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Data Protection and Privacy Policy
FIN COMMUNICATION s.r.o.
Having its registered office at Revoluční 762/13, Staré Mesto, 110 00 Prague 1 ̌
Registered in the Commercial Register maintained by the Municipal Court in Prague,
Section C, File 238177 IČ (ID Number): 03804330
Represented by Igor Tsybolyuk, Executive
Compliance with the Controller's Information Obligation

The Fin Communication s.r.o. Data Protection and Privacy Policy comes into effect on 25 May 2018. It is issued in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data ("Regulation" or "GDPR") in order to ensure compliance with the controller's information obligation pursuant to Art. 13 GDPR.
Categories of Personal Data

FIN COMMUNICATION S.R.O. (as the controller) may process, in compliance with the conditions below, the following categories of personal data.
1. Personal Identification Details and Address

These data include but are not limited to the title, name and surname, permanent address, registered address or place of business, company name, date of birth, personal number, IČ (ID Number), DIČ (Tax Number), billing address, numbers of identification documents submitted and copies thereof (all details that are not required to execute the contract are redacted on the copies), bank details, and signature. Personal data are processed to the minimum extent necessary to conclude and perform a contract.

2. Contact Details

These data include but are not limited to the contact person's e-mail address and phone number.

3. Other Details Confirming the Data Subject's Trustworthiness, Payment History and Financial Standing

These data include but are not limited to the data disclosed by the data subject to the controller for these purposes based on consent, and data available in legitimately operated registers.

4. Operational Data

These are data processed, in particular, to resolve any disputes arising from specific contracts, data resulting from direct communication in regard to the administration provided by FIN COMMUNICATION S.R.O., as the administrator, and for the purposes of accounting and ensuring compliance with statutory duties of FIN COMMUNICATION S.R.O.

5. Data Processed with the Data Subject's Consent

This includes personal data processing that is not required to perform a contract, statutory duties of the controller or to protect the legitimate interests of FIN COMMUNICATION S.R.O. Such processing aims to improve the quality of administration provided by FIN COMMUNICATION S.R.O. The data are processed only if consent has been granted and may be processed during the term of validity of the consent. Such consent may be withdrawn at any time in writing.
Purposes and Legal Grounds for the Processing of Personal Data

The scope of data processed depends on the purpose of the processing. For certain purposes, data may be processed directly on the basis of a contract or the legitimate interests of FIN COMMUNICATION S.R.O. or by law, all without the data subject's consent. Personal data may be processed for any other purposes only with consent.
1. Processing on grounds of contract performance, compliance with statutory duties and legitimate interests of FIN COMMUNICATION S.R.O.

It is mandatory to provide personal data necessary to perform a contract, comply with statutory duties of FIN COMMUNICATION S.R.O. and to protect the legitimate interests of FIN COMMUNICATION S.R.O. No contracting or administration is permitted without disclosure of personal data for these purposes. Processing for the purposes of contract performance and compliance with statutory duties cannot be rejected. This includes but is not limited to the following sub-purposes: compliance with statutory tax duties (compliance with statutory duties), billing (performance of a contract), purposes set forth in special laws for criminal proceedings, and compliance with the duty to cooperate with the Police of the Czech Republic and other state authorities (compliance with statutory duties). Assessment of a data subject's payment history to prevent any debts that might affect the decision-making of FIN COMMUNICATION S.R.O. regarding the conclusion of other contracts with clients. In addition, claims collection and other customer disputes (legitimate interest), securing evidence should such evidence be necessary to defend the rights of FIN COMMUNICATION S.R.O. (legitimate interest of FIN COMMUNICATION S.R.O.)

2. Processing of FIN COMMUNICATION S.R.O. Client Data on the Basis of Consent

For our client FIN COMMUNICATION S.R.O., we process, with our client's consent, certain data beyond the extent necessary to execute the contract as well as for commercial purposes, primarily to prepare a suitable range of services offered by FIN COMMUNICATION S.R.O. to its client. When approaching clients with suitable offers, the controller limits the processing only to the necessary data. Consent is granted voluntarily and can be withdrawn at any time. If the data subject withdraws its consent, it does not affect the processing of his or her personal data by FIN COMMUNICATION S.R.O. for any other purposes and on other legal grounds in accordance with this Personal Data and Privacy Policy. Commercial communication may be sent to our clients' contact persons on the basis of legitimate interests of FIN COMMUNICATION S.R.O. only until the client expresses its disagreement. Or on the basis of an express consent to the processing of personal data for commercial purposes. All commercial communication will contain a link to use in order to unsubscribe from such communication.
Terms of Personal Data Processing, Time Limits

Personal data intended for such purposes are processed to the extent necessary to achieve such purposes and for the time necessary to achieve such purposes or for the time prescribed by applicable laws and regulations. Personal data are then erased and disposed of within regular time limits. In relation to clients of FIN COMMUNICATION S.R.O., FIN COMMUNICATION S.R.O. is entitled, provided all their obligations to FIN COMMUNICATION S.R.O. have been met, to continue to process the clients' basic personal, identification details, address, contact and other details, and operational data in a client database for 4 years after the termination date of the last contract signed with FIN COMMUNICATION S.R.O.
Personal Data Disclosed in Negotiations that Did Not Result in a Contract

In the event that FIN COMMUNICATION S.R.O. and a potential client hold contract negotiations that do not end with the conclusion of a contract, FIN COMMUNICATION S.R.O. is entitled to process the personal data disclosed for 3 months after the end date of such negotiations.
Other Recipients of Personal Data

FIN COMMUNICATION S.R.O. uses professional services of other entities to comply with its contractual obligations. If such suppliers process personal data transferred by FIN COMMUNICATION S.R.O., they take on the position of data processors. They process personal data only if instructed to do so by FIN COMMUNICATION S.R.O. This includes but is not limited to claims recovery services, practice of attorneys, auditors, IT system administration. We sign a data processing agreement with all such entities. The agreement defines the processor's obligation to safeguard and secure personal data. When complying with its legal duties, FIN COMMUNICATION S.R.O. transfers personal data to administrative bodies and authorities specified in applicable laws and regulations.
Data Processing Methods

FIN COMMUNICATION S.R.O. processes personal data manually as well as using automation, and diligently keeps records of such activities in which personal data are processed.
Information about Data Subject Rights
1. Right of Access to Personal Data

Pursuant to Art. 15 GDPR, a data subject will have the right to access personal data which includes both the right to obtain a confirmation of personal data processing from FIN COMMUNICATION S.R.O., and the right to information about the purposes of processing and categories of personal data processed. In addition, data on recipients to whom personal data are made available and the term of processing. In addition, the data subject has the right to require that the controller rectify or erase personal data concerning the data subject or restrict their processing or to object to such processing. The data subject may request copies of personal data. If requested repeatedly, FIN COMMUNICATION S.R.O. may charge a reasonable service fee. The right to confirmation of the processing of personal data, to request a copy of personal data and information may be exercised in writing at the address of the registered office of FIN COMMUNICATION S.R.O.

2. Right to Rectify Inaccurate Data

Pursuant to Art. 16 GDPR, data subjects have the right to request rectification of any inaccurate personal data concerning the data subject processed by FIN COMMUNICATION S.R.O. Customers of FIN COMMUNICATION S.R.O. are also obliged to report any changes to their personal data and submit evidence of any such change. Rectifications of personal data may be requested in writing from the address of the registered office of FIN COMMUNICATION S.R.O.

3. Right to Erasure

Pursuant to Art. 17 GDPR, the data subject has the right to obtain the erasure of personal data concerning him or her unless FIN COMMUNICATION S.R.O. proves legitimate grounds for the processing of the personal data. FIN COMMUNICATION S.R.O. has implemented a mechanism for erasing personal data where the purposes, which determined the scope and parameters of the personal data processing, ceased to exist.

4. Right to Restrict Processing

Pursuant to Art. 18 GDPR, the data subject shall have the right to obtain restriction of processing until his or her issue has been resolved if the data subject contests the accuracy of the personal data, the grounds for their processing or if the data subject opposes their processing in writing at the address of the registered office of FIN COMMUNICATION S.R.O.

5. Right to Notification Regarding Rectification, Erasure or Restriction of Processing

Pursuant to Art. 19 GDPR, the data subject also has the right to be notified by FIN COMMUNICATION S.R.O. in the event of rectification, erasure or restriction of processing of personal data. FIN COMMUNICATION S.R.O. will make a notification upon written request of the data subject delivered to the address of the company's registered office.

6. Right to Data Portability

Pursuant to Art. 20 GDPR, the data subject has the right to portability of data concerning him or her and data provided by the data subject to a controller, in a structured, commonly used and machine-readable format and the right to request the transfer of such data to another controller by written request to the address of the registered office of FIN COMMUNICATION S.R.O. Requests will not be granted if it could have an adverse effect on the rights and freedoms of third parties.

7. Right to Object to the Processing of Personal Data

Pursuant to Art. 21 GDPR, the data subject has the right to object to processing of his or her personal data on grounds of the legitimate interests of FIN COMMUNICATION S.R.O. It is up to FIN COMMUNICATION S.R.O. to demonstrate the existence of such legitimate grounds for the processing that override the interests, rights and freedoms of the data subject. Otherwise, FIN COMMUNICATION S.R.O. will refrain from processing the data as objected without undue delay. The objection may be made in writing at the address of the registered office of FIN COMMUNICATION S.R.O.

8. Right to Withdraw Consent to the Processing of Personal Data

Consent to the processing of personal data may be withdrawn at any time. Consent may be withdrawn at any time, in the same form in which it was granted.
Automated Decision-Making

FIN COMMUNICATION S.R.O. does not employ automated decision-making.
Right to Contact the Office for Personal Data Protection

The data subject has the right to contact the Office for Personal Data Protection.

If you decide to exercise any of your rights, do not hesitate to send us your written request by e-mail or post at the following contact details:

E-Mail: support@primapay.cz
Mailing address: Revoluční 762/13, Prague 1, 110 00