GDPR.

If you are our customer, a newsletter subscriber or a visitor to our online shop, you entrust us with your personal data.

The security of your personal data is a priority for us. We therefore pay due attention to personal data and its protection. In this Privacy Policy we would like to inform you about what personal data we collect about you and how we further use it.

1. Basic provisions

1.1. The controller of personal data under Article 4(7) of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the „GDPR“) is opio a.s., Company ID: 10982230, with its registered office at Dukelská tř. 57d, 614 00 Brno, Czech Republic, file no. B 8566 kept by the Regional Court in Brno (hereinafter the „controller“).

1.2. The controller's contact details are:

• address: opio a.s., Company ID: 10982230, registered office at Dukelská tř. 57d, 614 00 Brno, Czech Republic
• e-mail: collalloc@collalloc.com
• telephone: +420 737 933 889

1.3. Personal data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

1.4. The controller has not appointed a data protection officer.

2. Sources and categories of personal data processed

2.1. The controller processes personal data that you have provided to it, or personal data that the controller obtained in connection with fulfilling your order.

2.2. The controller processes your identification and contact details and the data necessary for the performance of the contract.

3. Legal basis and purpose of processing personal data

3.1. The legal basis for processing personal data is:

• performance of the contract between you and the controller under Article 6(1)(b) of the GDPR,
• the controller's legitimate interest in providing direct marketing (in particular for sending commercial communications and newsletters) under Article 6(1)(f) of the GDPR,
• your consent to processing for the purposes of direct marketing (in particular for sending commercial communications and newsletters) under Article 6(1)(a) of the GDPR in conjunction with Section 7(2) of Act No. 480/2004 Coll. of the Czech Republic, on Certain Information Society Services, where no order for goods or services has been placed.

3.2. The purpose of processing personal data is:

• fulfilment of your order and the exercise of rights and obligations arising from the contractual relationship between you and the controller; when placing an order, the personal data necessary for the successful fulfilment of the order are required (name and address, delivery address, billing address, e-mail, telephone, bank details), the provision of personal data is a necessary requirement for concluding and performing the contract, without providing personal data it is not possible to conclude the contract or for the controller to perform it,
• sending commercial communications and carrying out other marketing activities,
• satisfaction with your purchase, which we ascertain through e-mail questionnaires within the Verified by Customers programme, in which our online shop participates. We send these to you each time you buy from us, unless, within the meaning of Section 7(3) of the Act on Certain Information Society Services, you refuse to receive our commercial communications. If you do not wish to receive a satisfaction questionnaire, please inform us at collalloc@collalloc.com, or you may at any time object by declining further questionnaires using the link in the questionnaire e-mail. For sending questionnaires, evaluating your feedback and analysing our market position we use a processor, which is the operator of the Heureka.cz portal; for these purposes we may pass on to it information about the goods purchased and your e-mail address.
• satisfaction with your purchase, which we also ascertain through the Google Customer Reviews programme. If you give consent on the order confirmation page, we will pass to Google your e-mail address, order number, delivery country and expected delivery date so that Google can send you a short questionnaire evaluating your purchase after delivery. You give consent voluntarily directly in the Google form and without it we will not send you a questionnaire.

3.3. There is no automated individual decision-making by the controller within the meaning of Article 22 of the GDPR.

4. Data retention period

4.1. The controller retains personal data:

• for the period necessary to exercise the rights and obligations arising from the contractual relationship between you and the controller and to assert claims arising from these contractual relationships (for a period of 15 years from the end of the contractual relationship),
• for the period strictly necessary to secure all rights and obligations arising from the purchase contract, i.e. for the duration of the order and the guarantee period,
• until consent to the processing of personal data for marketing purposes is withdrawn, at most 5 years, where personal data are processed on the basis of consent,
• discussion contributions 5 years,
• correspondence 2 years.

4.2. After the personal data retention period has elapsed, the controller shall erase the personal data.

5. Recipients of personal data (the controller's sub-processors)

5.1. Your personal data will be passed on to other persons or otherwise made available only where this is necessary within the performance of the purchase contract, on the basis of a legitimate interest, or where you have given prior consent.

5.2. We further pass on personal data:

• for the purpose of paying for the order online (by payment card, quick bank transfer button) to the payment processing service provider (GoPay Czech odštěpný závod),
• for the purpose of delivering the goods to the contracted carriers (PPL, Zásilkovna),
• for the purpose of ascertaining customer satisfaction in the Google Customer Reviews programme, on the basis of your consent, to Google Ireland Limited, or Google LLC,
• where necessary for the investigation of unlawful use of our services or for the purposes of court proceedings, the data may be passed to criminal investigation authorities, legal representatives and courts for the purpose of enforcing or concluding any contract with you.

5.3. We contractually require all these service providers to process your personal data in accordance with the personal data protection conditions and applicable legislation.

5.4. With the exception of the Google Customer Reviews programme (see clause 3.2), the controller does not intend to transfer personal data to a third country (a country outside the EU) or to an international organisation. Within that programme, personal data may be processed by Google LLC in the United States of America, on the basis of appropriate safeguards, in particular standard contractual clauses and Google's certification under the EU-US Data Privacy Framework.

6. Your rights

6.1. Under the conditions laid down in the GDPR you have:

• the right of access to your personal data under Article 15 of the GDPR,
• the right to rectification of personal data under Article 16 of the GDPR, or restriction of processing under Article 18 of the GDPR,
• the right to erasure of personal data under Article 17 of the GDPR,
• the right to object to processing under Article 21 of the GDPR,
• the right to data portability under Article 20 of the GDPR,
• the right to withdraw consent to processing in writing or electronically to the address or e-mail of the controller stated in Article 1 of this policy.

6.2. You also have the right to lodge a complaint with a supervisory authority if you believe that your right to personal data protection has been infringed. In the Czech Republic this is the Office for Personal Data Protection (uoou.cz); if you reside in another EU member state, you may also contact the supervisory authority of that state.

7. Personal data security conditions

7.1. The controller declares that it has adopted all appropriate technical and organisational measures to secure personal data.

7.2. The controller has adopted technical measures to secure data storage and the storage of personal data in paper form.

7.3. The controller declares that only persons authorised by it have access to personal data.

8. Final provisions

8.1. By sending an order from the online order form you confirm that you are familiar with the personal data protection conditions and that you accept them in full.

8.2. You agree to these conditions by ticking the consent box in the online form. By ticking the consent box you confirm that you are familiar with the personal data protection conditions and that you accept them in full.

8.3. The controller is entitled to change these conditions. It will publish the new version of the personal data protection conditions on its website.

9. Effective date

This Privacy Policy takes effect on 17 September 2018.