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PERSONAL DATA PROCESSING

1.1 ADMINISTRATORS AND PROCESSORS

Personal data administrator:

108 AGENCY s.r.o. and Members of the 108 REAL ESTATE group (108 AMCR, s.r.o., 108 Investment Advisory s.r.o., 108 AGENCY a.s., 108 AGENCY Hungary kft)

Processors of personal data:

Realman s.r.o., Bitrix, Inc., Google LLC, Contember LTD

Controllers and processors are required to ensure technical, physical, organizational and procedural security, which will be in line with industry standards, to prevent unauthorized access to personal data processed, breach of its confidentiality, security, loss, unauthorized destruction or alteration ("security incident") , all in accordance with the instructions and internal policies of the controller and with valid legal regulations on personal data protection.

1.2 PURPOSES OF PERSONAL DATA PROCESSING

Processing without consent

  • Ensuring the conclusion and subsequent fulfillment of the contractual obligation between the controller and the data subject;
  • Fulfillment of the administrator's legal obligations resulting from the aforementioned contractual obligation[1];
  • Implementation of business activities and management of business opportunities of 108 REAL ESTATE Group;
  • Protecting our legitimate interests[2].

In order to ensure the greatest possible protection of the data subject's privacy, each data subject has the right to object to his/her personal data being processed exclusively for the most necessary legal reasons or to the blocking of personal data. You can find more about the data subject's rights related to the processing of personal data in Article 1.7 of this statement.

Processing based on consent

  • Sending business and marketing materials and other marketing activities.
  • Organizing events such as conferences, trainings, seminars, workshops in both physical and electronic form.
  • Collection and publication of event records in both physical and electronic form.
  • Profiling and analysis of personal preferences and interests in order to present relevant content.

If you do not give the administrator consent to the processing of personal data for the purposes listed above or any of them (Processing based on consent), this does not mean that the administrator has refused to provide you with products or services as a result.

1.3 SOURCES OF PERSONAL DATA

The administrator obtained personal data directly from you, especially from completed forms, mutual communication or concluded contracts. In addition, personal data comes from publicly available sources, registers and records, for example from the commercial register. Furthermore, the administrator obtained personal data from third parties who are authorized to access and process your personal data and with whom they cooperate, as well as from information from social networks and the Internet that you yourself have placed there.

1.4 CATEGORIES OF PERSONAL DATA

To ensure your satisfaction from the proper fulfillment of the obligation, to ensure the fulfillment of legal obligations, to ensure a personalized offer of goods and services of the administrator and for the other purposes listed above, the administrator processes the following categories of personal data:

a) basic identification data – name, surname, residential address and identification number; b) contact details – telephone number and e-mail address; c) information about the use of the administrator's products and services - this is data about which products and services you have contracted with the administrator and which you are using now, including product settings, scope of services, etc.; d) information from mutual communication – information from e-mails, phone call records or other contact forms; e) invoicing and transaction data – this is mainly information appearing on invoices, agreed invoicing terms and accepted payments; f) geolocation information - information from the Internet browser or mobile applications that you use;

1.5 RECIPIENTS OF PERSONAL DATA

Personal data will be accessible to the administrators and processors of personal data mentioned above, as well as authorized employees and representatives of the Members of the 108 REAL ESTATE group.

1.6 TIME OF PERSONAL DATA PROCESSING

Personal data will be processed until the withdrawal of consent or for the period for which it is necessary in relation to the purposes mentioned above (i.e. for the duration of the contract, the existence of a legal obligation of the controller), but not for a period longer than 10 years.

After this time, all data will be irretrievably destroyed. The administrator will store personal data to the extent necessary to demonstrate its actions in accordance with applicable legal regulations.

1.7 DATA SUBJECT RIGHTS

The administrator does everything to ensure that your data is processed properly and, above all, securely. You are guaranteed the rights described in this article, which you can exercise with the administrator.

All communications and statements regarding your rights are provided by the administrator free of charge. However, if the request would be clearly unfounded or unreasonable, especially because it would be repeated, the administrator is entitled to charge a reasonable fee taking into account the administrative costs associated with providing the requested information. In case of repeated application of the request to provide copies of processed personal data, the controller reserves the right to charge a reasonable fee for administrative costs for this reason.

The administrator will provide you with a statement and possibly information about the measures taken as soon as possible, but within one month at the latest. The administrator is entitled to extend the deadline by two months if necessary and taking into account the complexity and number of applications. The administrator will inform you about the extension, including the reasons.

The right to information about the processing of your personal data

You are entitled to request information from the administrator as to whether personal data is being processed or not. If personal data is processed, you have the right to request information from the administrator, in particular, about the identity and contact details of the administrator, his representative and the employee responsible for the protection of personal data, about the purposes of processing, about the categories of personal data concerned, about the recipients or categories of recipients of personal data, about authorized administrators, about the list of your rights, about the possibility to contact the Office for Personal Data Protection, about the source of processed personal data and about automated decision-making and profiling.

If the administrator intends to further process your personal data for a purpose other than that for which it was obtained, it will provide you with information about this other purpose and other relevant information before the said further processing. The information provided to you in the exercise of this right is already contained in this Information, but this does not prevent you from requesting it again.

Right of access to personal data

You are entitled to request information from the administrator as to whether your personal data is being processed or not, and if so, you have access to information on the purposes of processing, categories of personal data concerned, recipients or categories of recipients, the period of storage of personal data, information on your rights (rights request correction or deletion from the administrator, restriction of processing, object to this processing), on the right to file a complaint with the Office for Personal Data Protection, information on the source of personal data, information on whether automated decision-making and profiling occurs and information regarding the procedure used , as well as the meaning and expected consequences of such processing for you, information and guarantees in case of transfer of personal data to a third country or international organization. You have the right to provide copies of processed personal data. However, the rights and freedoms of other persons may not be adversely affected by the right to obtain this copy.

Right to rectification

If, for example, you have changed your place of residence, telephone number or other fact that can be considered personal data, you have the right to request the correction of the processed personal data from the administrator. In addition, you have the right to supplement incomplete personal data, including by providing an additional statement.

Right to erasure (right to be forgotten)

In certain specified cases, you have the right to request that the administrator delete your personal data. Such cases include, for example, that the processed data are no longer needed for the aforementioned purposes. The administrator deletes personal data automatically after the expiry of the necessary period, but you can contact him at any time with your request. Your request is then subject to an individual assessment (despite your right to erasure, the administrator may have an obligation or legitimate interest to retain your personal data) and you will be informed in detail about its processing.

Right to restriction of processing

The administrator processes your personal data only to the extent strictly necessary. However, if you feel that the controller is e.g. exceeding the above-mentioned purposes for which it processes personal data, you can submit a request that your personal data be processed exclusively for the most necessary legal reasons or that personal data be blocked. Your application is then subject to an individual assessment and you will be informed in detail about its processing.

Right to data portability

If you wish the administrator to provide your personal data to another administrator, or to another company, the administrator will transfer your personal data in the appropriate format to the entity designated by you, if there are no legal or other significant obstacles preventing it from doing so.

Right to object and automated individual decision-making

If you find out or just believe that the administrator is processing personal data in violation of the protection of your private and personal life or in violation of legal regulations (provided that the personal data is processed by the administrator on the basis of public or legitimate interest, or is processed for purposes of direct marketing, including profiling, or for statistical purposes or for purposes of scientific or historical significance), you can contact the administrator and ask him for an explanation or you can also raise an objection directly against automated decision-making and profiling.

The right to file a complaint with the Office for Personal Data Protection

You can at any time contact the supervisory authority with your initiative or complaint regarding the processing of personal data, namely the Office for the Protection of Personal Data, with headquarters in Plk. Sochora 27, 170 00 Prague 7, website https://www.uoou.cz/.

Right to withdraw consent

You have the right to revoke your consent to the processing of personal data at any time, either by filling out the form/unchecking the box/sending a revocation to the administrator's address or by using the link in the e-mail communication.

All these rights can be exercised via email to the address: support@108realestate.cz or by letter to 108 REAL ESTATE a.s., Na Poříčí 1079/3a, 110 00 Prague 1, Czech Republic.

You have the right to contact the department responsible for the protection of personal data within 108 REAL ESTATE at the address dpo@108realestate.cz or you also have the right to file a complaint with the relevant supervisory authority (Office for the Protection of Personal Data).

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[1] The processing is necessary for the fulfillment of the contract, for the fulfillment of the administrator's legal obligations, for the protection of the legitimate interests of the administrator, or the processing takes place on the basis of the consent granted to the administrator.

The legality of the processing is also based, for example, on Act No. 563/1991 Coll., on accounting, according to which billing data is processed and stored, on Act No. 89/2012 Coll., the Civil Code, according to which the administrator defends his legitimate interests, or on the law No. 235/2004 Coll., on value added tax.

[2] The Administrator's legitimate interests are in particular the proper fulfillment of all the Administrator's contractual obligations, the proper fulfillment of all the Administrator's legal obligations, direct marketing, the protection of the Administrator's business and property, and last but not least, the protection of the environment and ensuring sustainable development.