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Personal Data Processing and Protection Principles

These Personal Data Processing and Protection Principles (the “Principles“) represent the basic principles governing the collection and processing of personal data by First Line Software (the “Company“).

As such, the Principles implement the rights and obligations of the Company arising from, in particular, the following generally binding laws and regulations:

  • Regulation (EU) 2016/679 of the European Parliament and the Council, 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/ES (General Data Protection Regulation) (“GDPR“);
  • Act No. 480/2004 Coll., on certain services in an information society and the amendment of certain laws (Information Society Services Act), as amended (the “Information Society Services Act“); and
  • Act No. 127/2005 Coll., on electronic communication and on the amendment of certain related law (Electronic Communications Act), as amended (the “Act on Electronic Communication“).

These Principles apply to everyone who visits the Company’s website at (the “Website“) regardless of whether or not they are in a contractual relationship with the Company.

What is personal data

In accordance with the GDPR, personal data is any information related to an identified or identifiable natural person (as opposed to a legal entity) – i.e., essentially, any information which either by itself or in conjunction with other information may serve to identify a specific natural person (“Personal Data“).

What personal data will be processed by the company

The Company may collect the following of your Personal Data:

Personal data which you yourself submit to the Company

This Personal Data includes, in particular, the information which you provide by filling in registration or order forms or other forms, or which you communicate to the Company via e-mail, phone, fax, or similar channels.  You may also provide Personal Data to the Company [within the context of consumer contests], [when posting reviews of products or services], [signing up for training] or [submitting a general enquiry].  Typically, this Personal Data will comprise first and last name, correspondence address, e-mail address, phone number, bank account details, choice of payment method, etc.

The Company will process the above-specified Personal Data for the following purpose:

  • to provide services, products, or information in which you have shown interest;
  • if you already are a customer: to provide information about other services and products similar to those which were the subject of your previous purchase;
  • if you are a new customer: the Company will only send you commercial messages and offers for products and services if you gave your explicit consent;
  • to review and evaluate your job application.

Personal data about you which the Company collects by itself

As you visit our Website, the Company may gather certain information which is indispensable to ensure the proper and convenient operation of the Website.  This information comprises the IP data needed for your computer to connect to the internet, your registration data, the type and version of browser used, the time zone setting, browser plug-ins (if any), information on your visit of the Website, including the valid Uniform Resource Locator (URL), the path you took to and from the Website (including date and time stamps), products you displayed or searched for, latency rates, download errors, duration of site visits, information on the way in which users interact with the site (e.g. scrolling, clicking, positioning of the mouse pointer), or the manner in which the Website was abandoned. 

The Company uses this personal data to manage and improve the Website and to ensure internal operations, including troubleshooting, data analysis, testing, research, statistical purposes, and counting page views.  This particular type of Personal Data may also be used to measure the efficiency of advertisements and to display commercial messages of relevance to the individual visitor.

Transfer of personal data

The Personal Data obtained about you by the Company may be passed on [within the group of companies known as [●], i.e., to affiliates of the Company;] and to third-party organizations (“Processors“) which help the Company discharge its contractual obligations by procuring certain services (such as courier and delivery services).  The Company will only ever transfer your Personal Data to those Processors who warrant an adequate level of protection of your Personal Data, and who will strictly process the Personal Data based upon a Data Processing Agreement. 

Within the meaning of the aforesaid, the Company may transfer Personal Data to the following Processors:

  • external partners and suppliers, for the purpose of discharging the Company’s contractual obligations;
  • provides of payment services and payment transaction processors, for the purpose of securing the transfer of cash funds and facilitating payment operations;
  • the providers of postal and mail delivery services, for the purpose of delivering products or services offered by the Company;
  • the administrator of the Website.

Under certain circumstances, the Company may be obliged to disclose your Personal Data to third parties (such as law enforcement) in accordance with the generally binding provisions of statutory law.

Means of protection

In order to protect the Personal Data, and minimize the risk of unauthorized access, the Company has taken organizational and technical measures. 

These measures include:

  • organizational restrictions to limit the circle of persons with the right to access the Personal Data; and
  • technical safeguards to secure the servers and the Website of the Company against unauthorized manipulation.

All persons who come into contact with the Personal Data have been instructed on the principles of protection of personal data, and are bound by non-disclosure duties when processing Personal Data.

Retention period

The Company will only retain the Personal Data for as long as absolutely necessary to fulfill its contractual obligations or its obligations under the law.  Personal Data which is being processed based on your consent will only be retained for as long as the purpose persists for which consent was given. 

Once the statutory reason has ceased to exist for which your Personal Data has been processed, the Company will erase the Personal Data and destroy all existing copies.

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