express your consent, you will not receive content and advertisements tailored to your interests.

We process technical cookies on the basis of legal regulations, but in the case of analytical and advertising cookies we need your consent. Consent is granted for the period indicated below for each cookie and can be withdrawn at any time by changing the cookie bar settings and clicking on the "you can refuse consent here" button.

Technical cookies are processed for us by the company drualas s.r.o. Analytical cookies are provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, as the operator of Google Analytics. The cookies collected are subsequently processed by Google Inc. in accordance with the privacy policy available at https://www.google.com/intl/cs/policies/privacy/#nosharing.

As a data controller, the Company uses the following types of cookies:¨

Temporary cookies - these are temporary files that allow you to monitor the activity of subjects on the website and are deleted when the browser window is closed. Persistent cookies - these are permanent files that allow the identification of the subject when browsing the website and improve the user experience of the subject. These files can be deleted at any time in the browser settings.

We do not use third-party cookies that track multiple websites to provide you with personalized content and advertising on third-party websites and other sales channels.

Data communicating and sharing

The Company can share the collected data:

1. With our business partners
   The Company can provide information to its cooperators, suppliers, consultants, software providers or to its business partners as long as they provide the Company with services consisting in processing the personal data the Company cannot provide itself. In no case we provide your personal data either for a consideration or without it to third persons that do not need your data for anything.
   
   We would like to assure you that all contractual partners of the Company are bound with the duty of silence, and adhere to valid legal regulations in the field of personal data protection.
    
2. For legal reasons or dispute resolving
   The Company can share your data as long as it is required so by law, regulations, operating contracts, legal processes or government bodies:

• with police and courts, government authorities or other third parties as long as it is necessary for reinforcing our legal claims, for protecting the rights or property of the Company or third persons;
• with other parties in connection with eventual merging of the Company, assets sales, consolidation or restructuring, financing or transferring the Company or its part to the ownership of another company.

3. With your consent
   The Company can also share your data in other ways as long as it notifies you on sharing and you will agree with it.

For necessary reasons we can provide your data outside the EU countries, primarily in case when the Company commences a business abroad. We would like to assure you that in such a case we shall always adhere to valid legal regulations related to transfers of personal data abroad.

Your rights in connection with personal data processing

In connection with the processing of your personal data you can exercise the following rights under the GDPR with the Company. For exercising of your application use the mail address of the Company stated herein. For reasons of clarity use this form.

1. Data saving and deleting
   We will keep your personal data for the entire duration of your contractual relation with the Company and, as the standard, for more ten (10) years after its termination unless other legal archiving requirements are stipulated. The Company will delete or made anonymous your data immediately after you have asked for (except the cases listed below).
   
   As long as it is allowed by law, the Company can keep some data even after the storing period is over in the following cases:

• if the Company is in the process of resolving a problem with you, e.g. a still unresolved dispute or a legal claim.
• if the law requires so from us, or when this data is stored by us in an aggregated or anonymous form.
• if we need such data for legitimated business purposes.

2. Access to your data
   You can contact us at any time with no charge and ask us for information whether we process your personal data and if so ask us for detailed information on this processing.
    
3. Your data change or error in data
   As long as any change in your personal data occurs during the contractual relation with the Company, e.g. name change, residential or registered address change or a change in your E-mail address or phone number, or you find out we process your data, which is outdated or erroneous, please let us know about that as soon as possible.
    
4. Processing restrictions on the processing of personal data
   If you feel that:

• we process your inaccurate data,
• processing of your data is illegal and you wish all data to be deleted,
• we no longer need your data for the above-stated purposes but you would like to use it for defending your legal claims e.g. in a court proceeding,
• you are already bothered with our messages although we have presumed you would be interested in them,

you can ask us for restricting the processing by limiting it just for some pieces of data or for specific processing purposes.

5. Objection against processing
   For reasons relating to your particular situation, you have the right to object at any time to the processing of personal data that is processed on the basis of Article 6 (1)(e) or (f) of the GDPR. If you object, the Company will not further process your personal data unless the Company demonstrates compelling legitimate grounds for the processing that override your interests or rights and freedoms or for the establishment, exercise or defence of legal claims.
   
   You have the right to object to the processing of personal data for direct marketing purposes at any time. If you object to the processing for direct marketing purposes, your personal data will no longer be processed for these purposes (we generally implement this by means of so-called "blacklisting").
    
6. Personal data processing consent recalling
   As long as the personal data processing is based on your consent, you can recall it at any time in writing (including via E-mail).
    
7. Personal data portability
   You may contact us at any time with the request to transfer the data we hold about you to third party (another data controller) according to your specification.
    
8. Complaints to the Office for Personal Data Protection
   If you consider that your data is being handled in breach of the law, you may lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of employment or place of the alleged breach, at any time if the data subject considers that the processing of his or her personal data infringes the GDPR. The competent supervisory authority for the Company is the Office for Personal Data Protection, located at Pplk. Sochora 27, 170 00 Prague 7, Czech Republic, tel.: 234 665 111, web: www.uoou.cz.

Date of Issue: 25.5.2018
Review: 6.4.2023
Valid from: 6.4.2023