RWS Moravia Customer Privacy Notice

In the context of our business relationship RWS Moravia, RWS Moravia (serving in a capacity of the Data Controller) will Process Personal Data about you in both paper and electronic format. 

In particular circumstances, RWS Moravia may not be solely but jointly responsible with other RWS Moravia subsidiaries and affiliates for the lawfulness of the processing of your Personal Data; we will provide you with an additional complementary notice in those cases. 

For definition of certain terms used in this Notice, please refer to Appendix 1. This Notice may be complemented by additional notices and policies.

Personal Data Provided by You RWS Moravia generally collects Personal Data directly from you (provided electronically, in writing, or verbally). You may also provide new, or updated or corrected data to RWS Moravia from time-to-time. 

To assist us in complying with our obligation to maintain Personal Data accurate you should notify the Privacy Manager in writing of any changes to your Personal Data. 

Where you have notified the Privacy Manager or we otherwise become aware of an inaccuracy in your information we will take steps to ensure that Personal Data is erased or rectified without delay.

RWS Moravia processes the below categories of Personal Data for the following Purposes, based on the Legal Basis listed hereof. The provision of the Personal Data is a contractual requirement and without the Personal Data RWS Moravia will not be in a position to properly administer our business contract or to fulfil the contract should provision of the Personal Data be linked to certain contractual obligations (such as if your business contact information was provided in order for RWS Moravia to fulfil notification obligations under the relevant obligations). 

3.1 Provision of Services to Customer

The Categories of Personal Data that RWS Moravia Processes about you, for this purpose, are the following: 

    > Identification and contact data. 

RWS Moravia processes the above Personal Data for the purpose of provision of services to the Customer under the relevant business contract. 

RWS Moravia uses different legal grounds as a basis for the Personal Data processing, namely: 

    > Performance of the relevant contract.

RWS Moravia retains your Personal Data for the period necessary to fulfil the purposes set out in this Notice or as required by applicable law, and, when the purposes are fulfilled, will delete or anonymize the Personal Data. 

It is our general policy to retain certain Personal Data relating to Customers for 3 (three) years (corresponding to the applicable statute of limitations) after the end of the relevant business contract and/or 10 (ten) years in case of a pending or threatening dispute, but in no event for longer than strictly necessary.

Personal Data of Customers may be shared with other RWS Moravia branches, subsidiaries, affiliates and holding companies (i.e. intra-group) or with third parties (external services suppliers acting as Data Processors) where appropriate or relevant for the same purpose as described above. 

6.1 Intra-Group 

RWS Moravia will need to share Personal Data of Customers with its branches, subsidiaries, affiliates and holding companies, depending on the purposes of the data processing described in Section 3 of this Notice, including staff members from Talent Administration team (HR), InfoSec, Accounting, Payroll, Legal, Facility Management etc.in accordance with Section 7.1. 

6.2 Third Parties 

We may also share Personal Data with suppliers that are engaged to perform services or functions on behalf of RWS Moravia and under its instructions. In all such cases, RWS Moravia will put in place appropriate contracts with these parties to ensure that they only process Personal Data in accordance with our instructions and in order to provide these services and protect the integrity and confidentiality of the Personal Data.

From time to time and for the purposes set out in Section 3 of this Notice, RWS Moravia may also disclose your Personal Data to its auditors, lawyers and consultants. 

RWS Moravia does not sell, rent or lease Customer’s Personal Data to third parties.

7.1 Intra-Group 

Due to the global nature of our operations, some of the Personal Data recipients (mentioned in Section 6) may be located in countries outside the European Economic Area (EEA), which do not provide an adequate level of data protection. International transfers will be to countries where RWS Moravia branches, subsidiaries, affiliates and holding companies have offices, including Argentina, Canada, China, Germany, Hungary, Ireland, Japan, the United Kingdom and the USA. The transfer of your Personal Data outside the EEA takes place on the basis of our Intra-Group Data Sharing Agreement, which is based on the standard data protection clauses adopted by the European Commission and in accordance with applicable law. You may ask the Privacy Manager (contact details in Section 9 below) for a copy of the above document. 

7.2 Third Parties 

Some of the third parties with whom we share Personal Data are also located outside the EEA. Certain third countries, such as Argentina, Canada, Japan or United States (with a limitation to the Privacy Shield Network), have been officially recognized by the European Commission as providing an adequate level of protection. Transfers to third parties located in other third countries outside the EEA take place using an acceptable data transfer mechanism, such as the Privacy Shield for transfers to self-certified US organizations, the EU approved Standard Contractual Clauses, Binding Corporate Rules, approved Codes of Conduct and certifications etc. or in exceptional circumstances on the basis of permissible statutory derogations. 

Please contact the Privacy Manager (contact details in Section 9 below), if you want to receive further information or, where available, a copy of the relevant data transfer mechanism.

Under the conditions set by applicable data protection laws, you may exercise the following rights regarding your Personal Data (see also Section 9 on how to exercise those rights): 

8.1 Access 

You have the right to obtain from us confirmation if Personal Data is being processed, the purpose of processing, the categories of data, the legal basis of the processing, information on recipients of the data and the non-EU countries in which they are located, the safeguards put in place for the transfer of data to non-EU countries, storage period of data or criteria to determine it, further information on your rights, our processing activities, sources of information and the significant and envisaged consequences of processing 

8.2 Rectification 

You have the right to request the rectification of inaccurate Personal Data and to have incomplete data completed. 

8.3 Objection 

You have the right to object to the processing of your Personal Data for compelling and legitimate reasons relating to your particular situation, except in cases where legal provisions expressly provide for that processing. In addition, you have the right to object where your Personal Data are processed for direct marketing purposes. 

8.4 Portability 

You may receive your Personal Data that you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit it to other data controllers without hindrance. This right only exists if the processing is based on your consent or a contract and the processing is carried out by automated means. 

8.5 Restriction 

You may request to restrict processing of your Personal Data if (i) you contest the accuracy of it – for a period we need to verify your request; (ii) the processing is unlawful and you oppose the erasure of it and request restriction instead; (iii) we no longer need it, but you tell us you need it to establish, exercise or defend a legal claim; or (iv) you object to processing based on public or legitimate interest – for a period we need to verify your request. 

8.6 Erasure 

You may request to erase your personal data if it is no longer necessary for the purposes for which we have collected it, you have withdrawn your consent and no other legal ground for the processing exists, you objected and no overriding legitimate grounds for the processing exist, processing is unlawful, or erasure is required to comply with a legal obligation. 

8.7 Right to lodge a complaint 

You also have the right to lodge a complaint with a supervisory authority, in particular in EU Member State of your residence, place of employment, or the location where the issue that is the subject of the complaint occurred. 

For the Czech Republic, please see contact details below: 

Address: 

Personal Data Protection Office
Pplk. Sochora 27
170 00 Prague 7
Czech Republic
E-mail address: posta@uoou.cz 

8.8 Right to refuse or withdraw consent 

Please note that in case we ask for your consent to processing, you are free to refuse to give consent and you can withdraw your consent at any time without any adverse negative consequences. The lawfulness of any processing of your Personal Data that occurred prior to the withdrawal of your consent will not be affected. 

8.9 Your California Privacy Rights 

Under California Civil Code Section 1798.83 (known as “Shine the Light” law), California residents who provide Personal Data are entitled to request and obtain from us once a calendar year information about the Personal Data we shared, if any, with other businesses for their own direct marketing uses. 

To obtain this information on behalf of RWS Moravia please send an email message to email address mentioned below with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response.

Address: 

Moravia IT s.r.o.
Vlněna 526/1
602 00 Brno
Czech Republic 

E-mail address: moravia@rws.com 

If you wish to exercise any of the afore-mentioned rights (see Section 8) or if you have any questions regarding this Notice, please direct your request to: 

Address: 

Moravia IT s.r.o.
Privacy Manager
Vlněna 526/1
602 00 Brno
Czech Republic

E-mail address: privacy@rws.com 

Phone number: +420-545552133

RWS Moravia may update this Notice from time to time. The new version will be effective as from the date indicated in that updated Notice, ensuring that individuals receive sufficient advance notice and draw their attention to any significant changes. 

In Brno, on April 1, 2020

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