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Information memorandum

Content

The general principles applicable to the processing of personal data.

Content 1

1. The general principles applicable to the processing of personal data. 1

2. Collection of personal data. 2

2.1. Reasons for collecting personal data. 2

2.2. Sending for direct marketing purposes. 2

2.3. Consent 2

2.4. Obtaining of personal data. 2

3. Use of your personal data. 3

4. Passing your personal data to other persons. 3

4.1. Passing for processing. 3

4.2. Third persons - data base producers to whom personal data will be transferred. 3

4.3. Passing outside the EU.. 3

5. Automatic individual decision making and profiling. 4

6. Time length of the processing of personal data. 4

7. Your rights. 4

7.1. Right to be informed. 4

7.2. Right to make a correction. 4

7.3. Right to be forgotten – right for data erasing. 5

7.4. Right to limit processing. 5

7.5. Right to object 5

7.6. Right to obtain your data. 5

7.7. Right to file a complaint 5

8. Measures implemented. 5

9. Personal Data Protection Officer 6

10. Contacts. 6

11. Conclusion. 6

1. The general principles applicable to the processing of personal data

Our company Alca plast, s.r.o., Biskupský dvůr 2095/8, 110 00 Prague 1, Czech Republic, ID No.: 256 55 809, VAT Reg. No.: CZ25655809, with its registered office at the Municipal Court in Prague, section C, insert 58560, will process your personal data. This policy sets out the rules governing personal data processing in order to preserve the personal data protection rights, privacy rights and to protect your personal data from being misused. We will follow this policy all the time when processing any of your personal data.

Personal data processing principles set out in this guideline correspond to the obligations embodied in 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 - General Data Protection Regulation (hereinafter referred to as "GDPR").

Through these policies, we also inform you of the facts and your rights that you must be aware of in accordance with the GDPR, and which ensure sufficient transparency in the processing of personal data.

This policy sets out the procedures and principles according which we will process and handle your personal data. If anything is unclear to you or you would like to ask anything regarding your personal data, please, feel free to use the contact information provided in this policy.

2. Collection of personal data

2.1. Reasons for collecting personal data

We will only collect and process your personal data if it is necessary for reasons as:

a) Meeting the requirements of the law.

b) Fulfilling the contract that you have signed or you are going to sign.

c) Providing the service you want to use.

d) The purposes of our legitimate interests, unless your interests or the fundamental rights and freedoms of subjects that require the protection of personal data are preferred.

2.2. Sending for direct marketing purposes

A legitimate interest may be the processing of your personal data for the purposes of direct marketing - sending of business notifications if we are already in a business relationship with you and the matter will be directly related to the goods or services we have already provided. However, you can unsubscribe from such marketing notifications at any time via the link included in the business notification or via the contact e-mail below.

2.3. Consent

In other cases, we may only collect and process your personal data with your explicit and independent agreement. You may revoke your agreement through the given contact details at any time. Specific conditions for the use of your personal data after agreement are always given in each individual consent.

2.4. Obtaining of personal data

We do not obtain your personal data from publicly available sources, but always from you or from third parties who cooperate with us and have obtained personal data from you in accordance with the law and have the authority to share it with us. In both cases, we will follow these guidelines.

We will either explicitly request your personal information from you or we may obtain the data if you are registered to our services, you are entering into a contract with us or using some of our services. Alternatively, you can provide your personal data by filling out forms on a website or through communication via phone call, e-mail, internet discussion or otherwise. Some information is automatically collected with your consent, such as using cookies when you visit our website.

We will always inform you about the specific reason for processing your personal data. Such information is either stated directly in the contract, or in the terms of the service provided or in this policy. Alternatively, you may ask us at any time about the reasons for processing your personal data through the contact details listed below.

3. Use of your personal data

We use your personal data primarily to provide our services, fulfil a contract, comply with legal requirements, notify about changes in our services to improve our services, enter or perform the required contract, or to comply with legal requirements. With your consent we may also use such information to inform you of other services and products that we or selected third parties offer and which you may be interested in, or which you may wish to use. We will always inform you about any further use of your personal data.

4. Passing your personal data to other persons

4.1. Passing for processing

We will not share your personal data with anyone except for the cases described in this policy.

Your personal data will be accessible by our employees who will be entrusted with use of such personal data. All employees, who will have access to your personal data, have written commitment to confidentiality, so your personal data may not be disseminated anywhere. These employees are also responsibly selected and properly trained to know how they should treat your personal data and under what conditions your personal information may be processed.

We pass on your personal data to some third parties if necessary. These persons are called data base producers. Our company is responsible for ensuring that these producers provide adequate assurance for personal data processing. All the data base producers are responsibly selected. At the same time, the producers will be contractually obliged to perform all their duties, ensuring that your personal data is adequately protected and the risk of misuse is minimised.

If you give us permission to do so, we may also provide certain information to selected third parties to inform you of the services and products that we or the selected third parties offer and which you may be interested in.

4.2. Third persons - data base producers to whom personal data will be transferred

The producers are primarily our company financial, legal, tax, marketing and other advisers and collaborators.

In addition, our company is in a consortium with Alca plast servis, s.r.o., ID No. 247 59 783, VAT Reg. No. CZ24759783, Prague 4 - Krč, U Habrovky 247/11, ZIP 14000, Czech Republic, Alca plast SK, s.r.o., ID No. 36 537 616, VAT Reg. No. 2020148614, Novozámocká 209, Nitra 949 05, Slovakia, S.C. ALCAPLAST RO S.R.L., ID. 24592465, VAT Reg.No. RO24592465, Str. Turda, Nr.15, 550052 Sibiu, Romania, Alca Plast HU Kft., VAT Reg. No. HU23550238, Fuvaros köz 1., 2900 Komárom, Hungary, Alca plast PL sp.z o.o., ID No. 241542800, VAT Reg. No. PL9372618244, Ul. Ks. Londzina 47, 43-382 Bielsko-Biała, Poland. These companies work closely together and share some administrative and staff resources. Therefore, the data will be shared among these companies, however, all companies provide sufficient guarantees to protect your personal data.

We may also share your personal data with other third parties in order to prevent the crime and reduce the risks, if required by law and where we consider it appropriate e.g. in response to the lawsuit or to protect the rights or property of our company, our partners or you.

4.3. Passing outside the EU

Your personal data is not passed on to countries outside the European Union or to international organizations, except where they are transmitted for better backup and data protection.

5. Automatic individual decision making and profiling

Our company does not perform any automatic individual decision making or profiling processes that would have any legal effect on you or would otherwise have any significant impact on you. If any change occurs, we will inform you immediately.

6. Time length of the processing of personal data

We only process your personal data for the necessary length of time. If your personal data is no longer needed for processing, we will immediately delete it.

In the case that we process your personal data on the basis of your consent, the processing time is stated in this consent.

If we process your personal data as a result of legal provisions, we process it for as long as the law requires it. If the law requires the archiving of certain data, we will archive your personal data in accordance with the law for the required time.

In the case that we process your personal data as a result of entering a contract or providing a service, we will be processing your personal data for the duration of the contract or providing the service and for the next 10 years after termination of the contract or provision of the service. However, during this time, we process your personal data only for the purpose of preventing any legal claims or conducting legal proceedings. The 10-year period then corresponds to the maximum limitation period after which the claims can be successfully enforced in court. In the event of legal or other proceedings in which your personal data is required, we will be processing such data for the duration of the proceedings, including any enforceable and other follow-up proceedings.

7. Your rights

7.1. Right to be informed

Feel free to use the contacts below to ask us to send you a confirmation whether or not we process some of your personal information and if we do, you have the right to access following information:

a) For what purpose do we process your personal data and what are its categories.

b) Who are the recipients and data producers of your personal data.

c) For how long your personal data will be stored; if this duration cannot be determined, what are the criteria to determine the duration.

d) For which personal data you may request removal or processing restrictions and object to such processing.

e) About the right to file a complaint with the Supervisory Authority.

f) About the personal data sources, if they have not been obtained from you.

g) Whether decision making or profiling is automatic.

We will provide copies of your processed personal data, if you ask for it. Requiring additional copies may be charged with the costs incurred. If you request in electronic form, copies will be provided in electronic form too, unless you do not request for another way. However, we have the right to require verification of your identity to ensure this information regarding your personal data does not reach an unauthorized person.

We will try to provide you with this information as soon as possible, depending on the volume of information you require. However, within 30 days at the latest.

7.2. Right to make a correction

If you find that some of your personal data are inaccurate, imprecise or incomplete, you have the right to get your personal information corrected or supplemented, without undue delay.

7.3. Right to be forgotten – right for data erasing

You have the right to get your personal data erased without undue delay if:

a) Your personal data is no longer needed for the purposes for which it was collected.

b) You are withdrawing your consent.

c) You will object to the processing.

d) We have processed your personal data unlawfully.

e) By deleting the legal obligation will be fulfilled according to the law.

f) Personal data were gathered in connection with the offer of information services company.

However, we will not delete your personal data because of any of the reasons above, if there is at least one of the reasons given according to the Article 17 (3) of the GDPR.

If your personal data has been disclosed or passed to third personal and it is feasible, we will also delete such data.

7.4. Right to limit processing

You have the right to restrict the processing of your personal data if:

a) You will tell us that your personal data is inaccurate and the data will be restricted for a period of time until the accuracy of our personal data is verified.

b) We process your personal data unlawfully, but you ask us to restrict the data and not to delete.

c) We will no longer need your personal data, but you will require the data to identify, exercise or defend legal claims.

d) You have objected to the processing and the data will be restricted for a period of time until it is verified that the objections are justified.

During the limitation of processing, your personal data may only be stored and processed only upon your consent, for the purpose of determining, enforcing or defending legal claims or for the public interest.

7.5. Right to object

You have the right to object to the processing of your personal data if we process it for direct marketing purposes. The objection must be sent to us in writing or via e-mail. In the event you object to processing for direct marketing purposes, we will no longer process your personal data to this extent unless we substantiate serious legitimate processing grounds that outweigh your interests or rights and freedoms, or determine, exercise or defend legal claims.

7.6. Right to obtain your data

If you ask us to do so, we will pass on your personal data in a structured, usable format so you can give them to another manager. As far as it is technically possible, you may ask us to pass on your personal data directly to the manager you identify.

7.7. Right to file a complaint

At any time, you may file a complaint regarding the processing of your personal data or the failure to comply with our obligations arising from the GDPR to the Surveillance Authority. The Supervisory Authority in the Czech Republic is the Office for Personal Data Protection (Úřad pro ochranu osobních údajů) with registered office at Pplk. Sochora 27, 170 00 Praha 7, www.uoou.cz.

8. Measures implemented

Our company has introduced personnel, organizational and technical measures to eliminate the various risks to your rights and freedoms and to protect your personal data. For this purpose, we trained all of our staff who are in contact with personal data. Furthermore, all personal data in physical form is secured against unauthorized access. For personal data in electronic form, we comply with security standards and are also protected against unauthorized access. At the same time, we have developed a risk analysis to prevent any risks and take appropriate action.

9. Personal Data Protection Officer

Our company has no obligation to appoint personal data protection officers regarding the GDPR, nor we have appointed anyone.

10. Contacts

In the event of any requests, requirements, comments or confusion, please contact us via e-mail This email address is being protected from spambots. You need JavaScript enabled to view it. or in writing to our headquarters. Feel free to use these contacts to address us with any matter relating to your personal data and the use of your rights.

11. Conclusion

These principles were adopted on the 16th May 2018. Our company may change these policies if they remain in compliance with the law and the GDPR. We will inform you of any changes to these policies on our website.