Triple Three s.r.o.
1 September 2018
1 PURPOSE OF THIS POLICY
2 WHO ARE WE AND WHAT DO WE DO?
The Sites and our Services are operated by Triple Three s.r.o. (hereinafter also as “we”, “us” or “our”). We are the data controller responsible for your personal information obtained in connection with the provision of our Sites and Services.
Triple Three s.r.o., Identification No. 294996, with its registered office at Karlovarská 1698/1, Řepy, 163 00 Praha 6, registered in the Commercial Register of the City Court in Prague, Section C, Insert No. 294996.
3 HOW TO CONTACT US?
• sending an e-mail to: ; or
• calling us on: +420 724065247; or
• post at: Triple Three s.r.o., Karlovarská 1698/1, Řepy, 163 00 Praha 6
4 WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?
We obtain your personal information from the following sources:
• Directly from you, either in person, via our Sites, on our social media pages or when you contact us or someone contacts us on your behalf;
• From third party service providers in the course of providing their services to us in connection with your use of our services;
• Providers of social media platforms (such as FaceBook, Twitter and Instagram) where you share our content through social media, by liking us on Facebook, following or tweeting about us on Twitter; and
• Otherwise as explained below in this What Personal Information do we collect and how do we use it? section.
Our primary goal in collecting personal information about you is to: (i) verify your identity; (ii) provide our services to you and carry out requests made by you on the Sites; (iii) help us improve our services; (iv) investigate or settle inquiries or disputes; (v) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vi) enforce our agreements with you; (vii) protect the rights, property or safety of us or third parties, including our other customers and users of the Sites; (viii) provide support for the provision of our Services; and (ix) use as otherwise required by law.
In particular, we use your personal information for the following purposes:
4.1 Fulfilment of products and services
We collect and maintain personal information that is voluntarily submitted to us during the use of the Sites and/or our services. We use the contact details which are provided to us so that we can fulfil the supply of services. We will use contact information to send you service related communications relating to our services.
4.2 Business administration and legal compliance.
We use your personal information for the following business administration and legal compliance purposes:
• to comply with our legal obligations;
• to protect our business and you from fraud and other illegal activities;
• to enforce our legal rights;
• protect rights of third parties; and
• in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
What is our legal basis?
Where we use your personal information in connection with a business transition, enforce our legal rights or to protect the rights of third parties it is in our legitimate interest to do so.
For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.
4.3 Other purposes
Any other purposes for which we wish to use your personal information that are not listed above, or any other significant changes we propose to make to the existing purposes will be notified to you using your contact details.
5 HOW DO WE OBTAIN YOUR CONSENT?
Where our use of your personal information requires your consent, you can provide such consent:
• at the time we collect your personal information following the instructions provided; or
The legal basis of consent is only used by us in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way.
You may at any time withdraw the specific consent you give to our processing your personal data. Please see How to access your information and your other rights section below for more details. Please note even if you withdraw consent for us to use your personal data for a particular purpose we may continue to process your personal data for other purposes where we have a legal right to do so.
6 WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
• Internally with our employees who are authorized by us to use your personal information for the purposes detailed above;
• externally with third party service providers.
The categories of third party service providers that we share your personal information with are:
• delivery companies;
• suppliers who host, provide, manage, support or administer certain aspects of our websites,
• suppliers who host, provide, manage, support or administer certain aspects of our IT and business administration systems and data centres;
• suppliers of email, online and social media advertising and other marketing services and systems;
• our professional advisers such as our lawyers, accountants, health and safety consultants and insurance brokers for our business administration and legal purposes;
• debt collection agencies and others for the purposes of enforcing any agreements that we have with you;
• any other third party where we are obliged to, or permitted to do so, by law, court order or to comply with any search warrant or similar instrument presented to us by any law enforcement, government officer or regulatory authority;
• in the event that our business is sold or integrated with another business, our lawyers, and other professional advisers, any prospective purchasers' lawyers and professional advisers, and any prospective purchaser (subject to duties of confidentiality).
7 THIRD PARTY LINKS AND SERVICES
8 HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
Whenever we collect or process your personal data we will usually keep it for one year after our last interaction with you or otherwise in accordance with our data retention policy. We will keep personal data you give us in relation to any contract that we have with you for three years and in some circumstances such as in relation to damages caused to you, us or any third party for three years. If your information is only useful for a short period e.g. for specific marketing campaigns we may delete it. At the end of that retention period, your data will either be deleted or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning. We keep the length of time that we hold your personal data for under review.
9 CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION
We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.
We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
• unauthorised access;
• improper use or disclosure;
• unauthorised modification; and
• unlawful destruction or accidental loss.
All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.
10 HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS
Your right of access.
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
Your right to rectification.
If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to erasure.
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to restrict processing.
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to data portability.
With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
Your right to object.
You can ask us to stop processing your personal information, and we will do so, if we relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
Your rights in relation to automated decision-making and profiling.
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
Your right to withdraw consent.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
Your right to lodge a complaint with the supervisory authority. For more information click here.
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the Office for Personal Data Protection, seated at Pplk. Sochora 727/27, 170 00 Praha 7 – Holešovice, . For detailed information please visit or via the phone number +420 234 665 111 or via the email address: .