Specific information documents
Specific information could be presented on the pages of the Website in relation to particular services or processing of the data provided.
Cookies
For more information on the cookies used by this website, see the following cookies policy link.
DATA CONTROLLER
Pursuant to articles 4 and 24 of GDPR, is the Simple Progress s.r.o., with a registered address at Praha 1, Nové Město, Hybernská 1012/30, in the person of the legal representative. Contact e-mail: info@simplebath.cz.
DATA PROTECTION OFFICER
It is individualized pursuant to art. 37 and art. 39 of the Regulation (EU) 2016/679. Contact e-mail: info@simplebath.cz
PURPOSES AND LEGAL BASIS OF THE PROCESSING
The personal data provided will be processed, in compliance with the conditions of lawfulness pursuant to art.6 of Reg. UE 2016/679, for the purposes, indicated here below:
A)
I. browsing the web site;
II. filling out the form for aimed at obtaining information from the Data Controller, or sending a spontaneous application for the selection of personnel; III. access to the restricted area;
B) Direct Marketing: through completion and filling out of forms for the receipt of communication material, for direct marketing activities, newsletters, market researches or other sample searches, and sale via automated electronic mail, paper mail, and telephone calls, material information on products from the Simple Progress, or inherent events and initiatives by the Data controller, even though the companies appointed as Data.
To compare and possibly improve the results of communications, Data Controller uses systems for sending newsletters and promotional communications with reports. Thanks to the reports, the Data Controller will be able to know, for example, the number of readers, openings, unique "clickers" and clicks; the devices and operating systems used to read the communication; the detail on the activity of individual users; the details of the emails sent, e-mails delivered or not, of those forwarded. All these data are used for the purpose of comparing, and possibly improving, the results of communications.
C) Profiling (nonautomated) with reference to preferences, personal interests, purchase habits, etc. in order to send commercial proposals of interest to the user.
LEGAL BASIS
The legal basis for the processing of data for the purpose A. I) is the legitimate interest art.6, par.1, lett. f): (recital 47) taking into consideration the reasonable expectations of Data Subjects at the time and in the context of the processing of personal data when the Data Subject can reasonably expect their data to be processed for this purpose. Legal basis for the processing of data for the purpose A.II) is the legitimate interest of Data Controller (art.6 par.1 lett. f) for the filling out the form to ask for information to Data Controller: contract/ pre-contract (art.6 par.1 lett. b) for sending a spontaneous application. Legal basis for the processing of data for the purpose A.III contract (art.6 par.1 lett. b).
La Legal basis for the processing of data for the purpose B) direct marketing and C) profiling (nonautomated) is the consent (art.6 par.1 lett. a). The legal basis for the processing of data for the purpose D) transfer of data is the consent (art.6 par.1 lett. a).
RECIPIENTS OR CATEGORIES OF RECIPIENTS OF PERSONAL DATA
Your processed data will be communicated to recipients, that will process the data as Data Processor (art. 28 del Reg. UE 2016/679) and/or as acting under the authority of the Data Controller and of Data Processor (art. 29 del Reg. UE 2016/679), or subjects having the role of Data Controllers, for the purposes indicated in point 3.
Precisely, data will be communicated to - subjects that provide services for the management of the information system used by the Simple Progress and the telecommunications networks (including e-mail and platforms); - studies or companies in the context of assistance and consultancy relationships - companies contractually linked to the Simple Progress and/or part of them to the sales/distribution network of the Simple Progress (such as branches, importers, distributors, forwarders, etc) possibly also based in countries outside the European Union (extra SEE); - competent authorities for fulfilling legal obligations and/or provisions of public bodies, upon request; - to the sales/distribution network in the territory. The updated list of designated Data Processors is available at the Simple Progress Praha 1, Nové Město, Hybernská 1012/30
DATA TRANSFER TO A THIRD COUNTRY AND/OR INTERNATIONAL ORGANISATION.
Personal data may be transferred to a third country outside the European Union (extra SEE), in order to comply with the aforementioned purposes. The data will be transferred according to Article 44 - General principle for the transfer; Article 45 - Transfer on the basis of an adequacy decision; Article 46 - Transfer subject to adequate guarantees, specifically the data will be transferred: - to third-party countries or international organizations for which the Commission has intervened with an adequacy assessment (Article 45 of the EU Reg. 2016/679) - to third-party countries or international organizations that have provided adequate guarantees and in which the interested party has rights to action and effective recording methods and means (article 46 EU Reg. 2016/679, also with contractual clauses and the other provisions referred to in Article 46, paragraph 3) - to third-party countries or international organizations on the basis of exceptions in specific situations (Article 49 of the EU Reg. 2016/679).
To receive information concerning the guarantees concerning the transfer of Data outside UE you can send an email to info@simplebath.cz.
DATA RETENTION PERIOD OR RELEVANT CRITERIA
The processing will be carried out in an automated and/or manual manner, with methods and tools aimed at ensuring the best security and confidentiality, by subjects specifically appointed to do so. In compliance with art. 5, paragraph 1 letter e) of EU Reg. 2016/679, the personal data collected will be stored in a form that allows identification of data subjects for a period of time not exceeding the achievement of the purposes for which the personal data are processed. The retention of personal data provided depends on the purpose of the processing:
- for the purpose A.I see the following Cookie policy link;
- for the purpose A.II 1 year for the form aimed at obtaining information from the Data Controller. The retention instead for the spontaneous application for the selection of personnel is of 24 months;
- for the purpose A.III, access to the restricted area – an area accessible only to employees and agents - for the period of time in which they hold the role that justifies their access to the area in question;
- for the purpose B) the retention period is until the exercise of the right of withdrawal;
- for the purpose C) the retention period is 12 months;
Timing determined on the basis of criteria that the interested party can have information on by sending an e-mail to info@simplebath.cz.
DATA SUBJECT’S RIGHTS
You can exercise your rights as expressed in the GDPR by sending an e-mail to Data Controller at info@simplebath.cz. Moreover, you can ask for data portability (art.20). In any case, the processing is based on consent, you can withdraw the consent at any time without prejudice to the lawfulness of the processing based on consent before the withdrawal. You can object to the processing and exercise the rights by sending an e-mail to info@simplebath.cz.
In order not to receive commercial and promotional communications through automated means (e-mail), you can write an e-mail at any time at the following address info@simplebath.cz with the subject "automated unsubscription" or use our system for automatic unsubscription and you will no longer be disturbed. In order not to receive commercial and promotional communications through traditional direct marketing communications (telephone calls, paper mail), you can write an e-mail at any time at the following address info@simplebath.cz with the subject "traditional direct marketing unsubscription". You have the right to object at any time to processing of personal data concerning profiling, with an e-mail at the following address info@simplebath.cz with the subject "no profiling”. Without prejudice to any other administrative and judicial appeal, if you believe that the processing of your data violates the provisions of Regulation EU 2016/679, pursuant to art. 15 letter f) of the aforementioned Regulation EU 2016/679, you have the right to lodge a complaint with the Data Protection Authority.
There is no automated individual decision-making.
NATURE OF DATA PROVISION AND REFUSAL
The provision of the data for the purposes indicated in points A.I, A.II and A.III is necessary. Any refusal to provide the necessary data shall make it impossible to use the services of the Data Controller. The provision of the data for the purposes B) and/or C) and/or D) is optional. The refusal of the consent for the purpose express in point B), will not be prejudice for the processing of personal data for the purposes indicated in point A) and C). Any refusal of the consent for the purpose indicated in point C) will not be prejudice for the purposes indicated in point A) and B). Marketing activity is only possible and will be carried out only with the specific consent of the interested party. The inclusion of data in the CRM is optional and will automatically result in the visibility of the same by those who have access, i.e. the data processors and any person acting under the authority of the Data Controller, that works at the point of sales in the world. Any refusal to provide the consent for the purposes indicated in point D), will not be a prejudice concerning the purposes indicated in point A), B) and C).
CHANGES TO PRIVACY POLICY STATEMENT
The Data Controller reserves the right to modify, update, add or remove parts of the privacy policy statement at the discretion of the same at any time. The Data Subject shall periodically verify these possible changes. In order to let Data Subject understand the modification, the informative notice shall contain the upgrade date. The use of the site, after the publication of the modification, shall constitute acceptance of these changes.
Upgrade date: 11th April 2020