Personal Data Processing
Steesio service provider: Steeso Group s.r.o.
Machine translation. This English text was generated automatically from the Czech original for convenience only. In case of any discrepancy, the Czech version (Zásady zpracování osobních údajů) prevails.
PERSONAL DATA PROCESSING PRINCIPLES
We are the business company Steeso Group s.r.o., ID number: 21441561, with registered office at Nové sady 988/2, Staré Brno, 602 00 Brno, registered at the Regional Court in Brno, file C section 138935 (hereinafter referred to as "We" or "Our company").
At the same time, we are the administrator of your personal data, who is responsible for their processing.
You can contact us via the following contact details:
E-mail: info@steeso.com
Address: Nové sady 988/2, Staré Brno, 602 00 Brno
This personal data processing policy (hereinafter referred to as the "Policy") was created in accordance with the GDPR regulation (hereinafter referred to as the "GDPR") and sets out how we process and protect your personal data.
What personal data do we process about you?
When we offer and provide you with our services, we come into contact with people and therefore also come into contact with their personal data. Our services may also include making available and operating the software platform on the domain https://app.steesio.eu/, which serves as a tool for managing operations and supporting the internal functioning of the company (hereinafter referred to as the "Platform"), and an e-learning environment containing thematically focused courses, lectures or information (hereinafter referred to as "E-learning"). In order to provide you with quality and professional services, we need to obtain some of your personal data. In order for you to better understand not only the scope of the processing of your personal data, but also the purpose of its processing, we classify this data into the following categories:
- Identification and address data, i.e. data that allow us to identify you so that we can enter into a contract with you for the provision of services in the areas of accounting, HR, law or operational management, including a contract for the access and use of the Platform or E-learning (hereinafter referred to as the "Agreement") and to be able to provide you with our services without undue legal and material risks, e.g. name, surname, social security number, date of birth, delivery address, billing address, registered office address, address of permanent residence, also your data on individual documents that you make available to us so that we can provide you with our services (data on invoices, labor law documentation, contracts, etc.);
- Data related to the Agreement and its performance, i.e. data arising in connection with the performance of the Agreement, e.g. date of conclusion of the Agreement, duration, date and reason for termination, date of payment of the price for the service, customer number, data necessary for the proper performance of the Agreement, data necessary for the establishment and management of a user account, setting access rights and making the Platform or E-learning available, rewards, date of reward payment;
- Electronic data, i.e. data generated in connection with your visit to our website, e.g. device IP/Mac address, cookies, device location data, authentication certificates,
- Contact data, i.e. data that allows us to establish contact and communicate with you, e.g. e-mail address, telephone number.
How do we get your personal data?
Your personal data may reach us in the following ways:
- By providing them to us when communicating with each other via phone, e-mail, post, web contact form, etc.
- By obtaining them from publicly accessible sources (e.g. public registers of persons, public lists, professional social networks).
- By obtaining them in the performance of our legal obligations.
- By getting them when you visit our website https://steesio.eu/, Platform or E-learning.
- By creating a user account, you log into the Platform or E-learning or start using them.
- By providing us with your data from the customer to whom you are assigned as a user, especially for the purpose of making the Platform or E-learning available (in this case, however, the processing of personal data is governed by the agreement on the processing of personal data that we have concluded with the customer, the customer, e.g. your employer, will inform you about such processing of personal data).
What are the purposes, legal grounds and period of personal data processing?
The tables below show the purposes and legal reasons (titles) for processing your personal data, as well as how long these data are stored with us.
According to these Principles, the purpose of processing is any activity that we perform as part of the provision of our services and for which we need to work with your personal data (this is mainly the conclusion and performance of the Contract, the fulfillment of our legal obligations, sending newsletters, etc.).
According to these Principles, the legal reason for processing is one of the four reasons described below for the legal processing of personal data in the sense of the GDPR:
| Legal reason | Explanation | Example of processing |
|---|---|---|
| consent | We process your personal data if you give us your consent. | Sending newsletters based on the fact that you have provided us with your email address via the web form. |
| performance of the Contract | We process your personal data if it is necessary to fulfill the Contract. | If we enter into a Contract together, we will process your identification, address and contact data so that we can fulfill our obligations and check the fulfillment of yours. |
| fulfillment of legal obligations | We process your personal data if it is necessary to fulfill a legal obligation. | In order to comply with our legal obligations, we must retain tax documents for 10 years. These documents show, for example, your first and last name, address, etc. |
| legitimate interest | We process your personal data if our legitimate interest in processing them outweighs your rights and freedoms. | When you enter our website, we process statistical data about your browsing. |
Purpose No. 1 - CONCLUSION AND PERFORMANCE OF THE AGREEMENT
We process your personal data primarily in order to be able to provide you with our services. You are under no obligation to provide us with your data for this purpose. However, without this data, we would not be able to provide you with our services, and the conclusion of the Contract would be impossible as a consequence.
| Partial activities | Scope of processed data | Legal reason | Processing time |
|---|---|---|---|
| Negotiating the conclusion, amendment or termination of the Agreement or its performance | Identification and address data; Data related to the Agreement and its performance; Contact details | Performance of the Contract | For the duration of the contractual relationship |
| Processing as part of the services provided in the areas of accounting, HR, law, etc. (some processing of personal data takes place, as this is basically a necessary prerequisite for the services provided) | Identification, address data and contact data and related data | Performance of the Contract | For the duration of the contractual relationship |
| Partial activities | Scope of processed data | Legal reason | Processing time |
|---|---|---|---|
| Communication, satisfaction evaluation, publication of reviews, processing of suggestions, complaints and complaints | Identification and address data; Data related to the Agreement and its performance; Contact details | Legitimate interest | For a period of 5 years from the termination of our contractual relations, or for a period of 5 years from the acquisition of personal data |
| Consent | Until you withdraw your consent |
Purpose No. 3 - FULFILLMENT OF LEGAL OBLIGATIONS
We also process some of your personal data for the purpose of fulfilling our legal obligations, especially accounting and tax. The processing of personal data for this purpose is justified by the fulfillment of legal obligations. We have to process this data about you.
| Partial activities | Scope of processed data | Legal reason | Processing time |
|---|---|---|---|
| Fulfillment of legal obligations in the field of accounting and taxes | Identification and address data; Contact information (especially information required to be provided on accounting and tax documents) | Fulfillment of legal obligations in the field of accounting and taxes, in particular Act No. 235/2004 Coll., on value added tax and Act No. 563/1991 Coll., on accounting | For the period specified by the relevant laws, in particular Act No. 235/2004 Coll., on value added tax and Act No. 563/1991 Coll., on accounting. Accounting data are processed for 5 years, tax documents for 10 years. |
Purpose #4 - SENDING COMMERCIAL MESSAGES
We also process some of your personal data (especially email address or telephone number) for the purpose of sending commercial communications (newsletters and offers of our services). We send commercial communications to our customers based on our legitimate interest or those who have consented to this (e.g. via a web form).
The processing of personal data for the purpose of sending business communications is justified by your consent, or our legitimate interest in direct marketing if you are our customer. The provision of personal data based on your consent is voluntary in this case, but without it it would not be possible to send you commercial messages. You can withdraw your consent at any time. You can also object to the sender based on our legitimate interest. If you let us know that you no longer wish to receive commercial communications, we will stop sending them immediately. For this, please use the contact details above.
The provision of personal data in this case is not a legal or contractual requirement. You are therefore under no obligation to provide us with your personal data for this purpose.
| Partial activities | Scope of processed data | Legal reason | Processing time |
|---|---|---|---|
| Sending commercial messages | Identification and address data; Contact information (mainly email address and phone number) | Legitimate interest in sending business communications to our customers pursuant to Act No. 480/2004 Coll., on certain information society services | Until you tell us that you do not wish to receive commercial offers, for a maximum period of 5 years from the moment you cease to be our customer |
| Consent | Until you inform us that you do not wish to receive commercial offers, or until you revoke your consent to the processing of personal data and the sending of commercial communications |
Purpose No. 5 – PROTECTION OF OUR RIGHTS
After the termination of our contractual relationship, we retain your data for a reasonable period of time given by statutory limitation periods for the purpose of protecting our rights, property or safety or the rights, property or safety of other persons. The processing of your data for this purpose is justified by our legitimate interest in protecting our rights, property or safety or the rights, property or safety of other persons.
The provision of personal data in this case is not a legal or contractual requirement. You are therefore under no obligation to provide us with your personal data for this purpose, however, we process your personal data for this purpose in situations where you have already provided us with your personal data.
| Partial activities | Scope of processed data | Legal reason | Processing time |
|---|---|---|---|
| Protecting our rights | Identification and address data; Data related to the Agreement and its performance; Contact details | Legitimate interest | For a period of 5 years from the termination of our contractual relations, or for a period of 5 years from the acquisition of personal data |
Purpose No. 6 – OPERATION OF THE PLATFORM
We also process your personal data for the purpose of making the Platform available, operating and managing it, including setting up and managing a user account, setting access rights, assigning a user to a customer, making relevant parts of the Platform available and providing basic technical support related to its use.
You are under no obligation to provide us with data for this purpose. However, without this data, it would not be possible to conclude a Contract, establish or use a user account and make the Platform available or ensure its proper use.
| Partial activities | Scope of processed data | Legal reason | Processing time |
|---|---|---|---|
| Establishing, managing and operating a user account; making the Platform available; setting access rights and assigning a user to a customer | Identification and address data; Data related to the Agreement and its performance; Contact details | Performance of the Contract | For the duration of the contractual relationship or the existence of the user account |
Even during the operation of the Platform, we continue to process personal data also within the scope of other purposes described in these Principles (protection of our rights - purpose No. 5, etc.).
Purpose No. 7 – OPERATION OF E-LEARNING
We also process your personal data for the purpose of making E-learning available and operating, including setting up and managing a user account, setting access rights, making relevant educational content available and providing basic technical support related to the use of E-learning. E-learning can be accessed from the Platform or otherwise linked to it.
You are under no obligation to provide us with data for this purpose. Bez těchto údajů však nemusí být možné E-learning zpřístupnit nebo Vám umožnit využívání jeho funkcionalit.
| Partial activities | Scope of processed data | Legal reason | Processing time |
|---|---|---|---|
| Establishing, managing and operating a user account; making E-learning available; setting access permissions | Identification and address data; Data related to the Agreement and its performance; Contact details | Performance of the Contract | For the duration of the contractual relationship or the existence of the user account |
Even during the operation of E-learning, we continue to process personal data also within the scope of other purposes described in these Principles (protection of our rights - purpose No. 5, etc.).
Purpose #8 - DIRECT MARKETING AND OUR PROMOTIONS
Personalized content and advertising technologies allow us to display our ads on partner websites to visitors who have already expressed interest in our website or services. We try to ensure that you only see ads that really interest you and not ads that have no connection to your personality and interests. Based on your interests and website behavior, you may be shown personalized content and offers on our website and on third-party websites and applications (including social networks). This is mainly made possible by cookies. You can read about managing your preferences regarding the processing of cookies in Information on the processing of cookies
For the purposes of direct marketing and the creation of personalized content and advertising, we also process e-mail addresses and telephone numbers, but always only on the basis of your prior consent. You can withdraw consent that has already been given at any time.
The processing of personal data for the purpose of direct marketing and the creation of personalized content and advertising is justified by your consent, or our legitimate interest in direct marketing. The provision of personal data based on your consent is voluntary in this case, but without it it would not be possible to provide you with personalized content and advertising. You can withdraw your consent at any time. The provision of personal data in this case is not a legal or contractual requirement. You are therefore under no obligation to provide us with your personal data for this purpose.
Purpose #9 - VISIT OUR WEBSITE
When you visit our website, we automatically process personal data about you on the basis of so-called cookie files. You can find more information about what cookies are, what cookies we use and what they are for, in the Information on the processing of cookies.
To whom do we disclose your personal data?
In order to be able to ensure the safety of your personal data and at the same time to offer and provide you with our services, the following groups of recipients and processors help us with the processing of personal data:
| Recipients | Reasons for disclosure |
|---|---|
| Legal advisers and auditors | We leave things we don't understand to the experts. To the extent necessary, we therefore transfer your personal data to various consultants or auditors for processing. In the vast majority of cases, this only concerns data contained in accounting and tax documents or data contained in contracts incl. Contracts. |
| Entities ensuring the operation of the website | In order to be able to offer and provide you with the highest level of service, we need to cooperate with a number of information and communication service providers (e.g. IT service and hosting providers, providers of security and integrity of our services and website). |
| Entities providing marketing and graphic services, organization of social events | Marketing agencies, marketing specialists or graphic designers can help us with the preparation and implementation of marketing campaigns. |
| Entities ensuring the distribution of business offers | We may entrust the sending of business offers to third parties, to whom, for this purpose, you will provide your personal data to the extent of the personal data that we process about you for the purpose of sending business offers (typically an email address or telephone number). |
| Entities providing payment services (banks, etc.) | In order to enable proper payment processing, we must pass your personal data on to entities that provide payment processing |
| Bodies of public power (courts, public prosecutor's office, bodies of state administration and self-government, Police of the Czech Republic, etc.) | We make your personal data available to public authorities in cases where we are obliged to do so on the basis of the Contract (typically when filing a lawsuit, proposal, initiative, etc.) or if required by law. Disclosure of personal data to these entities does not take place regularly, but only randomly. |
| Social network operators | Based on your interests and behavior on the website, you may be shown personalized content and offers on social networks. This is primarily made possible by cookies, which are used by so-called widgets that are embedded on our website. You can read about the management of your preferences regarding the processing of cookies in the document Information on the processing of cookies. |
Are your personal data also transferred outside the EU?
However, if we transfer your personal data for processing to a third country (outside the European Economic Area, which also includes countries outside the European Union - Iceland, Liechtenstein and Norway) or an international organization, we do so only on the condition that the European Commission has decided that this third country or international organization ensures an adequate level of protection, or if the recipient of the personal data has provided suitable guarantees of their protection and enforceable data subject rights and effective legal protection of data subjects are available in the destination country.
How are your personal data processed?
Personal data is processed manually and automatically. We keep proper records of all processing activities in accordance with the relevant legal regulations.
What are your rights as data subjects?
To exercise your rights, please contact us via our contact details, which are listed at the beginning of this Policy. We reserve the right to reasonably verify the identity of the applicant for the rights in question. If the requests are repeated and are clearly unreasonable or unreasonable, we may charge you a reasonable fee or refuse to comply with the request.
Right of access to personal data
If you want to know whether we are processing your personal data, you have the right to obtain from us information about whether your personal data is being processed, and if so, you also have the right to access your personal data. In the event of a repeated request, we are entitled to charge a reasonable fee for a copy of the provided personal data based on the administrative costs incurred.
The right to correct inaccurate and supplement incomplete personal data
If you believe that we are processing inaccurate or false data about you, you have the right to request their correction. You also have the right to supplement incomplete data. We will carry out the repair or addition without unnecessary delay, but always taking into account our technical and time capabilities.
Right to erasure
You have the right to request the deletion of personal data that we process about you in the following cases:
- Your personal data is no longer necessary for the purpose for which it was collected or processed;
- We process your personal data unlawfully;
- you have revoked the consent on the basis of which your personal data was processed, and we have no other authorization (legal reason) to further process this personal data;
- you object to the processing of your personal data if your personal data is processed for the purpose of marketing (e.g. sending newsletters);
- you object to the processing of your personal data, which we process on the basis of our legitimate interest, and if we are unable to demonstrate that our legitimate interest outweighs your right to erasure;
- there is some legal reason that requires the erasure of that personal data;
- we process the child's personal data without parental consent to such processing.
The right to restrict the processing of personal data
If you are not interested in a complete erasure, but only a temporary restriction of the processing of your personal data, you can request us to restrict the processing of your personal data.
Right to data portability
If you want us to transfer your personal data to a third party, you can exercise your right to data portability. However, if the exercise of this right could adversely affect the rights and freedoms of third parties, we will not be able to comply with your request.
The right to object
You have the right to object at any time to the processing of personal data that is processed for the purpose of fulfilling a task carried out in the public interest or in the exercise of public authority or for the purpose of protecting our legitimate interests. In the event that we do not prove that there is a serious legitimate reason for the processing that outweighs your interests or rights and freedoms, we will terminate the processing based on your objection without undue delay.
The right to withdraw consent at any time
If the processing of your data is based on your consent, you have the right to withdraw this consent at any time.
Regarding the processing of your personal data for the purpose of sending commercial communications, you can withdraw your consent to the processing of personal data and consent to the sending of commercial communications simply by replying "No" to the given email or expressing your disagreement in any other way in the reply, or by clicking on the relevant link, if it is provided at the end of the commercial communication.
The right to information about automated decision-making, including profiling
You are not the subject of any decision based solely on automated processing, including profiling, which would have legal effects for you or would similarly significantly affect you.
The right to file a complaint with the Office for Personal Data Protection
At any time, you have the right to file a complaint with the supervisory authority, which is the Office for the Protection of Personal Data, based in Plk. Sochova 27, 170 00 Prague 7, phone: 234 665 111. Complaints can be submitted via the contacts listed here.
Are data about children also processed?
Our products, services and website are not primarily intended for persons under the age of 16. We therefore do not intentionally collect their personal data. If we provide products or services to a person under the age of 16, we ask for the consent of the person who exercises parental responsibility for the child. If we discover that we have inadvertently obtained personal information about persons under the age of 16 without appropriate consent, we will take steps to delete that information as quickly as possible, except where we are required by applicable law to retain it.
What legislation governs data processing and privacy protection?
The processing of personal data in the Czech Republic is mainly governed by the following legal regulations:
- by Regulation (EU) 2016/679 of the European Parliament and of the Council, the General Regulation on the Protection of Personal Data,
- by Act No. 110/2019 Coll., on the processing of personal data,
- by Act No. 89/2012 Coll., Civil Code.
Conclusion
Legal regulations as well as our business strategy and related methods of processing your personal data may change. If we decide to update this policy, we will post the changes on our website and notify you of the changes. In cases where there is to be a more fundamental change to these principles, or in the case where the law requires us to do so, we will inform you in advance. We would like to ask you to read these policies carefully and check them continuously when you communicate with us or use our website.
Machine translation. This English text was generated automatically from the Czech original for convenience only. In case of any discrepancy, the Czech version (Zásady zpracování osobních údajů) prevails.