CM Trade Privacy Policy

CM Trade Via s. r. o., ID No.: 255 10 681, with its registered office at Olomoucká 3419/7, 618 00 Brno, Czech Republic, registered in the Commercial Register maintained by the Regional Court in Brno, Section C, File 29176 (hereinafter referred to as "CM Trade Via" or "We"), hereby in the position of administrator and processor of personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data (hereinafter referred to as the "Regulation") and Act No. 110/2019 Coll., on the processing of personal data, as amended (hereinafter referred to as the "Act"), informs all its customers, clients and business partners, if they are natural persons, or employees of its clients and business partners, or job applicants, or visitors and users of the www.cm-trade.cz website (hereinafter referred to as "Data Subjects" or "You"), about the basic aspects processing their personal data.

This Privacy Policy (the "Policy") sets out the basis on which we will process any personal data that we collect from you or that you provide to us, provided that they meet the specifics set out below.

The personal data controller is CM Trade Via s.r.o., ID No.: 255 10 681, with its registered office at Olomoucká 3419/7, 618 00 Brno, registered in the Commercial Register maintained by the Regional Court in Brno, Section C, File 29176.

Contact details of the personal data controller:

E-mail: info@cm-trade.cz
Post: Olomoucká 3419/7, 618 00 Brno, Czech Republic.

Please read the following carefully to understand the practices regarding your personal data and how we will handle it.

We apply a clear approach to explaining our procedures for the protection of personal data as recommended by supervisory authorities in accordance with the Regulation and the Act. This means that we strive to provide you with only relevant privacy information regarding the fulfilment of our legal obligations, your contractual relationship with us, your use of our services and interaction on the www.cm-trade.cz website, and to do so we use the simple form of this Policy. For your feedback or any questions you may have, please do not hesitate to contact us.

Data we process about you and purposes of processing

It is important for us that you know what and how we process your personal data and for what purposes we use it, in order to operate more effectively in providing professional information on personal data protection and to enable you to obtain essential information on personal data protection.

We may collect and process data about you when you are about to purchase or have already purchased the products we offer, when you are about to use or are already using our services, when you enter into a contract or otherwise communicate with us, or when you visit or otherwise use our website.

We obtain your personal data from several sources. The primary source of your personal data is you personally or your company or the company you represent (e.g. when we enter into a contract with you and you personally or the company you represent provide us with your identification data or payment data or send us your CV for these purposes). We may also obtain your personal data from publicly available sources, such as public lists, registers and registers (e.g. the Commercial Register or Trade Register) for the above purposes, or they may be provided to us by third parties or collected automatically (e.g. cookies on websites).

This is especially the case when:

it is necessary for the performance of a contract(e.g. provision of services, employment contract, cooperation agreement or other contract) to which you or the company or other legal entity with which you are a party or to take steps prior to entering into such a contract (e.g. a selection process with job applicants or negotiations with potential clients and partners); or
we are required to do so by applicable law(e.g. labour legislation, tax regulations, etc.); or
you have given us your consentto do so (e.g. email address for sending marketing communications), and you can withdraw your consent at any time; or
it is our legitimate interestin the interest of improving the quality of our services provided to you, in connection with the follow-up information about news concerning CM Trade Via to our clients or, for example, the identification of persons in the reception area, the protection of the network against harmful conduct.

You may provide us with some of this information by communicating with us, such as by telephone, e-mail or otherwise. We also collect some of them automatically, e.g. by using cookies when you visit our website.

We receive and store information that you provide to us in any way, including information that you provide to us if you are interested in our services or during the selection process if you apply for a job with us.

The provision of any information is voluntary, except where otherwise stated (legal obligation to provide data).

We respect the principle of data minimisation when we only store personal data that is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

These are in particular, but not exclusively, the following processing cases in relation to our customers, visitors and users of our website:

Processing of orders and conclusion of purchase contracts – customers and employees of business partners

Legal basis	Performance of the contract
Personal data	In particular, address, VAT number of natural persons, delivery address, e-mail, name, surname, telephone, bank account number
Purpose of processing	Processing of orders, delivery of ordered goods, archiving in case of complaints, disputes or changes in the contract
Processing time	10 years
Recipients/processors	Accountant, parcel carrier, online payment provider (e-mail only), web application developer and administrator, web hosting provider, ICT administrator

Legal basis	Legal obligation
Personal data	In particular, address, bank account number, e-mail, name, surname, telephone
Purpose of processing	Records of tax obligations
Processing time	10 years
Processors	Accountant, parcel carrier, online payment intermediary (e-mail only)
Recipients/processors	Developer and administrator of web applications, web hosting provider, ICT administrator

Handling a complaint

Legal basis

Legal obligation

Personal data

In particular, address, VAT number of natural persons, delivery address, e-mail, name, surname, telephone, bank account number

Purpose of processing

Records of complaint history

Processing time

1 month

Recipients/processors

Service/Repair

Legal basis	Legitimate interest
Personal data	In particular, address, VAT number of natural persons, delivery address, e-mail, name, surname, telephone, bank account number
Purpose of processing	Records of complaint history, protection of legitimate interests
Processing time	5 years
Recipients/processors	Legal and other advisors

Communication via the contact form

Legal basis	Legitimate interest
Personal data	In particular, e-mail, name, surname, phone number
Purpose of processing	Handling questions, inquiries, requests or comments of users/customers
Processing time	10 years
Recipients/processors	Web Application Developer & Administrator, Web Hosting Provider

Marketing, especially direct marketing

Legal basis	Legitimate interest
Personal data	E-mail, phone
Purpose of processing	Business communication with existing customers
Processing time	10 years
Recipients/processors	Developer and administrator of web applications, web hosting provider, ICT administrator, service provider for sending bulk e-mails or SMS

Legal basis	Consent
Personal data	E-mail, phone
Purpose of processing	Business communication with potential customers, site users
Processing time	10 years
Recipients/processors	Developer and administrator of web applications, web hosting provider, ICT administrator, service provider for sending bulk e-mails or SMS

Customer registration for the extended warranty service

Legal basis	Consent
Personal data	In particular, e-mail, telephone, name, surname, postal address
Purpose of processing	Records of customers to whom we provide an extended warranty for the purchased product
Processing time	Until consent is withdrawn
Recipients	Web Application Developer & Administrator, Web Hosting Provider

Cookies

Our website uses "cookies" and other technologies that store small amounts of data on your computer or device to enable the collection of statistical information from your web browser. Cookies are commonly used on the Internet and allow websites/portals to recognize a user's device without uniquely identifying the individual person using the computer. These technologies make it easier for you to log in to and use the site, provide us with feedback about which part of the site you visit, so that we can assess the effectiveness of the site and allow you to have a better user experience.

For more information about cookies, including how to see which cookies have been set and how to manage, block and delete them, please visit the www.allaboutcookies.org website. You can also set your browser not to accept any cookies.

Use of information

In particular, we use the information we collect about you to provide you with our products or services, to fulfil our contractual obligations to you or others, to comply with our legal obligations, to notify you of changes to our services, or to improve our services.

We use your personal data for the purposes for which we collected it.

We also use your selected data (e-mail address) for direct marketing purposes.

When processing your personal data, no decision-making based solely on automated processing, including profiling, takes place that would have legal effects on you or would similarly significantly affect you.

Disclosure of your information

We will not disclose your personal information to anyone except as described in this Policy.

CM Trade Via may publish personal data to the extent of the client's identification data or the client's representative in its promotional materials if agreed in advance with the client.

We may share your personal data with the following third parties in justified cases and to the extent necessary:

contractual partners of CM Trade Via, if it is necessary for the implementation of the contractual relationship or for the normal functioning of CM Trade Via (e.g. cloud and hosting service providers, IT infrastructure providers and administrators, postal service providers, translation agencies, website management, etc.);
other entities in cases where we are required to provide such data by law, or if it is necessary to protect our legitimate interests (e.g. state administration bodies, courts, the Police of the Czech Republic, etc.).

Personal data of third parties

Personal data of third parties, which means personal data of employees and partners or associates of clients or business partners of CM Trade Via and other natural persons involved in cooperation with CM Trade Via, or other data that CM Trade Via receives from a client or business partner in connection with the conclusion or performance of a contract, will be processed in accordance with applicable legal regulations in the field of personal data protection.

CM Trade Via will use personal data for the purpose of performing contracts with clients or suppliers. CM Trade Via will process personal data of third parties for the duration of the contractual relationship and further for the period stipulated by special legal regulations, if any. They will then be stored for a longer period of time if there is a justified need to store the data in connection with a specific case.

Data security

We ensure adequate procedures to prevent unauthorized access to personal data and its misuse.

We use necessary and appropriate systems and procedures to protect and secure the personal information you provide to us. We also use security procedures and technical and physical restrictions to access and use personal data on our servers. Only authorized personnel who work with the data have access to personal data.

Duration of storage of your personal data

When handling your personal data for specific purposes, we respect the principle of storage limitation, whereby we only store your personal data for as long as necessary.

CM Trade Via processes personal data of third parties for the duration of the legal basis for processing and further for the period stipulated by special legal regulations, if any. They will then be stored for a longer period of time if there is a justified need to store the data in connection with a specific case.

We store your personal data for the duration of our contractual relationship for the purpose of exercising the rights and obligations arising from it, as well as after its termination for other necessary purposes, such as compliance with our legal obligations, contractual obligations, dispute resolution and legal enforcement of legitimate claims or for possible administrative proceedings. These needs vary depending on the specific reason for storing them, and therefore the retention period for different types of your personal data varies significantly from case to case, and may be up to 10 years from the termination of the contractual relationship, except in cases of longer retention required by law (e.g. payroll sheets).

In exceptional cases, such as litigation, certain documents containing your personal data may be stored for a longer period of time to protect our legitimate interests. This is especially the case when we would have to submit these documents as evidence in a court dispute, in administrative proceedings or due to the enforcement of a decision.

Your rights

As a data subject, you have legal rights in relation to the processing of your personal data, which you can exercise at any time. These are the right (i) to access personal data, (ii) to correct and complete inaccurate and incomplete personal data, (iii) to erase personal data (the so-called "right to be forgotten"), (iv) to restrict the processing of personal data, (v) to data portability, and (vi) to raise an objection.

Right of access to personal data – you have the right to obtain information from us as to whether or not we process personal data concerning you, and if so, you have the right to access such personal data;
Right to rectification of personal data – if you believe that we process inaccurate or incomplete personal data concerning you, you have the right to have them corrected, or you have the right to have incomplete personal data completed, including by providing a supplementary statement;
Right to erasure of personal data (right to be forgotten) - if you ask us to erase your personal data, we will do so without undue delay, especially if:
- your personal data is no longer necessary in relation to the purposes for which it was collected or processed;
- your personal data are processed on the basis of your consent and you withdraw this consent and there is no other legal reason for the processing;
- you object to the processing of your personal data and there are no overriding or legitimate grounds for the processing of your personal data;
- your personal data is processed unlawfully;
- the legal obligation to process under European Union or national law no longer exists.
Right to restriction of personal data processing - you have the right to ask us to restrict the processing of your personal data if:
- you contest the accuracy of the personal data;
- the processing is unlawful and you have opposed the erasure of the personal data and request the restriction of its use;
- we no longer need your personal data for the purposes of processing, but at the same time you require them for the establishment, exercise or defence of legal claims;
- You have objected to the processing of your personal data and it has not yet been verified whether our legitimate grounds override your legitimate grounds.
Right to personal data portability – upon your request, we will transfer your personal data in a structured, commonly used and machine-readable format We process on the basis of a contract or consent and which you have provided to us, handed over to you or another controller, you can exercise your right to data portability. In the event that the exercise of this right would adversely affect the rights and freedoms of others, we will not be able to comply with your request;
Right to object - You have the right to object to the processing of your personal data for purposes of public interest or for the purposes of our legitimate interest. If the processing of personal data is based on our legitimate interest (including direct marketing), you can object to this processing if this processing relates to the purpose of the objection. In this case, your personal data will no longer be processed for this purpose.

We also point out that if you have given us your consent to process your personal data, you have the right to withdraw this consent at any time, by post at our registered office or by e-mail to info@cm-trade.cz.

We would also like to draw your attention to the possibility of filing a complaint with the supervisory authority for personal data protection which is the Office for Personal Data Protection, address: Pplk. Sochora 727/27, 170 00 Prague 7 – Holešovice, Czech Republic, e-mail: posta@uoou.cz, if you believe that the processing of your personal data violates a legal regulation or your rights.

If you wish to exercise any of your rights if necessary, please contact us at info@cm-trade.cz or by post at our registered office.

Changes to our Privacy Policy

Any changes we may make to this Policy in the future will be posted on this page and, where appropriate, we will notify you by email. Please check this page to be aware of any updates or changes to our Privacy Policy.

Contact Us

You can contact us at any time regarding the processing of your personal data by sending us an e-mail to info@cm-trade.cz or by post at our registered office.

We provide all communications and statements regarding your rights exercised free of charge. However, if the request is manifestly unfounded or excessive, in particular because it is repeated, we are entitled to charge a reasonable fee taking into account the administrative costs associated with providing the requested information. In the event of repeated requests for copies of the processed personal data, we reserve the right to charge a reasonable fee for administrative costs for this reason.

We will provide you with a statement and, if necessary, information on the measures taken, as soon as possible, but no later than one (1) month after the delivery of the complete communication. We are entitled to extend the deadline by two (2) months if necessary and with regard to the complexity and number of requests. We would inform you about the extension, including the reasons.

This Policy is effective from 1.9.2022 and will be updated regularly. You can always find the valid version at www.cm-trade.cz/en/navigation/page/4.

CM Trade Via s. r. o.

Company

Support