Information on personal data processing

Introduction

Dear Customers, Business Partners, Visitors and Users of information systems or applications,

By this document, we would like to inform you of the terms and conditions of processing your personal data in our company and of the manner and scope of our personal data processing within the ČEZ Group. We also inform you in this way of the protection of personal data and of your rights related to their processing.

Telco Pro Services, a. s., together with other companies, is a member of the ČEZ Group and control it as a managing entity.

When processing your personal data in the ČEZ Group, we act in compliance with European Union legislation, particularly compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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 “GDPR”), which comes into force on May 25, 2018 as a direct effective legal regulation also in the legal order of the Czech Republic, and also compliance with the relevant intrastate legal regulations, particularly the Personal Data Protection Act.

Privacy and personal data protection is important for us. This information about personal data processing (hereinafter “Information”) specifies the personal data collected by the ČEZ Group member companies from you or about you through communication with you in connection with use of the products and services they provide to you or in connection with other business relations between you. And, if applicable, which personal data they obtain from other entities or sources and how they use these data.

Besides this summary information, you will also find some details of the processing of your personal data in the documents, which we provide to you within the scope of mutual communication, or which will be displayed for you on the websites used by the ČEZ Group companies to simplify and speed up communication with you.

Personal data controller

The controller of your data is always the ČEZ Group company, to which you provided or that obtained them from you for fulfillment of one or more purposes. The company that provides you with products or services or your business partner usually controls your data. If you are a customer of several ČEZ Group companies, each of these companies controls your personal data related to its product, service or other business relationship.

If the Controller of your personal data is company Telco Pro Services, a. s., ID No: 291 48 278, having its registered office at Duhová 1531/3, 140 53 Prague 4, incorporated in the Commercial Register at the Municipal Court in Prague under File No. B 18830 (hereinafter “Telco Pro Services, a. s.” or “Our company”), you will find more detailed information about processing of your personal data below.”

The personal data, which we process

We process your personal data only to the extent that enables us to provide you with the products and services that you are interested in, respectively only the data necessary for our correct mutual business cooperation. And also to enable us to fulfill our legal obligations and ensure protection of our justified interests related to our mutual relationships.

For this reason, we collect and process your data mainly as users of our products and services, and our business partners, including potential future customers and business partners who are interested in our products and services or in business cooperation with us, or who we have contacted with our offer. According to the specific situation, we also process the data of, for instance, the participants of professional, social and other events organized by us or the representatives of legal entities, including the members of the statutory and other bodies.

For these purposes, our company mainly processes the following categories of personal data

In our company we consider basic data in particular to be:

  • the identification data: title, name, surname, date of birth, and if applicable, the identity card number, birth registration number or ID No.;
  • the contact data: permanent or temporary residential address, mailing or other contact address, address of the service point, telephone number, e-mail address.

We also process data, which are closely related to the way in which you use our services, or the data that you provide to us during use of our services or that you create otherwise. Alternatively data that exists by virtue of our business cooperation. We consider such data to be particularly:

  • Bank account number, information about the customer’s payment morale, customer number, EAN, business partner number, signature information obtained on the basis of readings taken from measuring devices, operating and localization data, IP address, cookies, data boxes ID and other personal data arising from fulfillment of a concrete contract or relevant legal regulation
Purposes of personal data use

We use your personal data, depending on the nature of our relationship with you, particularly for the following purposes:

  • Conclusion and performance of contract;
  • Ensuring interconnection and access to the distribution systems;
  • Ensuring operation activities and keeping technical records;
  • Settlement of property and legal relationships related to the operation of the distribution system;
  • Accounting and tax purposes;
  • Identification of abuses of distribution systems or services, e.g. finding, preventing and removing any unauthorized consumption of electricity and preventing losses in the distribution system;
  • Ensuring the financial settlement of contractual relationships, including any collection of receivables;
  • Providing access to localization data and calls to emergency line numbers;
  • Compliance with legal obligations, including crisis management, protection of confidential information or ensuring the operation of critical information infrastructure;
  • Protection of property and persons and safety of significant elements of the distribution system;
  • Keeping customer records;
  • Keeping the records of business partners.

 

The details of sources of your personal data that we process are given in the following examples.

Customer identification and authentication

For us to be able to conclude a contract with you and provide our services to you, we must know your basic data. We require your identification and authentication also in a case where you exercise your rights in matters of personal data protection. In order for you to be able to operate your supply via the application and communicate with us electronically, we control your access data – particularly the logins and passwords, which are used for your secure authentication.

Our reason for processing your data:

  • to conclude and fulfill your contract
  • for fulfillment of obligations under the legal regulations

As part of using our services, e.g. to obtain information on outages and breakdowns, you can use our websites.

Our websites, like the majority of other websites, use cookies. Based on these anonymous data object we can e.g. monitor the total number of visitors of our website.

“Cookies” are pieces of information that are saved by the website on the User’s hard drive. Thanks to cookies, websites are able to remember important information, which on the other hand makes its use by the User easier.

If you do not want to use cookies or if you want to be notified about any use of cookies by your browser, you have to make the appropriate setting in your browser. If you block all cookies, you will not be able to use all functionalities of our websites.

Our reason for processing your data:

  • to fulfill your contract
  • website activity monitoring

We collect and process only the data that are required and necessary for drafting your contract. For us to be able to conclude the contract with you, we require your name, date of birth and contact data. A further data area depends on the type of service, or type of business cooperation, which is the scope of contract. So for some services , it is necessary or desirable to to know the details of your service point or appliances.

Until signature of the contract, we use your personal data only for preparation of the draft contract at your request. After signature of the contract, we process the data for the purpose of its implementation; if the contract has not been signed, we process the data only if another purpose exists for its processing.

Our reason for processing your data:

  • for preparation of your contract
  • for fulfillment of obligations under the legal regulations
  • to protect our rights and justified interests

We respect your needs and preferences. For this purpose, we make an effort to get an overall view of how you use the service and your desires. We solve all sorts of issues with you relating to the given service, particularly its establishment, configuration, changes, provision of information about the service, etc. We also solve your requests, desires and complaints at our branches, on our customer care lines, websites, portal solutions, in the mobile applications and in other ways. Besides our services, these requests may also apply to exercise of your rights in matters of privacy and personal data protection. We ascertain whether you are a satisfied client of our CEZ Group member companies and you want to remain loyal to us. If you come to the branch, we want to easily identify you and offer you suitable service.

Similarly, we are also interested in the management of mutual relations if you are cooperating with us as our business partners.

For these reasons, we particularly process the relevant information about the services, or business cooperation and the data from our communication and interaction, which you provide to us.

Our reason for processing your data:

  • to fulfill your contract
  • to protect our rights and justified interests

Use of services

Your selection of our services results in our processing your data. This mainly concerns your basic data, information about the services or business cooperation, or further data. We register, control and keep them up-to-date in cooperation with you. On the electronic portals, which you use to operate the service, we display the basic information about you and provided services and we control this information in order to ease the operation of the services for you.

Our reason for processing your data:

  • to conclude and fulfill your contract

Sending of service messages

Within the scope of provision of our services, we send messages to you, which are used for more comfortable operation of the provided service. We process your contact details for this purpose.

Our reason for processing your data:

  • to fulfill your contract
  • for fulfillment of obligations under the legal regulations

Control and prevention of fraud

Due professional care during the performance of our activities also includes control and preventive measures. This concerns the activities of prevention, detection, investigation and other execution of the required steps for investigation of suspected fraud or theft.

Based on applicable legislation, distribution system operator has to ensure secure operation of the distribution system and therefore we operate stationary camera systems and record telephone communication on our telephone line for reporting breakdowns.

We also use mobile cameras. Recordings from them are used to document any finding, preventing and removing of unauthorized consumption of electricity pursuant to the provisions of Section 51 of Energy Act, to document any finding and preventing of losses in the distribution system, in order to use them as proofs for the purposes of recovering damages caused by such unauthorized consumption of electricity, in accordance with the requirements of legislation and practice of courts.

Only appointed employees of the Company can access the camera recordings. They may be provided only to the criminal authorities or administration authorities on the basis of their written request. Our company may also provide these companies with recordings at own discretion if it suspects a crime or offense, which is recorded. Records are archived only for a definite period that is set out in advance. Unless any decision on their handover is made, they are deleted upon the expiry of this period.

Camera records from stationary camera systems are stored no longer than 30 of from their recording. Audio recordings of communication on the telephone line for reporting breakdowns are retained for no more than one year from their recording. Audiovisual records from mobile cameras documenting unauthorized consumption of electricity are retained for 3 years and 9 months from the date of inspection or 9 months from the legal force of the decision on the settlement of the damages caused by the unauthorized consumption, in any case the total period shall not be shorter than 3 years and 9 months from the inspection of the service point.

Our reason for processing your data:

  • to protect our rights and justified interests
  • for fulfillment of obligations under the legal regulations

Safety

For these purposes, we protect both human life and health, physical property, e.g. by installation of cameras at important elements of the distribution system, and the data themselves. The camera systems are installed for the purpose of protecting persons and property from illegal conduct, mainly within the scope of prevention and clarification of the illegal conduct of persons in the buildings used by our company. We process the records from the cameras in compliance with the purpose of their acquisition and according to the strict rules to also ensure protection of your data. Processing of your data also helps us in the prevention of cyber risks.

Our reason for processing your data:

  • for fulfillment of obligations under the legal regulations
  • to protect our rights and justified interests

Accounting and taxes

We collect and process your identification data and transaction data for the purpose of fulfillment of our accounting and tax obligations to the regulatory and state authorities, which are stipulated for us by the Accounting Act, VAT Act and other Czech accounting and tax acts, and for reason of obligatory reporting to the regulatory bodies. Tax documents as well as any source documents for their issuance are archived for 10 years from their issuance in accordance with the VAT Act.

Our reason for processing the data:

  • for fulfillment of obligations under the legal regulations

Exercise of company rights

If we are compelled by the development of the situation in our mutual relations to collect our receivables by legal means, or if we are participants in court proceedings, which concern your person, we use your basic data, information about the products and services, information from our communication, or other data necessary for protection of our rights to the necessary extent.

Our reason for processing the data:

  • for fulfillment of obligations under the legal regulations
  • to protect our rights and justified interests

Testing of software changes

During implementation of new software, in some cases the use of the data of our clients in its effective testing cannot be avoided. In necessary cases, we use your data that are stored in the given software, if there is a lack of adequate testing data to test the software, its changes and, if applicable, also for the related training of our staff. At the same time, we prefer use of client data that are not up-to-date for the tests. If it is necessary to use your personal data for testing purposes, they are properly protected against misuse.

Our reason for processing the data:

  • to protect our rights and justified interests

Reporting, management of information, optimization of processes, training

Our staff process your personal during fulfillment of internal duties configured within the scope of each CEZ Group member company. Your basic data and service data are used for planning purposes, or for evaluation of greater efficiency. For these purposes, the data is aggregated (summed up from a large number of individual data to the total amount) and results in a cumulative number, without direct link to a particular person. Based on the legal regulations, we also process various reports.

Our reason for processing the data:

  • for fulfillment of obligations under the legal regulations
  • to protect our rights and justified interests

Research and development of services

For survey of the successfulness of our services, we use information about the services in order to improve and innovate these services through the analysis of the situation.

Our reason for processing the data:

  • to protect our rights and justified interests
Consent to processing of personal data

During our business or other relationship there may be situations associated with the possible processing of some of your personal data that we will not be able to use for a particular purpose without your consent. For example, some of your photos that you are uniquely identified with, voice or image recordings of your person, and more detailed information about your person. Our company may be interested to use them especially for communication, promotional or training activities.

We will inform you of such situations separately and offer you the opportunity to give our company the consent to use your precisely defined personal data for the specific purpose described and for the proposed period.

It will be at your sole discretion whether you will grant us the proposed consent or you will oppose it. Neither the conclusion nor the duration of our business relationship is conditional upon any such consent for the above purposes and no one will be forced to do so in any way.

Such consent given according to the GDPR may replace your initial consent regarding the same processing purposes, supplement your further consents, if applicable, regarding data processing and does not void or restrict the right of other ČEZ Group member companies to process your data, if such use is made possible for us directly by the legal regulation.

Of course, you can change or withdraw your consent at any time. The procedure for withdrawal of consent is given in the part I want to withdraw my consent.

Personal data sources

Our company obtains your personal data mainly from you within the scope of negotiation of a contract and also during its fulfillment, or from third parties mediating such negotiations.

Our company will always notify you when it is necessary to provide personal data for provision of a specific service and on the contrary, also when this is voluntary, but provision of such personal data makes mutual communication between you and our company easier and thus significantly increases the efficiency of the rendering of services.

We can also get your personal data from public records or from the state administration authorities. In specific cases, we can get your personal data also from non-public records on the basis of applicable legal regulations.

For the purpose of the legitimate interest in the safe operation of the distribution system, the safety of persons and property, our company monitors and records communication with you (mainly telephone calls on the telephone line for reporting breakdownd). We always notify you of this fact in advance.

The details of sources of your personal data that we process are given in the following examples

For these requirements, we use your data that are on record in the internal databases, which are obtained directly from you or about you on the basis of current, or also previous contractual cooperation, which contain information necessary for assessment of security and risk management. The source of this may also be your personal data shared between the CEZ Group member companies for this purpose

In cases in which we assert our justified interests, particularly our interest to act prudently, we can obtain your basic data and some other additional data also from the public registers, for instance, the Trades Register, Cadastre, the data boxes Register and similar. In some cases, personal data from these sources may also be obtained if required for the conclusion of a contract or by law. In many cases, a contract is concluded through another company acting on behalf of our company with power of attorney

Processing and sharing of personal data

Our company processes your data manually and automatically. During automated processing of your data, we however do not use automated decision-making, which could affect your rights.

Protection of your data in our company is organizationally and technically safeguarded in compliance with the applicable legal regulations. We require a comparable level of safeguarding of your personal data also from all our personal data processors.

For the above-stated purposes, besides our companies and their staff, your personal data may also be processed by some other ČEZ Group member companies or other data subjects outside the ČEZ Group as processors. We provide your data to these companies or data subjects only when they fulfill the organizational and technical conditions we have defined for ensuring their appropriate protection. And further that they are bound by written contract to comply with the negotiated conditions for processing of your personal data and ensuring their stipulated protection.

The reason for transferring of your data to these companies or subjects as processors is usually the fact that they use the knowledge, procedures or technologies with the necessary professional level, which makes it possible for them to more effectively achieve some of the above-stated processing purposes and at the same time also ensure the necessary protection of your personal data.

Some of our products or services are provided in cooperation with companies outside the ČEZ Group, such as business representatives and suppliers. Or they are accompanied at your request by a product or service other than cooperating companies. In all such cases, sharing or processing of your personal data occurs on the basis of personal data processing contracts concluded in compliance with the applicable legal regulations.

Your personal data, on the basis of a justified request, may also be handed over to third parties with authority to seek provision of such personal data. These are, in particular, various state authorities.

Personal data security

An important objective of our company is to protect and secure your personal data. We use various technologies, procedures and processes to protect your personal data from unauthorized access, use and publishing. We, for instance, process the provided personal data on computer systems and store them in data storage systems with restricted access, which are located in guarded buildings. For transmission of highly classified personal data (for instance, bank account numbers or passwords) in the Internet environment we use encryption to protect them

Where we store personal data

The personal data collected by our company are processed and stored exclusively in the territory of the Czech Republic.

The personal data processed by our processors are stored exclusively in the territory of the European Union.

How long we store personal data

Our company keeps your personal data for the period necessary to provide the services, completion of the required transactions or other necessarily purposes, such as fulfillment of our legal duties, contractual obligations, solution of disputes and legal enforcement of negotiated agreements. These needs differ depending on the type of the product or service provided, or other type of agreed contractual relationship, and for this reason, the real period for which we keep the information may vary significantly.

When handling your personal data for specific purposes, we respect the data minimization rules. We thus collect those of your personal data that we really need for a specific purpose. At the same time, we set strict internal archiving rules, which ensure that we do not keep such data for longer than we are authorized.

Almost for all contractual relationships, we must ensure documentation of the calculation and payment of tax, arising from the legal regulations on VAT and the related tax procedure. According to these legal regulations, we are obliged to keep tax documents and records containing detailed data related to the provision of selected services for a period of 10 years after expiry of the tax period in which the performance was realized. Thus, we are generally obliged to keep most of the basic data and information about the services on the basis of these legal regulations.

In exceptional cases, for instance, during litigation, our company may keep the documents containing your personal data for a longer period in order to protect our justified interests. This mainly happens in a case where we would have to present evidence in litigation, administrative or enforcement proceedings (with regard to the statutory limitation period according to the current Civil Code, for instance, in connection with provision of warranty, possibly with respect to the statutory limitation periods of the Criminal Code).

We keep the data that we process on the basis of your possible consent for the duration of the validity of your consent. To rule out doubts, we keep the actual consent and change or withdrawal of your consent from the title of our legitimate interests for duration of the validity of the consent and no later than 5 years after its termination

Your rights to protection of personal data

Our company strives for transparency and fair processing of your personal data, and ensuring their proper protection, always in compliance with applicable laws and regulations. For us to be able to reassure you about our responsible approach to handling your data, we are ready to quickly and professionally respond to your legitimate demands, which enable you to verify our responsibility when handling your data and possibly help us rectify deficiencies if they exceptionally occur in this aktivity. 

  • If the personal data processing is based on your consent, you have the right to revoke your consent to future processing at any time;
  • You have the right to request us as the data controller to provide you with access to your personal data and more detailed information about their processing;
  • You have the right to request us to correct your inaccurate or incomplete personal data;
  • You have the right to request us to provide you with your personal data in the normally used and machine readable format, which allows their provision to another controller, if we obtained them on the basis of your consent or in connection with conclusion and fulfillment of a contract, and they are automatically processed;
  • You have the right to object to processing of some or all your personal data;
  • You have the right to request restrictions on processing in specified cases;
  • You have the right to request us to delete your personal data if we no longer have any legal reason for their further processing; and
  • You have the right to lodge a complaint to the Office for personal data protection. 

When processing your personal data, we do so on the basis of appropriate legal titles that allow us to provide you with services, to ensure the operation of our company, fulfill our contractual and legal obligations, ensure the protection and security of our systems and our customers, or to fulfill other justified interests of our company as described in the above-stated parts of the Information, or we process your personal data based on your consent.

You have the right to access your data and other related information. However, this must not affect third party rights. We shall provide you free-of-charge with this data and information. In a case where you disproportionately request them too often, we have the possibility to request you to pay a fee equivalent to the costs of provision of these data and information. If we regularly send you a billing for provided services, you get the essential information about your personal data via this document.

It may happen that your data are incorrectly recorded, or not up-to-date. Of course, we shall correct them at your request. And similarly, we shall supplement your incomplete data if you notify us.

We fully respect your right to get your personal data deleted. As soon as all the reasons for keeping the data demise, we shall delete them even without getting a request from you. If you request us to delete your personal data earlier, we shall notify you of the reason and for how long we must keep your data before it is deleted.

Based on your objections, pending their solution we shall assess the situation and block access to or use of your personal data to which the doubts exist on whether they are being used in compliance with the applicable legal regulations.

You are not obliged to provide us with your personal data. We shall always notify you in concrete situations as to which of your personal data are necessary for conclusion of the given contract, and your eventual rejection shall lead us to the conclusion that we shall not be able to provide you with the offered service.

If you gave us consent to process your personal data, you have the right to revoke this consent at any time. Revocation of this consent has no impact on the processing of your data for the entire validity of your consent. Revocation of your consent will have an impact only on the processing of your data for a specific purpose or purposes, for which it was given. However, this has no effect on processing of your personal data for other reasons and the legal reasons if they relate to such personal data (e.g. fulfillment of the duties stipulated by a legal regulation).

If you receive our business offers on the basis of our legitimate interest, you can stop sending such offers at any time (Offers unsubscribe) in the following ways:

  • via the web form,
  • or write to us at the address Telco Pro Services, a. s., Duhová 1531/3, 140 53 Praha 4, with the code " personal data processing" 

For correct comprehension, we would like to draw your attention to the fact that restriction of marketing shall not result in ending of communication with you. As required, we shall continue to use your contact data to send you service messages, or other information of non-marketing character, which is related to your product or service that we shall provide to you or to any other type of contractual relationship between us

For us to understand each other better

In spite of all efforts at maximum comprehension of this document, you have probably found words or terms that you have never encountered before. Or you are not sure that you correctly understand their meaning.

For this reason, based on our experience we provide you with a glossary of terms, which can help us better avoid mutual misunderstanding.

Group

The CEZ Group represents the legal relationship between multiple CEZ Group companies (controlled companies) subject to a unified control by ČEZ, a. s. (controlling company), with which they form the concern on the basis of the unified control. For more detailed information see www.cez.cz

Justified interest

The interest of the controller or a third party, for instance, in a situation in which the data subject is the controller’s client.

Personal data

Information about a specific, identifiable person.

Recipient

The person to whom the personal data are provided.

ČEZ Group

The CEZ Group is a corporation of companies around the parent company ČEZ, a. s., mainly engaged in the energy sector, linked to this parent company, mainly through equity investments. For more detailed information see  www.cez.cz

Service

Any service, which ourcompany offers to you, including our services offered on-line and their support.

Controller

An entity that determines the purpose and resources for processing of personal data; and may also decide on delegation of their processing to another entity in the role of a processor.

Data subject

A live natural person whose personal data are the subject of processing.

Purpose

The reason for which the controller uses your personal data.

Processing

An activity by which the controller or processor performs when handling the personal data.

Processor

An entity that processes personal data for the controller.

Potential changes in this information

Over time, there may be a change in the legislation governing the rules and conditions for the processing and protection of your personal data, or a change in our conditions, procedures and methods of processing and protection of your personal data. We will keep you informed about them at all times by updating this information provided the given change will not require us to notify you also through individual communication (letter or electronic message).

Contact us

If you have a request or complaint relating to the processing of your personal data or a query for the person responsible for processing of personal data our company, please, contact us via our web form. We shall respond to your request, queries or complaints as soon as possible, but at the latest within one month of their delivery. If we shall not be able to respond to your request in time because of the complexity of its solution or a large number of requests from other persons, we shall notify you about the necessary extension of the period.

Our Data Protection Officer is Mgr. Petr Brázda LL.M. He can be contacted at the address: ČEZ, a. s., Duhová 2/1444, 140 53 Prague 4, or via the web form. For more details on how to contact the Data Protection Officer, description of his mission and competence to resolve your rights, visit the web site Data Protection Officer.