PRIVACY POLICY

PRIVACY POLICY

Last update effective: 23 May 2018

Who we are

Howlings s.r.o., ID no.: 275 72 102, with registered office at Vítkova 244/8, Karlín, 186 00 Praha 8 (hereinafter “Howlings”), is the data controller in the context of your use of the website https://www.expats.cz and related services (hereinafter the “Services”). At Howlings we value your privacy and in this Policy we explain how we collect and use your personal information as well as what are your rights when it comes to the personal information protection.



What personal information do we collect and how?

The majority of personal information we process is provided directly by you:

  • When you create an account and/or use within our Services

We collect data from you when you create an account with us and/or use our Services, request information, subscribe for a service, post a review, post a question or answer, submit a CV, upload content or otherwise actively send us data through the Services. This may include, but is not limited to, your user name, password, first and last name, e-mail, address, telephone number (including mobile phone number), gender, occupation, interests, messages you send to other users, and any other data contained in a submitted CV and any other information submitted to employers through the Services.

If you decide to make a purchase through our Services we may ask you for the details needed to facilitate the payment. This information includes your name, surname, IČO, DIČ, billing address, e-mail address, and telephone number (including mobile phone number). Expats.cz does not store your credit card number or CVV code.

  • Information we collect about you automatically

We automatically collect information about how you use our Services, the areas of our Services that you visit, as well as information about your computer including your IP address, physical location, browser and operating system type, and referring URLs. This information is necessary for providing personalized and location-based content as well as for analysing web traffic, troubleshooting problems, preventing fraud, and improving our services.

  • Information provided by third parties

We may also receive your personal information from third parties, for example if you choose to sign in with Facebook or similar sites, we import the requested information from your account and we make it part of your Expats.cz account.

What purposes we process your personal information for (and on what legal basis)?

  • Account maintenance and keeping in touch

We need your personal information to be able to create and maintain your user account and to be able to communicate with you and provide customer service.

The legal basis we rely on in this case is performance of contract.

  • Manage your requests within the Services

We need to process your personal information to be able to manage the requests you make within our Services.

The legal basis we rely on in this case is performance of contract.

  • Traffic optimization and distribution, protection of other users and prevention of fraud

We also process your personal information in order to improve our Services and develop them, and to ensure security and integrity of our Services and ensure that the Services operate effectively. We also need to make sure that our users are protected and safe while using the Services.

The legal basis we rely on in this case is legitimate interest.

  • Direct marketing

Occasionally we would like to let you know about promotions we think might be of interest to you. In order to be able to do that, we need to process your personal information.

The legal basis we rely on in this case is legitimate interest (if you have had previously created an account within our Services or otherwise used them), or your consent.

  • Facilitating Payment

If you provide credit, debit or other payment card and related details to us in order to make a payment, we will use such information only for the purpose of processing the payment.

The legal basis we rely on in this case is performance of contract.

  • Processing of personal information on the basis of consent

On some occasions we process your personal information on the basis of your consent. You have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.

  • Compliance with a legal obligation

Sometime we have to process your personal information in order to comply with a legal obligation. For example, we are required by law to retain business records (which may contain your personal information) for fixed periods of time.

How long do we keep personal information?

We will retain your personal information to the extent such retention is adequate, relevant and limited to what is necessary for the purposes for which they are processed. In particular, we shall not retain your personal information for any longer than necessary for the purposes of performing the processing outlined in this Policy.

How we share your personal information?

We share your information with third parties who assist us in being able to provide our Services to you. These are in particular professional service providers, such as marketing agencies, advertising partners and website hosts, who help us run our business. These entities are able to access your personal information as necessary to perform their functions, but they may not use that data for any other purpose.

Further, we disclose your personal information to the employers and service provides you choose to get in touch with through our web forms.

How do we process your personal information and how we keep it secure?

Processing of personal information is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the indicated purposes. We have implemented appropriate organisational safeguards and security measures to protect your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. The communication between your browser and our website uses a secure encrypted connection wherever your personal data is involved. We require any third party who is contracted to process your personal data on our behalf to have security measures in place to protect your data and to treat such data in accordance with the law. In the unfortunate event of a personal data breach, we will notify you and any applicable regulator when we are legally required to do so. Your personal information is processed only within the European Economic Area.

What are your rights when it comes to the personal data protection?

You have several rights under the data privacy legislation. These include, under certain circumstances, the right to:

  • Request access to your personal data: You have the right to obtain a copy of the personal data we hold about you and certain information relating to our processing of your personal data.
  • Request correction of your personal data: You are entitled to have your personal data corrected if it is inaccurate or incomplete. You can update your personal data at any time by logging into your account and updating your details directly, or by emailing us at the contact detailed above.
  • Request erasure of your personal data: This enables you to request that Howlings delete your personal data, where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons of which you will be notified, if applicable, at the time of your request. 
  • Request restriction of processing of your personal data: You have a right to ask Howlings to suspend the processing of your personal data in certain cases, for example if you want us to establish the accuracy of the data, or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data: You have the right to obtain a digital copy of your personal data or request the transfer of your personal data to another controller. Please note that this right only applies to automated data which you initially provided consent for us to use or where we used the data to perform a contract with you.
  • The right to complain to the data protection regulator — in the Czech Republic it is the Office for Personal Data Protection. We would, however, appreciate the chance to deal with your concerns before you approach the regulator, so please do contact us in the first instance.

Right to object to processing of your personal data

You have the right to object to the processing of your personal data where we believe we have a legitimate interest in processing it. You also have the right to object to our processing of your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms.

How can you exercise your rights towards us?

If you want to exercise any of your rights, please contact us using the contact information below. Please note that in order to be able to manage our request we need to be sure about your identity and we may require that you provide us with additional proof of identity if we deem this to be necessary.

Should you have any questions about this Policy, would like us to stop using your information, want to exercise any of your rights as set out below, or have a complaint, get in touch with us by e-mail at privacy@expats.cz, or by post at Vítkova 244/8, Karlín, 186 00 Praha 8.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time, to reflect how we are processing your personal information. If we make significant changes, we will make that clear within our Services, or by some other means of contact such as email, so that you are able to review the changes before you continue the Services.

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