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INFORMATION ON THE PROCESSING OF PERSONAL DATA
INFORMATION ON THE PROCESSING OF PERSONAL DATA
This document amends, in accordance with the 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 (General Data Protection Regulation) (Text with EEA relevance) (the “GDPR”) the detailed information on the processing of personal data of customers and guests (hereinafter referred to as “data subject”) of the Ryzlink Hotel, operated by Vinařství Fučík, s.r.o., IČO: 01568060, Purkyňova 2, 110 00 Praha 1 (hereinafter also “Winery”) as the personal data controller.
This document provides clear, complete, and truthful information about the scope of processing of personal data that the data subject shares with the Winery. The Winery declares technical and organizational security of protection of the personal data of data subjects. The Winery has also taken all necessary measures and precautions to minimize the risk of unauthorized or accidental access to the personal data of data subjects, its change, destruction or loss, unauthorized transfers, or unauthorized processing.
In case of additional questions about the processing of the personal data of data subjects, it is possible to contact the person authorized for personal data protection via e-mail address firstname.lastname@example.org, or by sending a letter to the following address: Purkyňova 2, 110 00 Prague 1 (addressed to the company Vinařství Fučík, s.r.o.).
Personal data controller
The Winery, as the controller of personal data of data subjects, determines the purpose and method of processing of personal data.
Purpose of the personal data processing.
The controller processes personal data for the purpose of:
conclusion and fulfilment of the Accommodation contract,
protection of their legitimate interests (Article 6 (1)f of the GDPR), described in more detail below;
compliance with legal obligations in relation to accounting and tax obligations.
Legitimate interests of the Winery
I.The Winery also processes the personal data of data subjects for the protection of its legitimate interests. Security and protection of the Winery´s property shall be considered a legitimate interest of the Winery, therefore the building of the Ryzlink Hotel is monitored by a camera system which records the movement of persons outside the building. Direct marketing, which Winery conducts through the sending of business news, newsletters, and marketing emails, is also to be considered a legitimate interest of the Winery. The Winery has a legitimate interest in informing the data subject about the offer of its own services and products if there is or has been a contractual relationship between the controller and the data subject, that the data subject can reasonably expect personal data to be processed for direct marketing purposes.
II.The data subject is entitled to, in the interest of his personal data protection, to request that his personal data will be processed only to the extent necessary to fulfill the legitimate interest of the Winery.
Collecting personal data
I. The Winery obtains personal data of data subjects directly from its customers.
II. The Winery does not obtain personal data of data subjects from third parties. If the data subject who makes the accommodation reservation provides personal data of a third party, the data subject is responsible for the third parties' consent to the disclosure of their personal data.
Categories of personal data processed
In order to ensure a proper course of the legal relationship between the Winery and data subject, the Winery processes the following categories of personal data:
basic identification data - name, surname, address of permanent residence, contact address,
contact details - telephone number and e-mail address,
billing information - account number, variable symbol,
other personal data that the data subject voluntarily enters in the booking note (incl. sensitive data, food allergies, or other health restrictions). This personal data is processed exclusively for the purpose of processing of the booking.
Legal basis for personal data protection
I. The lawfulness of the processing of personal data is determined by Article 6 (1) of the GDPR, according to which the processing is lawful if it is essential for fulfilment of the contract, legal obligation, protection of the Winery´s legitimate interests or if the processing takes place with the consent of the data subject.
II. The legality of processing, which is necessary for the fulfillment of the legal obligation that applies to the controller, is based, for example, on Act No. 563/1991 Coll., on accounting, according to which invoicing data is processed and stored, and on Act No. 586/1992 Coll. ., on income taxes, Act No. 235/2004 Coll., on value added tax.
Disclosing of personal data to third parties
I. The I. The Winery is obliged and entitled to disclose the personal data of data subjects to third parties (recipients, e.g. processors) on the basis of fulfillment of its legal obligations and contracts, and on the basis of its legitimate interests.
II. The Winery has the right to disclose personal data of data subjects to state administration bodies, tax administrators, courts, bodies active in criminal proceedings and the Police of the Czech Republic.
III. The Winery passes on the personal data of data subjects to other processors:
bfinance.cz accounting, s.r.o., IČO 28918991, Praha-Štěrboholy - Štěrboholy, K učilišti 40/20, Hlavní město Praha, PSČ 10200, which provides accounting services, in order to fulfill its legal obligations under Act No. 563 / 1991 Coll., on accounting.
Disclosing of personal data to third countries or international organizations
The winery does not disclose personal data of data subjects to third countries or international organizations.
Duration of personal data storing
The Winery will process and store personal data for at least the duration of the contract or the time necessary to fulfill the archiving obligations of the Winery, but no longer than 10 years from its termination. Personal data processed in pursuance of the Winery´s legitimate interest (direct marketing) will be processed for a period of 3 years from the last purchase of goods, or until unsubscribing from receiving marketing messages.
Rights of data subjects related to the processing of their personal data, and the exercise of these rights
I. The Winery informs data subjects that the controller of their personal data is Vinařství Fučík, s.r.o., IČO: 01568060, Purkyňova 74/2, Nové Město, 110 00 Prague 1, registered with the Municipal Court in Prague, Section C, Insert 207807.
II. The Winery declares that all the information which it is obliged to provide to the data subjects pursuant to Article 13 (1) (a) (c) to (f) and Article 13 (2) (a) a) GDPR is specified in this document.
The data subject is entitled to exercise his rights by sending an e-mail to email@example.com. Data subjects can also exercise their rights by sending a letter to Purkyňova 74/2, Nové Město, 110 00 Prague 1 (addressed to Vinařství Fučík, s.r.o./the Winery). In the interest of personal data protection of data subjects, the data protection officer will not provide information to a subject if there is any reasonable doubt concerning their identity. In order to eliminate these doubts, it is possible to contact the person authorized for personal data protection in person, following prior agreement.
III.Information, communications, statements, and updates of personal data in the event of its change are all provided by the Winery free of charge. In case of a repeated application, the Winery is entitled to demand a payment of an administrative fee, which will reflect the administrative costs of processing the application. Upon request, the Winery is ready to provide the subjects with a copy of the processed personal data. In case of a repeated request, the Winery is entitled to charge a reasonable fee covering the administrative costs associated with obtaining a copy. In the event of abuse of rights under this paragraph, the Winery is entitled to refuse access to the data.
IV.The Winery shall provide the information referred to in paragraph III. of this article in written or electronic form, if there is no doubt concerning the identity of the applicant. The Winery will not have doubts concerning the identity of the applicant especially when the application is sent via e-mail address and if it contains electronic signature. In case of doubt, Winery (in the interest of personal data protection) reserves the right to provide the requested information to the applicant in person after verification of his identity, following a prior agreement. The Winery reserves the right not to provide any information verbally or over the telephone.
V. The Winery is obliged to provide this information to the data subject within 1 month of the written delivery of his request/application. In justified cases, Winery may reasonably extend this period, but by no longer than another two months.
VI. In the event of a change in personal data (e.g. change of marital status, surname, bank account number, address of permanent residence, telephone number), the data subject is entitled to request that this change is taken into account. In connection with this right, data subjects are obliged to report this personal data change to the Winery. Data subjects can report this change in person at the address of the Winery or Ryzlink Hotel, or by means of a letter sent to the address of the Winery or via email. The data subject is obliged to provide supporting evidence for this change, if requested to do so. The Winery shall update the personal data without undue delay and no later than within one month of the written delivery of the notification of the change. Appropriate action will be taken if the need for clarification of inaccurate information arises.
VII. The Winery hereby informs data subjects of their right to lodge their complaints or suggestions with the supervisory authority, should they believe the processing of their personal data violates the GDPR. Data subjects have the right to lodge a complaint with the supervisory authority in the country of their habitual residence, or where the alleged breach of the protected rights in relation to personal data occurred. The Supervisory Authority in the Czech Republic is the Office for Personal Data Protection, with its registered office at Lt. Col. Sochora 27, 170 00 Prague 7.
VIII. In specific cases, the data subject is entitled to request that the Winery delete his personal data. Such a situation may arise, for example, where the data processed is no longer necessary for the purposes specified here, or if the consent to the processing of personal data has been revoked (and there is no other legal basis for personal data processing).
IX. The right to erasure (right to be forgotten) (according to paragraph VIII. of this article) shall not apply to circumstances provided for in Article XI. paragraph II. of this document, nor to cases where the Winery fulfills its legal obligations, due to the exercise or defense of its legal claims. If Winery, pursuant to this paragraph, exercises its right to reject data subject's request to erase his personal data, it is obliged to notify the data subject of this decision within 1 month, duly substantiate its decision, and at the same time inform the data subject of his rights.
X. The Winery processes personal data of data subjects within the scope which is strictly necessary. In case of data subject´s doubts concerning the necessity of personal data processing in a particular way, the data subject is entitled to request that his personal data is processed only within the scope which is necessary. In connection with this, data subject is entitled to request that the scope of processed personal data is limited.
XI. If tthe personal data of the data subject is processed on the basis of his consent, the data subject is entitled to revoke this consent at any time free of charge, by delivering the request to the address of the Winery or emailing it to the person authorized for personal data protection ( firstname.lastname@example.org ). In case of an electronic request, it is necessary that there is no doubt as to whether the sender of the email is indeed the subject of personal data.
XII. Data subject is entitled to request transferability of personal data he provided and disclosed to the Winery. The data subject may request the transfer of such data into his own hands for the purpose of such transfer, or have data transferred directly to his controller of choice. Personal data will be provided in a machine-readable format (e.g., XML). The transfer of personal data will be carried out in a way that minimizes possible security risks during the transfer (e.g., using encryption).
Vinařství Fučík s.r.o