within the meaning of Article 13 of 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) (the “Regulation“)
The Venture Club z.s., ID No.: 054 61 201, with registered office at Konviktská 291/24, Staré Město, 110 00 Prague 1, registered in the Commercial Register maintained by the Municipal Court in Prague, Section L, Insert 66843 (hereinafter also referred to as the “Controller“) hereby informs the data subjects – its members (regular and basic) about the processing of personal data under the conditions set out below.
1. Purpose and scope of the processing of personal data
The Controller processes the personal data of members listed below for the purpose of:
- maintaining a list of members, in accordance with the Trustee’s Articles of Association,
- ensuring proper communication with the members of the Manager, not only to fulfil the information obligations towards the members of the Manager, but also to fulfil the objectives of the Manager as declared in the statutes of the Manager;
(collectively referred to as “administrative purposes“)
The Controller processes the following personal data of data subjects for administrative purposes:
- first and last name (including maiden name), academic title, if any;
- date of birth;
- permanent home address/contact address (if different from the permanent home address);
- e-mail address;
- type of membership;
- date of membership creation/termination.
In this context, the Controller expressly informs the data subject that the above-described processing of personal data results from the Controller’s legal obligations and therefore the data subject’s consent within the meaning of Article 6(1)(c) of the Regulation is not required for these purposes – with the proviso that, pursuant to this provision, the data subject is therefore obliged to provide the Controller with the above-mentioned personal data for the purposes of membership with the Controller, for the purposes of processing as described above.
In addition to the aforementioned processing of personal data for administrative purposes, the Controller also informs the data subject that it uses his/her personal data in the scope of name, surname and contact e-mail address also for sending commercial communications, newsletter and any other promotional materials of the Controller (hereinafter referred to as “commercial communications“), in accordance with Section 7(3) of Act No. 480/2004 Coll, In accordance with the above-mentioned Act, the data subject is hereby expressly informed that he/she may refuse to receive commercial communications at any time by sending a notification to the Administrator at the following e-mail address: firstname.lastname@example.org.
2. Způsob zpracování a zpřístupnění osobních údajů
Within the framework of the processing of personal data pursuant to this Information, technical and organisational measures have been taken to ensure the protection of personal data of the data subject, in particular to prevent unauthorised or accidental access to personal data, their alteration, destruction or loss, unauthorised transfers, other unauthorised processing, as well as other misuse of personal data, even after the processing of personal data has been completed.
Personal data are processed at the Administrator’s registered office, i.e. at Konviktská 291/24, Staré Město, 110 00 Prague 1, and in the office premises rented by the Administrator for the purposes of administrative support of the Administrator’s operations and custody / archiving of documents located at Na Krocínce 656/5, 190 00 Prague 9, by individual persons acting on behalf of the Administrator by means of computer technology.
Furthermore, the Controller informs the data subject that his/her personal data is made available to the above extent to the cooperating company Venture Club Invest s.r.o., ID No.: 065 03 829, with the same registered office as the Controller (hereinafter referred to as the “Cooperating Company“), which operates the Invest information system, to the extent of the personal data necessary for the Controller’s needs arising from the data subjects’ membership of the Controller, extended by other personal data related to the registration of investments, provided that the data subject concerned enters into negotiations on the conclusion of a framework investment agreement with the Cooperating Company, for the purpose of carrying out asset management comparable to asset management (pursuant to Section 15 of Act No. 240/2013 Coll, on investment companies and investment funds, as amended) and other investment activities of the Cooperating Company related to the subject of the Administrator’s activities.
The controller also outsources the further development and maintenance of the Invest information system to Spinware s.r.o., company ID: 046 06 809, with registered office at Purkyňova 2855/97a, Královo Pole, 612 00 Brno, to which the personal data of the data subjects may be made available for this purpose, in full.
In view of the fact that the Controller provides accounting and tax consulting services through a third party, which legally processes personal data of data subjects for these purposes, the Controller hereby informs the data subject that his/her personal data are also processed by the EDM Utilitas Group, namely EDM Utilitas Tax, s.r.o., to the above extent, IČ: 242 60 843, with registered office at Revoluční 1080/2, 110 00 Prague 1, and EDM Utilitas Accounting, s.r.o., IČ: 029 39 053, with registered office at the same place.
Správce dále externím způsobem zajišťuje rovněž tvorbu, následnou údržbu webových stránek a správu online marketingových aktivit, a to prostřednictvím společnosti StartOnline s.r.o., IČ: 046 06 809, se sídlem Lucemburská 1599/31, 130 00 Praha 3, které jsou za tímto účelem zpřístupněny osobní údaje subjektů údajů, avšak jen v rozsahu jména, příjmení, e-mailové adresy a úrovně členství.
Personal data processed by the Controller pursuant to this Information may be further disclosed only to authorized public authorities and institutions or other entities if the conditions set out in the relevant legislation are met.
3. Rights of the data subject related to the processing of personal data
If a data subject requests information about the processing of his/her personal data or access to the processed personal data, the Controller is obliged to transmit this information / relevant personal data to the data subject concerned in electronic form without undue delay (unless the data subject has requested transmission in another form) – with the proviso that in the event of a repeated request, the Controller has the right to request reimbursement of administrative costs from the data subject concerned for the provision of information / transmission of a copy of the processed personal data.
In addition, the data subject has the right, under the conditions set out in Articles 16 to 20 of the Regulation, to have the personal data relating to the data subject concerned (i) rectified, (ii) erased, (iii) limited in scope to the processing or (iv) transmitted in a structured format to another controller without undue delay by the Controller.
The data subject shall also be entitled to object to the processing of his or her personal data, including by expressly objecting to the processing of personal data for the sending of commercial communications and other promotional purposes of the Controller.
The aforementioned procedure does not deprive the data subject of the right to address his or her request or other suggestion directly to the Office for Personal Data Protection.
4. Period of processing of personal data
The personal data of the subjects collected for administrative purposes will be processed both for the duration of the data subject’s membership with the Controller and for the following 10 years after the termination of this membership, unless a longer period is provided for by law (in particular due to the statutory archiving of relevant documents).
For the purpose of sending commercial communications and other promotional purposes, the Controller is entitled to process the personal data of the data subject in the scope of name, surname and e-mail address until the data subject explicitly refuses to receive further commercial communications, but no later than for a period of 10 years following the termination of membership.
5. Disposal of personal data
All personal data for which the time limit for processing within the meaning of Article 4 of this Information has expired shall be destroyed by the Controller without undue delay using appropriate technical and software means.
Personal data in electronic form shall be disposed of by deleting the relevant files on local disks / cloud managed under Active24 by ACTIVE 24, s.r.o., ID No.: 251 15 804, with registered office in Prague 8 – Karlín, Sokolovská 394/17, Postal Code 18600. Personal data on tangible media are destroyed by erasure or physical destruction of the respective media.
Personal data in documentary form, consisting in particular of contractual documentation stored in accordance with the relevant legal regulations, shall be physically destroyed by shredding after the expiry of the processing period pursuant to Article 4 of this Information, or a longer period provided by law for their archiving – provided that the Controller ensures the shredding either by itself or through a third party guaranteeing a proper process of destruction of personal data while maintaining confidentiality of personal data, to which this person will be obliged on the basis of a contract concluded with the Controller.
For the avoidance of doubt, the Data Controller may retain some information about the data subject for its own use, but only after secure anonymisation (i.e. creating a state where the resulting information cannot be reassigned to a specific data subject in any way).
Prague, 18 May 2018,
Venture Club z.s.
MUDr. Petr Šedivý
Chairman of the Committee