Protection of personal data

For what purposes do we process your data?

Our company does not process the personal and other data of the users of our website other than for purposes permitted by law, or for the purposes with which the user has expressed consent.

Unless otherwise specified in the relevant terms of service, this data is usually used for the following purposes:

• answering visitors' questions
• to protect our rights (e.g. in the event of a lawsuit regarding our services)
• for statistical purposes (in this context, however, your data is usually aggregated in such a way that it is not possible to determine your identity)
• measuring traffic to our website
• analyzing your preferences and displaying content that corresponds to your individual preferences
• organizing consumer contests, delivering prizes and reporting on such contests
• improving the content of our site and its development
• ensuring the security of our systems and network against attacks from the outside or abuse by users in the usual market standard
• for the purposes of fulfilling our legal obligations (e.g. documenting consent to the processing of personal data, prevention of criminal activity, etc.)
• to a reasonable extent for direct marketing, i.e. a more targeted display of content and advertising on our website to individual users and the sending of commercial messages, including so-called remarketing (targeted advertising) and behavioral advertising. However, we use third-party systems for these purposes.

We usually process your data in our own computer systems, although we may also use the systems of third parties (so-called processors).

Legal basis of processing

The legal basis for the processing of your personal data is the legitimate interests of ACOMWARE (given by the interest in protecting our rights, processing for statistical purposes, measuring our website traffic, analyzing your preferences and displaying content that corresponds to your individual preferences, improving the content of our website and its development, ensuring security of our systems and network and on direct marketing) and third parties and the fulfillment of legal requirements, in particular the prevention of criminal activity, the fulfillment of requirements according to regulations on the protection of personal data (in particular Act No. 101/2000 Coll. and Regulation No. (EU) 2016/679).

Processing for some direct marketing purposes (e.g. sending commercial communications from third parties by e-mail) may also be based on your consent. Please note that consents to the processing of personal data may be revoked at any time by contacting the contacts listed below. This does not affect the legality of processing based on consent that was given before its revocation.

What data do we process, for how long and what are their sources?

The data we collect in connection with the users of our site may usually include your first and last name, e-mail, telephone, your website address and the text of the message, i.e. the data entered in the forms on our site. We will also process data on how you gave us consent to the processing of your personal data (usually by storing information about the method and time of consent, including, for example, your IP address from which you clicked the relevant box) and when you revoked it.

All personal data are processed only to the extent necessary to fulfill the above-mentioned purposes and only for the time necessary to achieve the above-mentioned purposes, but no longer than for the period determined by the relevant legal regulations or in accordance with them. Personal data transmitted to ACOMWARE by the user with his consent are processed until the consent is revoked; however, our company may process some such data even after consent has been revoked, if it has another legal reason to do so (e.g. to document the fact that we processed the data with consent or for the possibility of defense against legal claims).

We usually archive the data obtained as part of inquiries for a maximum of 3 years (if they are not subsequently used to fulfill the contract). If it is a question of the processing time of other data, then if it is not explicitly stated in the terms of service or stipulated by a legal regulation, when determining the adequacy of the processing time of personal data, we base it mainly on these aspects (i) the length of the limitation period with a reserve in order to find out, that a lawsuit has been filed or other proceedings have been initiated, (ii) the likelihood of legal claims being brought against our company, (iii) the expected timeframes for detecting attacks on our network or other detections of security breaches (iv) customary market practices and recommendations of supervisory authorities and (v ) of the probability and importance of impending risks.

If we need information from you that will directly identify you or that will allow us to contact you for the purpose of providing the product or service you have requested, we will explicitly ask you for it.

For some (especially paid) services, we also need to know some additional information about users, so please carefully study the terms of the given service.

In connection with the use of our services, we may further collect certain additional information about you for the aforementioned purposes, for example, the name of the Internet service provider and the IP address with which you log in to our services, the date and time of access to these services, basic geographic location, etc.

We obtain the personal data processed by us either directly from you (by providing it to us, e.g. as part of filling out a form on our site or from individual correspondence with you), or as part of monitoring your activity within our site.

Risks and best practices

Any processing of personal data entails certain risks. These can be different with regard to the scope of the processed data and the method of their processing. Below are some recommended practices that can help you protect your data:

• if you provide us with your data, always think about whether it is necessary to provide the data. In particular, you should carefully consider providing data that relates to your personal life and aspects of it unrelated to the purposes for which you provide it. If you feel that we require too much data from you, contact us, we will check the adequacy of our request.
• if you provide us or publish personal data of third parties (your family members or other employees of your company, etc.) in our services, think about whether this transfer is necessary and necessary. If necessary, seek the consent of such third parties
• if one of our colleagues asks you to provide data, do not be afraid to ask whether it is necessary and whether the purpose of the processing cannot be achieved even without this data.
• people under the age of 18 are particularly vulnerable. If the transfer of data will concern these persons, it is necessary to consider all the circumstances particularly carefully. At the same time, it is necessary to consider whether the provision of such data does not require the consent of these persons or their legal representatives (e.g. parents). If you are a person under the age of 18, if you have doubts about whether you are capable of making the right decision, discuss the whole matter with your parent (or other legal representative) or contact us separately.
• if you log into our systems using a password, always use a unique strong password that you will not use for other devices and accesses. Do not share or disclose your password to anyone, including our employees. We will never require you to provide your password, so be especially careful of various e-mail requests to provide passwords, even if they are signed on behalf of ACOMWARE. These are probably fakes for the purpose of luring and then misusing the password.
• if you send us confidential data, try to use a secure method of communication, for example, encrypting the file with a password and passing the password through another communication channel.
• if you feel that our company is not fulfilling all its obligations, there has been an unauthorized data leak, or someone is impersonating our employee, please let us know as soon as possible. You can find the contacts of our company below.
• we always try to keep these lessons up to date. Therefore, we will make adjustments to these rules from time to time. We will inform you separately about more substantial changes, but it is not harmful to read these rules again from time to time.
• keep your information up-to-date in the interface of our services.

To whom can we make your data available?

ACOMWARE may make your personal data available to third parties only in cases where it is required or permitted by law or with your consent. ACOMWARE makes personal data available only to the usual extent to processors or other recipients:

• to suppliers of external services for ACOMWARE (typically programming or other technical support services, server services, sending e-mails, services related to the measurement of traffic to our sites and adapting their content to user preferences),
• operators of backup servers or operators of technologies used by ACOMWARE, who process them in order to ensure the functionality of the relevant ACOMWARE services,
•  to the extent strictly necessary to ACOMWARE's legal, economic and tax advisors and ACOMWARE auditors who process them for the purpose of providing ACOMWARE advisory services
• personal data relating to debtors with overdue debts may also be made available to companies providing debt insurance or collection agencies for the purpose of enforcing or collecting ACOMWARE claims
• upon request or in case of suspicion of illegal activity, personal data may also be transferred to public administration bodies.

Third Party Services on the Website

Please note that our website may contain elements that enable the collection of personal data or the monitoring of the behavior of users of this website by third parties (usually, however, in a so-called pseudonymized form, i.e. without the possibility of obtaining direct identification data).

Third parties who can thus gain access to your personal data, depending on the nature of the service you use or have used, can be:

• persons analyzing the traffic of our websites,
• payment gateway providers (payment card providers),
• operators of advertising systems in connection with targeted advertising.

The data obtained as part of remarketing can be shared with other participants of the relevant network, but again always only in a form that does not allow you to be specifically identified. You will learn more about this processing method below.

Some ACOMWARE websites also allow the function of sharing or rating content on social networks or direct transition to our social network accounts through third-party applications, such as sharing via the "Like" button of Facebook, further sharing within social networks such as Twitter, Youtube , Google+, etc. These applications can collect and use information about your behavior on the ACOMWARE website.

This processing is governed by the terms and conditions of these companies, which you can find in particular here:

Facebook        https://cs-cz.facebook.com/about/privacy

Twitter            https://twitter.com/privacy

Google+          https://www.google.com/policies/privacy/?hl=cs

Pinterest         https://help.pinterest.com/cs/help-topic/Legal%20and%20privacy

Flicker            https://policies.yahoo.com/ie/cs/yahoo/privacy/products/flickr/index.htm

Youtube          https://www.google.cz/intl/cs/policies/privacy/

LinkedIn         https://www.linkedin.com/legal/privacy-policy?src=li-other&veh=www.linkedin.com%7Cli-other

ACOMWARE has no control over data processing by the aforementioned services and applications. You must therefore contact the operators of such services regarding their processing of personal data.

Are you obliged to provide us with the data?

You provide your personal data to ACOMWARE voluntarily. If in some cases you are required to provide personal data for processing according to a special law, you will be separately informed about this fact.

Our services and children

Our services are not directly intended for use by persons under the age of 18.

Agreement

Please note that if the legal reason for the processing of your personal data is your consent, you can revoke such consent at any time free of charge at the contacts listed below. Revocation of consent does not affect the legality of processing based on consent that was given before its revocation.

Right to object

The right to object is your important right. It allows you to review the processing carried out on the basis of our so-called legitimate interest in the case where this is justified by your specific situation - i.e. in the case when the processing itself is permissible, but there are specific reasons on your part why you still do not want the processing to take place. In such a case, ACOMWARE will not further process such personal data unless there are serious legitimate reasons for the processing that outweigh your interests or rights and freedoms, or unless they are processed for the determination, exercise or defense of legal claims. However, the possibility to raise an objection does not apply to all cases of processing, e.g. it is not possible to use it in the case when we process your data necessary for the performance of the contract or when their processing is imposed on us by law. The right to object is enshrined in Article 21 of the Regulation.

You can object to processing via the contact details below or preferably via e-mail osobni.udaje@fdb188.com. In the e-mail, please state the specific situation that leads you to the conclusion that ACOMWARE should not process the data. He points out that even in the above cases, however, parallel processing of personal data will sometimes take place for other purposes, which will justify ACOMWARE continuing to process such data.

Automated decision making

Our company does not intend to carry out any automated decision-making that would have legal effects for you or similarly significantly affect you in the sense of Article 22 of Regulation (EU) 2016/679. If, for example, you were refused the possibility to register for our service due to an automatic check of e.g. a duplicate e-mail address, you can always contact the administrator of the relevant service or our company in general with a request for a final decision, which will always be based on an assessment by the operator .

Business communication

Please note that data about your name, surname and address (including electronic) provided to us for the purpose of negotiating a contract, concluding it or answering a question may be used for the purpose of offering business and services to ACOMWARE, a.s. By providing information about your e-mail address, ACOMWARE the possibility of sending ACOMWARE business communications (newsletters and business offers) by electronic means to these addresses until you express your disagreement with such use. As part of individual services, consent may also be granted to the sending of commercial communications from third parties; even if we send you commercial communications from third parties, we will not pass on your addresses to such third parties unless you give us your consent.

We may process data on how we obtained the opportunity to process your data for sending the above-mentioned messages, the texts of the messages sent and data on when you expressed your disagreement or revoked your consent for a reasonable period of time after you are removed from the database for sending commercial the message is discarded for the purpose of proving the basis on which we sent you the commercial message.

When sending commercial messages electronically, you will always have the option to refuse consent to such use of your electronic contact in a simple way and free of charge, even when sending each individual message.

Updating data

One of our duties as a personal data controller is to process accurate data, or to complete incomplete data, depending on the circumstances. If you provide us with information about a change in your data, you will help us fulfill this obligation properly. Therefore, if there is a change in the data provided by you, we would like to ask you to send information about such a change, or to change it in the service interface.

Information on your legal rights for the period up to 24 May 2018 according to Act no. 101/2000 Coll.:

In accordance with the provisions of § 5, § 11, § 12 and § 21 of Act No. 101/2000 Coll., on the protection of personal data, we hereby inform all users of ACOMWARE's web services who provide ACOMWARE with their personal data about their legal rights:

Every data subject has the right to access personal data and the right to correct personal data. Any data subject who discovers or believes that the administrator or processor is processing his personal data in violation of the protection of the private and personal life of the data subject or in violation of the law, especially if the personal data is inaccurate with regard to the purpose of their processing, may ask the administrator or the processor for an explanation, demand that the administrator or the processor remove the state thus created. In particular, this may involve blocking, correcting, supplementing or disposing of personal data. If the data subject's request is found to be justified, the controller or processor will immediately remove the objectionable condition. If the administrator or processor does not comply with the data subject's request, the data subject has the right to contact the Office for Personal Data Protection directly (this procedure does not preclude the data subject from contacting the Office for Personal Data Protection without further ado). If, as a result of the processing of the data subject's personal data, other than property damage has occurred, the procedure for asserting her claim is in accordance with a special law.

Instruction on your legal rights for the period from 25/05/2018 according to the Regulation of the European Parliament and the Council (EU) no. 2016679 of April 27, 2016 on the protection of natural persons in connection with the processing of personal data and on the free movement of such data and on the repeal of Directive 95/46/EC (hereinafter referred to as the "Regulation"):

Please note that you have the right with our company as the administrator of your personal data:

• request access to the personal data that we process about you, which means the right to obtain from our company as controller confirmation whether or not personal data relating to you is being processed and, if so, you have the right to obtain access to such personal data data and other information listed in Article 15 of the Regulation,
• request the correction of personal data that we process about you if it is inaccurate. Taking into account the purposes of the processing, in some cases you have the right to also request the completion of incomplete personal data,
• request the erasure of personal data in the cases specified in Article 17 of the Regulation.
• request the restriction of data processing in cases that are regulated in Article 18 of the Regulation,
• obtain personal data relating to you and
  • which we process with your consent, or
  • which we process for the fulfillment of the contract to which you are a party or for the implementation of measures taken before the conclusion of the contract at your request
• in a structured, commonly used and machine-readable format, and you have the right to transfer this data to another administrator, under the conditions and with the restrictions specified in Article 20 of the Regulation and
• you have the right to object to processing in the sense of Article 21 of the Regulation for reasons relating to your specific situation.

If we receive your request in the sense of the previous paragraph, we will inform you about the measures taken without undue delay and in any case within one month of receiving the request. If necessary, this deadline can be extended by another two months, taking into account the complexity and number of applications. If we do not accept the measure you request, we are obliged to inform you immediately and at the latest within one month of acceptance of the reasons for not taking the measure. In this context, we would like to point out that in certain cases stipulated by the Regulation, we are not obliged to comply with your request in whole or in part. This will be the case especially if your request is clearly unfounded or unreasonable, especially because it is repeated. In such cases, we may (i) impose a reasonable fee taking into account the administrative costs associated with providing the requested information or communication or taking the requested actions or (ii) refuse to comply with the request.

If we receive your request but have reasonable doubts about your identity, we may ask you to provide additional information necessary to confirm your identity.

We will store information about the fact that you have exercised your rights with us and how we handled your request for a reasonable period of time (usually 3-4 years) for the purpose of documenting this fact and protecting our rights.

We would also like to point out that if you believe that our company is processing your personal data unlawfully or otherwise violates your rights, you have the right to file a complaint with the supervisory authority (i.e. Office for Personal Data Protection) whether you have the right to request judicial protection.

Cookies within ACOMWARE services

We use so-called cookies to distinguish individual computers and individual settings of some services. These are small text files that our servers (as well as many other servers) store on individual computers using a web browser. Cookies can be thought of as the memory of a website that they believe will recognize the user on the same computer the next time they visit.

Cookies take up almost no space on the computer disk, their size is usually several kilobytes. Cookies are not used to obtain any sensitive personal data.

Standard web browsers support cookie management. For more detailed information, please use your browser's help. If your browser has the use of cookies enabled, we will assume that you agree to the use of standard cookies by our servers.

Use of so-called cookies

In accordance with the provisions of § 89 of Act No. 127/2005 Coll., on electronic communications, we hereby inform you that our servers use so-called cookies for their operation - small amounts of data that our servers send to your computer and which enable better use of our servers and adaptation of their content to your needs and preferences. Cookies are used by almost every website in the world. Cookies are generally useful because they increase the user-friendliness of repeatedly visited websites. If you use the same computer and the same Internet browser to visit our website, cookies will help your computer remember the pages you visited and your preferred settings for individual pages.

None of our cookies used on our website collects information that would contain your direct identification data.

Types of cookies

There are two types of cookies – temporary cookies that are stored on your computer only until the end of the browser session and permanent cookies that remain stored on your computer for longer. Temporary cookies enable the storage of information when moving from one website to another and eliminate the need to repeatedly enter certain data.

Permanent cookies help us to identify your computer if you visit our website again, but they do not allow us to identify you personally. Another advantage of persistent cookies is that they allow us to tailor our site to your interests and prevent the same ad from being displayed repeatedly. Even in this case, however, we cannot identify you personally in any way, and we store the relevant data completely anonymously and do not combine them with any other data.

What do we use cookies for?

To save personal settings

During the first visit, we will test the parameters of the computer and the Internet connection. This is then used, for example, for optimal settings of e.g. the video player.

For statistical recording, traffic measurement and network security

With each visit to our website, the analytical software saves anonymous cookies. These help to determine how many users visit our site repeatedly. In this way, we better understand how readers behave on our pages, what they prefer and what they are interested in. We also use the Google Analytics tool for these purposes. Details about this tool can be found here: https://www.google.com/intl/cs_ALL/analytics/index.html. However, you must contact Google for information on further processing within this tool.

If you want to refuse the measurement of your traffic by Google Analytics, install it in your browser Google Analytics Opt-out Browser.

This information is not linked in any way to other information. So we know, for example, that a given section is repeatedly visited by a hundred thousand people per month. But we don't know who they are.

Our servers can also participate in research on Czech internet traffic by NetMonitor. However, participation in this research beyond the scope of normal measurement cookies is subject to your consent. More information about this research can be found here: https://www.netmonitor.cz/o-projektu.

On our website, we also use tools for analyzing your preferences when using the website and displaying content. Such tools allow us to find out which part of our site is most visited and to make decisions based on this. How should we layout our pages?

The data we record can also be used to secure our network and prevent attacks on it.

To store registration information

For registered users, we store log-in or log-out information in cookies.

To deliver relevant content on our site

We also use some cookies to show you exactly the content that might be of interest to you. For this purpose, we also use tools that track the movement of users on our site, so that we can organize our site in a way that is more convenient for users.

For advertising purposes

Some cookies are created by advertising systems. With their help, they find out how many people have seen a certain advertisement or how many of them have seen it repeatedly. Through our web servers, cookies from other entities, namely operators of advertising systems that are operated on our website, can also be stored on your computer. However, these operators are directly responsible for such processing.

On some pages, we allow the placement of advertisements for multi-party systems, e.g. the system of Google, Facebook, the Adform system of Adform and the system of the Czech Publisher Exchange association. These systems typically use behavioral advertising techniques (see below). Advertising systems usually have their own personal data protection policies, our servers cannot read or write these cookies. In some cases, however, the above systems are used to show you our advertising in these systems.

Other cookies are used to better target advertising according to user behavior (behavioral advertising). This is data that is not linked to other types of cookies. We use the data obtained in this way exclusively to segment visitors in order to deliver a more relevant advertising message. Segments are created based on several general patterns of visitor behavior and the content of the pages they visit. Our company certainly does not create any detailed profiles of our visitors.

Some of the above-mentioned systems also use retargeting techniques, when you may be shown content on third-party websites that is related to what you viewed on other websites. Our company does not operate such a system itself. Therefore, please request information about such use from the operator of the systems that use the relevant cookies.

As part of segmentation, we may also collect general information about the approximate geographic location of your computer or mobile device. This data is collected to provide personalized content based on your geographic location.

Learn more about Google's policies here.
You can get more detailed information about the rules of the Facebook system here.
You can find the rules applicable to the system of the Czech Publisher Exchange association here.
You can find the rules applicable to the Adform system here.
You can opt out of the use of certain cookies on the above pages or at the address https://www.youronlinechoices.com/cz/vase-volby.

Measuring pixels and local storage

A measuring pixel (sometimes also called a web beacon) is a small graphic image placed on a web page, which, like a cookie, can be used to collect certain information from your computer, for example its IP address, the time when the content of the page was viewed, the type of browser and the existence of cookies previously set by the same server. Some of our sites may use web beacons to monitor the effectiveness of our site, to test whether the conditions for limiting the use of our services are met and in addition to cookies for the purpose of segmenting users for displaying content and advertising.

In some cases, we also use the so-called "local storage" of your internet browser or similar functionality via the so-called "Indexed DB" in the browser for purely technical purposes (e.g. saving volume settings, etc.). These are special storages in the browser where user settings can be saved. These settings are usually stored in these repositories until they are changed.

Cookie management settings in browsers:

Standard web browsers (Internet Explorer, Mozilla Firefox, Google Chrome, etc.) support cookie management. Within the browser settings, you can manually delete individual cookies, block or completely prohibit their use, they can also be blocked or enabled only for individual websites. For more detailed information, please use your browser's help.

If your browser has the use of cookies enabled, we will assume that you agree to the use of standard cookies by our servers.

You can find cookie management settings in the main browsers here:

Chrome:https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=cs

Edge: https://support.microsoft.com/cs-cz/help/12454/windows-10-microsoft-edge-privacy-faq

Internet Explorer: https://support.microsoft.com/cs-cz/help/17442/windows-internet-explorer-delete-manage-cookies

Firefox: https://support.mozilla.org/cs/kb/Povolen%C3%AD%20a%20zak%C3%A1z%C3%A1n%C3%AD%20cookies

How can you contact us?

You can use the following contacts for any comments and questions about the protection of personal data and for contact regarding the exercise of your legal rights:

ACOMWARE Ltd

Budějovická 778/3, 140 00 Prague 4

e-mail: osobni.udaje@fdb188.com

Databox ID: xbbi32q