If you are our customer, subscriber to our newsletter, or visitor of our website, you entrust us with your personal data. We are responsible for their protection and security. Please familiarize yourself with the data protection policy, principles, and rights you have under the GDPR (General Data Protection Regulation).
Who is the controller?
We, TTP invest, a closed-end investment fund a.s.
118 00 Prague 1 Malá Strana
VAT ID: CZ24141224, who operate the website www.zameklisno.cz. We process your personal data as controllers, meaning we determine how personal data will be processed and for what purpose, for how long, and we choose any other processors who will help us with processing.
If you wish to contact us during processing, you can reach us at firstname.lastname@example.org.
We declare that as controllers of your personal data, we meet all legal obligations required by the applicable legislation, in particular the Personal Data Protection Act and the GDPR, and therefore we: will process your personal data only on the basis of a valid legal reason, primarily legitimate interest, fulfillment of the contract, legal obligation, or given consent, will fulfill the information obligation in accordance with Article 13 of the GDPR before starting the processing of personal data, will enable and support you in exercising and fulfilling your rights under the Personal Data Protection Act and the GDPR.
Scope of personal data and processing purposes
We process personal data that you entrust to us for the following reasons (to fulfill these purposes):
● providing services, fulfilling the contract – your personal data to the extent of e-mail, which we necessarily need to fulfill the contract (e.g., sending access to the application, delivering goods, etc.)
● accounting – if you are customers, we necessarily need your personal data (billing data) to comply with legal obligations for issuing and recording tax documents.
● marketing – sending newsletters – your personal data (e-mail and name), gender, what you click on in the e-mail, and when you most often open them, we use for the purpose of direct marketing – sending business messages. If you are our customer, we do so from a legitimate interest because we reasonably assume that our news will interest you for X years from the last order. If you are not our customer, we will only send you newsletters based on your consent, for X years from granting it. In both cases, you can withdraw this consent by using the unsubscribe link in each email.
● advanced marketing based on consent. Only based on your explicit consent, we process your personal data to the extent of e-mail, name, gender, date of birth, and whether you have clicked on a link in our e-mail for the purpose of direct marketing using automated means. You can withdraw this consent at any time through our contact information.
Security and personal data protection
We protect personal data to the maximum extent possible using modern technologies that correspond to the degree of technical development. We protect them as if they were our own. We have adopted and maintain all possible (currently known) technical and organizational measures that prevent the misuse, damage or destruction of your personal data.
Transfer of personal data to third parties
To ensure specific processing operations that we cannot provide on our own, we use the services and applications of processors who can protect data even better than we can and specialize in such processing. These are providers of the following platforms:
Mailchimp – Application for sending newsletters.
Google – Google search console, Google Analytics and Google Adwords.
It is possible that in the future, we will decide to use additional applications or processors to facilitate and improve processing. However, we promise that in such a case, we will place at least the same requirements on the processor’s security and processing quality as on ourselves.
Transferring data outside the European Union
We process data exclusively in the European Union or in countries that ensure an appropriate level of protection based on a decision of the European Commission.
Your rights in connection with personal data protection
In connection with the protection of personal data, you have a number of rights. If you wish to exercise any of these rights, please contact us via e-mail: email@example.com.
You have the right to information, which is already fulfilled by this information page with the principles of personal data processing.
Thanks to the right of access, you can ask us at any time and we will provide you with the personal data we process and why within 14 days.
If something changes or you find your personal data inaccurate or incomplete, you have the right to supplement and change personal data.
You can use the right to restrict processing when you believe that we are processing your inaccurate data, when you believe that we are processing your data unlawfully, but you do not want to delete all data, or if you have objected to the processing. You can restrict the scope of personal data or the purposes of processing. For example, by unsubscribing from the newsletter, you limit the purpose of processing for sending commercial messages.
Right to data portability
If you want to take your personal data and transfer it to someone else, we will proceed as we would with the right of access, except that we will send you the information in a machine-readable format. We need at least 30 days for this.
Right to erasure (right to be forgotten)
Your next right is the right to erasure (right to be forgotten). We don’t want to forget about you, but if you wish, you have the right to do so. In such a case, we will delete all of your personal data from our system and the systems of all subprocessors and backups. We need 30 days to ensure the right to erasure. In some cases, we are bound by a legal obligation, and for example, we must keep tax documents issued for the period specified by law. In this case, we will delete all such personal data that are not bound by other laws. We will inform you by email when the erasure is completed.
Complaint to the Office for Personal Data Protection
If you feel that we are not handling your data in accordance with the law, you have the right to file a complaint with the Office for Personal Data Protection at any time. We would be grateful if you could inform us of any suspicions first so that we can take action and correct any errors.
Unsubscribe from newsletters and commercial messages
We send you emails with inspiration, articles, products, and services if you are our customer based on our legitimate interest. If you are not yet a customer, we only send them to you based on your consent. In both cases, you can unsubscribe from our emails by clicking the unsubscribe link in each email sent.
We assure you that our employees and collaborators who will process your personal data are obliged to maintain confidentiality about personal data and security measures whose disclosure would endanger the security of your personal data. This confidentiality also applies after the termination of contractual relations with us. Without your consent, your personal data will not be disclosed to any other third party. These personal data processing principles have been in effect since May 25, 2018, and replace the previous Data Protection.
Thank you for your time.
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