Policy for the handling of personal data

1. Information on the processing and protection of personal data

1.1. This document contains a summary of the main principles and information of EquiRadar s.r.o. , ID: 08671516, VAT: CZ 08671516, with registered office: Ronkova 1832/8, 180 00 Praha 8 (hereinafter referred to as "Company" or "EquiRadar") concerning the handling, processing and protection of personal data processed by the Company, as the controller of personal data in the performance of the Company's legal obligations under 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 ("GDPR").

1.2. The processing of personal data by the Company is not subject to the obligation to appoint a data protection officer within the meaning of Article 37 GDPR.

2. What personal data does EQUIRADAR process and how does it obtain it?

2.1. The personal data that EquiRadar processes about you can be broken down according to the individual purposes of processing in the manner described below.

2.2. For the purpose of concluding and executing the user agreement (hereinafter referred to as the "User Agreement"), on the basis of which a user profile is established for you and the EQUIRADAR portal is made fully accessible to you on the website www.equiradar.com or as software via Google Play or the Apple Appstore (hereinafter referred to as the "EQUIRADAR Portal"), the following data are in particular:

(a) identification and registration information including (i) first and last name, (ii) contact email, (iii) telephone number, (iv) information about your consent to the User Terms, (v) information about your user account on the EQUIRADAR Portal, and (vi) other registration information you provide to the Company as part of your registration on the EQUIRADAR Portal;

(b) the content that you upload to the EQUIRADAR Portal , including but not limited to: (i) information and data, (ii) photographs, videos, audio recordings and other media, and (iii) any other personal data that you publish or upload to your user account and the portal;

(c) technical data including: (i) IP address, and (ii) cookies, i.e. data about your previous use of the EQUIRADAR Portal and website, including information about the functions used and forms completed, information about your browser, plug-ins, time settings, device and operating system.

2.3. For the purposes of concluding and performing the contract or contracts for the provision of paid services of the EQUIRADAR Portal (hereinafter referred to as the "Service Contract"), the following personal data are in particular required in addition to the personal data listed under point 2.2 of this Policy:

(a) the identification data of the recipient of the services , including in particular: (i) the name and surname or the name of the natural or legal person who is the recipient of the services, (ii) the address of the residence or registered office of the recipient of the services, and (iii) the identification number (ID) or other similar number of the recipient of the services (if assigned);

(b) the contact details of the recipient of the services , including in particular: (i) contact address; (ii) contact email; (iii) telephone number; (iv) bank details; (vi) other contact details provided by you (e.g. data box, identification details of your representative); and

(c) information about the services provided, including in particular: (i) the subject matter of the contracts; (ii) information about the services and their provision; (iii) information about the transactions carried out; and (iv) other data relating to the service contracts (e.g. records of the due date and proper performance of obligations under the Service Contract, invoices, bank account number, evidence of payments made).

2.4. For marketing purposes, research purposes, evaluation of quality and satisfaction with the services provided and for the purpose of further development of the EQUIRADAR Portal, the Company also processes: i) the content you upload to the EQUIRADAR Portal pursuant to point 2.2 (b) above, ii) technical data pursuant to point 2.2 (c) above, and iii) information about the services provided pursuant to point 2.3 (c) above. The processing of such data for these purposes is subject to your consent. In the event that consent is not given and/or is withheld, the Company will process the anonymised data in a form that makes it impossible to link it to your personal data.

2.5. For the purposes of marketing and business communication, the Company also processes, in case of your consent to the processing of personal data, (i) identification data pursuant to point 2.2 (a) above, and (ii) identification and contact data of the recipient of the services pursuant to point 2.3 (a) and (b) above.

2.6. For the purpose of improving the EQUIRADAR Portal, the websites on which the Software is made available may use cookies. Therefore, the Company processes data about your previous use of the Software and the website (see technical data under point 2.2 above). Most of the cookies used are so-called "session cookies", which are deleted when you close your web browser; other cookies remain on your device until you delete them. These cookies allow EquiRadar to recognise your browser on your next visit. The provision of cookies is not a contractual or legal requirement. You can delete cookies on your device at any time and once deleted, EquiRadar cannot process any information contained in the cookie. You can also adjust your browser to be informed of the cookie settings and to allow cookies individually, or to disable cookies in specific cases or in general, or to activate the automatic deletion of cookies. However, the functions of the EQUIRADAR Portal may be limited if cookies are deactivated.

2.7. For statistical, analytical and marketing purposes, EquiRadar also processes the data you provide when using the Software using Google Analytics and the Google Visualisation API (Google Charts), provided by Google, Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (" Google"). This service uses an IP address and cookies that are transferred to a Google server in the USA. This data is subsequently used by Google for the purposes of evaluating your use of the website, compiling reports on the activities of the EquiRadar website and providing other services. The provision of personal data for processing in Google Analytics and Google Charts is not a contractual or legal obligation; you can disable the installation of cookies in your browser settings.

2.8. Personal data is obtained by the Company primarily directly from you in connection with the conclusion and performance of the User Agreement and Service Agreements, registration and management of the user profile, and the use of the EQUIRADAR Portal.

3. How does EQUIRADAR use personal data and for how long?

3.1. Your personal data is used by EquiRadar mainly for the following purposes:

(a) to enter into and perform the User Agreement and Service Agreements with you or the recipient of the Services;

(b) to communicate with you and the service recipient and to manage our contractual relationship;

(c) for marketing and other business communication with you and the recipient of the services;

(d) for statistical and analytical purposes and for the further development of the EQUIRADAR Portal;

(e) to monitor whether the EQUIRADAR Portal is being used in accordance with the terms of the User Agreement and Service Agreements;

(f) to fulfil their legal obligations; and

(g) to ensure the protection of EquiRadar's legitimate interests.

3.2. Your personal data is not processed for the purpose of automated decision-making or profiling pursuant to Article 22 GDPR, which would have legal effects on you or significantly affect you.

3.3. EquiRadar retains your personal data only for as long as any of the above processing purposes continue and thereafter only for the time and under the conditions in accordance with the applicable law.

3.4. Personal data processed by EquiRadar on the basis of your consent is retained for a period of five (5) years from the termination of the contractual relationship or until your consent is withdrawn.

4. Legal basis for processing your personal data

4.1. The legal basis that allows EquiRadar to process your personal data depends on the purpose for which EquiRadar processes the personal data. Therefore, in a particular case, EquiRadar may process your personal data without your consent because:

(a) it is necessary for the purposes of concluding or performing the User Agreement, Service Contract or any other contract concluded between you and EquiRadar (Article 6(1)(b) GDPR);

(b) it is necessary for the performance of EquiRadar's legal obligations, such as accounting and tax obligations (Article 6(1)(c) GDPR);

(c) it is necessary for the protection of EquiRadar's legitimate interests (Article 6(1)(f) GDPR).

4.2. The legitimate interests for which your personal data is processed are, in particular: (i) to assert claims under contracts, (ii) to monitor compliance with contractual terms; and/or (iii) to protect EquiRadar's property.

4.3. EquiRadar also processes your personal data on the basis of your consent (Article 6(1)(a) of the GDPR), namely (i) for direct marketing purposes, i.e. product offers, newsletters or other commercial communications, by sending them to your email address, postal address or by telephone contact; (ii) for indirect marketing purposes; (iii) for statistical and analytical purposes; and (iv) for the purposes of further development and improvement of the EQUIRADAR Portal.

4.4. Your consent to the use of your personal data processed for the purposes set out in Art. 4.3. above, you may withhold, restrict or withdraw your consent at any time by notifying us of the withdrawal of your consent to the processing of your personal data by sending an e-mail from your contact e-mail address: info@equiradar.com.

5. Who does EQUIRADAR provide your personal data to?

5.1. EquiRadar may disclose your personal data to:

(a) service providers who provide EquiRadar with their services related to EquiRadar's activities, in particular accounting firms, payment intermediaries, persons cooperating with EquiRadar in the administration of contracts or claims;

(b) to other persons in accordance with applicable law (e.g. notifications to tax authorities, police in the context of criminal investigations, etc.).

5.2. Your personal data may be transferred and stored within EU countries, but not to entities based outside the EU/EEA. An exception is the transfer of personal data to the following third countries. The safeguards to ensure adequate protection of personal data in accordance with the GDPR are set out in the table below:

6. What your rights are

6.1. In particular, you have the following rights in relation to the processing of your personal data:

(a) the right to clear, transparent and understandable information about how EquiRadar uses your personal data and what your rights are;

(b) the right of access to personal data and the provision of other information related to its processing by EquiRadar;

(c) the right to correct, update or complete incorrect and incomplete personal data;

(d) the right to have your personal data erased, in particular if (i) it is no longer necessary for further processing, (ii) you have withdrawn your consent to its processing, (iii) you have legitimately objected to its processing, (iv) it has been processed unlawfully, or (v) it must be erased by law;

(e) the right to restrict the processing of your personal data if (i) you challenge the accuracy of the personal data until EquiRadar has verified its accuracy, (ii) the processing is unlawful, (iii) EquiRadar no longer needs the data but you need the data for the purposes of pursuing your legal claims, or (iv) you object to the processing of the data until EquiRadar has verified that its legitimate interests outweigh your interests;

(f) the right to object to the processing of your personal data if EquiRadar processes it (i) for direct marketing purposes or (ii) for legitimate interest purposes;

(g) the right to obtain your personal data and transfer it to another service provider;

6.2. If you wish to exercise any of the above rights, please contact EquiRadar using the contact details below.

6.3. If you believe that your rights have been violated in connection with the processing of personal data, you have the right to lodge a complaint with a supervisory authority. This is the Office for Personal Data Protection, address: Pplk. Sochora 27, 170 00 Prague 7; website: www.uoou.cz.

7. How EQUIRADAR protects your personal data

7.1. In order to ensure the security and confidentiality of personal data, EquiRadar uses technical and organisational measures to ­protect against unauthorised access to and misuse of data, including IT security. These measures are regularly evaluated and updated by EquiRadar.

7.2. The processing of personal data is carried out manually and in electronic information systems, which are subject to physical, technical and procedural controls. In order to protect data, EquiRadar has set up a security mechanism including technical, organisational and personnel measures and EquiRadar requires the same level of protection from its processors.

8. Need more information or want to exercise your rights?

8.1. If you have any questions or requests regarding the processing of your personal data, ­need any other related assistance or wish to exercise your rights, you can contact us in the following ways:

(a) by sending a written request to Ronkova 1832/8, 180 00 Praha 8;

(b) electronically via the contact form on our website;

(c) electronically via email at info@equiradar.com;

(d) by phone on our number +420 797 724 642;

(e) in any other way that you still use to communicate with us.

9. Applicable Law

9.1. Legal relations under the Agreement are governed by Czech law. However, as a result of this choice, the Consumer is not deprived of the protection afforded by the provisions of the law which cannot be derogated from contractually and which would apply in the absence of a choice of law.

9.2. English translation of the terms is provided for your convenience. In case of conflicts of interpretation the Czech version prevails.