INFORMATION ON PERSONAL DATA PROCESSING

TLV s.r.o.
ID No.: 26106191
Registered office: Pitterova 2855/7, Žižkov 130 00 Prague 3
Registered in the Commercial Register maintained by the Municipal Court in Prague, Section C, Insert 161155
(hereinafter referred to as the "Seller")
as the controller of personal data hereby informs about the processing of personal data carried out in connection with the operation of the online store available through https://www.findeekids.com (hereinafter referred to as the "E-shop") and the conclusion and performance of purchase contracts or service contracts with customers of the E-shop (hereinafter referred to as the "Buyer") and with the registration of Buyers in the E-shop and further in connection with the operation of the Findee Kids application (hereinafter referred to as the "Application") by the Seller as the operator and used by Buyers and other users (hereinafter referred to as the "User"). This document also includes information on the rights that data subjects are entitled to in connection with the above-mentioned processing.

For any questions regarding privacy protection and exercising your rights, please use this contact:

  • e-mail: support@findeekids.com

1. PURPOSE, LEGAL BASIS, AND PERSONAL DATA PROCESSED

1.1. Purchase of goods or services in the E-shop

In order for the Seller to negotiate and conclude a purchase contract regarding goods or a service contract offered in the E-shop (hereinafter referred to as the "Purchase Contract") with the Buyer - a natural person, the Seller needs the following personal data of the Buyer:

  • identification data of the Buyer: name, surname, in the case of an entrepreneur also ID No., VAT No., registered office address

  • contact details of the Buyer: email, phone number, delivery, and possibly billing address

  • payment details of the Buyer: bank account number and other payment details, depending on the chosen payment method for the ordered goods

  • information from communication with the Buyer, information about the conclusion and performance of the Purchase Contract

Without the aforementioned data, it is not possible to conclude or perform the Purchase Contract. The legal basis for processing this data is the conclusion and performance of the Purchase Contract at the Buyer's request.

The Seller allows Buyers to register and create a user account in the E-shop. If the Buyer registers and creates a user account, a registration and user account management contract is concluded (hereinafter referred to as the "Registration and User Account Contract in the E-shop"). For the purposes of fulfilling this contract, we process the above-mentioned data and, in addition, the access data of the Buyer - a natural person (username and password in encrypted form).

The above-mentioned data is necessary for the Buyer's registration and the establishment and management of their user account, without which it is not possible to conclude or perform the Registration and User Account Contract in the E-shop. The legal basis for processing this data is the conclusion and performance of the contract at the Buyer's request.

1.2. USE OF THE APPLICATION AND PROVIDING PAID ACCESS

The Seller concludes a contract with the User for the use of the Application (hereinafter referred to as the "Application Use Contract").

Users are required to register in the Application. In order for the Seller to negotiate and conclude the Application Use Contract with the User, the Seller needs the following personal data of the User necessary for their registration and the establishment and management of their user account in the Application:

  • User ID: email address and password in encrypted form

  • IP address

  • information from communication with the User and other information about the course of the contractual relationship with the User

Without the aforementioned data, it is not possible to conclude or perform the Application Use Contract. The legal basis for processing this data is the conclusion and performance of the contract at the User's request.

The Application provides Paid Access, which the User can purchase through the Application. In order for the Seller to negotiate the terms of the Paid Access purchase and provide the Paid Access, the Seller needs the personal data of the User mentioned in section 1.2.2 of this document. Without this data, it is not possible to make the Paid Access purchase or provide the Paid Access. The legal basis for processing this data is the purchase of the Paid Access and the obligation to provide the Paid Access at the User's request.

To provide the Paid Access and fulfill the obligations associated with it, the Seller processes the following personal data of the User:

  • contact details of the User: email

  • data on the payment of the Paid Access: payment identifier, payment date

  • photographs and videos

  • phone number

  • information about the device from which the User accesses the Application

  • geolocation data and data from the pedometer

  • voice message recordings and text messages

  • information about completed calls

1.3. FULFILLMENT OF OBLIGATIONS ARISING FROM LEGAL REGULATIONS

The Seller must process personal data in cases where it is required by law. For this purpose, the Seller processes mainly personal data to the extent required by the relevant legal regulations in connection with the Seller's obligation to handle complaints from Buyers or Users, to keep accounts, and to fulfill related tax obligations, or to fulfill obligations imposed by the Archives Act.

1.4. LEGITIMATE INTERESTS OF THE SELLER

In justified cases, the Seller may process personal data also on the basis of the legal title of protecting its legitimate interests. However, the Seller always carefully assesses and ensures that the interest in processing your data for this purpose does not unduly infringe on your privacy.

Identification of persons acting for the Buyer - legal entity: This typically includes members of statutory bodies, employees, or other authorized persons who are not a party to the contract with the Seller but conclude, communicate with the Seller, and otherwise act on behalf of the Buyer. We need the personal data of these persons to be able to communicate and act with the Buyer for the purpose of concluding the Purchase Contract or the Registration and User Account Contract in the E-shop with the...

Proof of consent to the terms and conditions: In the case of concluding a contract with the Buyer or User online (by electronic means), we keep the data necessary to identify the Buyer or User as a contracting party so that we have a time stamp as proof of the conclusion of the contract and consent to our terms and conditions in a specific wording in case of later doubts or disputes.

Defense and assertion of legal claims: We process personal data for the purpose of protecting our legitimate interest, which is to ensure our defense in the event of possible legal disputes, court proceedings, or inspections by state authorities or other public administration bodies (typically the Czech Trade Inspection Authority, etc.). We process the data to be able to prove, if necessary, that we acted in accordance with our contractual obligations and legal regulations. In this context, we typica...

1.5. SENDING COMMERCIAL COMMUNICATIONS

In the case of Buyers with whom we have concluded a Purchase Contract or who have registered in the E-shop and created a user account, and in connection with this, we have obtained their email and/or phone number, or in the case of other persons who have actively and voluntarily subscribed to our newsletters, we process the personal data of these persons to the extent of their email and phone number for the purpose of sending information and news about our services and products (commercial communications).

The legal basis for processing personal data for the purpose of sending commercial communications is, in the case of Buyers with whom we have concluded a Purchase Contract or who have a user account, the legitimate interest of the Seller in informing about the Seller's latest offers.

The legal basis for processing personal data for the purpose of sending commercial communications in the case of persons who have actively subscribed to receive newsletters without us having concluded a contract with them is their consent given by subscribing to receive commercial communications.

If you no longer wish to receive these messages from us, you have the option to unsubscribe from receiving them for free at any time by following the procedure specified in each sent commercial communication, or within the user account, or you can contact us at the contact email provided above in this document at any time.

2. FROM WHOM DO WE RECEIVE PERSONAL DATA AND TO WHOM DO WE PROVIDE IT?

We primarily obtain personal data from data subjects (Buyers or Users). Unless otherwise stated, we do not obtain any other data about you except those you provide to us or that arise from your activity within the E-shop or the Application. Some personal data - especially contact and payment data of data subjects - may be obtained from independent controllers - providers of payment methods available in the E-shop or the Application (Apple Pay, Google Pay). Information on how these providers process your personal data can be found directly with these providers.

We may provide personal data under the conditions set by legal regulations to public administration authorities where required by legal regulations or if the given authority requests it within its competences.

We use the following processors for data processing:

  • providers of accounting services

  • contractors - natural persons providing IT programming services

  • providers of hosting services

Personal data may also be provided to our business partners who act as independent controllers of personal data with regard to your personal data. These include in particular:

  • the operator of the payment gateway through which online payments are enabled in the online store

  • cooperating carriers used for delivering goods

Information on how these partners process your personal data can be found directly with these partners.

Personal data may be transferred to countries outside the EU (specifically to the USA). In such a case, personal data is transferred to the USA in accordance with the decision of the European Commission that the USA is a country that ensures an adequate level of protection within the meaning of Article 45(3) of Regulation (EU) 2016/679 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), under the EU-US Data Privacy Framework and in accordance with the Data Privacy Framework List.

3. HOW DO WE PROCESS PERSONAL DATA?

We primarily process your personal data in electronic form by automated means in our IT systems or the systems of our individual processors. Personal data may also be processed manually in accordance with the relevant purpose where manual processing is necessary or appropriate.

Our employees or other persons working for us may handle your data for the purpose of correcting errors, inaccuracies, etc. However, these persons may process personal data only under the conditions and to the extent specified above and are bound by the obligation to maintain confidentiality about personal data and the security measures whose disclosure would jeopardize the security of personal data.

We always process personal data in accordance with the relevant legal regulations and ensure proper care and protection for them. We make sure that you do not suffer any harm to your rights, especially the right to maintain human dignity and your private and personal life.

4. HOW LONG DO WE PROCESS PERSONAL DATA?

4.1. Purchase of goods or services in the E-shop or use of the Application and providing Paid Access

Personal data processed for the purposes of concluding and performing a contract with the Buyer or User are processed for the duration of the contract (i.e., for the time necessary to fulfill the obligations arising from the contract or for the duration of your registration in the E-shop or the duration of using the Application).

Even after that, we may process personal data for the following purposes:

4.2. Fulfillment of legal obligations

Personal data processed based on our legal obligations are processed within the time limits set by these laws.

Personal data required by legal regulations governing the tax and accounting obligations of the Seller (typically billing data and information on the provided performance) must be processed for accounting and tax purposes. The processing period is 5 (five) years from the end of the accounting period; in the case of documents relevant for VAT payments, it is 10 (ten) years from the end of the tax period in which the performance took place. Relevant personal data are archived in accordance with the requirements of the Archives Act for the periods specified therein. Data processed for the purpose of handling complaints are retained for the duration of the warranty period.

4.3. Legitimate interests

Personal data, even after the termination of the contract with the Buyer or User, are processed to protect our legitimate interests (i.e., defense against potential claims by the Buyer or User or third parties, including court proceedings) for the duration of the relevant limitation periods. If no proceedings are initiated, we retain this data for 5 (five) years from the termination of the contractual relationship with the Buyer or User.

4.4. Sending commercial communications

As stated above, we send commercial communications and process personal data for these purposes until you unsubscribe from receiving them following the procedure specified in section 1.5 of this document.

4.5. Extended processing

Personal data may be processed for longer than stated above if a relevant reason for further processing arises, typically administrative or court proceedings for which personal data are relevant.

5. WHAT ARE YOUR RIGHTS?

First and foremost, you have the right to request access to your personal data, including obtaining a copy of all your personal data. You can do this by using the email provided in the header of this document.

Withdrawal of consent to processing: If we process your personal data based on your consent, you can freely and free of charge withdraw your consent to their processing at any time via your user account, the contact email provided above, or as specified elsewhere in this document. In this case, we will no longer process your personal data based on consent.
For personal data not processed based on consent, it is not possible to withdraw consent to processing. However, based on your request, we will always assess whether it is still necessary to process your personal data for any of the purposes stated above.

Your other rights:

We will always inform you about:

  • the purpose of processing personal data

  • personal data or categories of personal data being processed, including all available information about their source

  • the nature of automated decision-making, including profiling, and information regarding the used procedure as well as the significance and anticipated consequences of such decision-making for the data subject

  • the recipients or categories of recipients to whom personal data have been or will be disclosed, and in the case of the transfer of personal data to a third country, the appropriate safeguards relating to the transfer to ensure the security of personal data

  • the planned period for which personal data will be stored, or if it cannot be determined, the criteria used to determine this period

  • all available information about the source of personal data if not obtained from you

Your other rights include:

  • requesting an explanation

  • requesting the rectification, supplementation, restriction of processing, or deletion of personal data ("right to be forgotten")

  • requesting a copy of the processed personal data or requesting personal data concerning you in a structured, commonly used, and machine-readable format and transferring this data to another controller without any obstacles from us

  • submitting an inquiry or complaint to the Office for Personal Data Protection

  • objecting to the processing of personal data concerning you

6. HOW DO WE PROTECT YOUR PERSONAL DATA?

We protect your data using the following security measures: implementation and enforcement of internal regulations on personal data protection, antivirus protection, firewalls, encryption, access control to personal data and authorization data, backup, physical security measures, and more.

This version of the Information on Personal Data Processing is effective from September 1, 2024.