Personal data protection principles of the company GuideVision, s.r.o.
These Personal Data Processing Principles explain the manner in which GuideVision group companies (as further identified below), as (joint) controllers of personal data, process, in conducting their business operations and activities relating thereto, personal data relating to persons that they come into contact with in various situations (hereinafter referred to as “You”).
The GuideVision companies (hereinafter jointly referred to as “GuideVision” or the “Controller”), protect(s) all personal data being processed as strictly confidential and handles it in accordance with the valid and effective legal regulations in the field of personal data protection. The security of Your personal data is a priority for GuideVision.
The GuideVision companies specified above act as joint controllers of Your personal data within the meaning of Article 26 of the General Data Protection Regulation [Regulation (EU) 2016/679] (“GDPR”), i.e. they jointly determine the purposes and means of processing and they collect, retain and utilize (and otherwise process) Your personal data in the exercise of their business activity (the individual purposes for which personal data is processed are defined in more detail below).
The GuideVision companies have mutually entered into an Agreement on Joint Controllership Within the Group, under which they have arranged their shares of the responsibility to fulfill obligations under the GDPR, primarily as pertains to clearing the rights of data subjects, as follows:
- the GuideVision companies are all obligated to implement sufficient technical and organizational measures, pri marily including controlled access based upon the need-to-know principle, in order to ensure that, even when sharing personal data within the GuideVision group, maximum personal data protection and Your privacy are maintained;
- due to the nature of the internal administrative cooperation model and close interconnection of the GuideVision companies, the rule is that if a specific legal ground for the processing of personal data applies to one of the GuideVision companies, such legal ground automatically also applies to all of the other GuideVision companies as well; likewise, granted consent to the processing of personal data is provided for the benefit of all GuideVision companies; trequests relating to the exercise of the rights of data subjects should be aimed primarily in regard to the GuideVision company that is primarily processing personal data of specific data subjects (e.g. the company that is the employer of the specific employee / dealing with a specific job applicant, the direct business/contractual partner of a given customer, etc.); exceptions are GuideVision Suomi Oy (Finland) and GUIDEVISION UK LTD (Great Britain), for which the requests of data subjects are handled by GuideVision, s.r.o. (Czech Republic);
- if it is not entirely clear which specific GuideVision company is primarily processing the personal data of a specific data subject, GuideVision, s.r.o. (Czech Republic) clears the exercised rights of data subjects;
- if You contact any other GuideVision company with Your data subject rights, Your requests will be handled by the company that you contacted; however, there may be a slight delay in the response (however, in any case, within the period specified by the GDPR).
These Personal Data Processing Principles apply to the processing of personal data:
in the course of the performance of contracts with business partners,
of potential business partners, of participants of events that GuideVision organizes,
of job applicants and those interested in other collaboration,
for the purpose of sending commercial communications and targeted advertising,
of visitors of websites operated by GuideVision (“Websites”).
The Personal Data Processing Principles describe the purposes of processing personal data and the means of their processing, they inform of the individual categories of personal data being processed, their potential recipients, personal data retention periods and of Your rights in relation to personal data protection.
Purposes of personal data processing
Your personal data may be processed by the GuideVision companies for the following purposes:
- Performance of contract (primarily the performance of contracts with GuideVision business partners, including measures prior to entering into a contract, such as preparing an offer, conducting selection procedures etc.);
- Compliance with legal obligations (primarily obligations within the meaning of accounting and tax legislation); Protection of the Controller’s legitimate interest (e.g. protecting a Website and GuideVision networks from misuse);
- Handling requirements and requests (delivered by email or through a contact form);
- Sending commercial communications (newsletter) and targeted advertising (primarily on Websites).
Personal data being processed
GuideVision companies are entitled to process the following personal data according to the purpose of processing:
|Data of data subjects||Purposes of processing:|
|Name and surname||Performance of contract, Compliance with legal obligations, Protection of the Controller’s legitimate interest, Handling requirements and requests, Sending commercial communications and targeted advertising|
|Contact address||Performance of contract, Compliance with legal obligations, Protection of the Controller’s legitimate interest|
|Performance of contract, Compliance with legal obligations, Protection of the Controller’s legitimate interest, Handling requirements and requests, Sending commercial communications and targeted advertising|
|Telephone number||Performance of contract, Compliance with legal obligations, Protection of the Controller’s legitimate interest|
|Account number||Performance of contract, Compliance with legal obligations, Protection of the Controller’s legitimate interest|
|IP address and information acquired through cookies (see below)||Targeted advertising on Websites|
|Information stated in a curriculum vitae||Measures prior to entering into a contract (in the case of job applicants)|
Personal data are processed manually, as well as by automated means. Automated processing of personal data occurs for the purposes of performance of contract, primarily in order to secure internal processes within GuideVision that are necessary in order to secure the delivery of services. Automated processing of personal data also occurs in cases of consent granted for the sending of marketing communications and targeted advertising.
PROCESSING PERSONAL DATA ON THE BASIS OF CONSENT
If You grant any of the GuideVision companies consent to the processing of personal data for the purposes of sending commercial communications and targeted advertising, You acknowledge that the granting of consent is voluntary, and that consent may be withdrawn at any time. Consent is granted for a period of 5 years or until withdrawn.
Refusal to grant such consent has no effect on the option to enter into a contract with GuideVision, nor does it affect the business relationship or other relationship with GuideVision in any way.
Even if such consent is not granted, the specific GuideVision company is entitled to send You commercial communications pertaining to similar services to Your address, email address or by other means of electronic communication, provided that You have not previously expressed non-consent to such marketing contact* (such non-consent, a so-called optout, can also be expressed through a link in each of the sent marketing emails).
* Does not apply in case of Poland
If You grant any of the GuideVision companies consent to the processing of personal data for other purposes, always precisely specified in the form through which consent is granted, You acknowledge that the granting of consent is completely voluntary, consent is granted for the period of time stated in the relevant form and may be withdrawn at any time through the contacts set out below.
RECIPIENTS OF PERSONAL DATA
Within GuideVision, Your personal data are made accessible to authorized employees only (as well as to other authorized staff who are not in an employment relationship), or to individual processors of personal data who are contracted by GuideVision, or potentially to other recipients, as well as to independent controllers. For example, these include processors or controllers participating in the realization of services, payments, or providing marketing services. However, only ever to the extent necessary for the fulfillment of individual purposes of processing, and on the basis of a corresponding legal title for transferring and processing personal data. An up-to-date list of recipients of GuideVision personal data is available upon request through the email address firstname.lastname@example.org.
For internal administrative purposes within the group of businesses, Your personal data may also be transferred outside of the GuideVision companies, to related persons within the Infosys business group, specifically to (i) Infosys Limited, a company with registered office at Electronics City, Hosur Road, Bangalore 560 100, India, (ii) Infosys Limited (UK branch), an Infosys Limited branch office in Great Britain, with registered office at 10 Upper Bank Street, Canary Wharf, London, E14 5NP, United Kingdom of Great Britain and Northern Ireland, reg. no. BR003764, and (iii) Infy Consulting Company Limited, a company with registered office at 10 Upper Bank Street, Canary Wharf, London, E14 5NP, United Kingdom of Great Britain and Northern Ireland, reg. no. 06087315, as well as, in certain situations, to other collaborating persons, such as AspectWorks, s.r.o., a company with registered office at Pod Vápenkou 292, 252 44 Psáry, Czech Republic, identification number (IČO): 27374726, AspectWorks Group a.s., a company with registered office at Türkova 2319/5b, Chodov, 149 00 Praha 4, Czech Republic, identification number (IČO): 05550530 and ScienceSoft Oy, a company with registered office at Myyrmdenraitti 2, 01600 Vantaa, Finland (including non-European branches of ScienceSoft, specifically ScienceSoft USA Corporation, 5900 S. Lake Forest Drive Suite 300, McKinney, TX 75070, USA TTN 32057362090 and ScienceSoft CJSC, Belarus, Minsk, L.Bedy str. 2, TIN 101132899. When transferring Your personal data to third countries (i.e. to countries outside of the EU/EEA), the Controller ensures compliance with conditions for the protection and security of personal data required by the valid and effective legal regulations for the protection of personal data (primarily ensuring adequate protection of personal data).
In cases specified by law, GuideVision companies are entitled or obligated under the valid and effective legal regulations to transfer certain personal data to law enforcement authorities, for example, or to other public authorities.
PROCESSING PERSONAL DATA OF JOB APPLICANTS OR PERSONS INTERESTED IN OTHER COLLABORATION WITH GUIDEVISION
If you express interest in collaborating with GuideVision by way of a response to a specific job position advertised by us, GuideVision processes Your personal data including name, surname, e-mail, telephone, and potentially other data provided in a sent curriculum vitae (including a photograph, if You provide us with it voluntarily) for the duration of the relevant selection procedure (but for a maximum period of six months at most). Potentially, if You grant GuideVision consent to Your registration in a database of job and/or collaboration applicants, GuideVision processes Your personal data set out above for a period of three (3) years or until Your consent is withdrawn.
If You express a general interest in collaborating with GuideVision by sending Your personal data including name, surname, e-mail, telephone and possibly other data provided in a sent curriculum vitae (including a photograph, if You provide us with it voluntarily) through the form located on our career Website page or in any other manner and You grant GuideVision consent to Your registration in a database of job and/or collaboration applicants, GuideVision processes Your personal data for a period of three (3) years or until Your consent is withdrawn. For the period of time for which You allow us to do so, GuideVision can thus, on the basis of Your consent, send You job and/or collaboration offers that could be of interest to you. Processing is conducted by the Controller, who can, in certain cases, authorize contracted processors to perform processing, whereby these can include, for example, providers of processing software, services and applications. An up-to-date list of such processors is available upon request through the email address email@example.com. Within the scope of keeping a database of job and/or collaboration applicants, neither automated decision-making nor profiling is utilized.
You can withdraw consent to the processing of Your personal data at any time through the contact details provided below.
THIRD-PARTY PERSONAL DATA
Third-party personal data, which are understood to mean the personal data of employees of GuideVision business partners and other natural persons participating in collaboration with GuideVision, and potentially other data that GuideVision receives from a business partner in connection with entering into or performing a contract, will be processed in accordance with the valid and effective legal regulations in the field of personal data protection. GuideVision will use such personal data exclusively for the purpose of performing contracts with business partners. The business partner hereby acknowledges that GuideVision will process third-party personal data for the duration of the contractual relationship, as well as for the period of time prescribed by specialized legal regulations, if any. Such data shall be retained for a longer period of time if, in a justified case, the need arises to retain the data in connection with a specific case. The business partner is obligated to duly inform its employees and other natural persons participating in collaboration with GuideVision on the part of the business partner, as well as its clients if applicable, regarding the processing of personal data by GuideVision companies if GuideVision has access to client data within the scope of performance of contract.
PERSONAL DATA RETENTION PERIOD
We process and retain Your personal data for a period of time necessary in order to ensure all of the rights and obligations arising from the relevant contractual relationship, as well as for the period of time for which GuideVision companies are obligated, as personal data controllers, to retain the personal data under the generally binding legal regulations, or for the period of time for which You have granted us consent for processing. In other cases, the processing period is based upon the purpose of processing, which it must be proportionate to, or it is prescribed by the legal regulations in the field of personal data protection.
We process personal data according to the purpose of their processing for the period of time stated as follows:
|Purpose of Processing||Retention Period|
|Performance of contract||for the duration of the contract and for the period of time prescribed by the relevant legal regulation from termination of the contract|
|Compliance with legal regulations||for the period of time prescribed by the relevant legal regulation|
|Protection of the controller’s legitimate interest||for a maximum period of three (3) years from the commencement of data processing, unless specific legal regulations provide otherwise, or unless the need arises in a justified case to retain data for a longer period of time in connection with a specific case|
|Handling Your requirements and requests||for the period of time necessary in order to handle a relevant requirement (and to document such handling of the requirement)|
|Sending commercial communications||for the duration of a granted consent to sending commercial communications and targeted advertising, or until the consent to processing is withdrawn, or in accordance with the relevant legal regulations **|
|Measures prior to entering into a contract||for the duration of negotiations regarding entering into a contract (for the duration of a selection procedure), or for the duration of a granted consent (in the case of inclusion in a database of potential employees and collaborators, for a period of 3 years or until consent is withdrawn)|
** If the local legal regulations allow it, GuideVision is entitled to process Your email address within the meaning of the relevant law for the purpose of disseminating commercial communications pertaining to its own products or services (e.g. as a newsletter) provided that you have not refused such sending.
Cookie files are data files with a small content that are stored in Your computer, telephone or other device when You visit a Website. Cookie files serve to store and receive identifiers and other information regarding computers, telephones and other devices that You access Websites from, and they thus help us to provide, protect and improve the services offered.
On Websites, we use functional, basic analytical and marketing cookies.
They are utilized when visiting and using Websites, for information purposes only, i.e. if You do not register or do not grant us consent, we only collect data that Your browser transmits to our server, which is necessary so that we may display the Websites to You and guarantee that Your use of them is stable and secure.
BASIC ANALYTICAL COOKIES
These cookies serve merely to improve the functioning of Websites. They enable us to distinguish and determine the number of visitors and to monitor how our visitors use the Websites. They help us to improve the manner in which the Websites function, for example, by enabling users to easily find what they are looking for. These cookies do not collect information that could distinguish Your identity.
Through these tools, we analyze and regularly improve the functionality of our Websites. We can use the acquired statistics to improve our offer and to make it more interesting for You as the user.
These are used in order to monitor the preferences of users of Websites for the purpose of targeted advertising, i.e. displaying marketing and advertising communications in accordance with such preferences. Marketing cookie files utilize third-party tools. These marketing cookies will only be used on the basis of Your consent.
On our Websites, we utilize the following marketing tools (third party cookies):
- Advertising functions of Google Analytics beyond the scope of basic analytical functions (further information HERE);
- Adform tool, which uses cookie files to display advertising relevant to the user, to improve overviews of campaign performance, or to prevent the user from seeing the same advertising multiple times (further information HERE);
- Facebook marketing services, which enable advertising to be displayed to users of Websites when visiting the Facebook social network or other websites that also use these tools (further information HERE);
- LinkedIn marketing services, which enable us to obtain an overview of the types of users of Websites based upon LinkedIn profile data and to thus improve content targeting (further information HERE);
- Google Doubleclick marketing tools, which enable an exchange of Google advertising offers in real time (further information HERE).
PROCESSING COOKIE FILES OUTSIDE OF THE EUROPEAN UNION
On our Websites, we use the services of Google Tag Manager (more detailed information regarding ensuring privacy HERE). This is a technical platform that facilitates the provision and administration of other web services and programs in order to monitor Websites through so-called “tags”. In this regard, Google stores cookie files in Your device and analyzes the use of tools in order to monitor Your behavior while browsing Websites. Such data sent off by individual tags are merged under an integrated user interface, stored and processed. When using our Websites, the activation of Google tags causes the transmission to a Google server primarily of data such as Your IP address and Your user activity, which may also be processed and stored outside the EU, e.g. in the USA, in compliance with the relevant security standards. Monitoring tools used within the scope of the Google Tag Manager service ensure the anonymization of source codes prior to transmission through the Google address manager. The Google Tag Manager can thus only collect IP addresses anonymously through so-called IP address masking.
HOW CAN YOU SET COOKIES?
You can refuse cookie files in Your internet browser settings, or You can set the use of only certain ones (depending on the type of browser). However, if You do not permit us to use basic (functional) cookies, certain Website functions may not work as they should.
LINKS TO SOCIAL NETWORKS
Social media buttons are placed on our Websites, primarily for the option to interact with social networks, in order to make our Websites more interesting for You as a user. A connection with a relevant social network occurs only if You actively click on the relevant button. In such a case, Your web browser commences a connection to the relevant social network’s servers.
You can find a specific overview of cookies HERE.
RIGHTS OF DATA SUBJECTS
As a data subject, You have the rights set out below, which You are granted under the legal regulations, and which You can exercise at any time under the conditions set out by the legal regulations on the protection of personal data. These are specifically the right (i) of access to personal data, (ii) to the correction of inaccurate or false personal data, as well as to the rectification of incomplete personal data, (iii) to erasure of personal data, if the personal data are no longer necessary for the purposes for which they were collected or otherwise processed, or if it is determined that they were processed unlawfully, (iv) to restriction of processing of personal data, (v) to data portability and (vi) the right to object, upon which the processing of Your personal data will be terminated, unless it is proven that there are compelling, legitimate reasons for processing that override the interests or rights and freedoms of the data subject, primarily if the reason is the potential enforcement of legal claims. At the same time, You have the option of turning to supervisory authority
- Czech Republic – Úřad pro ochranu osobních údajů (uoou.cz),
- Poland – Urząd Ochrony Danych Osobowych (https://uodo.gov.pl/),
- Germany – supervisory authority of the respective federal state (https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html),
- Hungary – Nemzeti Adatvédelmi és Információszabadság Hatóság (naih.hu),
- Finland – Office of the Data Protection Ombudsman (tietosuoja.fi),
where You can potentially file a complaint.
- Right of access to personal data: if You wish to know whether GuideVision is processing personal data pertaining to You, You have the right to obtain information on whether Your personal data are being processed, and if so, You also have the right to obtain access to Your personal data.
- Right to the correction of inaccurate personal data or rectification of incomplete personal data: if You believe that GuideVision is processing inaccurate or false, obsolete or incomplete personal data about You, You have the right to require the correction or rectification thereof. GuideVision will carry out the correction/rectification without undue delay, in view of the technical feasibility.
- Right to erasure (i.e. the right to be forgotten): if You request erasure, GuideVision will erase Your personal data if (i) they are no longer necessary for the purposes for which they were collected or otherwise processed, (ii) processing is unlawful, (iii) You raise objections to processing and there are no overriding legitimate reasons for processing, or (iv) processing is not imposed upon GuideVision by a statutory obligation.
- Right to restriction of processing of personal data: if You do not wish for erasure, but merely for the temporary restriction of processing of Your personal data, You can require GuideVision to restrict the processing of Your personal data.
- Right to data portability: if You wish for GuideVision to transfer Your personal data that it is processing on the basis of Your consent or on the basis of a contract to a third party, You can utilize Your right to data portability. If the exercise of such right could cause an adverse impact upon the rights and freedoms of third parties, GuideVision will not be able to accommodate Your request.
- Right to object: You have the right to object to the processing of personal data that are being processed for the purposes of protecting the legitimate interests of GuideVision. If GuideVision fails to prove that there is a compelling, legitimate reason for processing that overrides Your interests or rights and freedoms, it will cease processing on the basis of Your objection without undue delay. If the primary essence of Your objection is aimed against the sending of commercial communications and targeted advertising, please use the link at the end of the last commercial communication (newsletter) that You have received from us, in order to unsubscribe from receiving commercial communications and processing of personal data for such purpose.
In the case of repeated or manifestly unfounded requests seeking to exercise the rights set out above, we will be entitled to charge a reasonable fee for the realization of a given right, or we will refuse such realization. We would inform You of such a procedure.
In the exercise of Your rights, contact us by mail at the registered address of GuideVision or by email at firstname.lastname@example.org. GuideVision reserves the right to verify the identity of the person seeking to exercise the relevant rights in a reasonable manner.
These Personal Data Processing Principles are effective from October 12, 2020.