RWS Moravia Marketing and Sales Privacy Notice

RWS Moravia Marketing and Sales Privacy Notice
(hereinafter referred as the “Notice”)

RWS Moravia, with regards to its marketing and sales activities supporting its core business activities, provides you with this Notice to inform you of RWS Moravia’s practices regarding the processing of your Personal Data. Please read this Notice carefully as it contains detailed information about the processing of your Personal Data, including your rights.

1. Objective and Scope

In the context of marketing and sales activities of RWS Moravia, RWS Moravia (serving in a capacity of the Data Controller) will Process Personal Data about you in both paper and electronic format.

For definition of certain terms used in this Notice, please refer to Appendix 1. This Notice may be complemented by additional notices as required.

Source of the Personal Data

Personal Data Provided by You: RWS Moravia can collect Personal Data directly from you (provided electronically, in writing, or verbally). RWS Moravia may, for example, ask you for information when we are in touch with you about your interest in our services, when you provide information to us via our website (www.rws.com/moravia), when we meet you at a conference or event. You may also provide new, or updated or corrected data to RWS Moravia from time-to-time.

To assist us in complying with our obligation to maintain Personal Data accurate you should immediately notify the Privacy Manager in writing of any changes to your Personal Data.

Where you have notified the Privacy Manager or we otherwise become aware of an inaccuracy in your information we will take steps to ensure that Personal Data is erased or rectified without delay.

Personal Data from Public Sources: RWS Moravia may also collect Personal Data from public sources such as social networks (e.g. LinkedIn, Facebook), Personal Data obtained from reputable data enrichment providers which usually have been pre-obtained from publicly available sources, Personal Data from public registers and/or Personal Data from the web-presence of your employer.

Personal Data from Third Parties: RWS Moravia may also lawfully receive Personal Data from third parties who provide services to RWS Moravia such as reputable data enrichment/enhancement providers.

3. Categories of Personal Data Processed, Purposes and Legal Bases for RWS Moravia’s Processing of Personal Data

RWS Moravia Processes the below categories of Personal Data for the following Purposes, based on the Legal Basis listed hereof. Where applicable, we will point out, at the time of the data collection, if the provision of the Personal Data is a statutory or contractual requirement and whether you are obliged to provide the Personal Data and the possible consequences of failure to provide such data.

3.1 Marketing

The Categories of Personal Data that RWS Moravia Processes about you, for this purpose, are the following:

  • Identification data, contact network data (IP address, cookies), contact website behavior data, business contact data and information, contact scoring for qualification, email data.

RWS Moravia Processes the above Personal Data for the purpose of creating and qualifying prospective customers for marketing and sales purposes. This, among other purposes, serves to gather and maintain a database of contacts, to evaluate these contacts and process the Personal Data of with our Sales team.

RWS Moravia uses different legal grounds as a basis for the Personal Data processing, namely:

  • Legitimate Interests as set out above.

3.2 Sales

The Categories of Personal Data that RWS Moravia Processes about you, for this purpose, are the following:

  • Identification data, contact network data (IP address, cookies), contact website behavior data, business contact data and information, contact role in sales case, contact scoring for qualification, contact relations with other sales cases, competitor identification data, customer contact identification data.

RWS Moravia processes the above Personal Data for the purpose of sales activities, sales projects for potential and existing customer base. This, among other purposes, serves to create and maintain a database of contacts and to contact them.

RWS Moravia uses different legal grounds as a basis for the Personal Data processing, namely:

  • Performance of the contract;
  • Legitimate interests as set out above.

4. Personal Data Retention

RWS Moravia retains your Personal Data for the period necessary to fulfil the purposes set out in this Notice or as required by applicable law, and, when the purposes are fulfilled, will delete or anonymize the Personal Data.

It is our general policy to retain certain Personal Data of contacts for up to 3 (three) years (corresponding to the applicable statute of limitations), but in no event for longer than strictly necessary.

5. Automated Decision-Making

RWS Moravia does not Process your Personal Data by automated decision-making, including profiling.

6. Disclosure of Personal Data

Your Personal Data may be shared with other RWS Moravia branches, subsidiaries, affiliates and holding companies or with third parties (external services suppliers acting as Data Processors) where appropriate or relevant for the same purpose as described above.

6.1 Intra-Group

RWS Moravia may share Personal Data with its branches, subsidiaries, affiliates and holding companies, depending on the purposes of the data processing described in Section 3 of this Notice, including staff members from the Marketing and Sales teams.

6.2 Third Parties

We may also share Personal Data with suppliers that are engaged to perform services or functions on behalf of RWS Moravia and under its instructions, for example, to provide cloud services, lookup and communication services, survey tools, etc. In all such cases, RWS Moravia will put in place appropriate contracts with these parties to ensure that they only process Personal Data in accordance with our instructions and in order to provide these services and protect the integrity and confidentiality of the Personal Data.

RWS Moravia does not sell, rent or lease your Personal Data to third parties.

7. International Transfers of Personal Data

7.1 Intra-Group

Due to the global nature of our operations, some of the Personal Data recipients (mentioned in Section 6) may be located in countries outside the European Economic Area (EEA), which do not provide an adequate level of data protection. International transfers will be to countries where RWS Moravia branches, subsidiaries and affiliates have offices, including Argentina, Canada, China, Germany, Hungary, Ireland, Japan, the United Kingdom and the USA. The transfer of your Personal Data outside the EEA takes place on the basis of our Intra-Group Data Sharing Agreement, which is based on the standard data protection clauses adopted by the European Commission and in accordance with applicable law. Please contact the Privacy Manager (contact details in Section 9 below), if you want to receive further information or a summary of the relevant safeguards of the relevant data transfer mechanism.

7.2 Third Parties

Some of the third parties with whom we share Personal Data are also located outside the EEA. Certain third countries, such as Argentina, Canada, Japan or United States (with a limitation to the Privacy Shield Network) have been officially recognized by the European Commission as providing an adequate level of protection. Transfers to third parties located in other third countries outside the EEA take place using an acceptable data transfer mechanism, such as the Privacy Shield for transfers to self-certified US organizations, the EU approved Standard Contractual Clauses, Binding Corporate Rules, approved Codes of Conduct and certifications, etc. or in exceptional circumstances on the basis of permissible statutory derogations.

Please contact the Privacy Manager (contact details in Section 9 below), if you want to receive further information or, where available, a copy of the relevant data transfer mechanism.

8. Your Data Protection Rights

Under the conditions set by applicable data protection laws, you may exercise the following rights regarding your Personal Data (see also Section 9 on how to exercise those rights):

8.1 Access

You have the right to obtain from us confirmation if Personal Data is being processed, the purpose of processing, the categories of data, the legal basis of the processing, information on recipients of the data and the non-EU countries in which they are located, the safeguards put in place for the transfer of data to non-EU countries, storage period of data or criteria to determine it, further information on your rights, our processing activities, sources of information and the significant and envisaged consequences of processing.

8.2 Rectification

You have the right to request the rectification of inaccurate Personal Data and to have incomplete data completed.

8.3 Objection

You have the right to object to the processing of your Personal Data for compelling and legitimate reasons relating to your particular situation, except in cases where legal provisions expressly provide for that processing. In addition, you have the right to object where your Personal Data are processed for direct marketing purposes.

8.4 Portability

You may receive your Personal Data that you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit it to other data controllers without hindrance. This right only exists if the processing is based on your consent or a contract and the processing is carried out by automated means.

8.5 Restriction

You may request to restrict processing of your Personal Data if (i) you contest the accuracy of it – for a period we need to verify your request; (ii) the processing is unlawful and you oppose the erasure of it and request restriction instead; (iii) we no longer need it, but you tell us you need it to establish, exercise or defend a legal claim; or (iv) you object to processing based on public or legitimate interest – for a period we need to verify your request.

8.6 Erasure

You may request to erase your personal data if it is no longer necessary for the purposes for which we have collected it, you have withdrawn your consent and no other legal ground for the processing exists, you objected and no overriding legitimate grounds for the processing exist, processing is unlawful, or erasure is required to comply with a legal obligation.

8.7 Right to lodge a complaint

You also have the right to lodge a complaint with a supervisory authority, in particular in EU Member State of your residence, place of employment, or the location where the issue that is the subject of the complaint occurred.

For the Czech Republic, please see contact details below:

  • Address:
    Personal Data Protection Office
    Pplk. Sochora 27
    170 00 Prague 7
    Czech Republic
  • Email: [email protected]

8.8 Right to refuse or withdraw consent

Please note that in case we ask for your consent to processing, you are free to refuse to give consent and you can withdraw your consent at any time without any adverse negative consequences. The lawfulness of any processing of your Personal Data that occurred prior to the withdrawal of your consent will not be affected.

 

8.9 Your California Privacy Rights

Under California Civil Code Section 1798.83 (known as “Shine the Light” law), California residents who provide Personal Data are entitled to request and obtain from us once a calendar year information about the Personal Data we shared, if any, with other businesses for their own direct marketing uses.

To obtain this information on behalf of RWS Moravia please send an email message to email address mentioned below with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response.

9. Contact Details

RWS Moravia’s contact details:

  • Address:
    Moravia IT s.r.o.
    Vlněna 526/1
    602 00 Brno
    Czech Republic
  • E-mail address: [email protected]

If you wish to exercise any of the afore-mentioned rights (see Section 8) or if you have any questions regarding this Notice, please direct your request to:

  • Address:
    Moravia IT s.r.o.
    Privacy Manager
    Vlněna 526/1
    602 00 Brno
    Czech Republic
  • E-mail address: [email protected]
  • Phone number: +420-545552133

10. Updates to this Notice

RWS Moravia may update this Notice from time to time. The new version will be effective as from the date indicated in that updated Notice, ensuring that individuals receive sufficient advance notice and draw their attention to any significant changes.

In Brno, on April 1, 2020

 

Appendix 1

Definitions
Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
Data Protection Laws means the GDPR and the relevant national implementing legislation.
GDPR means 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).
Personal Data means any information relating to an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier or to one or more factors specific of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing means any operation or set of operations performed on Personal Data or on sets of personal data, whether or not by automated means (e.g., computers), such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
RWS Moravia means the Moravia IT s.r.o., with its seat at Vlněna 526/1, Trnitá, Postal Code 602 00, Brno Czech Republic, Registration number: 032 51 853, registered in the Commercial Register led by the Regional Court in Brno, Part C, Entry 88437 and its branches, subsidiaries, affiliates and holding companies.