Privacy Policy – Vivanto Solutions

PERSONAL DATA PROCESSING POLICY

Vivanto Solutions s.r.o., ID No.: 01973746, with registered office at Hostěnice 283, 664 04 Hostěnice, South Moravian Region, Czech Republic, registered in the Commercial Register maintained by the Regional Court in Brno, Section C, Insert

Section C 106722/KSBR, (“Vivanto Solutions”), declares that all personal data processed is treated as strictly confidential and handled in accordance with the applicable data protection legislation. The security of your personal data is a priority for Vivanto Solutions. For this reason, on this page we will inform you about the data we hold and also explain why we need this data and how you can limit its collection.

Vivanto Solutions is, within the meaning of the General Data Protection Regulation (Regulation (EU) 2016/679 (“Regulation” or “GDPR”), the controller of your personal data, i.e. it collects, stores and uses (and otherwise processes) your personal data for the performance of its business activities (the individual purposes for which personal data is processed are further defined below for each category of data subject).

LEGAL REASONS for processing personal data

This Privacy Policy applies to all personal data collected by Vivanto Solutions (i) in the course of your use of the Vivanto Solutions website (the “Website”), as well as to all personal data collected by Vivanto Solutions (ii) for the performance of its legal obligations, (iii) on the basis of legitimate interest, and also (iv) for the performance of a contractual relationship with our Customers, or for the preparation of a contractual relationship with our Prospective Customers, and for the performance of a contractual relationship with our Business Partners.

Vivanto Solutions processes your personal data:

In a fair, lawful and transparent manner;

only for specific, explicit and legitimate purposes;

within a reasonable scope;

accurate and up-to-date;

for no longer than is necessary for the purposes for which it is processed;

in a manner that ensures their adequate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.

CUSTOMER

If you have purchased our products from us, made a purchase from our customer e-shop or used our services, you are our Customer and we will process your personal data to the extent set out below. In the case of our Customers, legal entities, we process personal data of natural persons representing the Customer.

Purposes of processing personal data

Your personal data may be processed by Vivanto Solutions mainly for the following purposes:

Performance of the contractual relationship;

Providing customer benefits, sending commercial communications and offers;

Operation of the customer e-shop;

Accounting and tax purposes (record keeping within the meaning of accounting and tax legislation);

Fulfilling other legal obligations (other legal obligations that Vivanto Solutions fulfils include, for example, providing information to public authorities).

Personal data processed

Vivanto Solutions is entitled to process the following personal data according to the purpose for which it has received it from the individual data subjects:

Data subjects’ data	Purposes of processing:
Name and surname	Performance of the contractual relationship Providing customer benefits, sending commercial communications and offers Customer e-shop operation Accounting and tax purposes Fulfilling other legal obligations
Function, position or academic degree	Performance of the contractual relationship Providing customer benefits, sending commercial communications and offers
Contact address	Performance of the contractual relationship Providing customer benefits, sending commercial communications and offers Accounting and tax purposes Customer e-shop operation Fulfilling other legal obligations
E-mail	Performance of the contractual relationship Providing customer benefits, sending commercial communications and offers Customer e-shop operation Fulfilling other legal obligations
Account number	Performance of the contractual relationship Accounting and tax purposes
VAT number (if applicable)	Performance of the contractual relationship Accounting and tax purposes Fulfilling other legal obligations
Telephone number	Performance of the contractual relationship Customer e-shop operation Fulfilling other legal obligations
Birth or ID number	Tax purposes (declaration of the Customer – natural person for VAT purposes).

At Vivanto Solutions, personal data is processed both manually and automatically.

Vivanto Solutions may also process other data about its Customers that the Customers provide to Vivanto Solutions in order to pursue the legitimate interests of Vivanto Solutions , to maintain good business relations, to streamline business communications and also for the purpose of fulfilling the contractual relationship.

Personal data of third parties, which means personal data Vivanto Solutions receives from the Customer in connection with the conclusion or performance of a contract, will be processed in accordance with applicable data protection legislation.

Recipients of personal data

At Vivanto Solutions, your personal data is only disclosed to authorised employees or individual processors and data controllers of Vivanto Solutions, and only to the extent necessary to fulfil the individual processing purposes.

A list of Vivanto Solutions’ recipients of personal data is available at the end of this document. Under certain conditions, we are then entitled to transfer some of your personal data to public authorities on the basis of applicable law.

Retention period

We process and store your personal data for the period of time necessary to ensure all rights and obligations arising from the respective contractual relationship, for the duration of the provision of customer benefits, and for the period of time for which Vivanto Solutions is obliged, as data controller, to store personal data in accordance with generally binding legal regulations. In other cases, the processing period results from the purpose of the processing or is determined by data protection legislation.

We process personal data according to the purpose of processing for the period of time indicated:

Purpose of processing	Preservation time
Performance of the contractual relationship	for the duration of the contractual relationship, the period of possible exercise of rights under the contract
Providing customer benefits, sending commercial communications and offers	in accordance with applicable law*, we provide customer benefits unless you refuse them, you can refuse the provision of customer benefits and the sending of commercial communications and offers at any time
Accounting and tax purposes	for a period of 10 years from the calendar year following the performance
Customer e-shop operation	for the duration of the contractual relationship and for a period of 10 years from the termination of the contractual relationship
Fulfilling other legal obligations	for the period of time specified by the relevant legislation

* Vivanto Solutions is entitled to process your e-mail address 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 relating to its own products or services in the event that you have not refused such transmission.

If you do not wish to receive our commercial communications and offers, you may notify us at any time, for example by email to gdpr@vivanto.cz, and we will terminate the mailing immediately.

POTENTIAL CUSTOMER

If you have expressed an interest in purchasing our product, for example by asking us to send you a catalogue, we consider you to be our Potential Customer and will process your personal data to the extent set out below.

Purposes of processing personal data

Your personal data may be processed by Vivanto Solutions mainly for the following purposes:

Contract negotiations (e.g. product selection and specification, preparation of contract documentation);

Sending commercial communications and offers;

Fulfilling other legal obligations (other legal obligations that Vivanto Solutions fulfills include, for example, providing information to public authorities).

Personal data processed

Vivanto Solutions is entitled to process the following personal data before concluding a contract:

Data subjects’ data	Purposes of processing:
Name, function, position or academic title	Contract negotiations Sending commercial communications and offers Fulfilling other legal obligations
Contact address	Contract negotiations Sending commercial communications and offers Fulfilling other legal obligations
E-mail	Contract negotiations Sending commercial communications and offers Fulfilling other legal obligations
Telephone number	Contract negotiations Fulfilling other legal obligations

At Vivanto Solutions, personal data is processed both manually and automatically.

Vivanto Solutions may also process other data about its Prospective Customers that Prospective Customers provide to Vivanto Solutions in order to serve Vivanto Solutions’ legitimate interests and to maintain good relations with Prospective Customers.

In the case of telephone communications with our sales force, please note that if you give us your consent, these telephone calls may be monitored for the purposes of improving our service. A recording of such calls may be retained for a maximum of 6 months (longer only in exceptional circumstances in relation to the resolution of a specific case).

Personal data of third parties, which means personal data Vivanto Solutions receives from a Potential Customer in connection with the negotiation of a contract, will be processed in accordance with applicable data protection legislation.

Recipients of personal data

Retention period

We process and store your personal data for the period of time necessary to ensure the purpose of the processing, i.e. for the time you are considering purchasing our product and entering into a contract.

The retention period of personal data for the purpose of sending commercial communications and offers of products and services is governed by applicable legislation. If you do not wish to receive our commercial communications and offers, you can notify us at any time, for example by email to gdpr@vivanto.cz, and we will immediately stop sending you the communication.

CALLERS TO THE SERVICE DEPARTMENT PHONE LINE

If you call our service department phone line with a question about the operation of our equipment, a request for service, a complaint or any other matter, the phone call is recorded. If you do not agree with the recording of the call, you can contact us via e-mail or write to us at our postal address. You can find out why we record the call and how long we process the recording below.

Purposes of processing a recorded telephone call

The call recording is processed mainly for the following purposes:

Fulfilling a contractual relationship or a caller’s request (for the purpose of proving legal action and protecting the rights of both Vivanto Solutions and the caller);

Legitimate interest (for the purpose of improving our services).

Processing time for the recording of a telephone call

Purpose of processing	Preservation time
Performance of the contractual relationship	for the duration of the contractual relationship, the period of possible exercise of rights under the contract
Legitimate interest	for service improvement purposes, the call recording is kept for a maximum of 6 months (longer only exceptionally in relation to the resolution of a specific case)

BUSINESS PARTNER

If you have entered into a contract with us as part of your business, you are our Business Partner and we will process your personal data to the extent set out below. In the case of Business Partners, legal entities, we process personal data of natural persons representing our Business Partner.

Purposes of processing personal data

Your personal data may be processed by Vivanto Solutions mainly for the following purposes:

Performance of the contractual relationship;

Sending commercial communications and offers;

Accounting and tax purposes (record keeping as defined by accounting and tax legislation);

Fulfilling other legal obligations (other legal obligations that Vivanto Solutions fulfills include, for example, providing information to public authorities).

Personal data processed

Vivanto Solutions is entitled to process the following personal data according to the purpose for which it has received it from the individual data subjects:

Data subjects’ data	Purposes of processing:
Name and surname	Performance of the contractual relationship Sending commercial communications and offers Accounting and tax purposes Fulfilling other legal obligations
Function, position or academic degree	Performance of the contractual relationship
Contact address	Performance of the contractual relationship Sending commercial communications and offers Accounting and tax purposes Fulfilling other legal obligations
E-mail	Performance of the contractual relationship Sending commercial communications and offers Fulfilling other legal obligations
Account number	Performance of the contractual relationship Accounting and tax purposes Fulfilling other legal obligations
ID NUMBER, VAT NUMBER	Performance of the contractual relationship Accounting and tax purposes Fulfilling other legal obligations
Telephone number	Performance of the contractual relationship Fulfilling other legal obligations

At Vivanto Solutions, personal data is processed both manually and automatically.

Vivanto Solutions may also process other data about its Business Partners or individuals representing Business Partners in order to serve the legitimate interests of Vivanto Solutions , to maintain good business relations with Business Partners, to streamline business communications and for the purpose of fulfilling the contractual relationship with Business Partners.

Personal data of third parties, which means personal data of employees and customers of Vivanto Solutions Business Partners and other individuals involved in the cooperation with Vivanto Solutions, or other data that Vivanto Solutions receives from a Business Partner in connection with the conclusion or performance of a contract, will be processed in accordance with applicable data protection legislation. This personal data will be used by Vivanto Solutions for the purpose of fulfilling contracts with business partners. The Business Partner hereby acknowledges that Vivanto Solutions will process the personal data of third parties for the duration of the contractual relationship and for the period of time stipulated by special legal regulations, if any. For a longer period of time, the data will then be retained if the need to retain the data arises in a justified case in connection with a specific case. The Business Partner is obliged to properly inform its employees, customers and other natural persons involved in the Business Partner’s cooperation with Vivanto Solutions about the processing of personal data by Vivanto Solutions.

Recipients of personal data

At Vivanto Solutions, your personal data is only disclosed to authorised employees or individual processors and controllers of Vivanto Solutions personal data, and only to the extent necessary to fulfil the individual processing purposes.

Retention period

We process and store your personal data for the period of time necessary to ensure all rights and obligations arising from the respective contractual relationship, and for the period of time for which Vivanto Solutions is obliged, as data controller, to store the personal data in accordance with generally binding legal regulations. In other cases, the duration of the processing is based on the purpose of

Purpose of processing	Preservation time
Performance of the contractual relationship	for the duration of the contractual relationship and for a period of 10 years from the termination of the contractual relationship, or for the period of possible exercise of rights under the contract
Sending commercial communications and offers	in accordance with applicable legislation*
Accounting and tax purposes	for a period of 10 years from the calendar year following the performance
Fulfilling other legal obligations	for the period of time specified by the relevant legislation

processing or is determined by data protection legislation.

We process personal data in accordance with the purpose of processing for the period of time indicated:

JOB SEEKER

If you are interested in employment with Vivanto Solutions and have therefore sent us your personal data, for example in the form of a CV, we will process this personal data.

Purposes of the processing of personal data

Your personal data may be processed by Vivanto Solutions for the following purposes:

selecting a suitable candidate for a job position;

offering future employment opportunities with Vivanto Solutions.

Personal data processed

Vivanto Solutions is entitled to process the data provided by the job seeker.

Personal data is processed both manually and automatically at Vivanto Solutions.

Recipients of personal data

At Vivanto Solutions, your personal data is only disclosed to authorised Vivanto Solutions employees and only to the extent necessary to fulfil the individual processing purposes.

Under certain conditions, we are then entitled to transfer some of your personal data to public authorities on the basis of applicable law.

Retention period

We process personal data in accordance with the purpose of processing for the following period of time:

Purpose of processing	Preservation time
Selecting the right candidate for the job	up to a maximum of three months after the selection of a suitable candidate for the post.
Offer future job opportunities.	for the period for which the jobseeker has given his consent.

WEBSITE VISITOR

You can find out about the processing of personal data of visitors to our Website at https://www.

DATA SUBJECT RIGHTS

The Customer, Potential Customer, Business Partner, Job Seeker or Website Visitor, as a data subject, has rights in relation to the processing of personal data which arise from the law and which he/she may exercise at any time. These include the right (i) to access personal data, (ii) to rectification of inaccurate and completion of incomplete personal data, (iii) to erasure of personal data if the personal data is no longer necessary for the purposes for which it was collected or otherwise processed or if it is found that it has been processed unlawfully, (iv) to restriction of processing of personal data, (v) to data portability, (vi) the right to object, after which the processing of personal data will be terminated, unless it is established that there are compelling legitimate grounds for the processing which override the interests or rights and freedoms of the data subject, in particular if the ground is the possible enforcement of legal claims; and (vii) the right to apply to the Data Protection Authority (www. uoou.cz).

Right of access to personal data: if you want to know whether Vivanto Solutions processes personal data, you have the right to obtain information about whether your personal data is processed and, if so, you also have the right to access your personal data. In the event of unreasonable, inappropriate or repeated requests, Vivanto Solutions will be entitled to charge a reasonable fee for a copy of the personal data provided or to refuse the request (the foregoing applies mutatis mutandis to the exercise of the rights set out below).

Right to rectification of inaccurate and completion of incomplete personal data: if you feel that Vivanto Solutions is processing inaccurate or incomplete personal data about you, you have the right to request its rectification and completion. Vivanto Solutions will correct or complete the data without undue delay, but always taking into account technical possibilities.

Right to erasure: in the event that you request erasure, Vivanto Solutions will erase your personal data if (i) it is no longer necessary for the purposes for which it was collected or otherwise processed, (ii) the processing is unlawful, (iii) you object to the processing and there are no overriding legitimate grounds for processing your personal data, or (iv) Vivanto Solutions is required to erase it by law.

Right to restriction of processing of personal data: in the event that you request restriction of processing, Vivanto Solutions will make the personal data inaccessible, temporarily delete or store it, or carry out other processing operations necessary for the proper exercise of the asserted right;

Right to data portability: if you want Vivanto Solutions to transfer personal data to a third party, you can exercise your right to data portability. If the exercise of this right would adversely affect the rights and freedoms of other persons, Vivanto Solutions will not be able to comply with your request.

Right to object: the right to object to the processing of personal data which is processed for the performance of a task carried out in the public interest or in the exercise of official authority or for the protection of the legitimate interests of Vivanto Solutions. If Vivanto Solutions does not demonstrate that there is a compelling legitimate reason for the processing which overrides the interests or rights and freedoms of the customer, it will terminate the processing without undue delay on the basis of the objection.

CONTACT

To exercise your rights, please contact us at the Vivanto Solutions registered office or by email at gdpr@vivanto.cz. Vivanto Solutions reserves the right to reasonably verify the identity of the applicant for the rights in question.

CONTACT TO THE SUPERVISORY AUTHORITY

Address:

Data Protection Authority

Colonel Anchor 27

170 00 Prague 7

PO Box: qkbaa2n

E-mail: posta@uoou.cz

phone: +420 234 665 111 (Headquarters)

GLOSSARY OF TERMS

In accordance with the Regulation, for the purposes of this Policy, the following shall mean:

A controller is an entity which, alone or jointly with others, determines the purposes and means of processing personal data or is under an obligation to process personal data imposed by applicable and effective law; for the purposes of this Policy, Vivanto Solutions Ltd;

the processor is a natural or legal person, public authority, agency or other entity that processes personal data for the controller;

the data subject is an identified or identifiable natural person (not a legal person – company or organisation);

the recipient is a natural or legal person, public authority, agency or other body to whom the personal data are disclosed, whether or not it is a third party (except public authorities which may obtain personal data on the basis of valid and effective legislation);

personal data any information about a natural person (data subject) who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, date of birth, identification number, address and contact details, location data, network identifier or to one or more of