This privacy and cookie policy clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) we collect, use and process as a part of our online offer and the websites, functions and contents connected with it as well as external online presences, such as our Social Media Profile.
This notice applies to you, the User of our Services and us the provider of the Services and governs the processing of your personal data in context of our Services and business.
This Policy was last updated on the 15 January 2021.
Who We Are
We are Axellerato Solutions s.r.o., Frydlantska 1312/19, 182 00 Praha 8-Kobylisy, Czech Republic with Registered ID: CZ17100721. If you have any questions about your personal information, or how we use it, you can contact us via email at data@axellerato.com.
We are the data “controller”, which means we are responsible for deciding how and why your personal information is used. We’re also responsible for making sure it is kept safe, secure and handled legally.
What Is Personal Data?
Personal data refers to any information relating to an identified or identifiable natural person (“Personal Data”).
The Regulation
If you live in the European Economic Area, Regulation (EU) 2016/679 (General Data Protection Regulation) is the European Regulation and in the Czech Republic, it is the “Czech Act No. 110/2019 Coll., on Personal Data Processing”.
The Supervisory Authority
The Office for Personal Data Protection (OPDP) in the Czech Republic is the relevant authority for us in matters of data protection. You have the right to make a complaint at any time to the OPDP (www.uoou.cz). However, to address your questions and concerns we request that you contact us via data@axellerato.com before you approach the OPDP.
Accuracy
It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
Automated decision-making and profiling
We do not use automation for decision-making and profiling.
Processing of special categories of data
No special categories data is processed.
Children Data
Our website is not intended for children and we do not knowingly collect data relating to children. If you become aware that your Child has provided us with Personal Data, without parental consent, please contact us and we take the necessary steps to remove that information from our server.
Cookies
We use cookies on our website. To learn more about the cookies we use and how to disable them please view our cookie policy.
What Personal Data do we collect?
We may collect personal information from you in the course of our business, your use of our Services or when you purchase one of our digital solutions.
In general the personal data we collect is limited to the following:
- Identity Data includes: first name, last name, username or similar identifier, title, photos or other images.
- Contact Data includes: billing address, delivery address, email address and telephone numbers, and any social media accounts used to contact us.
- Financial Data includes: bank account and payment card details.
- Transaction Data includes: details about payments to and from you and other details of products and services you have ordered or commissioned from us.
- Technical Data includes: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes: any username and password to access our systems, commissions or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes: information about how you use our website, products, and services.
- Marketing and Communications Data includes: your preferences in receiving marketing from us and any third parties made known to you and your communication preferences.
- We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
- Information you provide, such as when you contact us.
Data collected is linked and if we have already collected some of your data, we will only ask you for the remaining data that is necessary to carry out the service contracted for.
How do we obtain personal data?
We collect personal data from you as part of our business and about you and others as necessary in the course of providing our services. We collect personal data using technology tools and services, including our website and services and email communications sent to us.We gather information about you when you provide it to us, or interact with us directly.In particular via:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you: commission or order for our products or services (for example, by telephone, email or via our websites); subscribe to our publications; request marketing to be sent to you; enter a promotion or survey; make a general inquiry about our products or services; or give us feedback.
Automated technologies or interactions. As you interact with our website or social media accounts, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties: analytics providers such as Google based inside or outside the EEA; advertising networks, such as Google or Facebook, based inside or outside the EEA; search information providers, such as Google, based inside or outside the EEA.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from publicly available sources.
What are the purposes for processing?
- Provision of the online offer, its contents and the website functions.
- Provision of contractual services, our clients, our services and customer care.
- Answering contact enquiries and communication with our users and customers.
- Marketing, advertising and market research.
- Security measures.
How we use your personal data?
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
- To register you as a new customer or account holder;
- To process and deliver a service;
- Manage payments, fees and charges;
- Pass your details to a customer or administrative or technology providers in order to perform our services;
- Collect and recover money owed to us;
- To manage our relationship with you;
- To enable you to take part in a competition or complete a survey;
- To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
- To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
- Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy);
- To use data analytics to improve our website, products/services, marketing, customer relationships and experiences;
- To make suggestions and recommendations to you about goods or services that may be of interest;
What are the relevant legal bases for processing your data?
In accordance with Art. 13 GDPR the following informs you about the legal basis of us processing your data and unless the legal basis is not specifically mentioned, the following applies:
- Consent – This is where we have asked you to provide explicit permission to process your data for a particular purpose. (Art. 6 Para. 1 lit. a and Art. 7 GDPR)
- Contract – This is where we process your information to fulfil a contractual arrangement we have made with you. (Art. 6 Para. 1 lit. b GDPR)
- Answering your business enquiries – This is where we process your information to reply to your messages, e-mails, posts, calls, etc. (Art. 6 Para. 1 lit. b GDPR)
- Legitimate Interests – This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way. (Art. 6 Para. 1 lit. f GDPR). Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.
- Legal Obligation – This is where we have a statutory or other legal obligation to process the information, such as for the investigation of crime. (Art. 6 Para. 1 lit. b GDPR)
- Vital interests – This is where we process your information for communications about security, privacy and performance improvements of our services. Or for establishing, exercising or defending our legal rights. (Art. 6 para. 1 lit. d GDPR)
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). We may send you product or service renewal reminders close to the anniversary of taking up a product or service or other communications we are obliged to send under a legal or contractual obligation.You may receive marketing communications from us if you have expressly requested information from us about our services, or purchased goods or services, or made an inquiry, or if you provided us with your details when you entered a competition or registered for a promotion. We will not, however, send you generic marketing unless you have expressly consented to receive it.
Third-party marketing
We will seek your express opt-in consent before we share your personal data with any company for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time or by following the ‘opt-out’ or ‘unsubscribe’ links in any marketing message sent to you or by contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service commission or order, warranty registration, product/service experience or other transactions, or where we need to keep your contact details or make contact with you for contractual performance or legitimate interest purposes.
Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, the data processed by us will be deleted or restricted in their processing. If the data is not deleted because they are required for other and legally permissible purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
When do we disclose your Personal Data?
We may share your information with organisations that help us provide the services described in this policy and who may process such data on our behalf and in accordance with this policy, to support this website and our services. This will only be done in accordance with the above mentioned legal basis.
Also, if you have consented to it, or where we have a legal obligation to do so or on the basis of our legitimate interests (e.g. when using hosting providers, tax, business and professional advisors, commercial partners, customer care, accounting, billing and similar services that allow us to perform our contractual obligations, administrative tasks and duties efficiently and effectively).
In relation to information obtained about you from your use of our services, we may share a cookie identifier and IP data with analytic and advertising network services providers to assist us in the improvement and optimisation of our website which is subject to our Cookie Policy.
We may also disclose information in other circumstances such as when you agree to it or if the law, a Court order, a legal obligation or regulatory authority ask us to. If the purpose is the prevention of fraud or crime or if it is necessary to protect and defend our right, property or personal safety of our staff, the website and its users.
How do we protect your Personal Data?
The data we collect from you may be stored, with appropriate technical and organisational security measures applied to it, on our server in the Czech Republic. In all cases, we follow generally high data protection standards and advanced security measures to protect the personal data submitted to us, both during transmission and once we receive it.
International transfers
Our main operations are based in the Czech Republic and your personal information is generally processed, stored and used within in the Czech Republic and other countries in the European Economic Area (EEA).
In some instances, your personal data may be processed outside the European Economic Area. If and when this is the case we take steps to ensure there is an appropriate level of security so your personal information is protected in the same way as if it was being used within the Czech Republic and the EEA.
Where we need to transfer your data outside the Czech Republic or the EEA we will use by the European Commission approved Standard contractual clauses in all contracts concerning the transfer of personal data to third countries. As well as transfer personal data only to a non-EEA country with privacy laws that give the same protection as the Czech Republic and the EEA.
Your Rights
You have a number of ‘Data Subject Rights’. Below is some information on what they are and how you can exercise them. There is more information on the Office for Personal Data Protection website (www.uoou.cz).
- information about the processing of your personal data.
- obtain access to the personal data held about you.
- ask for incorrect, inaccurate or incomplete personal data to be corrected.
- request that personal data be erased when it’s no longer needed or if processing it is unlawful.
- object to the processing of your personal data for marketing purposes or on grounds relating to your particular situation.
- request the restriction of the processing of your personal data in specific cases.
- receive your personal data in a and send it to another controller.
- request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers.
- Where the processing of your personal information is based on consent, you have the right to withdraw that consent without detriment at any time through our contact form.
The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal personal information about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it. We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your personal information.
We encourage you to get in touch if you have any concerns with how we collect or use your personal information. You do however also have the right to lodge a complaint directly with the OPDP.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Online presences in social media
We maintain online presences on the basis of our legitimate interests. We maintain online presences within social networks and platforms in order to communicate with customers, interested parties and users who are active there. Unless otherwise stated in this policy, we process the data of users if they communicate with us within the social networks and platforms, e.g. write articles on our online presences or send us messages.
Economic Analyses and Market Research
In order to run our business economically, to identify market trends, customer and user wishes, we analyse the data available to us on business transactions, contracts, enquiries, etc. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata, whereby the persons concerned include customers, interested parties, business partners, visitors and users of the online offer.
This analyses is carried out for the purposes of business management evaluations, marketing and market research. The analyses serve us to increase user-friendliness, to optimise our offer and business efficiency and are not disclosed externally, unless they are anonymous analyses with summarised values.
Calendly
On this website, we have integrated components of Calendly. Calendly is a global provider of a platform that facilitates scheduling of appointments and processes Personal Data upon the instruction of the data exporter in accordance with the terms of the Agreement and the DPA.
When a Calendly User comes to Calendly to schedule an event with a Calendly Member, he/she voluntarily gives Calendly certain information. This can include the name, email address and phone number; email addresses of other people; subject of the meeting; and any other information the user provides Calendly or as required by the Calendly Member he/she is scheduling with. If the user receives an invitation from a Calendly Member but do not wish to become a Calendly User, they can contact the Calendly Member who sent the invitation through other means to set up a meeting.
A Calendly Member may also connect their calendar with Calendly. The calendar integration checks the duration and free/busy status of the events in the calendar so that Calendy doesn’t book the user’s calendar when he is busy. Calendly doesn’t store who the user is meeting with, their email, the meeting title or any other details about the appointments in the connected calendar.
Calendly uses cookies, web beacons and other technologies to receive and store certain types of information when a user interacts with Calendly through a computer or mobile device subject to Calendly’s opt-out preferences.
When a user uses Calendly, their servers automatically record information (“log data”), including information that a user’s browser sends whenever he visits the Calendly Website. This log data may include the user’s web address he/she came from or are going to, the device model, operating system, browser type, unique device identifier, IP address, mobile network carrier, and time zone or location.
Hosting and Content Delivery Networks (CDN)
This website is hosted by an external service provider Web Hosting World websitewebhostingworld.net. The personal data collected on this website is stored on Web Hosting World’s servers. This may include, but is not limited to, IP addresses, contact requests, meta and communication data, contractual data, contact data, names, website accesses and other data generated via a website.
Web Hosting World is used for the purpose of fulfilling the contract with our potential and existing visitors and users and in the interest of a secure, fast and efficient provision of our online offer by a professional provider.
Web Hosting World will only process your data to the extent necessary to fulfil its service obligations and follow our instructions regarding this data.
Changes
This Privacy Notice and our commitment to protecting the privacy of your personal data can result in changes to this notice. Please regularly review this Privacy Notice to keep up to date with any changes.
Queries and Complaints
Any comments or queries on this policy should be directed to us using the following contact details.
Ilie Nejdanov trading as Axellerato
Frydlantska 1312/19, 182 00 Prague 8-Kobylisy, Czech Republic
Registered ID: 09815465
data@axellerato.com