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Let us inform you about how Ultra Premium Brands Slovakia s.r.o., registered office: Fialkové údolie 1934/15, Bratislava - Staré Mesto district 811 01, ID number: 54 112 893, company registered in the Commercial Register of the City Court Bratislava I, section: Sro, file no.: 157108/B, Tax identification number: 2121570539, VAT number: SK2121570539 (hereinafter also referred to as "we" or "UPB") processes your personal data in connection with the offering, negotiation, provision of products and services.
The purpose of this document - Information Memorandum is to provide you with information, in particular, about what personal data we collect, how we handle it, from what sources we obtain it, for what purposes we use it, to whom we may provide it, where you can obtain information about your personal data, which we process, and what are your individual rights in the area of personal data protection.
Therefore, please familiarize yourself with the content of this Information Memorandum. We will answer your questions at the address UPB, Fialkové údolie 1934/15, Bratislava - Staré Mesto district 811 01, e-mail address: Office UPB Slovakiaoffice.sk@upb.cz>.
UPB has a number of legal obligations regarding the processing of personal data of customers, which we must comply with, and without the provision of your personal data, we would not be able to provide you with our products and services at all. We also process customers' personal data beyond the scope of legal obligations, for the purpose of customer care, so that we can address you with a targeted offer of products and services. In some cases, we need to obtain your consent for this. If you do not give your consent in these cases, the products or services provided by us may be limited or otherwise modified depending on the scope of the data that we are authorized to process. We inform each customer about the extent of restrictions or modifications.
Unless explicitly stated otherwise, all the information provided here also relates to the processing of personal data of potential customers, i.e. persons with whom we have not yet established a contractual relationship, but with whom we are already in contact, or former customers.
The information provided here is also applied to the appropriate extent to the processing of personal data of other persons, such as authorized persons, authorized persons or representatives of legal entities, regarding which we obtain data, when providing services to our customers, although we do not have a direct contractual relationship with them.
1.1. Principles of personal data processing
When processing your personal data, we honor and respect the highest standards of personal data protection and in particular adhere to the following principles:
(a) We always process your personal data for a clearly and comprehensibly determined legitimate purpose, by determined means, in a determined manner, and only for a period that is necessary in view of the purposes of their processing; we only process accurate personal data of customers and we ensure that their processing corresponds to the stated purposes and is necessary for the fulfillment of these purposes;
(b) We protect and process your personal data in a manner that ensures the highest possible security of this data and that prevents unauthorized or accidental access to personal data, alteration, destruction or loss of personal data, unauthorized transmission, other unauthorized processing or misuse;
(c) we always inform you clearly about the processing of your personal data and about your rights to accurate and complete information about the circumstances of this processing, as well as about your other related rights;
(d) we follow appropriate technical and organizational measures to ensure a level of security corresponding to all possible risks; all persons who come into contact with the personal data of customers are obliged to observe the confidentiality of information obtained in connection with the processing of this data.
2.1. Information about the administrator
The administrator of your personal data is
Ultra Premium Brands Slovakia s.r.o., registered office: Fialkové údolie 1934/15, Bratislava - borough of Staré Mesto 811 01, ID number: 54 112 893, company registered in the Commercial Register of the City Court Bratislava I, section: Sro, file no.: 157108/B, Tax identification number: 2121570539, VAT number: SK2121570539.
2.2. Legal basis for processing and purposes of processing
As an administrator, UPB determines the purpose and means of personal data processing and is responsible for the compliance of personal data processing with relevant applicable legal regulations in the field of personal data protection (in particular Regulation of the EP and Council (EU) 2016/679 on GDPR, hereinafter referred to as the "Regulation"). We can process your personal data only on the basis of some legal title of processing established in the Regulation.
2.2.1. Processing of personal data without your consent
These are generally situations where you are obliged to sell us certain personal data as a condition for us to be able to provide you with our product or service, or when we are authorized to process your personal data obtained in another way.
We are authorized by law to process your personal data without your consent:
(a) primarily for the following purposes, compliance with our legal obligations, in particular
(i) fulfillment of the obligation to act prudently,
(ii) preventing damage to UPB property;
(iii) prevention of fraudulent conduct to which customers or UPB may be exposed;
(iv) fulfillment of notification obligations towards public authorities;
(v) fulfillment of UPB's obligations towards supervisory and supervisory authorities and fulfillment of prudent business rules;
(vi) fulfillment of archiving obligations;
(vii) fulfillment of accounting and tax obligations;
(viii) fulfillment of obligations under the Act on the Protection of Health from the Harmful Effects of Addictive Substances;
(ix) conducting complaint proceedings and fulfilling other obligations of UPB according to the Civil Code resulting from defective performance or the right to return goods;
(x) fulfillment of obligations in the identification and control of the customer according to the law on certain measures against the legalization of income from criminal activity and the financing of terrorism;
(b) for the purpose of concluding or fulfilling a contract with you. Personal data is necessary, among other things, to be able to conclude the relevant contract with you and to fulfill the obligations arising from it (including delivery of goods) without unreasonable legal risks, including termination of the contract with you;
(c) for a certain reason of legitimate interest of UPB, especially for
(i) protection of the rights and legally protected interests of UPB, authorized beneficiaries or other relevant persons, for example when documenting the facts that UPB needs to prove to third parties, the collection of claims or other application of claims,
(ii) the development and evolution of the products and services provided;
(iii) resolution of all contentious agenda, especially for the purposes of conducting court or other disputes.
(iv) offering related products and services to customers without obtaining their consent (for direct marketing purposes),
(v) protection of the safety of property and persons located in the premises monitored by the camera system.
2.2.2. Processing of personal data with your consent
As a rule, these are situations where you voluntarily agree to us processing the personal data provided by you or otherwise obtained. If you do not give consent, it may be the reason that UPB will not be able to provide some products or services, or will be forced to modify the availability, scope or conditions of the provided products and services in a justified way.
Based on your consent, UPB processes your personal data for the following purposes:
(a) customer care; these are activities that do not constitute the fulfillment of a contract or other legal framework for the processing of personal data and which include e.g. market research;
(b) sending newsletters and other commercial communications, if sent;
(c) sending small gifts - gifts as part of marketing campaigns.
2.3. Scope of processed personal data of customers
UPB processes your personal data to the extent necessary to fulfill the above purposes. We mainly process contact and identification data, descriptive and other data and, to the necessary and authorized extent, also data about other persons. More detailed information on the scope of processed personal data of customers is provided in Annex no. 1 of this Information Memorandum.
Some specific categories of personal data and their processing methods:
Communication record
UPB may monitor and record selected communications with customers, especially written communications and possibly also telephone calls. In the case of creating records of telephone calls, we will always notify you in advance. The content of this communication is confidential and we use it exclusively for the purposes of complying with legal obligations, concluding and fulfilling a contract, protecting rights and legally protected interests, or with your consent for customer care purposes.
Camera records
UPB can monitor and record records of your movement, behavior and communication in areas monitored by a camera system (especially in UPB offices). In the case of making camera recordings, we will always notify you in advance before entering the monitored premises. The images taken are confidential and we use them exclusively for the purpose of protecting rights and legally protected interests.
2.4. Method of personal data processing
The way in which UPB processes your personal data includes both manual and automated processing, in the systems of UPB and its processors. One of the ways of processing UPB's personal data can also be the automated evaluation (profiling) of personal data about customers; in doing so, derivative data about the customer is also created. This is done mainly for customer care and marketing purposes.
Your personal data is primarily processed by UPB employees and, to the extent necessary, by third parties - processors. Before any transfer of your personal data to a third party, we will always conclude a written contract with this person, which contains the same guarantees for the processing of personal data that UPB itself observes in accordance with its legal obligations.
2.5. Recipients of personal data
Your personal data of customers is made available to UPB in connection with the fulfillment of their work duties, during which it is necessary to deal with personal data of customers, but only to the extent that is necessary in each case and in compliance with all security measures.
In addition, your personal data is transferred to third parties who participate in the processing of personal data of UPB customers. Before any transfer of your personal data to a third party, we will always conclude a written contract with this person in which we will adjust the processing of personal data so that it contains the same guarantees for the processing of personal data that UPB itself observes in accordance with its legal obligations. Recipients of personal data may be entities defined in Annex no. 2 of this Information Memorandum.
2.5.1. In accordance with the relevant legal regulations, UPB is authorized or obliged to transfer your personal data:
(a) to competent state administration bodies, courts and law enforcement authorities for the purpose of fulfilling their duties and for the purpose of executing the decision;
(b) to other persons to the extent stipulated by legal regulations, for example to third parties for the purpose of collecting UPB's claims against customers.
2.5.2. With your consent and to the extent according to 2.2.2, we transfer your personal data to:
(a) to other persons for the purpose of disseminating information, offering products and services of UPB or other persons to customers (except in cases of direct marketing, for which UPB does not need the consent of customers). In the case of granting your consent, we will carry out such transmission in full accordance with the other conditions stated in this Information Memorandum, especially in connection with the purpose, scope and period of processing of personal data. We will only transfer your identification and contact data to the extent necessary for the given recipient. Customers whose personal data will be transferred may be selected based on criteria agreed with the recipient (especially socio-demographic, economic or based on the scope and frequency of services provided by UPB). During such transfer, we will take special care to ensure that the security of the transferred personal data is not compromised or misused.
2.6. Transfer of personal data abroad
2.6.1 Sending personal data within the EU and EEA
Your personal data is processed on the territory of the Slovak Republic and on the territory of other states of the European Union ("EU") and the European Economic Area ("EEA") or in countries in which there is a Commission decision on the corresponding protection of personal data, where they are based or are located entities processing your personal data and which share the same personal data protection standards as the Slovak Republic. UPB, nor entities involved in the processing of personal data of customers, do not transfer personal data of suppliers to countries outside the EU and EEA or to countries where there is no Commission decision on the corresponding protection of personal data.
In the event that UPB decides to send personal data other than those mentioned in the previous paragraph, it will notify you of additional information pursuant to no. 13 par. 1. letter f) Regulation.
2.7. Time of personal data processing
Personal data of customers is processed by UPB only for the period that is necessary in view of the purposes of their processing. We continuously assess whether there is still a need to process certain personal data necessary for a certain purpose. If we find that they are no longer needed for any of the purposes for which they were processed, we will dispose of the data. In this context, it applies that personal data processed by UPB:
(a) for the purpose of fulfilling the contract, they are processed for the duration of the contractual relationship with the customer;
(b) due to the fulfillment of a legal obligation, they are processed for the period specified by the relevant legal regulation
(c) for the purposes of the legitimate interests of UPB or third parties, they are processed for the duration of the legitimate interest, unless there is some fact that results in an earlier termination of processing (e.g. objection to processing for the purposes of direct marketing), as a rule, personal data are processed after the duration of the respective limitation periods;
(d) based on your consent, they are processed for the period for which the consent was granted, or until the time when it was revoked by you; unless otherwise specified, consent is granted by default for a maximum period of 3 years, after which UPB asks the subjects of personal data to grant consent again.
2.8. Right to withdraw consent
In this Information Memorandum, we have tried to explain why we need your personal data and that we may process them for some purposes only with your consent. You are not obliged to give UPB consent to the processing of your personal data, and you are also entitled to revoke this consent at any time. We remind you that we are entitled to process some personal data for certain purposes even without your consent. If you withdraw your consent in such a case, we will stop processing the relevant personal data for purposes requiring the relevant consent, but we may be authorized or obliged to continue processing the same personal data for other purposes.
If you do not give or withdraw your consent, we may:
(a) modify the availability, scope or terms of some of its products or services accordingly, or
(b) refuse to provide you with our products or services if we determine that such consent is necessary to provide the product or service under the given conditions.
If you wish to withdraw your consent to the processing of personal data, please contact UPB, either in person at the address Fialkové údolie 1934/15, Bratislava - Staré Mesto district 811 01, or in writing at the same address, or e - by email to the address: Office UPB Slovakiaoffice.sk@upb.cz>.
2.9. Sources of personal data
We mainly collect personal data of customers:
(a) from the customers themselves, e.g. when concluding contracts related to UPB products or services or during the actual use of products or services by customers, etc.;
(b) from publicly available sources (public registers, records or lists);
(c) from third parties authorized to handle the customer's personal data and transfer them to UPB upon fulfillment of the specified conditions,
(d) from those interested in UPB products and services as part of marketing actions and campaigns;
(e) from own activity, namely by processing and evaluating other personal data of customers.
2.10. The right to request access to personal data
2.10.1 If you ask us for information regarding the processing of your personal data, we will provide you without undue delay with all information and confirmation about what data we process about you and allow you access to this personal data and information about the purposes for which your personal data is used processed, categories of processed personal data, about the recipients or categories of recipients to whom they were made available and the planned processing time, or if it cannot be determined, the criteria used to determine this time;
2.10.2 If other prerequisites are met, you have the right to request from UPB the correction or deletion of your personal data or restriction of their processing. You have the right to object to the processing of your personal data and the right to file a complaint with the Office for Personal Data Protection regarding the processing of personal data.
2.10.3 You further have the right for us to provide you with information about the source of personal data, unless we have obtained it from you and the right to inform you of cases of decision-making based solely on the automated processing of your personal data, including the procedure used and the meaning and expected consequences for you.
2.10.4 At your request, we will provide you with one copy of your processed personal data. For additional copies, we are entitled to charge you a reasonable fee in the amount of administrative costs.
2.11. The right to correct and supplement personal data
2.11.1 You have the right to have your inaccurate or incomplete personal data corrected or supplemented without undue delay.
2.12. Right to erasure
2.12.1 If this is not prevented by obligations arising for UPB from legal regulations or the need to keep personal data for the purposes of legal protection of UPB, you have the right to have UPB delete personal data concerning you without undue delay, provided that:
(a) personal data is no longer needed by UPB for the purposes for which they were collected or otherwise processed;
(b) you revoke the consent on the basis of which UPB processes and there is no other legal reason for their processing;
(c) you object to the processing of personal data and there are no overriding legitimate reasons for the processing on the part of UPB or the processing is in the form of direct marketing;
(d) UPB processes personal data illegally;
(e) personal data must be deleted to comply with a legal obligation by law that applies to UPB.
2.13. Right to restriction of processing
2.13.1 You have the right for UPB to limit the processing of your personal data if:
(a) you object to the inaccuracy of the personal data, for the time necessary for us to verify the accuracy of the personal data;
(b) the processing is unlawful, but you will refuse the erasure of the personal data and request the restriction of their use instead;
(c) UPB no longer needs the personal data for processing purposes, but you will require them to determine, exercise or defend legal claims;
(d) you object to the processing (for a purpose other than direct marketing), unless it has been verified whether UPB's legitimate reasons prevail over your legitimate reasons.
2.13.2 If the processing of personal data is limited, UPB will, with the exception of their storage, process them only with your consent, or for the purpose of determining, enforcing or defending legal claims.
2.13.3 If UPB restricts the processing of personal data at your request, you will be notified in advance if the processing restriction is lifted.
2.14. The right to data portability
2.14.1 If UPB will process your personal data automatically on the basis of your consent or concluded contract, you will have the right to receive personal data concerning you and which you have provided to UPB in a structured, commonly used and machine-readable format.
2.14.2. If it is technically feasible and if there are no other reasons preventing it, UPB will transfer the personal data directly to another administrator designated by you at your request.
2.15. The right to object to processing
2.15.1 We expressly warn you that in the event that UPB processes personal data for the purposes of direct marketing or for another reason of its legitimate interest, you have the right to object to the processing of personal data concerning you at any time. In such case, UPB will not further process your personal data until we have demonstrated the existence of serious legitimate reasons for processing that would prevail over your interests or rights and freedoms, with the exception of processing for the determination, exercise or defense of legal claims.
2.15.1 If you object to processing for direct marketing purposes (including profiling), we will no longer process your personal data for these purposes.
2.16. The right to file a complaint with the Office for Personal Data Protection
You have the right to file a complaint with the Office for Personal Data Protection regarding the processing of your personal data.
In certain cases, UPB also handles personal data of customers on behalf of another person (another administrator). This is, for example, cooperation with third parties in the mediation of products or services of third parties or cooperation with third parties on loyalty programs. For more detailed information, it is always necessary to contact the specific administrator of personal data, if UPB is not authorized to provide information in a specific case.
As part of customer care, UPB develops technologies so that you can use modern electronic means of communication to use our products and services. These are mainly services connected with the use of the Internet and the use of social networks. At the same time, we are aware of the special nature of providing our products and services, which is why we take care to protect customers' personal data when using these tools and applications.
Social networks
You can also reach us through various social networks. We use these communication channels mainly as marketing tools, currently our products and services are not provided through them.
Cookies
When providing our products and services, we also use cookies, which are small text files that are saved on the user's computer when the website is first loaded. Thanks to these files, we can more easily identify the way visitors work with the content of our websites. This helps us to communicate more favorably with our website visitors, or to target our marketing more effectively.
This Information Memorandum is valid and effective as of January 1. 2022. The current text of the Information Memorandum is published on the UPB website and is also available at the UPB headquarters.
Annex no. 1 – Scope of processed personal data
2. Contact data - contact addresses, telephone numbers, e-mail, fax addresses or other similar contact data.
Annex no. 2 – Recipients of personal data
According to the article of the Information Memorandum marked as Recipients of personal data (point 2.5), the recipients of identification, contact and other personal data of customers listed in Annex 1 may be entities that fall into one of the following categories of suppliers of goods and services for UPB:
suppliers of goods
suppliers of transport, transport and postal services
suppliers of IT services
suppliers of marketing services
suppliers of accounting services
legal service providers
members of the network of UPB sales representatives
business consultants UPB
