1. General Provisions

1.1 Introduction

We place great emphasis on protecting the personal data of our website visitors, our potential and existing customers, and other individuals who provide us with their personal data. This Privacy Policy (the "Privacy Policy") provides you with the necessary information on how we, TKC Real Estate a.s., Company ID 27416445, with its registered office at Vlastislavova 152, Nusle, 140 00 Prague 4, Czech Republic, collect, store, and further process your personal data as a data controller in connection with the operation of our website www.tkcgroup.cz and other websites managed by our company, including sites for individual real estate projects (the "Site"), the offering of our properties and other services, or in any other way.

1.2 Scope

This Privacy Policy explains and informs you about:

• how we collect and process your personal data,
• what your rights are and how you can exercise them.

1.3 Familiarization

We recommend that you read this Privacy Policy carefully. By continuing to use our Site and providing your personal data, you confirm that you have been informed about how we use your personal data, as set out in this Privacy Policy and in the relevant privacy notices.

1.4 Applicable Legislation

This Privacy Policy provides you with information in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR").

2. Contacting the controller

2.1 Contact details

You can contact us directly via our email [email protected] or at our registered office address.

3. Terms and definitions

3.1 Personal data

Is any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, surname, date of birth, location data, or email address.

3.2 Processing of personal data

Is any operation or set of operations which is performed on your personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

3.3 Controller

Is a natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

3.4 Processor

Is a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.

3.5 Purpose

Is the reason for which the controller processes your personal data.

3.6 Cookies

A cookie is a small data file (text file) that a website asks your browser to store on your device when you visit it, in order to remember information about you, such as your language preferences or login details.

The cookies we use can be divided into those used by us (technical cookies), which are necessary to provide you with the website's functions, and optional cookies – which are cookies for website customization, as well as analytical and marketing purposes. This also includes other technologies that function in a similar way.

For more information, please see our Cookie Policy.

3.7 Recipient

Is the person who receives personal data.

3.8 Third party

A natural or legal person, public authority, agency, or body other than the data subject, the controller, the processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

3.9 Consent

A freely given, specific, informed, and unambiguous indication of your wishes by a statement or by a clear affirmative action, signifying agreement to the processing of personal data relating to you.

4. Personal data processed, purposes, methods, and duration of processing

4.1 Scope of processed data

4.1.1 Sources of personal data

We obtain your personal data from various sources, primarily directly from you or from our activities, specifically:

• when you visit the Website;
• when you sign up for our newsletter;
• when you enter into a contractual relationship with us.

4.1.2 Data collected

We only process personal data that you or other persons authorized by you provide to us through the sources described above. In particular, we process the following personal data:

• Identification data: first name, last name, date of birth, place of residence, and, where applicable, company registration number (IČO) and registered office address.
• Contact details: email address, delivery address, phone number.
• Payment and transaction data: account number, account holder name, details of payments made.
• Contract performance data: subject of the contract, information on the fulfillment of contractual obligations, related communication, data on the enforcement of claims arising from the contract, etc.
• Cookie data: when accessing or using the Website, we may use cookies and other tracking technologies to automatically collect the following information:
  • device information (hardware model, operating system and version information, unique device identifiers, mobile network information, device storage information),
  • location information (IP address, time zone, mobile service provider information),
  • usage data (including, but not limited to, frequency of use, areas and features of our Website you visit, general usage patterns, and engagement with individual features).

4.1.3 Purpose, reasons, and duration of processing

We process your personal data for the following purposes:

• Informing interested parties about news. If you subscribe to our newsletter, we use your Identification Data and Contact Data to inform you about new events within our company and to promote our products and services, including via email and telephone contact. The legal basis for this processing is your consent, and we process your personal data until you withdraw your consent, but for no longer than 3 years.
• Fulfillment of contractual obligations. If you are negotiating a contract with us or a contract has already been concluded, we use your Identification Data, Contact Data, Payment and Transaction Data, and Contract Performance Data to enable us to enter into a specific contract with you (e.g., for the sale or lease of real estate). The legal basis for this processing is the performance of the contract, and we process your personal data until all obligations arising from the contractual relationship have been fulfilled.
• Support and promotion of our products and services. If you are negotiating a contract with us or a contract has already been concluded, we further use your Identification Data, Contact Data, and Contract Performance Data to ensure our legitimate interests, which are the promotion of our products and services and the dissemination of information about them. We process your personal data for a period of 3 years from the date of termination of the contractual relationship or the termination of negotiations on the conclusion of a contract.
• Internal records and protection of our rights. If we process or have processed your personal data for the purposes mentioned above, we will process your Identification Data, Contact Data, Payment and Transaction Data, and Contract Performance Data to ensure our legitimate interests, specifically the protection of our rights and interests (i.e., legal claims), which include maintaining our internal records and monitoring the proper provision of our services. We process your personal data for this purpose for the duration of the limitation period, including any time covering its potential suspension or interruption, but typically no longer than 16 years after the termination of the contract with you. In the event of the initiation of judicial, administrative, or other proceedings, we also process your personal data to the necessary extent for the entire duration of such proceedings for the purpose of exercising or defending our legal claims.
• Fulfillment of our legal obligations. In accordance with applicable law, we process your Identification Data, Contact Data, Payment and Transaction Data, and Contract Performance Data to fulfill our legal obligations. This includes, for example, tax, accounting, and archiving obligations. We process your personal data for these purposes for the period stipulated by the relevant legal regulations.
• Website operation and security (essential cookies). We process your cookie data, which is necessary for the operation of the Website, including its presentation, functionality, and security. For this purpose, we identify you as a visitor while you browse or when you log in repeatedly to the Website. The legal basis for this processing is our legitimate interest in the proper functionality and operation of our Website. We generally store your personal data for up to 2 years after your visit to our Website.
• Promotion and marketing on our Site (marketing cookies). We process your Cookie Data, which is necessary for targeting and displaying our advertising (marketing cookies); your data may also be shared with third parties. For this purpose, we promote products and services on the Site, display marketing communications regarding products and services you have shown interest in, and promote our brand through online advertising; your data may also be shared with third parties. The legal basis for this processing is your consent, granted via the Cookie sidebar. We retain your data for the duration of your consent, but in any case, for no longer than 2 years from the date consent was received.
• Site customization (functional cookies). We process your Cookie Data, which is necessary for customizing the Site (functional cookies). This allows us to simplify your browsing experience. To this end, we adapt the Site—including location, language settings, and device preferences—to your needs; your data may also be shared with third parties. The legal basis for this processing is your consent, granted via the Cookie sidebar. We retain your data for the duration of your consent, but in any case, for no longer than 2 years from the date consent was received.
• Site traffic analysis (analytical cookies). We also process your Cookie Data, which is necessary for analyzing traffic on our Site (analytical cookies). For this purpose, we monitor traffic on our Site, optimize it, ensure the security of your data, and improve its performance and user-friendliness; your data may also be shared with third parties. We process your data based on the consent you provided via the Cookie sidebar. We retain your data for the duration of your consent, but in any case, for no longer than 2 years from the date consent was received.

4.2 Cookies

4.2.1 Processing via cookies

When you use our Site, we may process your personal data (Cookie Data) through cookies and other tracking technologies. Cookies are small text files stored in your web browser that allow us or third parties to recognize you. Cookies may be used to collect, store, and share information about your activities across different websites, including our Site. This also applies to other similar technologies used for this purpose.

4.2.2 Cookies used

We use the following cookies:

• Technical cookies – are necessary to ensure the proper functioning of the website;
• Optional cookies – preference, marketing, and analytical cookies.

4.2.3 Cookie settings

You can choose to allow or decline all or only some cookies. Declining cookies may negatively affect the functionality of websites, including our Site. You can adjust your cookie preferences or delete them from your electronic device at any time.

Detailed information regarding cookies can be found on the website of your respective web browser provider. Read more information in our Cookie Policy.

4.3 Methods of data processing

We process your personal data for the purposes described above using automated means, which includes the use of statistical methods. In some cases, we may also process your personal data manually.

4.4 Data Regarding Children

We do not knowingly collect or request personal data from persons under the age of 16. If you are under 16, please do not attempt to register on our Site or send any personal data.

4.5 Consequences of Not Providing Data

Providing your personal data is a requirement necessary for entering into a contract for the provision of our services, including ensuring the functionality of the Site. If you do not provide this data, we would be unable to provide our services to you or display the Site.

5. Transfer of Personal Data to Third Parties and Recipients

5.1 Data Transfers

We are authorized to transfer the personal data we collect in the ways described above to third parties who provide services related to the provision of our Services, including administration or IT support, data analytics, organization and storage of personal data, etc. These entities act as processors or controllers of your personal data.

5.2 Recipients

We may share the collected personal data primarily with the following recipients:

• our IT system suppliers, who may have access to your personal data in certain cases and act as data processors;
• analytics and marketing service providers, who act as data controllers or processors;
• our external legal service providers, who are necessary for the enforcement of our claims and the protection of our legal rights, and who act as data processors or controllers.

5.3 Adequate Level of Security

We guarantee that we have entered into personal data processing agreements with processors who ensure the same level of security for your personal data as described in this Privacy Policy. We also strive to ensure that all controllers with whom we share any personal data maintain adequate security for the processed data.

In cases where personal data is transferred outside the European Economic Area, we ensure that an adequate level of protection for the transferred data is maintained in accordance with the GDPR.

5.4 Confidentiality and Exceptions

We, including our processors and controllers, are obligated to maintain the confidentiality of all personal data. The only exceptions are requirements to disclose personal data to designated public authorities and other entities legally entitled to request such data (e.g., the Police of the Czech Republic, the Financial Administration, etc.).

6. Security of Your Personal Data

6.1 Security Measures and Policies

We have implemented necessary technical and organizational internal control measures and information security processes in our system that align with best practices and are commensurate with the potential risk.

We also take into account future technological advancements to protect your personal data from unauthorized disclosure, access, or loss. These measures include, but are not limited to, staff training on data protection, regular data backups, data recovery procedures, data breach accountability mechanisms, and software and hardware security.

7. Your rights

7.1 Information provided

If you exercise a right in accordance with this Article 7 of the Privacy Policy or any other applicable law, we will inform every recipient who processes your personal data about the action taken, provided that notifying the recipient is possible and/or does not require disproportionate effort.

7.2 Exercising your rights

If you wish to exercise your rights or obtain relevant information, please contact us using any of our contact details. When you contact us, we must ask you to provide your identification details or other personal data that you have previously provided to us.

Providing this information is necessary to verify that you are indeed the person who submitted the request. We will provide a response no later than one month after receiving such a request, though we reserve the right to extend this period by two months.

7.3 Your rights

In accordance with applicable laws, you may request:

• access to the personal data we process;
• correction of personal data;
• erasure of personal data;
• data portability;
• restriction of processing;
• object to processing;
• file a complaint.

You may withdraw your consent to the processing of your personal data at any time.

7.4 Correction of your personal data

In accordance with the GDPR, you have the right to correct any inaccurate or incomplete personal data we process about you. If you would like to request a correction of your personal data, please contact us using any of our contact details.

We take measures to ensure that your personal data is accurate and up to date. You may contact us at any time with a request regarding your personal data that we are currently processing.

7.5 Erasure of your personal data

You may ask us to delete your personal data at any time. Once you contact us with such a request, and if any of the grounds for erasure apply, we will delete the relevant personal data from our databases without undue delay, unless we are processing some of your personal data due to a legal obligation or for the establishment, exercise, or defense of our legal claims.

7.6 Withdrawal of consent to personal data processing

You may withdraw your consent to the processing of personal data at any time without providing a reason. If you wish to withdraw your consent, please let us know using any of our contact details.

Please note that the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

7.7 Access to your personal data and portability

You have the right to obtain information about the processing of your personal data and a copy of the personal data we process. Upon your request, we may transfer all or part of the personal data you provided (processed by automated means based on a contract or consent) directly to a third party (another data controller) specified in your request, provided that such a request does not adversely affect the rights and freedoms of others and is technically feasible.

7.8 Restriction of processing

If you submit a request to restrict the processing of your personal data, particularly in cases where you have concerns about the accuracy, legality, or our need to process your personal data, we will assess your request and may limit the processing of your personal data to the necessary minimum (processing for the establishment, exercise, or defense of our legal claims, or for the protection of the rights of another natural or legal person, or for other reasons).

However, if we lift the restriction on processing and continue to process your personal data, we will notify you without undue delay.

7.9 Objection to processing

You have the right to object at any time to the processing of your personal data based on your specific situation, provided that such processing is based on our legitimate interest. We will no longer process your personal data unless we can demonstrate compelling legitimate grounds for doing so, or if such processing does not relate to direct marketing.

7.10 Complaint to the Office for Personal Data Protection

You have the right to file a complaint regarding our processing of personal data with the Office for Personal Data Protection, located at Pplk. Sochora 27, 170 00 Prague 7, Czech Republic, website: https://www.uoou.cz/.

8. Updates to this Privacy Policy

8.1 Versions and updates

This Cookie Policy is effective as of December 5, 2024. We update our Privacy Policy on an ongoing basis. Any changes to this Privacy Policy become effective once they are published on this website: https://www.tkcrealestate.cz

Questions and comments

If you have any comments or questions regarding any part of this Privacy Policy, require support, or have any claims, please contact us via email at [email protected] or at our registered office address.

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