Instruction on the processing of personal data by ACOMWARE, s.r.o

This instruction summarizes the basic principles of personal data processing by the company ACOMWARE, s.r.o., with registered office at Budějovická 778/3, Michle, 140 00 Prague 4, ID: 25047965, registered in the commercial register maintained by the Municipal Court in Prague, section C, insert 92586 (hereinafter also just "ACOMWARE"), which is the controller of personal data in these cases. Below you will find out how our company will process your data. This instruction is prepared mainly in the sense of EU Regulation No. 2016/679, from now on we will also call it "GDPR".

Content

1) Instruction on the processing of personal data for contractual partners of ACOMWARE, s.r.o

2) Instruction on the processing of personal data of job applicants in ACOMWARE

3) Instruction on the processing of personal data of people within fan pages on social networks

4) Business communication

5) Cookies within ACOMWARE services

6) Right to object
7) Updating data
8) Personal identification number
9) Are you obliged to provide us with the data?
10) Our services and children
11) Agreement
12) Automated decision making
13) Transfer of personal data abroad
14) Risks and best practices
15) Education about your rights
16) How can you contact us?

Instruction on the processing of personal data for contractual partners of ACOMWARE, s.r.o

This instruction summarizes the basic principles of personal data processing by ACOMWARE, s.r.o., if it concerns personal data of real or potential contractual partners - natural persons (except employees).

Overview of processed (types) of data and their sources

In this section, you will learn what types of personal data we will process about you. All information about an identified or identifiable natural person (also called "data subject"); an identifiable natural person is a natural person who can be directly or indirectly identified, in particular by reference to a certain identifier, for example a name, identification number, location data, network identifier or to one or more special elements of physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person. The personal data that we will process about you will usually be obtained directly from you, or as part of contractual cooperation with you. In justified cases (especially when recovering owed amounts), we can also search for additional information about you from open sources.
Personal data of contractual partners - natural persons (hereinafter referred to as "partner") or natural persons who are contact persons of contractual partners, which ACOMWARE will process, includes in particular data provided by partners, typically:

In connection with the communication with the partner, ACOMWARE may also store some technical data, i.e. the time of the communication with the partner and the IP address from which it will be sent. For potential contractual partners - businessmen, our company can process data obtained from open sources (e.g. their websites or advertisements entered by them) in order to then be able to contact them by phone with an offer of services. Our company can store such basic data in its CRM system for further contact. In the same way, we will process some data from public sources to verify the trustworthiness of contractual partners, especially those who will participate in the processing of personal data that we will carry out.
If the supplier will provide ACOMWARE with programming or configuration (setting changes) within the ACOMWARE systems in the form of remote access, the entire course of this remote session, incl. The IP address from which the connection was made, recorded for the purposes of IT security, supervision of the processing carried out and protection of processed personal data.
If the supplier will provide ACOMWARE with data processing within the ACOMWARE systems, the data on its activity in these systems will be logged in the normal scope.
Telephone numbers with which communication took place from company devices (without any related data) may also be stored in a special register for a reasonable period of time for the purpose of properly billing telecommunications services, protecting the rights of ACOMWARE and possibly distinguishing between private and work calls. However, in addition to the administrators of the relevant system, only the employees from whose devices the communication took place have access to such data.

Processing purposes

In this section, we present an overview of the purposes for which we will use (process) your personal data. Usually, each piece of data is used for multiple purposes at the same time. The means of processing, processing time, etc. also depend on the specified purposes. In certain cases specified in the GDPR, we may process your data for purposes other than those listed below, however, these are exceptional and limited cases, which the GDPR requires the fulfillment of other conditions.
The primary purpose of processing the contractual partner's personal data will be:

Data (in particular obtained from electronic communication with the partner, such as IP address and time of communication, logs of its activity in ACOMWARE systems and recordings of the progress of the remote session) will also be used for the purpose

Further, the personal data of the partner will be used by ACOMWARE for the purpose

in particular according to the regulations governing accounting and taxation, regulations regarding the protection of personal data (both as a partner or persons acting on his behalf, this is about documenting the fulfillment of ACOMWARE's obligations according to the GDPR), regulations on the regulation of advertising, etc. and for purposes

Legal basis of processing

Any processing of personal data must be lawful - it must be based on one of the legal bases of processing listed in the GDPR. Similar to the purpose, each data can be processed on the basis of multiple legal reasons for processing. If all legal grounds no longer apply, we will stop processing your data. Possible legal grounds for processing are listed in Article 6 GDPR. Please note that if we process your personal data on the basis of your consent, you have the option to withdraw this consent at any time (to withdraw, use the interface of the service you are using, or contact us at the contacts listed below). Revocation of consent does not affect the legality of processing based on consent that was given before its revocation. However, contractual partners' data are usually not processed on the basis of consent.
The legal basis for the processing of partners' personal data is
• the necessity of fulfilling the contract (including the collection of incurred claims),
• legitimate interests of ACOMWARE (given by the interest in registering contractual relationships and the interest in protecting their rights, especially against legal claims and illegal activities including IT security, processing for statistical purposes and further development of ACOMWARE services, processing for direct marketing) and third parties (especially other of contractual partners participating in performance in which the partner will also participate) a
• fulfillment of legal requirements (especially prevention of criminal activity, fulfillment of requirements according to regulations on personal data protection (especially Act No. 110/2019 Coll. and GDPR), bookkeeping, fulfillment of obligations according to tax regulations and regulations regulating advertising (especially Act No. 40 /1995 Collection) ).

The time after which the data will be processed

Our company cannot process your data for any length of time, but the processing time is limited to the period when we really need your data. We try to limit the length of this period so that it properly takes into account both your and our interests. Sometimes it is more difficult to determine the necessary processing time, or for security reasons it is not appropriate to communicate the exact length of this time, so below we at least list some criteria according to which we decide when determining the length of processing of your data.
Personal data will be processed for a reasonable period of time with regard to the purpose of processing (e.g. contracts and data obtained in connection with their performance will be registered for a standard period of 10 years from their termination; this time limit will not apply to contracts for which this will justify their nature, e.g. long-term license agreements, agreements regarding the creation or termination of property rights, contracts for the acquisition of securities, contracts regarding the use of public funds, contracts for the supply of buildings, some other risk contracts, handover protocols for buildings, etc., where the archiving period will be determined individually and will exceed a period of 10 years or will be stored for an unlimited period). If the processing period is determined by legal regulations, personal data will be processed for such a period, unless the reasons listed below justify a longer processing period.
A basic overview of the fact that a contract was concluded with an entity on the part of ACOMWARE, when it happened and what the subject of performance was, can be stored in the contract database without a time limit.
ACOMWARE will process the contact details of partners for the purpose of sending commercial messages until the partner expresses his disapproval of such sending. Even then, however, ACOMWARE will process basic data about why it sent commercial communications to the partner for a reasonable period of time to prove the legitimacy of such sending.
Recordings of the course of the remote session for programming or configuration work will be kept for a period of several months. Only a limited number of administrators and a security specialist have access to these records. Activity logs in the systems are stored for years.
The above-mentioned times may also be exceeded in individual cases, when justified by the circumstances, e.g. if a legal dispute with a partner is initiated or an inspection by a public administration body is in progress, etc.
When determining the adequacy of the processing time of personal data, it will be based mainly on these aspects
• the length of the limitation period,
• the likelihood of raising legal claims,
• usual procedures on the market,
• the probability and significance of imminent risks and (v) possible recommendations of supervisory authorities.

How the processing will take place and its consequences

Nowadays, most of the processing takes place by computer, so we will usually process your data in a computer system (e.g. in our CRM system, within the Gmail application in the case of e-mails, in our accounting system in the case of data necessary for invoicing, etc. ). Of course, this does not exclude the processing of documents in filing cabinets, such as the system for storing paper contracts or business card filing cabinets maintained by our individual employees.
ACOMWARE will process personal data mainly in its computer systems and the computer systems of processors. ACOMWARE will process the documents in its filing cabinet; our individual employees can also keep their own card files (e.g. business cards). The provision of processed data by the partner is voluntary (however, without the provision of certain data, the contract will not be concluded, and in some cases, certain data are subsequently required by law, especially accounting regulations).

Transfer of personal data to other persons (recipients of personal data)

Not all processing of personal data is carried out by our company itself. We sometimes hire third parties, so-called personal data processors, for processing. We try to choose only such processors who are sufficiently trustworthy. In some cases, we may also make your data available to persons who will be independent administrators of personal data or joint administrators together with our company.
ACOMWARE may make personal data available to third parties only in cases where it is required or permitted by law or with the consent of the partner. ACOMWARE makes personal data available only to the usual extent to processors or other recipients - suppliers of external services (typically programming or other technical support services, suppliers of computer systems, server services, e-mail distribution and archiving service providers), (backup) server operators or technology operators used by ACOMWARE, who process them in order to ensure the functionality of the respective services. In addition, personal data may be made available to the strictly necessary extent to legal, economic and tax advisors and auditors or persons forming a concern with ACOMWARE, who process them for the purpose of providing consulting services. Personal data relating to debtors may also be made available to companies providing debt insurance or debt collection agencies for the purpose of recovery or debt collection. Some activities are also provided centrally by the concern, of which ACOMWARE is a part, where, for example, central lists of suppliers are kept.
Some special regulations allow the persons concerned to request the communication of certain data, e.g. according to § 6b paragraph 2 of Act No. 40/1995 Coll. the distributor of the advertisement is obliged to notify the person who demonstrates a legitimate interest who is the sponsor and processor of the advertisement.

A range of support activities for ACOMWARE is provided by its parent company MAFRA, as, ID: 45313351. Upon request or in case of suspicion of illegal activity, personal data may also be transferred to public administration authorities.
In the case of payment transactions, banks or payment service providers on the Internet can obtain certain data within the normal scope.

Instruction on the processing of personal data of job applicants in ACOMWARE

This instruction summarizes the basic principles of personal data processing by ACOMWARE, s.r.o., if it concerns the personal data of potential collaborators.

What data about you will we process and what are their sources?

We will primarily process personal data about you that you pass on to us or for which you agree to pass them on, e.g. as part of messages on LinkedIn or servers for sharing applicant data (typically data contained in your CV).
For the initial contact with you, we can also use published data regarding your professional activity, our contacts on social networks or recommendations from your acquaintances.
As part of the process of accepting applicants, we usually process the following data (or some of them):
• name and surname
• contact details (address, telephone, e-mail)
• data on your previous work experience
• information about your education
• Your language skills, etc.
• data obtained as part of correspondence with you
• data that we obtain during basic verification of your personal data from public sources, e.g. the LinkedIn network (even here, however, this will be absolutely necessary data used to verify the applicant to the extent allowed by law, especially the data listed in the CV).
In connection with a personal meeting with you or a telephone conversation with you, we may also note that
• what impression you made on us or how your behavior corresponds to the information provided in your CV.
In connection with your response to the job advertisement on our website, we may also store some technical data, i.e
• the time of your reply a
• The IP address from which it will be sent.
If you give us consent to use your data, we will also store data about this
• how and when this consent was given and when it was withdrawn.

How we will collect data about you

We will primarily obtain data directly from you. If we contact you ourselves, we will do so on the basis of published data relating to your professional activity, as part of our contacts on social networks (especially LinkedIn) or recommendations from your acquaintances.

What will we use your data for?

We will use your personal data to offer employment, or to select a suitable candidate to fill a position within the ongoing selection process, or in another competition for a comparable position.
Please note that you can revoke your consent to participate in the selection process at any time free of charge at the contacts listed below. We recommend using either the contact directly with the person from our personnel department who deals with you, or the e-mail address osobni.udaje@fdb188.com. In the event of withdrawal of your consent or your request to cancel your participation in the selection process, we will exclude you from the given selection process and delete your data (we may keep this data for a reasonable period of time for the purpose of protecting our rights). Revocation of consent does not affect the legality of processing based on consent that was given before its revocation.
Your personal data will thus be primarily used
• to select a suitable candidate to fill a position within the ongoing selection procedures (including external cooperation).
If you are selected to fill the given position and a contract is concluded with you, the data you provide (especially your CV) may become part of your personal file.
We will also use your basic identification data, data obtained about you as part of your e-mail correspondence with us or as part of your activity on our website (e.g. data obtained as part of your response to an advertisement)
• for the purposes of protecting the rights of our company or third parties against possible illegal actions that could be carried out as part of such activities and for the purposes of IT security of our website and network.
We will also use data about how you gave us consent or basic data about you and how we obtained data about you
• to fulfill our legal obligations, in particular obligations according to the regulations on personal data protection (evidence of your consent to data processing, etc.) and possibly
• for purposes related to the verification of the fulfillment of contracts concluded with the operators of the above services for sharing resumes.

How long will we process your data?

The processing of personal data for the basic purpose, i.e. for the selection of a suitable candidate to fill a position within the ongoing selection process or comparable positions, will be carried out until the given position is filled and further for a period of approx. 6 months after it is filled (so that we can contact you with an offer of this position in the event that the initially selected candidate did not prove himself for the given position; after this time, emails exchanged with you may be archived for a reasonable period of time, in order to protect our rights or the rights of third parties). If we hire you, your CV and other similar data about you will become part of your personal file and we will process it for the duration of this file.
If you give us your consent to use your data for offers of other positions in the future as well, we will process your data for the above-mentioned purpose (i.e. contacting you for the purpose of offering cooperation) for the period until your consent is revoked.
For the other purposes mentioned above (protection of rights, IT security, fulfillment of legal obligations), we will process the necessary data about you (usually, however, not your CV) for a reasonable period of time, while determining the adequacy of the processing time of personal data based mainly on these aspects
• the length of the limitation period with a reserve for learning that a lawsuit has been filed or other proceedings have been initiated
• the likelihood of legal claims against our company
• expected deadlines for detecting attacks on our network or other detections of security breaches
• usual procedures on the market
• the probability and importance of imminent risks and
• recommended procedures of supervisory authorities.

On what legal basis do we process your data?

The legal basis for the above processing is yours
• consent (for the purpose of including you in the selection process or in our resume database for the purpose of offering jobs in the future) and
• the legitimate interests of our company (especially in the case of initially obtaining contacts from you otherwise than with your consent, for the purposes of processing your data for the purpose of protecting the rights of our company or third parties against possible illegal actions and for IT security purposes).
Please note that the provision of personal data for processing with your consent is voluntary on your part, but without your consent we will not be able to include you in the relevant tenders.
Furthermore, the above-mentioned processing is also the legal basis
• fulfillment of our company's legal obligations, especially in the area of personal data protection regulations (GDPR).
Please note that if consent is the basis for the processing of your data, you have the right to revoke it at any time. Revocation of consent does not affect the legality of processing based on consent that was given before its revocation.

To whom can we make your data available?

We can make your data available to the usual extent to processors or other recipients - suppliers of external services for our company (typically programming or other technical support services, including the registration system for keeping a database of applicants, sending e-mails), operators of our servers or operators of technologies used by us , who process them in order to ensure the functionality of the respective services. In addition, personal data may be made available to the strictly necessary extent to our legal, economic and tax advisors and auditors, who process them for the purpose of providing advisory services. Upon request or in case of suspicion of illegal activity, personal data may also be transferred to public administration bodies. ACOMWARE uses its parent company MAFRA, as to provide some services
If one of our company's employees recommends you, we can provide him with basic information about the stage of the selection process and whether we have selected you for this position.

Instructions on the processing of personal data within the ACOMWARE website

This document summarizes the basic principles of handling the personal data of ACOMWARE website users. ACOMWARE processes personal data in addition to the GDPR in accordance with Act 110/2019 Coll., on the protection of personal data, ev. Act No. 127/2005 Coll., on electronic communications, Act No. 480/2004 Coll., on certain information society services, as amended, and other legal regulations. Therefore, please pay due attention to the above regulations.

For what purposes do we process your data?

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 misuse by users, in accordance with 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
• legitimate interests of ACOMWARE,
given by the interest in protecting our rights, processing for statistical purposes, measuring traffic to our site, analyzing your preferences and displaying content that corresponds to your individual preferences, improving the content of our site and its development, ensuring the security of our systems and network and for direct marketing) and of third parties and
• fulfillment of legal requirements, in particular prevention of criminal activity and fulfillment of requirements according to regulations on personal data protection (especially 127/2005 Coll. and GDPR).
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 relation to inquiries from users of our site will usually include – if you fill it in yourself –
• Your first and last name,
• e-mail,
• telephone,
• the address of your website a
• the text of the message, i.e. the data entered in the forms on our website.
We will process further
• data on how you provided us with data or consent to the processing of your personal data.
usually by storing information about the method and time of granting consent, incl. e.g. your IP address from which you clicked the relevant box a
• when you revoked it.
You can learn more about what data and why we process cookies and other network identifiers below.
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.
To whom can we make your data available?
ACOMWARE makes personal data available only to the usual extent to processors or other recipients:
• 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's auditors, who process them for the purpose of providing ACOMWARE's 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.

Instruction on the processing of personal data of people within fan pages on social networks

This document summarizes the basic principles of handling the personal data of visitors to fan sites on social networks Facebook, Instagram, LinkedIn and Twitter of the company ACOMWARE s.r.o., with registered office at Budějovická 778/3, 140 00 Prague 4, ID: 25047965, entry in the commercial register: Municipal Court in Prague, section C, file 92586 (hereinafter referred to as "ACOMWARE"), which operates as such (in most cases ) as the controller of personal data (in addition to the operators of the aforementioned social networks who are other controllers of personal data). 

We would like to point out, however, that according to § 5 of Act No. 480/2004 Coll. individual users, or the operator of the given social network, are primarily responsible; however, if you alert our company to the objectionable content of such posts, we will deal with your notification properly.

For what purposes do we process your data?

In this section, we present an overview of the purposes for which we will use (process) your personal data. Usually, each piece of data is used for multiple purposes at the same time. The means of processing, processing time, etc. depend on the specified purposes in certain specified cases in GDPR we may process your data for purposes other than those listed below, however, these are exceptional and limited cases that GDPR subject to the fulfillment of other conditions.

Our company does not process personal and other data of visitors to fan sites other than for purposes permitted by law, or for the purposes with which the user has expressed consent.

The data is thus used for the following purposes:

We process your data only within the scope of the possibilities given by the relevant social networks, if we transfer the data outside the given network, this is only for the use of tools that are used for more comfortable management of contributions, otherwise only for the use of aggregated data (which does not allow to identify individuals in any way) or in the case of an individual incident (e.g. a threatening comment on an article). The exception is data obtained from you for the purpose of a job offer, which can be copied outside the relevant network and used for this purpose. 

We may process aggregated data in our own systems or those of external suppliers, but this data does not enable us to identify you in any way.

As part of the Facebook service, our company operates so-called chatbots. Chatbot is an automatic system that is able to answer your questions (especially regarding events organized by our company). IN 

Legal basis of processing

Any processing of personal data must be lawful - it must be based on some v GDPR listed legal basis of processing. Similar to the purpose, each data can be processed on the basis of multiple legal reasons for processing. If all legal grounds no longer apply, we will stop processing your data. Possible legal reasons for processing are listed in Article 6 GDPR. Please note that if we process your personal data on the basis of your consent, you have the option to revoke this consent at any time (to revoke, use the interface of the service you use, delete the data using the appropriate tool of the given social network, or contact us at the following contacts). Revocation of consent does not affect the legality of processing based on consent that was given before its revocation.

The legal basis for the processing of your personal data is our legitimate interests (given by the interest in operating fan pages, protecting our rights, processing for statistical purposes, measuring the number of visitors to our pages, improving the content of our fan pages and their development, ensuring the security of our systems and network and directly marketing) and third parties (especially our contractual partners participating in fulfillment for you or persons you mention in your contributions) and fulfillment of legal requirements (especially prevention of criminal activity, fulfillment of requirements according to regulations on personal data protection (especially Act No. 110/ 2019 Coll GDPR), accounting and fulfillment of obligations according to tax regulations (e.g. for competitions organized within fan sites).

For further communication with contacts obtained for the purpose of a job offer, the legal basis is also the implementation of measures taken before the conclusion of the contract at the request of the data subject (when negotiating a specific job to which the visitor responded to the offer) or the consent of the data subject (in the case of processing personal data for offers other jobs).

What data do we process and what are their sources?

In this section, you will learn what types of personal data we will process about you. All information about an identified or identifiable natural person (also called "data subject"); an identifiable natural person is a natural person who can be directly or indirectly identified, in particular by reference to a certain identifier, for example a name, identification number, location data, network identifier or to one or more special elements of physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person. The personal data that we will process about you will usually be obtained directly from you, or as part of monitoring your activity within our website (accounts). In justified cases (especially when recovering owed amounts), we can also search for additional information about you from open sources.

As part of our fan pages, we only learn about you data that is provided to us by the relevant social network or by you personally. If you do not comment or tag any of our articles or content, or if you do not send us a message, we will not have any information about you beyond the information accessible on the given social network (however, the operator of the relevant social network may have this information). If you comment or mark any of our articles or content, or send us a message, we will usually find out your first and last name, possibly the set language, time zone, gender and the time of your reaction and the text of your post. However, we do not copy this data outside the environment of the given social network and do not process it further (with the exception of the above-mentioned technical systems facilitating the management of our accounts, e.g. responding to your comment or answers to your question and with the exception of processing data for a job offer based on active communication with you, where we can store the relevant data in our system for managing job offers), unless it is a case of an individual incident (e.g. a threatening comment on an article). We do not enrich your data in any way with data from your profiles on the given network, with the exception of possible visits to your profile on the LinkedIn network in order to find out whether your work profile published by you on this network meets our requirements.

How long do we process the data?

Our company cannot process your data for any length of time, but the processing time is limited to the period when we really need your data. We try to limit the length of this period so that it properly takes into account both your and our interests. 

We process data within social networks primarily in an aggregated form, i.e. in such a way that it is not possible to identify individual users. In such a case, we may store such data without a time limit. Otherwise, we can process data that is accessible within the social network until it is deleted from it (even if we usually do not work with it in any way). Details on processing for job offer purposes can be found here here.

When determining the adequacy of the processing time of personal data, we are based in particular on the following points of view: (i) the length of the limitation period with a reserve for us to learn that a lawsuit has been filed or another proceeding has been initiated, (ii) the probability of raising legal claims against our company, (iii) ) expected deadlines for detecting attacks on our network or other findings of security breaches (iv) usual procedures in the market and recommendations of supervisory authorities and (v) the probability and significance of imminent risks.

To whom can we make your data available?

Not all processing of personal data is carried out by our company itself. We sometimes hire third parties, so-called personal data processors, for processing. We try to choose only such processors who are sufficiently trustworthy. As part of the service, we can also make data about you available to third parties - employers, if you give us your consent.

As stated above, we try to process personal data only within the social network in which it is stored. Exceptions may be technical systems that facilitate such a message for us, or data processing for the purposes of a job offer. 

If we were to process personal data outside the relevant social network, ACOMWARE may make your personal data available to the following processors or other recipients:

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.

Agreement

Consent is only one of the reasons for processing, but the GDPR places special requirements on obtaining it. If you feel that your consent is being coerced by us, contact please us and we will deal with this case immediately. 

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.

Automated decision making

According to GDPR as a data subject, you have the right not to be the subject of any decision based solely on automated processing, including profiling, which has legal effects for you or significantly affects you in a similar way (Article 22). Although the GDPR stipulates several exceptions for cases where such automated decision-making is possible, our company tries not to carry out such processing. 

Our company does not make any automated decision-making in connection with social networks that would have legal effects for you or similarly significantly affect you in the sense of Article 22 GDPR (EU) 2016/679. 

Terms of privacy protection of the respective social networks

Information on how the relevant social network operator handles your personal data can be found here:

Facebook

Instagram

LinkedIn

Twitter

Business communication

Please note that the data about your name, surname and address (including electronic) and the segment of your activity transferred to us for the purpose of negotiating a contract, concluding it or preparing an offer, may be used for the purpose of offering the business and services of ACOMWARE, as The same applies if you provide us with this data yourself as part of the newsletter sending request. By providing information about your e-mail address, ACOMWARE obtains 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 (also applies to legal entities). 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.
Data on how we obtained the possibility 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, we can

process for a reasonable period of time (max. 4 years, unless it is to resolve an incident) after you have been removed from the database for sending commercial messages, in order to demonstrate the basis on which we sent you commercial messages.
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.

Cookies within ACOMWARE services

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 activity, especially for distinguishing individual computers and individual settings of some services ) – 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 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 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.
Cookies take up almost no space on the computer disk, their size is usually several kilobytes.
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.
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,
which are stored on your computer only until the end of the browser session and
• persistent cookies,
which remain stored on your computer 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.

To improve our site

From time to time, we may use functionality on our site that tracks how users behave on it, in particular which links they click on the most and which place they mouse over first. This helps us optimize our site to make it more user-friendly.

For statistical recording, traffic measurement and network security

Each time you visit our website, the analytical software stores its own 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. If you want to refuse the measurement of your traffic by the Google Analytics system, install the Google Analytics Opt-out Browser in your 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.
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.
You can get more information about Google's rules here.
You can get more information about the rules of the Facebook system here.
The rules applicable to the system of the Czech Publisher Exchange association can be found here.
The rules applicable to the Adform system can be found here.

You can opt out of the use of certain cookies on the above pages or at 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
Edge
Internet Explorer
Firefox

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. 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 GDPR.
If the legal reason for the processing of your personal data is the legitimate interest of ACOMWARE (this is in particular the processing of data for IT security purposes, for statistical purposes and further development of ACOMWARE services and the protection of the rights of ACOMWARE and third parties, etc.), you have for reasons related to your specific situation the right to object to such processing of personal data at any time. 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. The person concerned can raise an objection to the processing via the contact details listed 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.
In the case of data processing for the purposes of direct marketing (sending marketing messages), it is always possible to raise an objection without further ado, so in this case you do not have to give any reasons why you do not wish to continue to send marketing messages. In these cases, the best way to object is to unsubscribe from further communications by clicking on the link that will usually be included in them for this purpose. You have the same right according to § 7 of Act No. 480/2004 Coll.
Please note that even in the above-mentioned cases, parallel processing of personal data will usually take place for other purposes that will justify ACOMWARE continuing to process such data (e.g. for the purpose of protecting our rights or proving the legal reasons why we are doing business with you sent the 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.
If there is a change in the data provided or other data provided by the partner, we may ask for information about such change to be sent. In order to update data, ACOMWARE can be contacted at the contacts listed below, preferably by e-mail at osobni.udaje@fdb188.com.

Personal identification number

We will process your social security number only if you provide it voluntarily or if it is required by law (unless it is explicitly stipulated by law, our company does not, for example, insist that you include your social security number on contracts, so it is better not to include it in contracts) .
In the event that a partner - a natural person voluntarily provides ACOMWARE with information about his social security number on the basis of or in connection with the concluded contract, he agrees as the bearer of this social security number in the sense of § 13c paragraph 1 of Act No. 133/2000 Coll. with the fact that ACOMWARE uses this personal identification number for the purposes of recording contracts, provided performance and protection of ACOMWARE's rights, to archive, process and use it for this purpose. However, subsequent processing is already covered by a legitimate interest according to Article 6 paragraph 1 letter f) GDPR.

Are you obliged to provide us with the data?


You usually 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 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.

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 the GDPR. If it was for you e.g. the possibility of registration to our service is refused due to automatic checking of e.g. duplicate e-mail addresses, 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.

Transfer of personal data abroad

While the principle of free movement of persons within the EU applies under the GDPR, the GDPR restricts the transfer of personal data abroad outside the EU. By default, our company does not transfer personal data to countries outside the EU. However, it may happen that your personal data will be processed in a computer system whose servers will be located outside the EU. With regard to the systems usually used in business, they would these were systems using servers located mainly in the United States of America. In such a case, we would choose a trusted company as a contractual partner, and the transfer would be ensured by the so-called standard contractual conditions issued by the European Commission.

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. Not all information that you can fill in, for example, in the application form is mandatory. Filling in some data can help us, for example, to contact you, but you can decide not to provide us with such data. 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) 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.
> Photo and video coverage is taken as part of the conferences. We are not able to delete or not capture individual people within the footage of several people, and it would not even be reasonable. If our photographers and videographers were to take portrait pictures of you and you did not agree to it or would not like them to be published, the best way is to directly ask the person in question not to take/delete such a picture.
> Persons 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 contact us separately. However, our conferences are not intended for persons under the age of 18, unless expressly stated otherwise.
> If you log in to 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, e.g. 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 that 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.

Education about your rights

A natural person has the right with our company as a personal data administrator:
a) to request access to personal data processed by the administrator, which means the right to obtain from the administrator a confirmation as to whether or not the personal data relating to her are being processed, and if so, she has the right to obtain access to this personal data and other information listed in Article 15 GDPR,
b) request the correction of personal data processed about her if they are inaccurate (Article 16 GDPR). Taking into account the purposes of the processing, in some cases it has the right to also request the completion of incomplete personal data,
c) request deletion of personal data in cases regulated in Article 17 GDPR.
d) request the restriction of data processing in cases that are regulated in Article 18 of the GDPR,
e) obtain personal data relating to her and
(i) which we process with her consent, or
(ii) which we process for the performance of a contract to which such a natural person is a party or for the implementation of measures taken prior to the conclusion of the contract at his request
in a structured, commonly used and machine-readable format, while having the right to transfer this data to another controller, under the conditions and with the restrictions set out in Article 20 GDPR and
f) has the right to object to processing in the sense of Article 21 of the GDPR for reasons relating to her specific situation (see above).
If we receive such a request, we will inform the applicant of 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. Our company is not obliged to comply with the request in whole or in part in certain cases stipulated by the GDPR. This will be the case in particular if the request is manifestly unfounded or disproportionate, especially because it is repeated. In such cases, we may (i) impose a reasonable fee that reflects the administrative costs associated with providing the requested information or communication or taking the requested action, or (ii) refuse to comply with the request.
If we receive the above request, but have reasonable doubts about the identity of the applicant, we may ask him to provide additional information necessary to confirm his identity.

We will store the information that the data subject exercised his rights with us and how we processed his request for a reasonable period of time (usually 3-4 years) for the purpose of documenting this fact, for statistical purposes, improving our services and protecting our rights.
In the event that the data subject believes that ACOMWARE processes his personal data without authorization or otherwise violates his rights, he has the right to file a complaint with the supervisory authority (i.e. the Office for the Protection of Personal Data - www.uoou.cz) or he has the right to request judicial protection .

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
tel.: +420 737 289 119
Databox ID: xbbi32q

Our company has also appointed a so-called personal data protection officer, whom you can contact in matters related to the processing of personal data:
ACOMWARE Ltd
Vladan Ramis
e-mail: vladan.ramis@fdb188.com
phone: +420 225 063 137

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ACOMWAREACOMWARE Ltd
Budejovice 778/3
140 00 Prague 4

We are partners

This is the website of the company ACOMWARE s.r.o., with headquarters in Prague 4 - Pankrác, Budějovická 778/3, ZIP Code 140 00, ID: 25047965, registered in the commercial register maintained by the Municipal Court in Prague, section C, insert 92586.
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