This document contains information regarding the protection of personal data provided by visitors to the websites www.flet.cz, www.david-bures.cz, and www.michal-bures.cz, our clients, and those interested in our services.
The purpose of this document is to inform you (data subjects) of your rights and to provide clear information on how your personal data will be handled. We appreciate the trust you place in us when providing your personal data, and therefore we process personal data in accordance with Regulation (EU) 2016/679, i.e. the General Data Protection Regulation ("GDPR").
For the sake of completeness, we assume that all data you provide to us is true and up-to-date and that, in the event of any changes in this regard, you will inform us without undue delay so that we can take corrective action.
Fletstock s.r.o., ID No.: 27448380, with its registered office at Vodičkova 791/41, 110 00 Prague 1, a company registered in the Commercial Register at the Municipal Court in Prague, file no. C116438, contact email: david.bures@flet.cz, contact telephone: +420 603 971 155
and
Fletstock RENT s.r.o., ID No.: 07304145, with its registered office at Vodičkova 791/41, 110 00 Prague 1, a company registered in the Commercial Register at the Municipal Court in Prague, file no. C298578, contact email: radka.buresova@flet.cz, contact telephone number: +420 603 971 155
(jointly referred to as "joint controllers" and individually as "controller")
We process data that you provide to us yourself. In specific cases, this may include providing data by filling out one of the forms on the website, providing data when preparing contracts and related documents and in connection with the implementation of contracts (i.e., in particular in connection with the brokerage of the purchase or sale or lease or sublease of real estate or with real estate management), during personal contact (including data provided during property viewings), by telephone, in writing, by e-mail, or by other means of communication (SMS messages, messages in applications such as Skype, FB Messenger, Whatsapp). If we need your consent to process certain personal data for specific purposes, we will only process such data for that purpose with your consent.
Personal data we process:
First name, last name, title, address, date of birth, age, birth number, ID number, VAT number, telephone number, email address, education, IP address, cookies, information about services ordered, information about the services we have provided to you, your marital status, gender, data about real estate properties whose sale, rental, or management we arrange for you (in connection with other data).
A. Processing of personal data for the purpose of concluding a contract and fulfilling contractual obligations
In order to conclude a contract with you, provide you with the services you have ordered, and communicate with you in relation thereto, we process the following personal data: first name, last name, title, address, date of birth, age, birth number, company ID number, VAT number, telephone number, e-mail, education, IP address, cookies, information about the services you have ordered, information about the services we have provided to you, your marital status, gender, data on real estate whose sale, rental, or management we mediate for you (in connection with other data).
The legal basis (authorization) for processing this data is directly the fulfillment of contractual obligations under the contract concluded between us. Such an obligation may be, for example, the preparation of a purchase agreement for a brokered property, the preparation of a mortgage loan agreement, the preparation of a property management agreement, etc. This does not necessarily have to be a contract concluded in the classic printed form, signed by hand. It may also be, for example, a contract concluded verbally or by telephone.
For this purpose, we process personal data for the duration of the contractual relationship between us. After the termination of the contractual relationship, some data is retained for the purposes of fulfilling legal obligations or for the purposes of legitimate interest, as you will read in the following sections of this document.
We process personal data for the purpose of performing a contract for the duration of the contractual relationship between us.
B. Processing of personal data for the fulfillment of obligations under accounting, tax, and other legal regulations
In order to comply with our obligations under applicable laws, particularly in the area of accounting and tax law, and our obligations under Act No. 253/2008 Coll., on certain measures against the legalization of proceeds from crime and the financing of terrorism (the "AML Act"), we process some of the above-mentioned personal data.
In the case of short-term rentals, we process the following personal data in accordance with applicable laws: name, surname, address, email, date of birth, passport/ID card number, visa number.
The period for which the data is processed is determined directly by the relevant laws that impose the obligation to process it on us.
C. Processing of personal data for the purposes of our legitimate interests or those of a third party
Legitimate interest can cover a wide range of situations. Therefore, we inform you about the legitimate interests for which we process personal data:
Legitimate interest is the protection and demonstration of our rights and legal claims, in particular from concluded contracts or caused damage. For these purposes, we process personal data for a period of 4 years after the termination of contractual cooperation or our last contact, if no contract was concluded. This period is set in view of the limitation periods for claims, taking into account that we may not learn of a possible claim brought before a court immediately at the time it is brought by the other party. For these purposes, data from contracts and our mutual communication are stored.
Direct marketing is also a legitimate interest. We will process the following personal data of our clients for the purpose of sending commercial communications: first name, last name, email, telephone number.
D. Processing of personal data based on your consent
If you give us your consent, we will process your personal data to send you offers of our services. We will need your consent for this processing if you are not our client. Before you give us your consent, we will inform you about what data and for what specific purpose the consent will apply. You can withdraw your consent at any time. However, if we also process some of your personal data on the basis of another legal title (see points A to C above), we will continue to process personal data for these purposes after you withdraw your consent, as consent is not required for such specific purposes.
Consent to the processing of personal data for marketing and business purposes may be revoked at any time. The revocation must be made by an explicit, comprehensible, and definite expression of will, either by email to the controller's email address or in each individual commercial communication sent.
Other persons who specialize in the given processing and act in full compliance with the GDPR assist us in securing some of our contractual activities or legal obligations. These persons are in the position of recipients of your personal data. In particular, these are cooperating accountants, law firms, data storage providers, and software application providers. We have concluded contracts with personal data processors in which the fulfillment of obligations in the area of personal data protection is agreed upon so that your data remains secure. The current list of recipients of personal data can be found here: Arcaisoft s.r.o. – IT company programming the company system, www.abes.cz – legal software for real estate agencies, www.mailchimp.com – email marketing, www.zvladneme.cz – real estate management software, www.idoklad.cz – online invoicing service, www.havelpartners.cz – law firm, www.akancelar.cz – law firm, This One s.r.o. and VÍTKOVICE ACCOUNTING a.s. – accounting firms, www.signi.com – electronic signature broker, Microsoft – Office 365, data storage and software application provider, www.acronis.com – corporate data backup system, Shift2Cloud s.r.o. – cyber security.
It is possible that in the future we will decide to use other applications or processors to facilitate and improve processing. Even in such a case, we will place at least the same demands on security and quality of processing on the processor as we do on ourselves. Personal data will also be made available to the relevant public authorities if we are required to do so by law (i.e., in particular in the case of an inspection where the authority is entitled to request the submission of personal data).
A. Right of access to personal data
This is the right to confirm whether we process your personal data and, if so, to access this data and information about its processing.
B. Right to rectification of personal data
This is the right to have inaccurate personal data concerning you corrected without undue delay. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
C. Right to erasure of personal data (right to be forgotten)
In cases specified by law or the GDPR, you have the right to request that we delete your personal data without undue delay (the GDPR lists the reasons in Article 17, including exceptions where deletion will not be carried out).
D. Right to restriction of processing
In the cases specified in Article 18 of the GDPR, you have the right to request that we restrict the processing of your personal data.
E. Right to data portability
Under the conditions set out in Article 20 of the GDPR, you have the right to obtain your personal data and transfer it to another controller. If technically feasible, you have the right to request direct transfer to another controller.
F. Right to object
In cases where we process personal data for legitimate interests, you have the right to object to such processing, and we will then no longer process the data unless our legitimate interests outweigh your interests or rights and freedoms. If the legitimate interest is direct marketing, then raising an objection will always result in the termination of further processing for direct marketing purposes.
G. Right to withdraw consent
In cases where we process your personal data on the basis of consent, you have the right to withdraw your consent at any time, in which case the relevant processing of personal data will be stopped immediately. However, withdrawal of consent does not affect any processing of your personal data based on other legal grounds, if such legal grounds exist.
H. Right to lodge a complaint with a supervisory authority
If you believe that your rights in the area of personal data protection are being violated, you have the right to file a complaint with the Office for Personal Data Protection. More detailed information about the Office and personal data protection can be found directly on the Office's website at www.uoou.cz.
For more information, including the text of Regulation (EU) 2016/679 (GDPR), please visit the website of the Office for Personal Data Protection at www.uoou.cz.
All personal data processing is carried out within the EU.
The controller does not transfer personal data to third countries or international organizations.
If you have any further questions about the processing of your personal data by us, you can contact us at david.bures@flet.cz.
This version is effective from June 17, 2020.