Principles of personal data protection of clients and other persons
Version of 25 May, 2018
WHO PROCESSES YOUR DATA:
Schaffer & Partner is a team of tax advisors, auditors and attorneys-at-law who form the following firms, which pose as independent administrators in relation to the subjects of the data:
- Schaffer & Partner s.r.o., ID: 25607707, seated at Vodičkova 710/31, 110 00 Prague 1, entered in the Commercial Register of the Municipal Court in Prague, Section C, Insert 54384,
- Schaffer & Partner Legal s.r.o., ID: 28936060, seated at Vodičkova 710/31, 110 00 Prague 1, entered in the Commercial Register of the Municipal Court in Prague, Section C, Insert 154241
- Schaffer & Partner Audit s.r.o., ID: 25648641, seated at Vodičkova 710/31, 110 00 Prague 1, entered in the Commercial Register of the Municipal Court in Prague, Section C, Insert 57948
- Schaffer & Partner Consulting s.r.o., ID: 25762664, seated at Vodičkova 710/31, 110 00 Prague 1, entered in the Commercial Register of the Municipal Court in Prague, Section C, Insert 67976
(hereinafter also referred to “Schaffer & Partner”)
At present moment, there is no appointed data protection officer; to exercise your rights related with your personal data processing, do not hesitate to contact us directly at:
- address: Vodičkova 710/31, 110 00 Prague 1, Czech Republic
- phone number: +420 221 506 300
- E-mail: email@example.com
WHICH DATA ARE PROCESSED:
Schaffer & Partner may store and otherwise process personal data of our clients and other persons which are provided to us, by our clients if it is necessary in connection with making use of our legal, tax and auditing services, or personal data of other persons who provided Schaffer and Partner with such data along with a consent for the data processing.
THE PURPOSES OF THE PERSONAL DATA PROCESSING:
- Schaffer & Partner may process the data for one or more of the following purposes:
- Provision of legal services in accordance with the Law on Advocacy, tax advisory services, performance of auditing activities and those directly connected to the clients
- Provision of information on news in law, tax and audit areas, news on developments within the Schaffer & Partner group and emailing advertising messages
- Intermediation of contacts and support in the area of international business
- Organization of professional seminars, lectures, workshops and other specialist events
- Meeting the legal obligations connected with the identification of the clients in accordance with AML
- Keeping the accounts and fulfilling our other statutory obligations
THE PERSONAL DATA PROCESSING AUTHORIZATION
Schaffer & Partner is entitled to process the personal data on the basis of at least one of the following authorizations:
- Meeting the contract requirements. The most common legal basis for collecting and processing of personal data is conclusion of a contract on provision of legal, tax, auditing and/or other services. For such purposes, you are obligated to provide personal data since without them a contract may not be entered into and the performance may not be effected. The personal data also need to be processed so that the legal, tax and auditing services could be provided appropriately.
- Meeting the legal requirements. Meeting the legal requirements of Schaffer & Partner, especially the client identification obligation in accordance with AML, keeping the accounts, invoicing and other tax documents etc.
- Consent. In certain cases, Schaffer & Partner processes the personal data on the basis of a freely given consent, which may be withdrawn at any time in accordance with the procedure included in this information. The refusal to give or the withdrawal of the consent bears no connection with personal data processing on the basis of another authorization.
- Legitimate interests of Schaffer & Partner. Schaffer & Partner is entitled to process personal data for the purposes of its legitimate interests; namely, these include direct marketing or ensuring the website security.
THE PERSONAL DATA ADDRESSEES
Within the scope of its authorization, Schaffer & Partner may also transfer/provide personal data to the following bodies:
- Public authorities (courts, administrative bodies, financial and customs administration etc.)
- Other persons on the basis of the client’s instructions
- Providers of maintenance and the IT administrator
- Other persons cooperating with Schaffer & Partner, in particular on the basis of a permanent cooperation agreement or mandate agreement
- Other Schaffer & Partner advisory group members, firms being a part of Schaffer & Partner German advisory group, namely, Schaffer & Partner mbB Steuerberater, Wirtschaftsprüfer, Rechtsanwälte, seated Äußere Sulzbacher Straße 118, Nuremberg, Postal Code: 904 91, Federal Republic of Germany, entered into the registry of partner companies of the Municipal Court of Nuremberg No. PR 285, and the partner office in Slovakia, LEON Tax, k. s., ID: 45 325 014, seated at Galvaniho 7/D, Bratislava, Postal Code: 821 04, Slovak Republic.
THE PERIOD OF DATA STORAGE
Schaffer & Partner processes and stores personal data only for a time period necessary for the above purposes; mainly, the data are to be processed during the period of validity of a contract on provision of services to the client and after its termination the data will be dealt with in accordance with the arrangements in force, esp. laws Nos. 85/1996 Coll. (Law on Advocacy), 523/1992 Coll., on Tax Advisory, 93/2009 Coll., on Auditors, 499/2004 Coll. (Law on Archives).
In the case of processing of personal data on a basis of a given consent for a period for which the consent was given if the consent is not withdrawn before; after such period, Schaffer & Partner will keep the personal data (namely the consent and/or its withdrawal) to the necessary extent for a possible defence of Schaffer & Partner´s rights.
Also, we would like to inform you that personal data are kept if legal provisions require doing so solely for the period stipulated by these provisions (esp. the storage periods for tax and accounting documents).
RIGHTS IN CONNECTION WITH YOUR PERSONAL DATA PROTECTION
The right to withdraw the consent. If your personal data are processed on a basis of your consent, you are fully entitled to withdraw it by contacting us at firstname.lastname@example.org; the legality of the personal data processing performed before the consent withdrawal is not affected; neither does the withdrawal have effect on processing of personal data on a basis of another authorization, especially in connection with processing necessary for meeting contractual or legal requirements.
Right to access. In accordance with Article 15 of GDPR, a subject has the right to obtain confirmation from Schaffer & Partner whether their personal data are being processed and if this is the case, which data they are, including information on the purposes of the processing, categories of the data concerned, their recipients, the envisaged period of the data being stored, the existence of the right to request erasure or rectification of the data, the right to register a complaint with a supervisory authority, information on the source of the data, if they were not collected from the subject and the existence of automatic decision-making including profiling.
Right to rectification and completion. You have the right to request Schaffer & Partner to rectify your personal data if they are inaccurate or to complete them if they are incomplete. You may also do so yourself via your personal profile at our website if you are registered.
Right to erasure/right to be forgotten. You have the right to request Schaffer & Partner to erase your data if legal grounds apply, especially if your personal data are no longer necessary for the above purposes, you withdrew your consent or you objected to the processing and Schaffer & Partner is not obligated to process your personal data to meet legal requirements or to establish, exercise and/or defend the legal claims of Schaffer & Partner.
Right to restriction of processing. You have the right to request Schaffer & Partner to restrict your personal data processing if
- You contest the accuracy of the personal data
- The processing is unlawful and you request the restriction of the data use instead of their erasure
- You need your personal data for establishment, exercise and/or defence of your legal claims although Schaffer & Partner does not need the data for purposes of further processing, or
- You have objected to the processing on a basis of legal grounds for the purposes of our legitimate interests (especially in connection with direct marketing)
Right to data portability. If you request so, Schaffer & Partner has to transfer your personal data to another controller; also, you have the right to obtain the data in a structured, commonly-used and machine-readable format.
Right to object. You have the right to object to processing your personal data on the grounds of legitimate interests of Schaffer & Partner as pursued by Schaffer & Partner especially in connection with direct marketing.
Right to lodge a complaint. You have the right to lodge a complaint with the Czech Office for Protection of Personal Data or another supervisory authority in connection with your personal data processing.
WHEN YOU CAN OBJECT AND WHAT IT MEANS
In accordance with Article 21 of the GDPR, you have the right to object to processing of your personal data at any time, if the data are being processed on the grounds of authorization for the performance of a task carried out for reasons of public interest or it is necessary for the reasons of legitimate interests of Schaffer & Partner. In the case of Schaffer & Partner, you have the right to object to processing for direct marketing purposes. Should you require Schaffer & Partner to stop sending you our newsletter or other business information in connection with direct marketing, you may object to it at any time, and Schaffer & Partner will no longer process your personal data for this purpose and will not be sending you business information any further. The objection may be made via our email at email@example.com or by clicking the link regarding the information that you do not wish to receive the business information included in all commercial communication.