Dear Consumers and Partners,
We would like to inform you about the principles and procedures for processing your personal data in accordance with the provisions of Act No. 101/2000 Coll., on the Protection of Personal Data, as amended, and 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 (hereinafter referred to as “Regulation”).
- BASIC INFORMATION
Personal data controller: a GW Group company that has entered into a Purchase Agreement or Business Cooperation Agreement with the Consumer or Partner or is negotiating the entering into of an agreement with them.
In the case of CCTV footage, the administrator is Green Ways s.r.o., Comp. Reg. No.: 255 75 767, with its registered office at Prague 1, Ovocný Trh 572/11, Postcode 11000, Czech Republic, registered in the Commercial Register maintained by the Municipal Court in Prague, File No. C 164641 (hereinafter referred to as “GW CZ”).
The data controller is hereinafter referred to as “GW”.
+ 420 776 678 577
GW Group: a holding group consisting of the following companies:
- GW CZ;
- Green Ways s.r.o., Comp. Reg. No: 358 84 819, with registered office at Bratislava, Lazaretská 12, postcode: 81108, Slovakia, registered in the Commercial Register maintained by the District Court Bratislava I, File No. 31617/B;
- Green Ways sp. z o.o., with registered office at Rybnik, Ul. Prosta 169, Postcode 44-203 Poland, registered in the National Commercial Register maintained by the District Court in Gliwice under number 0000257153;
- GW Group s.r.o., comp. reg. no: 096 39 209 with its registered office at Prague 1, Ovocný Trh 572/11, Postcode 11000, Czech Republic, registered in the Commercial Register maintained by the Municipal Court in Prague, File No. C 339465;
- GW Europe s.r.o., comp. reg. no: 116 32 631, with its registered office at Prague 1, Staré Město, Na příkopě 988/31, Postcode 11000, Czech Republic, registered in the Commercial Register maintained by the Municipal Court in Prague, File No. C 352085;
- GW Production s.r.o., comp. reg. no: 107 67 231, with its registered office at Prague 1, Staré Město, Na příkopě 988/31, Postcode 11000, Czech Republic, registered in the Commercial Register maintained the Municipal Court in Prague, File No. C 348083;
- GW Real Estates s.r.o., comp. reg. no: 107 66 995, with its registered office at Prague 1, Staré Město, Na příkopě 988/31, Postcode 11000, Czech Republic, registered in the Commercial Register maintained by the Municipal Court in Prague, File No. C 348073;
- GW 3 s.r.o., comp. reg. no: 107 66 669, with its registered office at Mirošov, náměstí Míru 3, Postcode 33843, Czech Republic, registered in the Commercial Register maintained by the Regional Court in Pilsen, File No. C 40595.
Data subjects: Consumers with whom GW has concluded a Purchase Agreement or prospective Purchase Agreements and Partners with whom GW has concluded a Business Cooperation Agreement or prospective Business Cooperation Agreements (collectively also “Customers” or “Data Subjects”).
Data Protection Officer: GW has not appointed a data protection officer.
Transfer of personal data to a third country or international organisation: GW does not transfer personal data to third countries or international organisations.
Data processing time: GW processes personal data for the term of the contractual relationship, and upon termination of the contractual relationship, GW immediately deletes all personal data in the Customer’s profile on the website www.gw-int.net or www.gw-int.pl in the “My Green Ways” section. Purchase contracts, including the consent of the legal representative of a minor Consumer, if applicable, and Business Cooperation Agreements are kept for a maximum of 6 years after the termination of the contractual relationship, depending on the statute of limitations in the country whose law governs the contract. GW processes personal data processed for the performance of obligations arising from special legal regulations for the period of time specified by these legal regulations. These periods may be exceeded in individual cases and after an assessment of the relevant circumstances if necessary, for example, to protect the legitimate interests of GW or the Customer (in the event of ongoing litigation or inspection by a public authority, etc.). GW always processes personal data for the time necessary to achieve the purpose of the processing. The records from the camera system are processed by GW for a maximum of 3 days. Records of telephone calls with Customers are retained by GW for a maximum of 4 years (depending on the nature of the call).
Automated Individual Decision Making: GW does not carry out automated individual decision-making or profiling.
Supervisory Authority: The supervisory authority is:
- for the Czech Republic: The Office for Personal Data Protection, with its registered office at Pplk. Sochora 27, 170 00 Prague 7, e-mail: email@example.com, tel.: + 420 234 665 125;
- For Slovakia: The Office for Personal Data Protection, with its registered office at Hraničná 12, 820 07 Bratislava, e-mail: firstname.lastname@example.org, tel.: +421 232 313 214;
- For Poland: The Office for Personal Data Protection with its registered office in Warsaw, ul. Stawki 2 00-193 Warszawa, email: email@example.com, tel.: +48 22 531-03-00
- For Hungary: Nemzeti Adatvédelmi és Infotmációszabadság Hatóság, with its registered office at 1125 Budapest, Szilágyi Erzsébet fasor 22/C., e-mail: firstname.lastname@example.org, tel: +36 (1) 391-1400.
- SOURCES OF PERSONAL DATA
GW obtains personal data directly from the Data Subjects, namely from Consumers in the context of the negotiation of the Purchase Agreement and in the course of the contractual relationship, and from Partners in the context of the negotiation of the Business Cooperation Agreement and in the course of the contractual relationship.
GW always informs its Customers about the processing of their personal data.
GW may also obtain personal data of its Customers from its communications with Customers, in particular from telephone conversations with them. Customers are informed of this in advance.
In order to ensure the safety and protection of GW CZ’s property, camera systems are installed in GW CZ’s premises in Staré Město, and Customers are always informed of their location by means of information signs. Personal data of Customers may also be obtained in this way if the Customers are in the monitored premises.
- LEGAL BASIS FOR PROCESSING
Customers’ personal data is processed based on the following legal titles:
- processing for the purpose of performance of the contract;
- processing for the purpose of fulfilling GW's legal obligation;
- processing for the purpose of GW’s legitimate interest, which is:
- in the case of monitored calls, to improve the quality of GW’s services and to assert and enforce contractual claims (for orders or other communications related to contractual performance);
- in the case of CCTV footage taken in GW CZ buildings, to ensure security and protection of GW CZ property;
- in the case of sending commercial communications, GW’s interest in providing relevant information to Customers about GW’s products or activities.
- (iv)PURPOSE AND SCOPE OF THE PROCESSING
For the purpose of contracting, registration and performance of concluded contracts or for the purpose of compliance with legal regulations, in particular in the field of accounting and taxation, GW processes the following data of its Customers: name, surname, business name, date of birth, identification number, VAT number, residence/headquarters, telephone, e-mail, signature, data on the personal turnover of the entire Network (as this term is specified in the respective contracts between GW and Consumers, respectively Partners; hereinafter referred to as the “Network”), any undelivered or returned orders, the turnover of the entire business group and the amount of the remuneration, and in the case of minor Consumers over 16 years of age, where applicable, the name, surname, e-mail and signature of their legal representative.
In order to fulfil its contractual obligations towards Customers (in particular the processing of orders) and to systematically improve the quality of services provided by GW to its Customers, GW monitors and records communications with Customers, in particular telephone calls with them. Thus, the Customer’s identification data (especially name, surname, telephone number, assigned registration number with GW) and the Customer’s descriptive data (voice recording, time and length of the call, information about orders, complaints, etc.) are processed.
In order to ensure the safety and protection of GW CZ’s property, camera systems are installed in GW CZ buildings, which record only video. Personal data of Customers located in the monitored premises are processed in the scope of descriptive data (image record).
For the purpose of sending commercial communications and informing Customers about GW’s products or activities, GW may process personal data of Customers in the following scope: name, surname, business name, e-mail and/or telephone number.
- RECIPIENTS OF PERSONAL DATA
GW does not transfer personal data to any third parties. However, for the purpose of fulfilling its contractual obligations to its Customers, GW is obliged to disclose Customer Personal Data to Partners or Consumers in the Upstream Network.
In addition to GW, the following entities may also have access to Customer Personal Data:
- other GW Group companies that may provide certain activities for GW in the context of streamlining GW Group operations;
- accounting companies that are authorised to carry out accounting operations and are provided with the personal data of Partners and Consumers for this purpose;
- IT solution companies that are entrusted with the IT administration of the software programs used by GW and are provided with personal data of employees, Partners and Consumers for this purpose;
- a company operating server storage services (dedicated server);
- web hosting service provider;
- the operator of the telephone call data storage and the administrator of the camera system.
- any other external service providers where personal data is disclosed, such as legal, economic or tax advisers, auditors or computer system suppliers.
GW may also provide the Partner’s contact details to a potential Customer who resides in the Partner’s geographical area for the purpose of facilitating a transaction between the Partner and that Customer.
All recipients are bound by confidentiality in relation to the personal data of Customers. GW has entered into personal data processing agreements with processors that guarantee an adequate level of organisational and technical security of the data and define the purpose of the processing, and the processors may not use the data for other purposes.
- (vi)CUSTOMERS’ RIGHTS
The data subject has:
- the right of access to personal data: The data subject has the right to obtain confirmation from GW as to whether or not personal data concerning him or her are being processed and, if so, to obtain access to such personal data and to the following information: a) the purpose of the processing; b) the categories of personal data concerned; c) the recipients to whom the personal data have been or will be disclosed; d) the intended duration for which the personal data will be stored; e) the existence of the right to request the controller to rectify or erase the personal data or to restrict or object to the processing; f) the right to lodge a complaint with a supervisory authority; g) any available information on the source of the personal data, unless obtained from the data subject; h) the fact that automated decision-making, including profiling, is taking place. The data subject also has the right to obtain a copy of the personal data processed.
- the right to rectification of personal data: The data subject has the right to have inaccurate personal data concerning him or her corrected or incomplete personal data completed by GW without undue delay.
- the right to erasure of personal data: The data subject has the right to have the personal data concerning him or her erased by GW without undue delay if: a) the personal data are no longer necessary for the purposes for which they were collected or otherwise processed; b) the data subject withdraws the consent on the basis of which the data were processed and there is no further legal basis for the processing; c) the data subject objects to the processing and there are no overriding legitimate grounds for the processing; d) the personal data have been unlawfully processed; e) the personal data must be erased in order to comply with a legal obligation under EU or Czech law; f) the personal data were collected in connection with the offer of information society services. The right to erasure does not apply if the processing is necessary for compliance with legal obligations, for the establishment, exercise or defence of legal claims and in other cases provided for in the Regulation.
- the right to restriction of processing: The data subject has the right to have GW restrict the processing in any of the following cases: a) the data subject contests the accuracy of the personal data for as long as necessary to allow GW to verify the accuracy of the personal data; b) the processing is unlawful and the data subject refuses the erasure of the personal data and requests instead the restriction of its use; c) GW no longer needs the personal data for the purposes of the processing, but the data subject requires it for the establishment, exercise or defence of legal claims; d) the data subject objects to the processing until it is verified that GW’s legitimate grounds override those of the data subject.
- the right to object to processing: The data subject has the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which GW processes on grounds of legitimate interest. In this case, GW will no longer process the personal data unless it can demonstrate compelling legitimate grounds for the processing which override the interests or rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
- the right to data portability: The data subject has the right to obtain personal data concerning him or her provided by GW in a structured, commonly used and machine-readable format and the right to transmit such data to another controller without hindrance from GW to whom the personal data have been provided, provided that: a) the processing is based on consent and b) the processing is carried out by automated means. In exercising his or her right to data portability, the data subject has the right to have personal data transmitted directly from one controller to another controller, where technically feasible.
- the right to lodge a complaint with the supervisory authority: If the data subject considers that GW does not process his or her personal data in a lawful manner, he or she has the right to lodge a complaint with the supervisory authority
- the right to information regarding the rectification or erasure of personal data or restriction of processing: GW is obliged to notify individual recipients to whom personal data has been disclosed of any rectification or erasure of personal data or restriction of processing, except where this proves impossible or requires disproportionate effort. If the data subject so requests, GW will inform the data subject of these recipients.
- the right to be informed in the event of a data breach: Where a personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, GW will notify the data subject of the breach without undue delay. Notification to data subjects is not be required where: (i) the controller has put in place appropriate technical and organisational safeguards and these safeguards have been applied to the personal data affected by the personal data breach, in particular those which render the data incomprehensible to anyone not authorised to have access to them, such as encryption; (ii) the controller has taken subsequent measures to ensure that the high risk to the rights and freedoms of data subjects is no longer likely to occur; (iii) it would require disproportionate effort.
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