Personal data processing policy

Harmonikas s.r.o. with registered headquarters at Poděbradova 2506, 440 01 Louny, VAT: CZ250 36 441, registered in the public register kept at the Regional Court in Ústí nad Labem, Section C, Insert 13794 (hereinafter referred to as the “Company”), protects all processed personal data as strictly confidential and handles them in accordance with the applicable legal regulations in the field of personal data protection. The security of your personal data is a priority for our Company.

Within the meaning of the General Data Protection Regulation (Regulation (EU) 2016/679), the Company is the controller of your personal data, i.e. it collects, stores and uses (and otherwise processes) your personal data for the performance of its business activities (the individual purposes for which personal data is processed are set out in more detail below), which consists of the production of harmonicas and voices.

This Personal Data Processing Policy applies to:

1. The processing of personal data carried out by the Company during your use of the website www.harmonikas.cz (the “Website”),
2. the processing of personal data by the Company in the course of communicating with you by email or telephone,
3. the Company’s processing of personal data during the course of business relationships with clients and suppliers; and
4. processing of personal data that is necessary for the purposes of protecting the Company’s legitimate interests.

The Personal Data Processing Policy describes the purposes of processing personal data and the methods of processing, informs about the different categories of personal data processed, their potential recipients, the retention period of personal data and your rights in relation to the protection of personal data.

Purposes of the processing of personal data

Your personal data may be processed by the Company for the following purposes:

- The performance of a contract, including its negotiation (orders, work contracts, technical services);
- Sending commercial communications, offering services and products, and targeting advertising (the Company may send commercial communications or newsletters, and offer services via email; data collected when you visit the Website may also be used for targeting advertising););
- Protecting the legitimate interests of controllers (protecting the Company’s rights and legitimate interests, such as protecting the network against harmful conduct or protecting against misuse of the Website, industry monitoring of the labour market and services);
- Handling requests sent via electronic forms (in particular in the case of your interest in the production of a customized bellows).

Personal data processed

The company is entitled to process the following data according to the purpose of processing:

Purpose of processing:

Performance of the contract, Sending commercial communications, offering services and products and targeting advertising, Protecting the legitimate interest of the controllers, Handling enquiries sent using the form for the production of a customised bellows.

Purpose of processing:

Personal data is processed by the Company both manually and automatically. The automated processing of personal data occurs mainly for the purpose of fulfilling the contractual relationship and offering services. The Company is entitled to collect, store and use certain information by automated means, such as statistical information whenever you visit the Website.

Processing of personal data on the basis of consent

If you give the Company your consent to the processing of personal data for the purpose of sending personalised marketing communications (in these cases profiling may also occur) or for the purpose of contacting the Company’s business partners with offers of services and products, either by e-mail or telephone, you acknowledge that the provision of this consent is voluntary and that you may withdraw your consent at any time in writing to the Company’s address or by e-mail to harmonikas@harmonikas.cz. Consent is granted until revoked. Failure to provide consent shall not affect the performance of the Agreement.

Recipients of personal data

The Company only makes your personal data available to authorised employees and cooperating processors of personal data contracted by the Company, always only to the extent necessary for the fulfilment of the individual purposes of processing and on the basis of the corresponding legal title for the processing of personal data. The Company is entitled or obliged to transfer certain personal data to law enforcement authorities or other public authorities in cases provided for by law.

Příjemci osobních údajů

Společnost Vaše osobní údaje zpřístupňuje pouze oprávněným zaměstnancům a spolupracujícím zpracovatelům osobních údajů smluvně sjednaným Společností, vždy pouze v míře nezbytné pro naplnění jednotlivých účelů zpracování a na základě odpovídajícího právního titulu pro zpracování osobních údajů. Společnost je v zákonem stanovených případech oprávněna, resp. povinna některé osobní údaje předat na základě platných právních předpisů například orgánům činným v trestním řízení či dalším orgánům veřejné moci.

Personal data of third parties

Personal data of third parties, which means personal data of employees and customers of the Company’s clients or suppliers and other natural persons involved in cooperation with the Company, or other data received by the Company from a client or supplier in connection with the conclusion or performance of a contract, will be processed in accordance with applicable data protection legislation. The Company will use such personal data for the purpose of performing contracts with clients or suppliers. The Company will process the personal data of third parties for the duration of the contractual relationship. It will then be retained for a longer period of time if the need to retain the data arises in a justified case in connection with a specific situation.

Retention period of personal data

The Company shall process and store your personal data for the period necessary to ensure all rights and obligations arising from the relevant contractual relationship and for the period for which the Company, as a data controller, is obliged to store personal data under generally binding legal regulations or for which you have given your consent to the Company for processing. In other cases, the processing period is based on the purpose of the processing, which must be proportionate, or is determined by data protection legislation.

The Company processes personal data according to the purpose of processing for the period of time specified herein:

Purpose of processing	Retention time
Performance of the contract	for the duration of the contractual relationship and for 5 years after termination of the contractual relationship
Sending commercial communications, offering services and products and targeting advertising	for the duration of the consent to the processing of personal data, or until the consent to the processing is withdrawn, or in accordance with specific legislation*
Protection of the legitimate interest of controllers or third parties	for a maximum period of 3 years from the start of processing, or unless the need to keep the data for a longer period arises in the context of a specific situation
Handling requests sent via the enquiry form	for the time necessary to process the relevant request

* The Company is entitled to process your e-mail address within the meaning of Section 7(3) of Act No. 480/2004 Coll., on Certain Information Society Services and on Amendments to Certain Acts (Act on Certain Information Society Services), as amended, for the purpose of disseminating commercial communications relating to its own services and products (e.g. in the form of a newsletter or bulletin) in the event that you have not refused such transmission.

Right to information

You have the right to ask the Company for information about what personal data we process about you, to what extent and for what purpose.

- Right to access personal data: If you want to know whether the Company is processing personal data, you have the right to be informed if your personal data is being processed and, if so, you also have the right to access your personal data.
- The right to rectification of inaccurate and completion of incomplete personal data: if you believe that the Company is processing inaccurate or incomplete personal data about you, you have the right to request rectification and completion. The Company will correct or complete the data without undue delay, but always taking into account technical possibilities.
- Right to erasure: In the event that you request erasure, the Company will erase your personal data if

it is no longer necessary for the purposes for which it was collected or otherwise processed,
the processing is unlawful,
you object to the processing and there are no overriding legitimate grounds for processing your personal data; or
a legal obligation to process under European Union or national law has ceased.

- Right to restriction of processing of personal data: in the event that you request restriction of processing, the Company will make the personal data inaccessible, temporarily delete or store it or carry out other processing operations necessary for the proper exercise of the exercised right.
- Right to data portability: if you want the Company to transfer the personal data that it processes about you in electronic form on the basis of a contract or consent and that you have provided to them to a third party, you can exercise your right to data portability. If the exercise of this right would adversely affect the rights and freedoms of others, the Company will not be able to comply with your request.

This Personal Data Processing Policy is effective from 1 January 2022.