INFORMATION ON PERSONAL DATA PROCESSING

Asociace komerčních televizí, z. s., with its registered office at Vinohradská 3217/167, 100 00 Praha 10 –- Strašnice, corporate ID: 05939704, recorded in a public register maintained by the Municipal Court in Prague, Section L, Insert 67929 (hereinafter referred to as “AKTV”), processes personal data in compliance with legal regulations, predominantly Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 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) (hereinafter referred to as the “Regulation”).

  1. Overview of subjects, their personal data processed and the sources thereof
    1. In relation to its mission and activities, AKTV processes personal data of the following entities:
      1. Representatives of AKTV members – contact details of contact persons and other representatives of its members – name, surname, position in a company, business e-mail address, business phone number for the purpose of membership;
      2. Participants of educational events and conferences – typically names and surnames of participants, their phone numbers, e-mail addresses, or data on their employers if invoices are issued to them, specification of a conference for which the participant is registered, video and audio-visual recordings from public premises of the conference and presentations submitted by participants, if any; in case of paid events, data on their corporate ID, tax ID, place of business, billed and paid (outstanding) amounts, account number and data on any ongoing performance. In respect of communication with participants, AKTV may store the time of the communication with participants and IP addresses in addition to the communication content. In respect of e-mail communication, regular data relating to the message sent together therewith are stored in the e-mail client interface.
      3. Potential speakers at educational events and conferences – when addressing prospective speakers, AKTV may store their names and surnames, their phone numbers and e-mail addresses, information on their employer and position, and the content of communication with them. If an addressed person asks us not to contact them we will keep a database of persons not to be contacted, including their basic data;
      4. Website visitors – typically network identifiers (‘cookies’), and IP addresses. This information is anonymous (e.g. type of browser, name of the domain of the internet connection provider). The purpose of processing is to improve (analytical cookies) and ensure proper functioning of the website (necessary cookies);
      5. Visitors to AKTV headquarters – identification data: name, surname, identity card and data on COVID-19 identifiers.
    2. Your personal data to be processed by us are usually received from you, or collected as part of data storing on our website or within the organisation of a relevant educational event or conference (e.g. your photos); in addition, some data are collected individually by AKTV (e.g. as part of making video or audio-visual recordings of conferences for news coverage purposes) or as part of communication with participants (e-mails).
    3. Registration for conferences is carried out either via AKTV’s website or using the Google Forms software (via completion of the form) or by e-mail registration.
    4. Please note, the video and audio-visual recordings are made at conferences for AKTV’s news coverage purposes.
  2. Purposes of processing
    1. This section includes a list of purposes for which we will use (process) your personal data:
      1. AKTV membership – AKTV processes personal data of its member representatives for the membership purposes and to call and hold meetings of AKTV bodies including the taking of minutes thereof;
      2. Educational events and conferences – the primary purpose of the processing of participants’ personal data is organising educational events and conferences. In this context, the data will be further used to record and duly perform contractual relationships of AKTV, for statistical purposes, further development of AKTV’s services relating to the conferences organised, to collect receivables and protect the rights of AKTV and third parties (e.g. other contractual partners), especially against unlawful activities. The data (mainly those collected from communication with participants, such as IP address and time of communication) will also be used to ensure IT security of AKTV. The basic identification data of participants, or data on their participation in a  conference, may be used for the purposes of direct marketing (i.e. to send offers of other similar events of AKTV by e-mail);
      3. In addition, personal data of participants will be used by AKTV for the purposes of fulfilling legal obligations, primarily in compliance with the regulations providing guidance on accounting and taxation and regulations relating to personal data protection;
      4. Commercial communication –- newsletters – we can process the information on our prospective, current or past partners for the purposes of direct marketing, which typically means e-mailing or contacting by phone to offer products or services similar to those you received from us, i.e. especially offers to participate in our conferences or offerings of our related products or services. Sending the offers is not limited in time; however, if you express your wish not to be sent the offerings, we will no longer do so. Nevertheless, we will continue processing basic mailing data for a reasonable period of time to be able to demonstrate why we have sent you the offerings. We will not transfer your data to any third parties for the purposes of sending offerings (except for our sub-suppliers – processors who will process the data directly for us). Pursuant to Section 7 of Act No. 480/2004 Coll., AKTV will send commercial communication to the partners’ addresses (including e-mail addresses), they will be contacted via unsolicited direct mailing containing commercial communication relating to similar AKTV conferences. Such newsletters will be sent at reasonable intervals in connection with other similar events, usually no more than once every six months.
  3. Legal basis for processing
    1. The legal basis for the processing of participants’ personal data is:
      1. The need to meet contractual or other legal obligations with respect to members and their representatives and obligations arising from agreements on participation in an educational event or conference;
      2. Legitimate interests of AKTV arising predominantly from the interest in keeping records of contractual relations, collecting receivables and protecting its rights against unlawful activities including IT security, processing for statistical purposes, further development of AKTV’s services, publishing data within conference coverage and promotion, and interest in direct marketing; and legitimate interests of third parties (especially other contractual parties involved in the preparation of relevant conferences);
      3. Meeting statutory requirements (predominantly preventing torts, meeting the requirements stipulated in personal data protection regulations (primarily Act No. 101/2000 Coll. and Regulation (EU) 2016/679, bookkeeping, and meeting obligations under tax regulations).
    2. In individual cases, personal data may be processed based on consent (e.g. using e-mail addresses for sending commercial communication other than that relating to AKTV’s similar events).
    3. Please note that if the legal ground for personal data processing is your consent you can withdraw the consent at any time free of charge using the contact details below. Withdrawal of consent shall not affect the lawfulness of the processing based on consent given before its withdrawal. It is possible to withdraw consent and refuse further commercial communication at any time in each individual e-mail message containing AKTV’s commercial communication.
  4. Right to object
    1. The right to object is an important instrument protecting your interests. It allows you to have the processing carried out based on our legitimate interest reviewed in the event justified by your specific situation, i.e. in a situation when the processing as such is permissible but there are specific reasons on your part why you do not want the processing to take place.
    2. If the legal ground for the processing of participants’ personal data is AKTV’s legitimate interest (predominantly data processing for the purposes of IT security, for statistical purposes and further development of AKTV’s services and protection of rights of AKTV and third parties, direct marketing or disclosure of conference coverage), participants have the right to object to personal data processing on the grounds relating to their specific situation at any time. In this case, AKTV will discontinue processing the personal data unless serious legitimate grounds for processing arise prevailing over the participant’s interests or rights and freedoms, or unless the data are processed to determine, perform or defend legal claims.
    3. Participants can object to the processing using the contact details stated below, or preferably via e-mail address
      aktv@aktv.cz
      . In the e-mail, please specify the situation that makes you conclude that AKTV should not process your data.
    4. In the case of data processing for the direct marketing purposes (sending marketing messages), an objection may always be raised without the need to give reasons. The best way to object in these situations is to unsubscribe from receiving further commercial communication by clicking on the link that is usually included in the message for this purpose.
    5. Please note that even if the objection to processing is approved, AKTV still may process your data for some other reasons in a limited scope, e.g. if required to do so by special legislation.
  5. Data processing term
    1. AKTV cannot process your data for any length of time; the processing term is limited to the period when we actually need your data. We seek to limit the period so that it properly reflects both our and your interests.
    2. Personal data will be processed for a reasonable period of time with respect to the purpose of the processing.
    3. For the purposes of membership, AKTV processes the data for the duration of the membership of a person represented by a representative, or until AKTV has been notified that the particular representative has ceased to be authorised by the member.
    4. For the purposes of educational events and conferences where participation is free of charge, AKTV will store records of their participants for up to four years from the date of the conference. However, if participants attend another conference in the meantime, a new term for their data processing will start.
    5. For the purposes of educational events and conferences where there is a fee to attend, AKTV will record basic data on participants (name and surname, date of birth, corporate ID, tax ID, specification of the conference they attended, specification of a company they represented, specification of amounts paid, etc.) for up to six years of the date of the educational event or conference to keep records of contracts and performance received and for bookkeeping purposes.
    6. If the data on participants are processed as part of conference coverage, the period of their disclosure will not be limited. The same applies to photographs or video recordings from educational events or conferences and provided presentations, if any.
    7. The contact details of participants for the purposes of sending commercial communication (primarily offerings to participate in other conferences) will be processed by AKTV until a participant disagrees therewith. After such disagreement, AKTV will nevertheless continue processing basic data on why commercial communication was sent to the participant for a reasonable period of time to prove legitimacy thereof.
    8. When processing data for other purposes, AKTV determines the term of processing on the following grounds: (i) length of the limitation period, (ii) probability of making legal claims, (iii) common market practice, (iv) probability and significance of the risks involved, and (v) recommendations of supervisory authorities, if any.
  6. Data updating
    1. One of our obligations as a personal data controller is to process accurate and up-to-date data, and complete any incomplete data with respect to the circumstances. If you provide us with information on changes to your data you will help us meeting the obligation.
    2. If data provided by a participant change, we kindly ask you to notify us thereof.
    3. In order to update data, AKTV can be contacted using the contact details below, preferably via email
      aktv@aktv.cz
      .
  7. Manner of processing
    1. Today, most processing is automated, which means that in general, we will process your data in a computer system. However, this does not exclude the processing of documents in the files, such as the system for storing hard copy contracts.
    2. AKTV processes personal data primarily in its computer systems and its processors’ computer systems. AKTV will process hard copy documents in the files. The provision of the processed data by participants is voluntary but without certain data, participation in a conference is not allowed and in some instances, certain information is required by law, in particular by accounting regulations.
  8. Transfer of personal data to other entities (recipients of personal data)
    1. Not all personal data are processed by AKTV itself. We sometimes hire third parties (‘personal data processors’) to carry out the processing. We seek to select only processors that are sufficiently trustworthy. For the processing, we always conclude a written contract with processors in which we agree on the necessary scope of protection and confidentiality regarding the personal data processed.
    2. AKTV only discloses the usual scope of personal data to processors or other recipients – providers of external services (typically programming or other technical support services, providers of computer systems, server services, e-mail distribution and providers of archiving services), operators of (backup) servers or operators of technology used by AKTV who process the data to ensure the functionality of the relevant services, and persons assisting AKTV in organising conferences, e.g. providers of premises and stewarding services. Personal data may also be disclosed on the need-to-know basis to legal, economic and tax advisors and auditors processing the data in order to provide advisory services. Personal data relating to debtors may be disclosed to receivable insurers or collection agencies for the purposes of receivable collection or recovery. Furthermore, personal data of participants may be disclosed to a company providing AKTV with conference insurance or relating responsibilities. Upon request or in case of suspected illegal activities, personal data may be transferred to public authorities. If a conference is co-organised by another entity, personal data may also be provided thereto.
    3. If the Google Form service is used for registration, the data provided in the forms will be made available to Google, or a member of AKTV who will be in charge of registration via this service. The principles of data protection of Google, Inc. are available here.
  9. Information on the rights of data subjects
    1. With respect to AKTV as a personal data controller, a natural person has the right to:
      1. Require access to the personal data processed by the controller, which means the right to receive confirmation from the controller as to whether the personal data relating to the natural person are processed or not; if so, the natural person has the right to access the personal data and other information specified in Article 15 of the Regulation;
      2. Require rectification of the processed personal data concerning the natural person (Article 16 of the Regulation) if the data are inaccurate. With respect to the purposes of processing, in certain circumstances the natural person has the right to require completion of incomplete personal data;
      3. Require erasure of personal data in cases specified in Article 17 of the Regulation;
      4. Require restriction of data processing in cases specified in Article 18 of the Regulation;
      5. Obtain personal data that concern the natural person and
        1. That we process with the natural persons’s consent; or
        2. That we process for the performance of a contract to which the natural person is a party or for the implementation of measures adopted before the conclusion of the contract upon the natural person’s request in a structured, commonly used and machine-readable format, and the natural person has the right to transfer the data to another controller under the conditions and with the limitations specified in Article 20 of the Regulation;
      6. Object to processing pursuant to Article 21 of the Regulation on the grounds relating to the person’s specific situation.
    2. If we receive such request, we will inform the requesting party of the measures taken without undue delay and in any case within one month from the receipt thereof. This deadline may be extended for additional two months if necessary, taking into account the complexity and number of requests. In certain circumstances specified in the Regulation, AKTV shall not be obliged to grant the request in whole or in part. This predominantly includes situations in which the request is manifestly unfounded or unreasonable, primarily because it is repeated. In these circumstances we may (i) impose a reasonable fee reflecting the administrative costs incurred when providing the requested information or communication or taking the requested action or (ii) refuse to grant the request.
    3. If we receive the above-specified request but have reasonable doubts as to the requesting party’s identity, we may ask for the provision of additional information needed to confirm the identity.
    4. We will store the information that you have exercised your rights with us and how we have dealt with your request for a reasonable period of time (usually for three years) in order to keep evidence of the fact, for statistical purposes, to improve our services and to protect our rights.
    5. If you opine that AKTV processes your personal data unlawfully or otherwise violates your rights you have the right to lodge a complaint with the supervisory authority (the Office for Personal Data Protection) or you have the right to seek a judicial remedy.
  10. How can you contact us?
    1. For any comments and questions about personal data protection and to contact us regarding the exercise of your legal rights, you may use the following contacts:

Asociace komerčních televizí, z. s.

Vinohradská 3217/167 100 00 Praha 10 –- Strašnice

e-mail: aktv@aktv.cz

Data box ID: mkvinvm