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Information for Data Subjects about Personal Data Processing in Relation to Visiting the GasNet Website

Pursuant to Act No. 110/2019Coll., about Personal Data Processing, amended and Regulation (EU) 2016/679 of the European Parliament and of the Council, dated 27 April 2016 on the protection of natural persons in regard to the processing of personal data and on the free movement of such data, and repealing Directive No. 95/46/EC (General Data Protection Regulation). 

In this document, we would like to inform you about the principles and procedures related to processing your personal data and about your rights pursuant to the provisions in Act No. 110/2019Coll., about Personal Data Processing, amended (hereinafter referred to as the “Law”), Regulation (EU) 2016/679 of the European Parliament and of the Council, dated 27 April 2016 2016/679 on the protection of natural persons in regard to the processing of personal data and on the free movement of such data, and repealing Directive No. 95/46/EC (General Data Protection Regulation), Act No. 127/2005Coll., about Electronic Communication, amended and Act No. 480/2004Coll., about some services in an information society, amended.

Hereby this document, the Controller in the sense of the EU GDPR, the owner and operator of the GasNet Group website, GasNet, Ltd., address: Klíšská 940/96, Klíše, 400 01 Ústí nad Labem, ID: 27295567, registered in the Commercial Register maintained by the Regional Court in Ústí nad Labem, Section C, File 23083, (hereinafter referred to as “GasNet“), meets its obligations pursuant to the provisions in Articles 13 and 14 of the EU GDPR, by providing information about processing the personal data of the Data Subjects in a transparent manner.

The information regarding personal data processing amends the personal data processing of the visitors to our website. For complete information about personal data processing by the GasNet Group, as required by generally binding legal regulations, including the range and purpose of processing, an overview of the rights and responsibilities of GasNet and the Data Subjects and an updated list of Processors, go to the GasNet website (www.gasnet.cz/informace-o-zpracovani-osobnich-udaju-gn) or to the GasNet Služby website (www.gasnet.cz/informace-o-zpracovani-osobnich-udaju-gns). Upon a written request, GasNet shall provide the Data Subjects with this information at any time during legal proceedings. This information is available at GasNet’s Registered Office.

The rights and responsibilities of GasNet and the Data Subjects when using this website is also governed by the rules for using websites, as published on www.gasnet.cz (hereinafter referred to as the “Rules”). The rules apply to all persons (Data Subjects), who visit this website (hereinafter referred to as the “Users”). The User consents with the Rules by visiting any GasNet website or by using any information on the GasNet’s website in any way.

Links to other websites that are available on the websites operated by GasNet but are not part of the GasNet Group website, are not under the management or control of GasNet. If the User visits any one of these websites, the visitor should be informed about the website’s personal data protection policy. The Operator bears no responsibility for the policies and procedures of other subjects.

This information is of an informative and legally normative nature. This information is not part of any legal act, unless expressly stated otherwise in individual cases.

1. INSTRUCTIONS ON USING COOKIES AND OTHER SIMILAR TECHNOLOGIES

When visiting a website operated by GasNet, information may be saved on the Data Subject’s device in the form of “cookies”. Cookies are small data or text files that we save onto your internet browser or onto your device’s data warehouse and we primarily use it to ensure that your web runs properly, to personalize content, to track traffic and to provide social media functions.

Some cookies allow us to link your activities while browsing our website from the moment you open the window until you close it. Once you close the internet browser window, these cookies are deleted. Other cookies remain on the end device for a set period of time and are activated every time you open a website that has created that specific cookie, if you use the same device and the same internet browser to visit that website. Cookies for example, allow the website to adapt to the interests of the Data Subject or to save the Data Subject’s user name, which then no longer has to be re-entered.

We also use so-called measuring pixels (sometimes called web beacons), which are small graphic images that work similarly to cookies. Unlike cookies, which are saved on your computer’s hard disk, pixel tags are an integral part of websites.

For the sake of simplicity, this document will refer to these and other similar technologies as “cookies”. We not only save cookies on your device but we also read the cookies that our web has saved onto your device. Furthermore, for the sake of simplicity, this document will only refer to “processing”. Cookies are commonly used by almost every website in the world. However, none of the cookies used on our website collect information that would contain your direct identification data.

If the Data Subject does not want his / her computer to be recognized, it is necessary to set the internet browser settings so that the cookies are deleted from your computer’s hard disk, to block the cookies or set notifications before the cookies are saved (see Article 6).

2. WHAT PERSONAL DATA DO WE PROCESS VIA COOKIES?

In relation to the relevant legal entitlements and processing purposes, GasNet and its contractual partners process the following personal data or categories of personal data, by means of cookies:

  • Other electronic data: the device’s IP/MAC address and other IT identifiers, browser and the device’s operation system, including its version and language setting, approximate geographical location and other metadata from the cookies related to the behaviour of the Data Subjects (users) on the website.
  • Additional / derived data: personal information that are generated (and further processed) as a result of the address analyses.

3. WHAT DO WE USE THE COOKIES FOR?

If you go to our website, we process the personal data stated in Article 2 for the below stated purposes, based on the following legal entitlements:

3.1 GASNET’S LEGITIMATE INTERESTS

The legal entitlement to processing personal data, where GasNet’s legitimate interests / rights prevail over the Data Subject’s legitimate interests / rights, taking into account the reasonable expectations of the Data Subjects based on the relationship with GasNet. These include cases that do not require consent to process personal data.

This especially includes the following purposes:

  • To manage the life cycle of consents granted in the sense of this document;
  • To ensure security and functionality of the website, to solve related technical issues or security incidents;
  • To ensure that the contact form on the website is properly linked with the GasNet customer contact centre information system;
  • To keep the website running intact with the user’s requests;
  • Technical support for the optimal way of playing videos, by means of estimating the range of the user’s bandwidth frequency.

Cookies and other files that provide the above-stated specified purposes are necessary so that our website runs properly. If you block these cookies on your browser, our website may not run properly and we may not be able to provide you with our products or services.

3.2 THE DATA SUBJECTS‘ CONSENT WITH PROCESSING PERSONAL DATA

The legal entitlement to processing personal data, where it is not possible to use other legal entitlements in the sense of Article 6 of the EU GDPR.

This especially includes the following purposes:

  • To save information about the preferred language setting, if the web currently offers more options;
  • To improve the customer’s experience, where we obtain information on the basis of which we will be able to improve the website in the future. Our intention is to improve our services to make sure they run smoothly;
  • To create statistics and reports, particularly to monitor traffic on our website, its individual pages and to measure the effectiveness of the displayed content. Our interest here is to measure the effectiveness of our website and the costs of managing and editing its content. For this purpose, we can obtain further derived data from your behaviour on the website and use this data for this purpose;
  • To identify the user when navigating among the individual web pages and when revisiting the pages, so that we can remember the user login from the specific device. Therefore, we don’t have to ask for the e-mail address and password again. Moreover, we can save the version that the user sees, if the website currently offers more options;
  • As part of the segmentation, we can also collect general information about the approximate geographical location of your device or its type. This is only an approximate geographical position based on the information obtained from the IP address and the general device category (mobile, tablet, desktop, TV, including the operation system and type of browser). This data is collected in order to provide personalized content based on your approximate geographical location and to optimize the structure, graphics and website content based on the type of device;
  • For analytical and statistical purposes: every time you visit our website, the analytical software saves cookies in the context of the above-mentioned. We also use the Google Analytics tool for these purposes. For more information about this tool, see here;
  • To recommend relevant content of our website: to improve our services and to improve the understanding of how our visitors use our services. We also use the Hotjar analytics tool, which monitors the services used in the scope of a so-called heatmap or to analyse the users’ behaviour. However, this tool is not used across the board (with the exception of questionnaires). It is only used to the limited extent necessary and for a limited number of visitors per month. The Hotjar tool may also be used to interact with users by means of questionnaires. For more information about privacy protection within the scope of this tool, see here. For more information about the cookies within the scope of this service, see here;
  • For advertising and information purposes: Advertising systems include selected third-party platforms (social media and platforms for saving and playing video content). They are used to find out how many people viewed the accompanying ad or they link the user with his already existing profile on the given platform. Cookies of these subjects may also be saved on your computer by means of our website. However, these operators are directly responsible for such processing. Ad systems usually have their own privacy policies. Our servers can neither read nor write these cookies.
  • Retargeting: Some of the above-stated systems also use retargeting techniques, where you may see content related to what you were viewing on the other websites, on the websites of third parties. Therefore, please ask the system operators about which relevant cookies they use. Our company does not operate these systems, but it may use targeted advertising as a customer within the scope of Facebook systems (so-called Facebook Pixel), Google (AdWords) or Seznam (Sklik).

4. AN OVERVIEW OF THE COOKIES AND THE RELATED INFORMATION USED

The individual types of cookies and their processing period is described in the tables below. The necessary cookies are processed on the basis of legitimate interests (see 3.1). Other types of cookies are processed on the basis of your consent (see 3.2.).

GasNet reserves the right to change its privacy policy at any time. The updated version will always be available on the website.

5. RECIPIENTS AND PROCESSORS OF PERSONAL DATA

GasNet processes all of the mentioned personal data as the Controller in the sense of the EU GDPR, which means that GasNet defines the purpose for which it collects your personal data, it determines the means of processing and it is liable for its proper implementation.

GasNet cooperates with authorized external partners to ensure selected activities are carried out. GasNet transfers selected personal data to these companies, which are personal data processors in the sense of the EU GDPR, solely for the purpose of dealing with the given agenda.

Processors may process personal data for GasNet exclusively based on a contract about personal data processing or a similar legal agreement, guaranteeing organizational-technical data security, while defining the purpose of processing, where the processor can neither use the data for other purposes nor transfer the data to other subjects. The above-mentioned purposes primarily deal with the following categories of processors:

PROCESSOR CATEGORIES AGENDA

Marketing, PR, media and communication

Ensure communication with the public, preparation and realization of company ads, promotional and communication material, campaigns and events.

Professional associations and consulting services

Advisory and consultation services in the area of recruitment and personnel consulting, including professional associations in the area of the company’s business, information and digital technologies, as well as in professional areas related to GasNet’s business activities.

IT service provider and software supplier

Development and maintenance of relevant GasNet HR systems, websites, etc.

Companies from the GasNet Group

Providing selected services and providing service to existing customers by companies from the GasNet Group.

For a complete list of processors and recipients (typically, state authorities) of personal data in the sense of the EU GDPR, go to the GasNet website (www.gasnet.cz/informace-o-zpracovani-osobnich-udaju-gn).

In some cases, GasNet can also transfer your personal data to other subjects, who are in the role of independent personal data controllers. These include the following subjects:

  • IT service provider and software supplier: Google Inc; for the purpose of personalizing ads, offering their own similar products and services or offering other kinds of products and their partners’ products.

In exceptional cases, personal data is transferred to Data Subjects for processing into third countries or to international organizations (outside of the EU or outside of the so-called group of countries with adequate personal data protection and free transfer regime, as specified by the decision of the European Committee, as published in the EU Journal), particularly to the United Kingdom of Great Britain, Northern Ireland and the United States of America. However, GasNet guarantees that such transfer of the Data Subjects’ personal data may only take place on the basis of sufficient legal grounds, as defined in Articles 44 – 49 of the EU GDPR.

Pursuant to the paragraphs above, if any of the legal grounds used should be amended, revoked or declared invalid by a competent court in the future, GasNet will immediately and in good faith seek an alternative way to ensure legal grounds to process personal data.

6. MANAGING COOKIES AND THE RIGHTS OF DATA SUBJECTS

You can view and change the cookie settings or your consent with the cookies at any time by means of the “COOKIE SETTINGS”, which are available in the footer of our website.

Refusing to grant consent to processing cookies does not affect using the necessary cookies that are essential for the website to run properly. If you block these cookies on your browser, our website may not run properly and we may not be able to provide you with our products and services. Revoking your consent to processing cookies does not affect any previous processing done on the basis of the user’s consent granted prior to revoking it.

The standard web browsers (Chrome, Internet Explorer, Edge, Mozilla Firefox, Safari, etc.) also support cookies. You can manually delete, block or completely disable the use of individual cookies in the browser settings. You can also block or allow cookies for individual websites. For more detailed information, go to the “help” section of your browser.

You can find setting options for managing cookies on the following commonly used browsers:

Unfortunately, deleting cookies are never fully guaranteed, especially for the following reasons:

  • Deleting expired cookies is a function of the web browser (product of a third party, functionality is not guaranteed);
  • Browsers have a function to save and renew the session status of open tabs and windows, where they save the web and the related cookies;
  • If the computer is backed up, the back-up may include files (memory / cache browser, local storage browser, etc.), which also contain these cookies.
  • If the processing of personal data is based on your consent, the right to withdraw your consent with future processing.
  • The right to ask us, the Controller, to access your personal data and detailed information about its processing.
  • The right to ask us to correct inaccurate or incomplete personal data.
  • The right to ask us to provide your personal data in a commonly used and machine legible format, allow the data to be transferred to another controller, if the data was obtained on the basis of your consent or in relation to concluding and fulfilling a contract and if the data is processed automatically.
  • The right to object to the processing of some or all of your personal data.
  • The right to ask us to delete your personal data, if there is no other legal reason for its further processing.
  • The right to file a complaint at the Office for Personal Data Protection.

For detailed information about your rights, including ways of exercising your rights in the case of personal data protection, go to the GasNet website (www.gasnet.cz/informace-o-zpracovani-osobnich-udaju-gn) or to the GasNet Služby website (www.gasnet.cz/informace-o-zpracovani-osobnich-udaju-gns).

7. DATA PROTECTION OFFICER

You can contact our Data Protection Officer directly at: dpo@gasnet.cz to deal with all matters related to processing your personal data, inquiries, exercising a right, filing a complaint or anything else.

8. EFFECT

This document comes into effect on the day it is published, so 20 December 2021. The text was last updated on 20 December 2021.