INFORMATION ON PROCESSING OF PERSONAL DATA
In accordance with 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 rules relating to the free movement of personal data, and repealing Directive 95/46/EC
(hereafter “the Regulation“)
GTL, spol. s r.o., Identification No.: 48534668, with its registered office at Řecká 1107, 250 81 Nehvizdy, Czech Republic
Registered with the Commercial Register kept by the Municipal Court in Prague, Section C, Insert 18884
represented by Alexandros Koranis, CEO, managing director, who is the main contact person in regard to the processing of personal data (a data protection officer has not been appointed)
Phone No.: +420 323 618 380
(hereafter “the Company“)
1. If interested in our services, the Company as the Controller processes personal data which are necessary for the provision of its services and the fulfillment of contractual obligations towards its clients, to the extent of:
a) identification data in terms of name, surname, identification No. and VAT No., registered seat, status of a natural or legal person, position in the organization (job title) if representing a legal entity;
b) contact data in terms of personal data to be used to communicate with you, namely email address, phone number, delivery address, address of the loading/unloading place, invoice data;
c) data necessary for the performance of a contract, i.e. data relevant for entering into a contract and subsequent provision of Company’s services; also, data that are of company legitimate interests (e.g. data on the level of monies due and monies owed to assess potential risks); furthermore, data resulting from the provision of services or from compliance with legal obligations of the Company (type of payment including bank account number; complaints data);
d) data regarding services provided/requested – i.e. all data necessary for complying with the contract, namely data on goods/ shipments transferred and/or stored, customs clearance information, insurance data if requested;
e) personal data resulting from activities related to Company operations, such as a client number, employee ID number, etc.;
f) personal data in the form of visual recordings or camera footage located on the premises, on the grounds of Company’s legitimate interest in protecting its property and that of third parties
(hereafter also as „Personal Data“).
The Company does not process any special category of Personal Data.
2. As part of undertaking its business activities, the Company processes Personal Data for different purposes and to a various extent:
- without your consent – on the grounds of a contract with the Company, legitimate interests pursued by the Company, and/or the fulfillment of its legal obligations;
- with your consent – i.e. Personal Data not falling under the category of mandatory legal information which are voluntarily provided by you with the consent to be processed by the Company
What kind of processing the Company can respond to without your consent depends on the purpose of the respective processing and in what position you are in relation to the Company, whether the Company has a contract or you order services from the Company. Your data may also be processed by the Company if you are the addressee of a shipment or goods whose transport is ordered from the Company, if the Company communicates (e.g. as a job seeker) or if you show interest in the Company’s services as a potential customer.
3. To dispel any doubts, the Company asserts to process your Personal Data without your consent if such data are necessary for entering into a contract, and subsequently for the performance of such contract to which you are party. Furthermore, the Company also processes your Personal Data without your consent in cases when authorized/entitled to process any personal data obtained in another way, i.e. on the grounds of the following legal claims:
1. Meeting legal obligations of the Company in relation to the provision of its services, i.e performance of the Company’s business activity (see the objects clause);
2. Complying with the rules and regulations regarding the code of conduct with contractual partners and clients;
3. Preventing damage to the property of the Company, its clients, as well as third parties;
4. Preventing fraudulent or any other illegal behavior;
5. Fulfilling reporting and any further obligations toward public authorities;
6. Meeting obligations related to the execution of legal decisions, distraints, and/or insolvency procedures;
7. Meeting obligations regarding archiving
8. Meeting obligations related to wages, staff, and any other HR agenda;
9. Meeting obligations related to accounting and tax regulations;
10. Meeting any other obligations stipulated by legal regulations,
for the reason of and purposes related to entering into a contract or performance of such a contract between you and the Company; namely provision of services, conduct of business, or performing any other duties under the terms of the contract, including the process of negotiating a conclusion of and/or any changes to the contract,
b) on the grounds of Company legitimate interests, i.e. protection of the property of the Company, its clients as well as third parties in particular; along with recovery of claims, information necessary for the providers of services related to securing of claims; collection of receivables or any other way of exercising Company’s rights; solving legal disputes, especially for the purposes of conducting court proceedings or any other lawsuits.
With consent, the Company processes your Personal Data which are not the subject of any legal requirements (as mentioned above), and which are freely provided by you with the consent to be processed by the Company.
- The purpose of processing Personal Data is as follows: All Personal Data provided to the Company are always processed strictly according to the purpose for which they have been collected, as described in the consent and declaration form; or (if there is a purpose other than that for which the Personal Data have been collected) the purpose of processing Personal Data is defined in compliance with the valid legal claims according to legal regulations in place.
All Personal Data acquired by the Company are processed lawfully, fairly and in a transparent manner, and are always adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed, and in accordance with GDPR.
Granting consent to the processing of Personal Data constitutes a contractual requirement of the Company making it possible to further proceed with the following:
- In case of job applicants: registration of the candidate as an applicant for the position offered by the Company, subsequently leading to signing of a potential employment contract or work agreement outside the employment contract with the Company;
- In case of other natural persons: negotiation about other forms of contractual relationship (mostly a business one) between you and the Company and/or signing of a subsequent contract.
- To a limited extent, the Personal Data are disclosed and transferred to the following third parties involved in the operations of the Company:
Partners and any other collaborating persons of the Company involved in the performance of Company’s business; providers of transport and/or package deliveries (e.g. our partner companies abroad specializing in international transportation); providers of warehouses and storage services; providers of customs clearance procedures and insurance policies;
Providers of services related to server maintenance, websites, cloud and any other IT tasks
external accounting companies, law firms, providers of other counseling services, debt collection agencies;
administrative bodies, public authorities, etc.
- Personal Data are not usually transferred to the countries outside the EU and the EEA. If a transfer of Personal Data to a third party situated outside the EU or the EEA renders necessary, the Company will keep up to its obligations to secure and protect your Personal Data, following the standards in accordance with GDPR. All such transfers will be carried out by the Company only under the terms of the third party adopting and committing to follow the appropriate Standard Contractual Clauses issued by the EU.
- Personal Data are processed by the Company solely for the duration of the contract or for the period of time necessary for the Company to meet its archiving obligations in accordance with the applicable legal regulations, but no longer than 10 years after the termination of the contract.
- If you contact us via our Company website, you can be asked to provide the following Personal Data so we can get back to you: name, surname; contact address, phone number, email address, etc. Your consent to the processing of Personal Data will be required (on a designated form). Visitors of our websites are not tracked (with the exception of standard cookies); therefore the Company receives solely the Personal Data you consented to provide via the Consent and Declaration Form.
- In compliance with the GDPR (the Regulations) you, as a data subject, have the following rights which you hereby acknowledge:
- Right of access to Personal Data provided to the Company, i.e. you have the right to obtain from the Company confirmation as to whether or not your Personal Data are being processed, and, where that is the case, you have access to the following information: the purposes and extent of processing, to whom the Personal Data have been or will be disclosed, the period for which the Personal Data will be processed and stored; your right to request rectification or erasure of your Personal Data or restriction of processing of Personal Data, the right to lodge a complaint to be provided with the information on the source of Personal Data obtained, and whether there exists an automated decision-making, including profiling. You also have the right to obtain a copy of your Personal Data undergoing processing. The first copy is free of charge. For any further copies requested, the Company may charge a reasonable fee based on administrative costs.
- Right to rectification of Personal Data, i.e. you can request rectification of inaccurate Personal Data, including the right to have incomplete data completed.
- Right to erasure of Personal Data, e. the Company is obliged to erase your Personal Data on the following grounds: (i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent on which the processing is based and there is no other legal ground for the processing; (iii) you object to the processing and there are no overriding legitimate grounds for the processing, (iv) the Personal Data have been unlawfully processed; and/or (v) the Personal Data have to be erased for compliance with a legal obligation to which the Company is subject. (vi) Withdrawal of a consent to the processing of Personal Data which has been provided via a form submitted online can be done by sending an email to firstname.lastname@example.org, in which it has to be clearly and intelligibly stated that you withdraw your consent to the processing of your Personal Data which has been confirmed and submitted via an online form.
- Right to restriction of processing your Personal Data; i.e. unless resolving all disputes regarding processing of your Personal Data, meaning (i) you have contested the accuracy of the Personal Data; (ii) the processing is unlawful but you oppose the erasure of the Personal Data and request the restriction of their use instead; (iii) the Company no longer needs the Personal Data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims; (iv) or you have objected the processing; the Company shall only store your Personal Data, and their further processing can be done only with your consent or for the establishment, exercise or defence of legal claims.
- Right to data portability; i.e. you have the right to receive the Personal Data which you have provided to the Company with your consent or as part of a contract in a structured, commonly used and machine-readable format, and, where technically feasible, you have the right to have your Personal Data transmitted directly from the Company to another controller.
- Right to Object to the processing of Personal Data; i.e. you have the right to object at any time to processing of your Personal Data in the form of a letter or an email. Consequently, the Company shall no longer process your Personal Data unless demonstrating compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
Right to lodge a complaint with the Office for Personal Data Protection at the address: www.uoou.cz
- All the above-mentioned rights can be exercised in the form of a recommended letter sent to the registered office of the Company or in the form of an email sent to the email address stated in Paragraph 9c.
- Following the processing of Personal Data, the data are not used for profiling or for the automated decision-making.
- In the event of the Company intending to use Personal Data for a purpose other than that specified in this information clause, the Company will immediately provide you with the information on such a purpose or any other necessary information as specified in this clause.
- This document containing information on GDPR takes effect as of 05/25/2018.