PERSONAL DATA PROTECTION PRINCIPLES OF THE COMPANY PARK HOLIDAY a.s.

The company PARK HOLIDAY a.s. operates a recreational complex on the principle of club facilities. We therefore consider privacy and personal data protection to be our primary duty during provision of our services. This document provides an overview of the main principles of processing and protection of personal data at the company PARK HOLIDAY a.s

1. Who processes my personal data?

We are the company PARK HOLIDAY a.s., Identification Number: 27426971, with its registered address at Kvetnoveho povstani 194, Prague 10 - Benice, Zip Code 103 00, registered in the Commercial Register maintained by Municipal Court in Prague, file No. C 99398 (hereinafter referred to only as "PARK HOLIDAY a.s."), phone No. +420 267 268 111, e-mail: ochranaou@parkholiday.cz. Within the framework of our activity, we process your personal data and become the controller of the personal data. This also applies, if you provided us with some of your personal data before an agreement was concluded (you are interested in our services, you have sent an order, etc.).

2. Why and on what legal basis do you process personal data?

We process your personal data in particular in framework of the process of concluding and fulfilling agreements. The legal basis therefore is the conclusion and performance of an agreement itself. On this legal basis, we process the personal data for the following purposes (in brackets, if applicable, we eventually specify the scope of processing):

• concluding a club membership agreement (identification and contact details, club services membership preferences, identifying information about persons that will use the services in framework of the club members, such as family members, partners, children, etc.)
• booking of accommodation, catering, sports and leisure and other complementary services (identification and contact details, data on the nature of the requested service, start and end of the service, special requirements and preferences)
• provision of accommodation or other services including guest records (identification and contact details, data on the nature of the provided service)
• confirmation  of the legal representative´s responsibility for use of services by children (name and surname of the child, date of birth, name of the child´s legal representative, service specification)

 Beyond performance of an agreement, we must fulfil our legal obligations. They consist in particular of:

• keeping of a book of records according to the Local Taxation Act (in the extent of name, surname, address of the permanent residence or permanent residence abroad, number of ID card or travel document, duration of stay, the purpose of stay)
• for foreigners, keeping of a house book according to the Act on the Residence of Foreigners (in the extent of the name and surname of the alien, date of birth, nationality, permanent residence abroad, travel document number, or visa number, start and end of accommodation)
• compliance with tax obligations
• fulfilment of obligations according to the Accounting Act
• compliance with the obligation to provide assistance to public authorities in the extent and under the conditions laid down by law
• complaints and requests handling, complaint procedures

We will not avoid processing based on our legitimate interest (you can object to this processing):

• We are a club facility. Therefore, if you are not a member of the PARK HOLIDAY club, we ask you to fill in the so-called guest card (name and surname, year of birth, phone number, e-mail address, permanent address or contact address, date of visit, or name of the member you are a guest of) before entering the premises restricted for club members, e. g. for purposes of single use of our services. Without filling in the guest card, we cannot allow you access to the above mentioned premises.
• In order to protect the property of the company PARK HOLIDAY a.s., as well as the property of our customers, we operate the CCTV system (CCTV records).
• In case of late payment for our services, we are entitled to invite you to make a payment, or we are entitled to recover our claims.
• We then process some data for our statistical purposes.

In the above-mentioned extent, the provision of personal data is mandatory and without it we could not enter into an agreement with you or provide the required services. We do not need your consent to processing this personal data. However, you can object to processing on basis of our legitimate interest (see Section 7.7 for details).

We process other personal data on basis of your consent. Based on this:

• We can send you offers of our services and inform you of the regular and extraordinary events of the company PARK HOLIDAY a.s., also in form of sending of business communications (the name and surname, date of birth, address, telephone number, e-mail address, your preferences and the type of services used so far).

 3. What personal data is processed during provision of services?

Within the framework of our activity, we process the following categories of personal data:

• Identification data: Name, surname, permanent address or permanent residence abroad, date of birth, number of ID or of a travel document, or visa number, nationality, signature; in the case of an entrepreneur, a business name, place of business, ID, VAT ID.
• Contact details: In particular the contact address, contact phone number, contact email address.
• Data on the nature and parameters of the provided services: In particular the time of accommodation (start and end of accommodation), the purpose of stay, data on the required and used services, special requirements and preferences.
• The data that allows us to charge the provided services: In particular, the payee´s billing currency, in which you want to make payments.
• Data that allows us to look after our clients: Our mutual communication (oral, written or electronic) and personal data resulting from this communication, e. g. for the purpose of integrating a member in the PARK HOLIDAY club, handling requests for interruption of membership, etc.
• Data we process on the basis of your consent: On the basis of the provided consent to marketing communication, we process the name and surname, date of birth, address, phone number, email address, preferences and type of the already used service.
• CCTV recordings: In order to ensure the security of our clients and employees and the protection of assets of the company PARK HOLIDAY a.s., as well as of our clients.

4. How long do we store persona data?

In the provision of accommodation services, we are obliged, according to law, to process and store personal data for the purpose of keeping th so-called book of records in the scope of the guest´s name and surname, permanent address or place of permanent residence abroad, ID card or travel document, duration of stay, purpose of stay, all for 6 (six) years of the last entry in this book.

During provision of accommodation services to foreigners, we are required by the Act on Stay of Foreigners to keep personal data kept in so-called house book, including the name and surname of the foreigner, date of birth, nationality, permanent residence abroad, travel document number, or visa number, start and end of accommodation for a period of 6 (six) years as of the last entry into this book.

The invoices issued by PARK HOLIDAY a.s. are stored in compliance with the Value Added Tax Act for 10 (ten) years from their issue. We are required to prove the legal reason for issue of invoices and therefore, for a period of 10 (ten) years from their termination, we also store the relevant supporting documents.

In our customer database, we process our customer´s identification and contact information, data on provided services and data on mutual communication for the duration of the service, and for 10 (ten) years from on the expiration date the last contract between PARK HOLIDAY a.s.  and this client.

The CCTV records are processed for 10 (ten) days from the date they were made. In the event of recording of an incident, the records are kept for the strictly necessary time.

We store the personal data processed on the basis of the provided consent for the period for which consent was granted or until the consent was withdrawn, unless we have a different legal basis for its processing.

5. Whom do we transfer the personal data to?

We carefully select the partners whom we entrust your personal data and who are able to provide such technical and organizational security of your personal data, so no unauthorized or accidental access or other misuse can occur. The company PARK HOLIDAY a.s. passes the personal data to the following categories of recipients:

• persons ensuring operation of some of our provided services
• persons, who provide us with IT support and security services
• persons, who provide us with security and property protection services
• persons, who provide services in the field of bookkeeping and tax advisory
• payment gateway providers (payment card providers)
• marketing support service providers and advertising campaign management
• legal advisers for purposes of enforcement our claims

The processors are companies based both in the Czech Republic and with their seats in a member state of the European Union or in the so-called safe states. The transfer and processing of personal data in countries outside the European Union is always in accordance with applicable legislation.

Furthermore, we are required to transfer some of your personal information to public authorities, and only to the extent and under the conditions set forth by law.

6. What do we do for the security of your personal data?

We have adopted all the technical and organizational measures necessary to ensure adequate protection of the processed personal data, taking into account the nature, scope, context and purposes of the processing, as well as the variously and potentially different risks to the rights and freedoms of individuals.

We apply the system of management and control procedures to prevent unauthorized or accidental access to, modification, destruction or loss of data, unauthorized transmission, unauthorized processing, and other misuse of data.

All persons who come into contact with the personal data of our clients or potential clients in the performance of their work or contract obligations are bound by a statutory or contractual duty of confidentiality.

However, please note that no data transfer over the Internet or storage technologies can guarantee 100% security.

7. What are my rights in relation to processing of my personal data?

In the context of the processing of the personal data, all rights are in accordance with the applicable law (from 25 May 2018, this is in particular, the General Regulation on Personal Data Protection, No. 2016/679, so-called GDPR). You have the following rights:

 the right to any time withdraw the granted consent to processing;

• the right of access to the personal data;
• the right to rectification and completion;
• the right to erasure;   
• the right to restriction of processing;
• the right to object;
• the right not to be the subject of decision-making exclusively based on automated processing;
• the right to portability;
• the right to lodge a complaint.

7.1. Right to withdraw consent

The provided consent may be withdrawn at any time, either by use of the link determined therefor, included in each sent business communication, or by sending of the requirement to the e-mail: ochranaou@parkholiday.cz. The withdrawal of consent is free of charge.

The withdrawal of consent does not change the fact that, until the withdrawal of the consent, the provided personal data are processed lawfully and in accordance with legal regulations. The withdrawal of consent does not affect the processing of personal data, we process on another basis than the consent (i.e., if processing is necessary, for example, for performance of the contract or for fulfilment of a legal obligation, we will still process your personal data).

7.2. Right to access

Upon request, we will inform you, whether we process any personal data relating to your person. If so, we will inform you of the purpose of such processing, categories of the concerned personal data, categories of recipients or planned storage period. If no rights and freedoms of other persons are affected, we will provide you with a copy of the processed personal data relating to you free-of-charge. Nonetheless, we may charge a reasonable fee corresponding to our administrative costs for any further copies.

The right to confirmation of the processing of personal data and other information in framework of the right to access can be exercised at the address ochranaou@parkholiday.cz.

We would like to inform you that in case of exercise of the right to access to the personal data, we may ask you to identify yourself to us for the purposes of verification of your identity. This is a preventive security measure, in order we prevent access of unauthorized persons to your personal data.

7.3. Right to rectification and completion

You may ask for rectification of inaccurate data that relate to your person. You are further entitled to provide us with additional personal data, if they are necessary.

You may send us a request to rectification or completion of the personal data to ochranaou@parkholiday.cz.

7.4. Right to erasure

Our systems are set in order they ensure automatic erasure or anonymization of the personal data, which we do not need for the purpose that it was processed for.

Nonetheless, it you believe that the erasure still did not occur or that we unauthorizedly process any your personal data, you may send us a request to erasure of the personal data. Your personal data need not be erased, e. g. in cases, if we would need them for establishment, execution or defence of our legal claims, or if processing of such a data is imposed by law. There are more such exceptions and you will find them all in Article 17 par. 3 of GDPR.

The right to erase may be executed at ochranaou@parkholiday.cz.

7.5. Right to restriction of processing

Upon your request, we restrict processing of the personal data, if:

• you believe that the data relating to your person, processed by us, are inaccurate. Such processing shall be restricted until verification of accuracy of such personal data;
• processing is illegal, but you refuse erasure of personal data and instead of that, you ask for restriction of their use;
• we shall no longer need the personal data for our purposes, but you will need them for establishment, execution or defence of legal claims;
• you made an objection against processing due to personal reasons (e. g. due to reasons resulting from your specific information), which would be based on our legitimate interest.  Then we are obliged to restrict such personal data processing until verification, whether our legitimate interest overrides your personal reasons (i. e. reasons resulting from your specific situation).

In case of processing restriction, we only may, in respect to such personal data:

• store it,
• further process it with your consent,
• further process it due to establishment, execution or defence of legal claims,
• further process it due to protection of rights of another natural or legal person or due to important public interest of EU or a member state.

The right to restrict the processing of personal data may be executed at ochranaou@parkholiday.cz.

7.6 Right not to Subject to Automatized Decision-Making

You are entitled not to be subject to automated decision-making, exclusively based on automated processing, if such decision would legally affect you or would substantially relate to you.

7.7 What does it mean to have the right to object?

If a particular case concerns personal data processing, which would be necessary for purposes of our legitimated interest (i. e. not processing on the basis of a consent, for contract performance, etc.), you may, for reasons relating to your particular situation, make an objection against such processing. If we do not show that our legitimate interest in specific processing prevails over your interests or rights and freedoms, we will terminate such processing.

You can object to the processing of your personal data for direct marketing purposes. In this case, we will no longer process your personal data for this purpose.

The objection in the hereinabove mentioned sense may be lodged at ochranaou@parkholiday.cz.

7.8. Right to transferability

You have the right to transferability of the personal data. If the processing is based on your consent or is necessary for the performance of a concluded agreement and it is automated, you are entitled, under Article 20 of GDPR to obtain the personal data from us, that you provided us, in a structured, commonly used and machine-readable format. Nonetheless, the request cannot be fulfilled if execution of this right may result in adverse impact to rights and freedoms of third parties.

The right to transferability can be executed at the address ochranaou@parkholiday.cz.

7.9. Right to lodge a complaint

If you believe that your personal data are being processed unlawfully, you can contact the supervisory authority, which is, in the territory of the Czech Republic, the Office for Personal Data Protection (www.uoou.cz).

8. Mailing of business communications

Our business communications are marked by the abbreviation OS (BA), the term "mailing for marketing purpose" (business communications) or other appropriate indication, which states that the communication is a business communications within the meaning of the applicable legislation. The person of the sender is always obvious in our business communications.

Only people over the age of 16 years can grant us the content to mailing of business communications.

9. Where can address a question?

If you have any questions, you can contact us at any time at Kvetnoveho povstani 194, Prague 10 - Benice, CZ 103 00, phone No.: +420 267 268 111, or e-mail: ochranaou@parkholiday.cz.

We would like to inform you that in case of exercise of the right to access personal data or other rights, we may ask you to identify yourself to us for the purposes of verification of your identity. This is a preventive security measure, in order we prevent access of unauthorized persons to your personal data.

In order to keep records of our legal obligations, all communication with you is monitored and archived.

10. Amendment of the Privacy Policy

These privacy policies becomes effective from 1. 1. 2020. We are entitled to change this policy unilaterally. In such case, we are obliged to notify you of the change in advance.

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