Privacy policy

I. Introductory Provisions

These Privacy Policy Principles (hereinafter referred to as the "Policy") are issued by HULMAN-kovošrot s.r.o., Company ID: 25568311, with its registered office at Vídeňská 999, 691 23 Pohořelice, registered with the Regional Court in Brno, File No. C 33689/KSBR.

HULMAN-kovošrot s.r.o. is the controller of personal data (hereinafter also referred to as the "Controller"), as it determines the purposes and means of processing personal data.

Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as the "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier.

The Controller issues this Policy for the purpose of personal data protection in accordance with the legislation of the Czech Republic and the legislation of the European Community, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation - GDPR), which serves as an internal instruction for the employer and a notice to data subjects about their rights.

II. Purposes of Personal Data Processing

2.1 The Controller processes personal data:

1. For the purpose of fulfilling contracts

   This includes, in particular, employment contracts, contracts with the Controller's suppliers for the delivery of services and goods, and contracts with customers. The Controller processes personal data in a database for the purpose of executing concluded contracts and communicating with contractual partners, and stores these contracts in electronic and written form.

2. To fulfill legal obligations of the Controller

   This includes, in particular, the fulfillment of obligations set by legal regulations in the course of the Controller’s business activities, where laws require the Controller to provide personal data to state authorities or third parties, or such provision is based on a contractual agreement between the Controller and the data subject.

3. To protect the legitimate interests of the Controller

   In certain cases, the Controller handles personal data if it is necessary to protect its legitimate interests, for example, in administrative or court proceedings, or where such handling is essential for other reasons related to the Controller’s business activities, such as collecting data on job applicants, potential customers, or suppliers.

2.2 The Controller processes personal data of individuals, employees, suppliers (including third-party service providers), contractors, affiliated companies, representatives, and corporate clients. The data may include the person’s name, academic or other titles, date of birth, personal ID number, photograph, contact details (email, phone, address), and other information necessary for fulfilling contracts, employment, or business with the data subject or a legal entity they represent.

2.3 The Controller may transfer personal data to companies within the same group for the purposes of evaluating financial results, planning further business activities, optimizing contractual relationships, performing work for another employer within the group, or to subcontractors who evaluate business performance, create marketing campaigns, and business strategies. Where possible, data will be anonymized to the greatest extent.

2.4 Personal data is not processed under Article 6(1)(f) of the Regulation.

2.5 The Controller is not required to appoint a Data Protection Officer.

2.6 The Controller does not intend to transfer personal data to third countries.

III. Means of Processing Personal Data

3.1 The Controller processes personal data using electronic databases and lists, stored in software accessible via computers and smart devices, including both manual and automated processing (including algorithmic processing) in information systems. The software is installed either on the Controller’s server (located at the company headquarters) or on individual devices (desktops, notebooks, smart devices). The Controller also uses printed databases and records with personal data.

3.2 Printed documents containing personal data are stored in the Controller’s office and archive located at its headquarters. These documents are kept in locked rooms with access restricted to employees. The implemented protective measures have not resulted in any data breaches or misuse during the company's operation, thus the level of security is considered adequate.

IV. Principles of Personal Data Security

4.1 All employees and persons working for the Controller must comply with these Policy Principles and applicable legal regulations on personal data protection, especially:

1. Refrain from unauthorized handling of personal data

   Anyone who accesses personal data must use it solely for the purpose for which it was provided, and must not copy or back up such data for personal use or third parties. They must process the data only to the extent necessary for the intended purpose and respect the rights of the data subject.

2. Ensure protection of personal data against misuse or theft

   All access to electronic personal data must be password protected. Passwords must not be shared, and data must not be disclosed to third parties. The server room where personal data is processed electronically is located at the Controller’s headquarters in a locked room called “Server Room.” Only the server administrator has access. Personal data must not be copied outside the server. Printed data must be stored in a locked cabinet or in a way that prevents unauthorized access.

4.2 Any suspected or confirmed breach or threat to personal data must be reported immediately to the company director or via email to hulman@hulman-kovosrot.cz

4.3 Any person who comes into contact with personal data must become familiar with this Policy and sign a record of being informed as an authorized person.

V. Data Subject Rights

5.1 The data subject has the right to information regarding the processing of their personal data.

5.2 The right to rectification of inaccurate personal data concerning them.

5.3 The right to erasure (“right to be forgotten”) if the data is no longer necessary for the purposes for which it was collected, or if the data subject withdraws their consent and no other legal basis for processing exists, or if the data has been unlawfully processed.

5.4 The right to restrict processing.

5.5 The right to data portability.

5.6 The right to object to processing under Article 6(1)(e) or (f) of the Regulation, including profiling based on these grounds.

5.7 The right not to be subject to automated decision-making, including profiling.

5.8 The right to withdraw consent at any time. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

5.9 The right to lodge a complaint with a supervisory authority. Complaints can be sent to the Office for Personal Data Protection, Pplk. Sochora 27, 170 00 Prague 7, Czech Republic, or via email: posta@uoou.cz

5.10 The data subject is not obliged to provide personal data. If data is not provided, the relevant contract may not be concluded or executed by the Controller.

VI. Use of Cookies

6.1 The Controller collects information using various technologies, such as cookies. These are used when visiting the Controller’s website or apps, or when using third-party platforms. Cookies are small files that store information on a user’s computer, mobile phone, or other device. They help the Controller or third parties understand which parts of the website are most popular and how users interact with the website.

VII. Personal Data Retention Period

Personal data will be retained for a period of 5 years from the end of the authorization or obligation to process it.

VIII. Contact Information of the Controller

If you have any comments or questions regarding this Privacy Policy, please contact the Controller. The Controller’s website and applications may contain links to websites it does not own or control, and it is not responsible for their privacy practices.

• HULMAN-kovošrot s.r.o.
• Company ID: 25568311
• Vídeňská 999, 691 23 Pohořelice, Czech Republic
• Registered with the Regional Court in Brno, File No. C 33689/KSBR
• Phone: +420 777 108 010
• Email: hulman@hulman-kovosrot.cz