EEA PRIVACY NOTICE
This privacy notice applies to TCCM s.r.o. ID: 27901084, seated at Jindřišská 937/16, Nové Město, 110 00 Praha 1, Czech Republic, kept by Municipal court in Prague, file number C 125246 (hereunder as “TCCM,” “we” or “us”) websites located and operated by TCCM entities located in a country within the European Economic Area (EEA).
TCCM respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit website (regardless of where you visit it from) or when you provide your data to us to enable us to carry out services or sell goods to you or where your data may be transferred to us by our customers for us to carry out services for them. This privacy notice tells you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format, so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
01. Important information
Purpose of this privacy notice
We know how important privacy is to our customers, and we strive to be clear about how we collect, use, disclose, transfer, and store your personal information. This privacy notice aims to give you information on how TCCM collects and processes your personal data through your use of this website, including any data you may provide through this website or otherwise when you sign up to our newsletter, purchase a product or service or take part in a competition or where we are asked to process personal information on behalf of one of our commercial customers.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
TCCM is made up of different legal entities, details of which can be found here https://tccm.com/. This privacy notice is issued on behalf of the TCCM entities located in a country in the EEA so when we mention “TCCM”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the TCCM responsible for processing your data. If required, we will let you know which entity will be the controller for your data when you purchase a product or service with us. TCCM s.r.o. is the controller and responsible for this website.
We have a dedicated team responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us here: email@example.com
You have the right to make a complaint at any time to the relevant supervisory authority for data protection. A list of EU Data Protection Authorities can be found here http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. We would, however, appreciate the chance to deal with your concerns before you approach a Data Protection Authority, so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 21 December 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
02. The data we may collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
03. How is your personal data collected?
We use different methods to collect data from and about you including through:
04. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at firstname.lastname@example.org.
Purposes for which we will 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 at email@example.com 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 in the table below. Please see below purposes of using your personal data. If you have not provided your personal data for any of the specific purposes listed then we will not use it for that particular purpose.
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:
Promotional offers from us
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 or our commercial customers (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We may also use the data we hold about you to invite you to events that may be relevant or of interest to you and your business.
We will get your express opt-in consent before we share your personal data with any company outside the TCCM for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at firstname.lastname@example.org at any time.
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 purchase, warranty registration, product/service experience or other transactions which are necessary to provide you performance of the contract or other contractual obligations.
TCCM may receive Personal data from its commercial customers as part of the services it provides to those customers. In such a case it would normally be the customer that is the data controller and TCCM is the data processor. We will not use that personal data for any purpose other than the fulfilment of our contractual obligations to that customer or in accordance with the customers instructions. Your data is controlled by such customers.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
05. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Our Services make use of social network plugins (“Plugins”). When you use a service that contains Plugins, information may be directly transferred from your device to the operator of the social network. We have no influence on the data gathered by the Plugin. If you are logged into the social network, your use of our Service can be referenced to your social network account. If you interact with the Plugins, for example by clicking “Like”, “Follow”, or “Share”, or enter a comment, the information may automatically show in your social network profile. Even if you are not logged into your social network account, it may be possible that the Plugins transmit your IP address to the social network operators. Please consider this when using our Services.
For information about the social network operators of the Plugins used in our Services (“Operators”) please see below:
06. International transfers
We share your personal data within the TCCM. This will involve transferring your data outside the European Economic Area (EEA).
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
07. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
08. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and other regulatory purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
09. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.:
If you wish to exercise any of the rights set out above, please contact us at email@example.com. For more information on these rights please see the glossary below
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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at firstname.lastname@example.org.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties
Other companies among TCCM acting as joint controllers or processors and who are based in another EEA country and provide IT and system administration services and undertake leadership reporting.
External Third Parties
YOUR LEGAL RIGHTS
You have the right to: