We at LUXURY GUIDE INTERNATIONAL, s.r.o., ID No.: 24149217, registered office at Truhlářská 1106/9, Nové Město, 110 00 Prague 1, registered in the Commercial Register kept by the Municipal Court in Prague, Section C, Insert 183170 (hereinafter referred to as „LUXURY GUIDE INTERNATIONAL“), undertake to protect your personal data.
In this document you will find information on why, when, how and what personal data is processed within LUXURY GUIDE INTERNATIONAL. You will also find a way to contact us if you have any questions about the processing of your personal data or how to correct your personal data.
We may change and update our personal data processing policy in certain circumstances. We therefore recommend that you monitor this document in your own interest and ensure that you are always up to date with its contents.
We encourage you to read the information carefully. We have done our best to make it as clear as possible. If something is still not clear to you, we will be happy to explain any term or section to you. You can contact us at any time in writing at Luxury Guide International, s.r.o., Pařížská 5, Prague 1, 110 00 or by e-mail at firstname.lastname@example.org.
When processing personal data, we are governed by applicable legislation, in particular:
– Act No. 110/2019 Coll., on the processing of personal data;
– European Union law, in particular 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 and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as „GDPR“).
2. Useful terms
Let us explain some basic concepts relating to data protection:
„Personal data“ means any information about an identified or identifiable natural person; an identifiable natural person is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, a network identifier or to one or more specific elements of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
‚Data subject‘ means the natural person to whom the personal data relate;
‚Data controller‘ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union or Member State law, that law may determine the controller concerned or the specific criteria for its appointment. Unless otherwise specified in this policy, in the terms of a specific contract or in the consent, LUXURY GUIDE INTERNATIONAL is the controller of the personal data.
‚Data Processor‘ means a natural or legal person, public authority, agency or other entity that processes personal data for the Controller;
‚Processing‘ means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automated processes, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or any other disclosure, alignment or combination, restriction, erasure or destruction.
3. What personal data do we process?
We respect the principle of data minimization. We only process information about you that we strictly need to fulfil a contractual obligation or that you provide us with your consent beyond the strictly necessary processing.
At LUXURY GUIDE INTERNATIONAL we process the following categories of personal data:
– Identification and address data: name, surname, title, date of birth, permanent address; if you are a business, ID number, registered office, VAT number;
– contact details: contact address, telephone number, fax, e-mail and other similar information;
– other data necessary for the performance of the contract in the case of orders: bank account;
– data resulting from communication;
– data processed on the basis of consent;
– transactional data: number or other identification of the contract, information on the subject matter of the contract or performance of the contract.
4. Why do we process your personal data?
We always process your personal data to the extent necessary for the relevant purpose – e.g. for:
– For the purposes of providing the services and concluding the contract, we process your personal data necessary for your identification, as well as other personal data necessary for the performance of the contract (e.g. bank account details).
– Order delivery: we process your personal data in order to properly process and deliver your order. In some cases, personal data may also be transferred to third parties (e.g. the carrier of the goods).
– Customer service: if you contact us with a question/problem, we need to process your data to answer/resolve it.
– Marketing: based on your consent, we send you commercial communications to the email address you provided when you placed your order, or if you have only subscribed to the LUXURY GUIDE INTERNATIONAL newsletter. You can easily unsubscribe from receiving commercial communications by clicking on this link.
We will not share your personal data with third parties for their marketing purposes unless we have received your consent for these purposes. In the event that you have given us such consent but later no longer wish to receive marketing materials from the third party, please contact the relevant third party directly.
– Exercise of rights and legal claims: we may also process your personal data on the grounds that we need it to exercise our rights and legal claims (e.g. if you have an outstanding claim against us)
– Accounting and tax: we collect and process your identification and transaction data in order to comply with our accounting and tax obligations to regulatory and government authorities imposed by the Accounting Act, the VAT Act and other accounting and tax laws.
– Inspections by public authorities: we may also process your personal data because we need it for the purposes of inspections by public authorities and for other similarly compelling reasons.
Beyond the above, any other personal data may be processed if you voluntarily provide it to us. We reserve the right to destroy unsolicited personal data. We will inform you of this procedure where appropriate.
The transfer of data that you provide us with your consent is voluntary. We require the transmission of other data because the processing of such data is necessary for the conclusion or performance of a contract, the fulfilment of our legal obligations or the protection of our legitimate interests. If you do not provide us with such data, we cannot conclude the relevant contract with you.
5. How long do we keep your personal data?
We will only retain your personal data for as long as necessary to fulfil the purposes set out in this policy or to comply with our legal obligations. We have set up an internal archiving policy to ensure that we do not hold data for longer than we are entitled to.
The latest period of processing of personal data that we apply at LUXURY GUIDE INTERNATIONAL is 10 years from the date on which the legal relationship between you and LUXURY GUIDE INTERNATIONAL was terminated, or 10 years from the end of the tax year in which the transaction took place. The obligation to keep identification and transaction data is imposed on us by the Accounting Act, the VAT Act and other accounting and tax laws. However, we also store your personal data for a period of 10 years because of our legitimate interests, in particular in the event that we have to provide evidence in a legal dispute, in view of the statutory limitation periods under the Civil Code.
We keep the data we process with your consent for as long as the consent is validly given. For the avoidance of doubt, we retain the consent itself and any modification or withdrawal of consent on the grounds of our legitimate interests for the entire period of validity of the consent and for 10 years after it has expired.
If we ask you for your consent to the processing of your personal data by LUXURY GUIDE INTERNATIONAL, the request for your consent will be clearly worded and will provide you with a reasonable basis for decision-making. You may withdraw your consent at any time by contacting us using the contact details set out at the beginning and end of this policy.
We will only retain your personal data for as long as necessary to fulfil the purposes described in this policy or the purposes of which you have been informed by other means. This means that once you have given us consent to process your personal data, we will retain your data in accordance with your consent and/or until you withdraw your consent. However, even if you withdraw your consent, we may retain some of your personal data for as long as necessary to comply with our legal obligations and for the purposes of defending us in any legal proceedings.
7. Sources of personal data
Depending on the situation, we process data that we have received directly from you, as well as data from publicly available sources and registers and data obtained from third parties (for example, our business partners). If someone passes on your personal data to us, they must inform you in advance.
WEBSITES AND SOCIAL NETWORKS
You can visit the LUXURY GUIDE INTERNATIONAL website without having to provide your identity or any other information about yourself.
In the event that you fill in your personal data on our website as part of placing an order, you give us your consent to process your personal data. This data is subject to all the protections as described in this document.
In the event that you contact us via a social network, in particular via our Facebook page https://www.facebook.com/luxuryczechia or via our Instagram account https://www.instagram.com/luxury_cz/, all data protection also applies to data collected from your Facebook or Instagram profile and communications made via Facebook Messenger or Instagram.
When you use our website, your personal data is processed via cookies. „Cookies“ are data files placed on your computer by websites and/or applications that serve as unique identifiers.
The information obtained through cookies is used to improve the services we provide, for example, to personalise our website, to prevent you from re-displaying notifications you have already viewed or to update the website.
Cookies are for your convenience and we recommend that you enable them. However, you can block each of the categories of cookies (with the exception of truly essential cookies) in your browser settings. Blocking or disabling cookies may hinder the functionality of the website. For these purposes, we provide below a list of the cookies we use:
– Strictly necessary cookies
– CDN system cookies
– Analytical/performance cookies
– Functional cookies
– Targeting/advertising cookies
8. Disclosure and transfer of personal data
We manage your personal data in principle within LUXURY GUIDE INTERNATIONAL. If we entrust a third party to carry out certain activities forming part of our services, the processing of the relevant personal data may be carried out by that third party.
In some cases, these third parties become the processor of the personal data. The processor is entitled to handle the data solely for the purpose of carrying out the activity for which it has been authorised by the relevant controller. In this case, your consent is not required for the purposes of the processing activity.
In particular, the processors may be:
– IT service providers,
– provider of occupational health and safety services,
– providers of printing and mailing services, including couriers.
Beyond the above, we only transfer personal data outside LUXURY GUIDE INTERNATIONAL if we have your consent to do so or if required by law. Some public authorities and other organisations are entitled to request this information by law.
We strive to keep the data you entrust to us as secure as possible. To this end, we have put in place a number of technical and organisational measures to protect your personal data from accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing.
We restrict access to your personal data to those employees of LUXURY GUIDE INTERNATIONAL who need the information for the purposes of processing it on our behalf and who are contractually obliged to maintain the security and confidentiality of your personal data.
As we have already mentioned, in certain cases we transfer, or are required to transfer, personal information to third parties. In such cases, we choose trusted partners who we have ensured will maintain at least the same level of privacy protection as we provide at LUXURY GUIDE INTERNATIONAL.
When transferring personal data to public authorities, we always use the most appropriate and secure options offered by the relevant authority.
10. Your rights related to the processing of personal data
In order to exercise your rights with regard to the personal data we process, we require your identification. Please note that if we are unable to verify your identity electronically or if we have reasonable doubt about your identity, we will ask you to provide proof of identity or other proof of identity. This is the only way to ensure that we do not disclose your personal data to another person or make unauthorised modifications to your personal data.
a. Right to information and access to personal data
We respect the principle of transparency in the processing of personal data. In accordance with Article 15 of the GDPR, where this principle is defined, we will always provide you with information about what personal data we process about you.
If you request information about the processing of your personal data, we will provide you with information about the purpose of the processing, the personal data or categories of personal data that are the subject of the processing, including any available information about the source, recipient or categories of recipients. You will also be informed of the intended period for which the personal data will be stored or, if this cannot be determined, the criteria used to determine this period, and the existence of the right to request the rectification or erasure of your personal data or the restriction of its processing or to object to such processing, as well as the right to lodge a complaint with a supervisory authority.
You have the right to request from LUXURY GUIDE INTERNATIONAL a copy of the personal data processed, provided that the rights and freedoms of others are not adversely affected. We may charge a reasonable fee based on administrative costs for additional copies at your request. If you make a request electronically, we will provide you with the information in the electronic form that is commonly used unless you request otherwise.
b. Right to rectification
When processing your personal data, we aim to ensure that it is accurate and up-to-date. We will endeavour to erase or correct inaccurate or incomplete personal data. If you become aware that any personal data we process about you is incorrect or out of date, please notify us. You have the right to have LUXURY GUIDE INTERNATIONAL correct inaccurate personal data concerning you without undue delay. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed.
In some cases, we cannot rectify personal data. This is particularly the case if your incorrect or outdated personal data is contained on a tax document which we archive according to the law.
Any corrections will also be communicated to the recipients to whom the personal data was provided, except where this is impossible or requires disproportionate effort.
c. Withdrawal of consent to the processing of personal data
Further processing of your personal data that is carried out on the basis of your consent to the processing of personal data may be prevented at any time. Simply withdraw your consent to such processing. If you would like your personal data not to be further processed by LUXURY GUIDE INTERNATIONAL, please use this form.
d. Right to erasure (right to be forgotten)
You have the right to have LUXURY GUIDE INTERNATIONAL delete the personal data concerning you without undue delay.
LUXURY GUIDE INTERNATIONAL is obliged to delete personal data without undue delay if one of the following reasons applies:
(a) the personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
b) you withdraw the consent on the basis of which the personal data was processed and there is no further legal basis for the processing;
(c) the personal data have been unlawfully processed;
d) the personal data must be erased to comply with a legal obligation under European Union or Czech law.
In this case, we will delete all your personal data that we process. The exceptions are where the processing is carried out because of a legal obligation or because of our legitimate interest in the exercise and defence of legal claims.
The deletion will also be notified to the recipients to whom the personal data was provided, except where this is impossible or requires disproportionate effort.
e. Right to restriction of processing
You have the right to have LUXURY GUIDE INTERNATIONAL restrict the processing of your personal data in any of the following cases:
(a) you contest the accuracy of the personal data, for the time necessary to allow LUXURY GUIDE INTERNATIONAL to verify the accuracy of the personal data;
b) the processing is unlawful and you refuse the erasure of the personal data and request instead a restriction on its use;
c) LUXURY GUIDE INTERNATIONAL no longer needs the personal data for the purposes of the processing, but you require it for the establishment, exercise or defence of legal claims;
d) an objection to processing has been raised, pending verification that the legitimate interests of LUXURY GUIDE INTERNATIONAL outweigh your grounds for objection.
Any restrictions will also be notified to the recipients to whom the personal data has been disclosed, except where this is impossible or requires disproportionate effort.
f. Right to portability of personal data
You have the right to obtain the personal data concerning you that you have provided to LUXURY GUIDE INTERNATIONAL in a structured, commonly used and machine-readable format and the right to transmit this data to another controller without being prevented from doing so by LUXURY GUIDE INTERNATIONAL if:
(a) the processing is based on consent to the processing of personal data or the processing of personal data for the purposes of concluding and performing a contract; and
b) the processing is carried out by automated means
In exercising your right to data portability, you have the right to have the personal data transmitted by LUXURY GUIDE INTERNATIONAL directly to another controller, if technically feasible. The right to data portability must not adversely affect the rights and freedoms of other persons.
However, LUXURY GUIDE INTERNATIONAL does not currently carry out automated processing of personal data and the transfer of your personal data to another controller is therefore not possible at this time.
g. Right not to be subject to automated decision-making, including profiling
You have the right not to be the subject of any decision based solely on automated processing, including profiling (i.e. any form of automated processing of personal data consisting of the use of such data to evaluate certain personal aspects relating to you), which has legal effects concerning you or similarly significantly affects you. This right does not apply if the automated decision is necessary for the conclusion or performance of a contract between you and LUXURY GUIDE INTERNATIONAL or is based on your explicit consent; however, in these cases you have the right to human intervention in the automated decision by LUXURY GUIDE INTERNATIONAL, the right to express your opinion and the right to challenge the automated decision.
However, LUXURY GUIDE INTERNATIONAL does not currently carry out such processing of personal data.
h. Right to object
If personal data are processed on the basis of the legitimate interests of LUXURY GUIDE INTERNATIONAL, you have the right to object at any time to the processing of personal data concerning you for these legitimate interests. This objection must be substantiated by you in order for us to be able to assess it properly. Your objection and the reasons for it will then be assessed and weighed against the legitimate interests of LUXURY GUIDE INTERNATIONAL. If your reasons outweigh the legitimate interests of LUXURY GUIDE INTERNATIONAL, the processing of your personal data will be restricted or your personal data will be deleted.
i. Right to lodge a complaint with a supervisory authority
You have the right to lodge a complaint against the processing of your personal data with the supervisory authority, which is the Office for Personal Data Protection, located at Pplk. Sochor 27, 170 00 Prague 7 – Holešovice.
In case of any uncertainties or questions regarding the processing of your personal data, and to exercise any of the above rights, you can contact us at any time in writing at Luxury Guide International, s.r.o., Pařížská 5, Prague 1, 110 00 or by e-mail at email@example.com