Personal data processing

Personal data processing

1. Personal data protection

• Related legislation
  • REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("GDPR")
  • Act No. 110/2019 Coll. on the processing of personal data ("the Act")
  • Act No. 111/2019 Coll. amending certain acts in connection with the adoption of the Act on the processing of personal data
• What is GDPR?
  • The General Data Protection Regulation or GDPR is a piece of legislation that establishes a uniform standard for the protection of individuals' personal data across the EU.

• What rights does the GDPR give you as an DSP?
  • One of the biggest benefits of the GDPR is that it significantly strengthens the rights of individuals, or data subjects, in relation to the data that concerns them. In particular, the GDPR strengthens and clearly regulates the right of access, rectification, erasure, the right to be forgotten, the right to restriction of processing, data portability and, last but not least, the right to object. A detailed description of these rights and how to exercise them can be found below.
• What are the grounds for erasure of your personal data?
  • Personal data is no longer necessary for the purpose for which it was collected or processed.
  • You withdraw your consent to processing if the processing is based on consent and there is no other legal basis for the processing.
  • You object to processing on the basis of a legitimate interest of the data controller, e.g. processing for direct marketing purposes.
  • The personal data has been processed unlawfully. 

 2. Terms

• Data Subject ("DSP")

The natural person (including self-employed persons) to whom the personal data relates (e.g. potential, current or former customer, job applicant, supplier, etc.);

• Personal data

Any information about an identified or identifiable person; although this sounds complex, it is essentially just data through which a person can be identified (identifiable) or which can be linked to that person through other identifiers, in particular by reference to an identifier such as a name, an identification number, location data, a network identifier, or to one or more specific elements of the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person; specific personal data may be grouped into coherent groups - categories of personal data (e.g. (e.g. contact, identification, descriptive);

• Controller

Algotech, a.s. as the entity that determines the purpose and means of processing personal data, carries out the processing and is responsible for it. Algotech may authorize or delegate the processing of personal data to a processor, unless a specific law provides otherwise;

• Processor

Any entity that, on behalf of Algotech, Inc., processes personal data in accordance with the GDPR and the Act, based on an executed contract for the processing of personal data;

• Recipient of personal data

An entity that is authorised to handle personal data on the basis of a special law (e.g. the Police of the Czech Republic, the financial administration);

• Purpose of the processing of personal data

The reason for which it is necessary or expedient to process the personal data of the data subject;

• Cookies

Electronic data that the WWW server sends to the browser, which then stores it on the user's computer (SU). The browser then sends this data back to the server on each subsequent visit to the same server. Cookies are commonly used to distinguish individual users, store user preferences, etc.

• Processing of personal data

Any operation or set of operations concerning personal data or sets of personal data which is carried out with or without the aid of automated processes, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or any other disclosure, alignment or combination, restriction, erasure or destruction.

3. Categories of personal data processed

Algotech, a.s. processes the following categories of personal data in relation to the relevant legal basis and purpose of processing:

• Identification and contact data of the DSP (in particular name, surname, residential address, business name, registered office, delivery/contact address, ID number, bank account, e-mail, telephone number, password to the algoPortal application);
• Data on the contractual relationship (in particular the amount of payments, the product used, information on the use of the product and services, data on any breach of contractual obligation by the customer);
• Other data obtained from the DSP or in the context of communication with the DSP (data recorded in the helpdesk, voice recording of the DSP during his/her dealings with the service desk staff);
• Documentation (photographs, video recordings) of events we organise;
• Electronic data on visits to the Algotech, a.s. website (IP address, cookies). 

 4. Legal basis for processing personal data

Algotech, a.s. processes personal data of the DSP on the basis of the following legal grounds (titles):

• Performance of a contract;
• Performance of a legal obligation;
• Legitimate interest of the company;
• Valid consent to the processing of personal data.

5. Purposes of processing personal data

    5.1 Performance of the contract

• Algotech, a.s. processes personal data of the DSP for purposes related to the performance of the contractual obligations of the parties, in particular for the purposes of valid conclusion, modification and termination of the contract in accordance with the relevant legislation, related invoicing and, where applicable, evaluation of the level of services provided.
• The scope of the personal data processed is defined by the purpose and type of contractual relationship, in particular: first name, surname, date of birth, permanent address, delivery or other contact address, registered office, business registration number, bank account number, password to the algoPortal application, information on the scope and level of services used.

    5.2. Compliance with a legal obligation

• Algotech, a.s. processes personal data of the DSP for the purpose of fulfilling legal obligations, e.g. in the areas of taxation, bookkeeping, etc. 

    5.3 Legitimate interest

• Legitimate interest shall apply as the legal basis for processing personal data where the legitimate interests/rights of the controller outweigh the interests/rights of the DSP, taking into account the reasonable expectations of the DSP based on his/her relationship with the controller. These are cases for which consent to the processing of personal data is not required.
• These include in particular the following purposes:
• Selection procedures for filling a position;
• Protection of Algotech, a.s.'s fundamental or other important rights arising from generally binding legal regulations and contracts in the context of various disputes, inspections, investigations, proceedings and in relation to contractors and third parties;
• Prevention of fraudulent conduct detrimental to Algotech, a.s. in cases of reasonable suspicion, for the period of time provided for by generally binding legislation;
• Direct marketing, i.e. offering goods and services related to the ICT field and related products and services for the duration of the contractual relationship between DSP and Algotech, Inc;
• Informing about the company's activities on social networks;
• Collection of debts during the statutory limitation periods;
• Manual or automated verification/evaluation of the credit risk/ creditworthiness or solvency of the DSP and assessment of the DSP 's solvency through registers (information databases) recording records of liabilities, for the duration of the contractual relationship between the DSP and Algotech, a.s.;
• Recording of voice calls to the customer service desk for the purpose of proving legal facts in the context of the performance of the contract.

    5.4 Consent to the processing of personal data

• In the event that Algotech, a.s. processes the personal data of the DSP for other purposes that cannot be subsumed under the purposes set out in Articles 5.1, 5.2 and 5.3, it may only do so on the basis of the granting of valid consent to the processing of personal data by the SO, which is an expression of free will.
• The DSP grants consent to the processing of personal data by signing the relevant written form or confirming the electronic version of the consent, primarily for marketing purposes, which means any commercial communication and offer of products and services provided by Algotech, Inc.
• Consent is also given by the DSP during a telephone call to Algotech's information line. In this case, it is a consent to the recording/monitoring of the call.
• Consent to the processing of personal data is voluntary and free.
• The consent given may be withdrawn in part or in full at any time.

 6. Method of processing personal data

• Personal data is processed both automatically and manually and may be made available to processors with whom Algotech, a.s. has concluded a contract for the processing of personal data, or to other persons in accordance with the relevant legislation.

 7. Duration of processing

* Algotech, a.s. is entitled to process the e-mail address of the DSP within the meaning of Section 7(3) of Act No. 480/2004 Coll. on certain information society services and on amendments to certain acts (Act on certain information society services), as amended, for the purpose of disseminating commercial communications concerning its own services and products (e.g. in the form of a newsletter or bulletin) in the event that you have not refused such transmission.

 8. Recipients and processors of personal data 

• In addition to Algotech, a.s., personal data may also be processed by its contractual processors for the purposes described above, on the basis of personal data processing agreements concluded in accordance with the GDPR and the Act.
• The following categories of third parties are processors or joint controllers of the Company's personal data: job portal service providers, marketing agencies, consulting service providers, information systems companies, IT and other support services companies.
• The processing of personal data may only be carried out for Algotech, a.s. by processors with guarantees of the organisational and technical security of such data and with a specification of the purpose of the processing, and the processors may not use the data for other purposes.
• The personal data of the DSP may be transferred to third parties who have the legal authority to require the transfer of the personal data in question, upon a lawful request. 

 9. Cookies

9.1 Policy on the use of cookies

• When you visit and use Algotech's website (the "Website"), cookies or other technologies such as pixels (collectively, "cookies") are activated on your device. Cookies are small content files that are used to store and receive identifiers and other information about the computers, phones and other devices from which you access the Website and help us to provide, protect and improve the services we offer.
• The use of cookies enables us to offer you content and services that best meet your needs and interests. Cookies allow us to record information about your visit to the Website, making your next visit easier and faster.

9.2 What cookies do we use?

Algotech, a.s. IČO24775487, with registered office at Sokolovská 668/136d, Karlín, 186 00, Prague 8, registered in the Commercial Register maintained by the Municipal Court in Prague, Section B, Insert 16709 (hereinafter referred to as "we" or "Company") uses necessary, preferential, statistical and marketing cookies on the Website.

• Necessary cookies

These cookies are necessary for the proper functioning of the Website to enable us to display the Website to you and to guarantee the stability and security of its use.

• Preference cookies

Preference cookies enable the Website to remember your preferences (for example, your preferred language or region where it is located) and to recognise that you return to our Website, thus enabling us to make it more convenient for you to use it.

• Statistical cookies

These cookies are used to improve the functioning of the Website. They allow us to recognise and track the number of visitors and to monitor how visitors use the Website. They help us to improve the way the Website works, for example by enabling users to easily find what they are looking for. These cookies do not collect personally identifiable information.

We use these tools to analyse and regularly improve the functionality of our Website. We may use the statistics obtained to improve the user experience and to make your visit to the Website more interesting for you as a user.

• Marketing cookies

These are used to track the preferences of Website users for the purpose of targeting advertising, i.e. displaying marketing and advertising messages (including on third party sites) in accordance with these preferences.

Marketing cookies use tools from external companies. These marketing cookies will only be used on the basis of your consent.

We use the following marketing tools on our Website:

• Google Analytics advertising features beyond basic analytics (more information HERE);
• Additional Hotjar services that may process user information as part of Website optimization (more information HERE);
• Adform -a tool that uses cookies to serve ads relevant to the user, to improve campaign performance reports or to prevent the user from seeing the same ad multiple times (more information HERE);
• Facebook Marketing Services, which enable the display of ads to Website users when they visit Facebook or other sites that also use these tools (more information HERE);
• Leady - a tool of Imper CZ, s.r.o. to identify legal entities, visitors to the Website, who may be interested in our services (more information HERE);
• Marketing tools of the company Seznam.cz, a.s., which enable the implementation of advertising displayed in search engines and in the content and partner network of Seznam.cz (more information HERE).

9.3 How can you set cookies?

You can refuse cookies in your browser settings or set to use only some of them (depending on the type of browser). However, if you do not allow us to use basic (functional) cookies, some features of the Website may not work as they should.

You can find your computer's privacy settings, where you can refuse or disable the use of cookies, in the menu of the relevant internet browser. You can find the cookie settings for the most commonly used browsers at the following links:      

• Chrome
• Firefox
• Opera
• Microsoft Edge

9.4 Connecting to social networks

Social networking buttons are placed on our Website, mainly to allow interaction with social networks, to make the Website more interesting for you as a user. A connection to the relevant social network will only occur if you actively click on the relevant button. In this case, your web browser will initiate a connection to the servers of the respective social network.

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We may change the use of cookies depending on the technologies available and in order to improve user experience and information, so if you wish to do so, please read this notice again from time to time.

 10. Rights of the DSP

Under the terms of the GDPR and the Act, the DSP may exercise the following rights:

• Algotech, a.s. will respond to any request from the DSP related to the exercise of its rights without undue delay, within a maximum of one month from the receipt of the request. This time limit may be extended by a further two months if necessary to take account of the complexity and number of requests, of which the DSP will be informed. In the case of serious requests (e.g. data transfer requests or erasure requests), Algotech, a.s. is entitled to require verification of the identity of the DSP (e.g. verified signature of the DSP on the request, email with electronic signature or telephone verification).
• In the case of repeated or manifestly unfounded requests to exercise the right of the SO, Algotech, Inc. may charge the applicant a reasonable fee. The DSP will be informed in advance of the exercise of this option and the estimated amount of the fee.

 11. Effectiveness

• This information shall take effect on May 25, 2018.
• Date of last revision - July 2021. 

 12. Contact

• If you wish to exercise your rights or have a data protection query, please contact us: 

Algotech, Inc.

Address:  Futurama Business Park

Sokolovská 668/136 D

186 00 Prague 8

E-mail: dpo@algotech.cz