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DATA PROCESSING PRINCIPLES OF DFNC Group Ltd. | 1819

DFNC GROUP Ltd., company ID number: 220 82 841, with its registered office at Revoluční 1082/8, Nové Město, 110 00 Prague 1, Czech Republic (hereinafter referred to as “the Company”), is a business engaged in the international trade of military material within the scope of the permit issued under Act No. 38/1994 Coll., as amended. In the course of its business activities, including the operation of the website www.1918.eu, the Company processes personal data within the meaning of the General Data Protection Regulation (Regulation (EU) 2016/679).

The purpose of these Data Processing Principles (hereinafter referred to as “Principles”) is to inform you, as data subjects whose personal data is processed by the Company (hereinafter referred to as “You”), about the processing of your personal data carried out by the Company in the course of its business activities and about your rights related to such processing.
The protection of your personal data is a priority for the Company, and the processing of personal data is carried out in accordance with all applicable legal requirements and the fundamental principles of data processing.

PROCESSED PERSONAL DATA

The Company processes the following personal data (categories of personal data) – in relation to a specific data subject, only to the extent necessary in view of the processing purpose and the nature of the relationship between the data subject and the Company:

  • Identification data, including name, surname, date of birth, personal identification number, and, if applicable, identity document details;
  • Contact data, including permanent residence address, other contact (correspondence) address, telephone number, and email address;
  • Payment data, including bank account number;
  • Basic profile data, including gender, nationality, marital status;
  • Professional profile data, including educational background, professional qualifications (including information from professional CVs);
  • Property data, including information about financial standing, payment habits, and economic credibility, including information about indebtedness;
  • Contractual data, including details regarding contracts with the Company, goods and services provided by the Company, related demands, complaints, and communication;
  • Data on rights and legal claims, including information about rights and legal claims against the Company and/or third parties (or vice versa);
  • Health data;
  • Data relating to criminal proceedings and convictions in criminal matters; and
  • Audio/visual data, including photographs, video recordings, and/or voice recordings.

The Company may also process additional personal data not listed above, related to clients and other business partners, or other third parties. Such processing will be duly informed in accordance with legal requirements and these Principles.
Personal data is collected primarily from the data subjects themselves. It is also collected from publicly available sources (such as the internet, public registers, commercial registers, trade registers, or insolvency registers). Personal data is also obtained through third parties, particularly clients and other business partners of the Company, as well as government authorities.

PURPOSES OF DATA PROCESSING

The Company processes your personal data for the following purposes:

  • Contractual agenda, for the purpose of entering into contracts with clients and other business partners, amending, and terminating contracts, fulfilling rights and obligations arising from contracts, maintaining records of contracts, and related communication; In this context, the Company processes identification data, contact data, payment data, property data, contractual data, and data on rights and legal claims.
  • Business agenda, for the purpose of fulfilling obligations under legal provisions governing the international trade of military material under the relevant Czech laws and regulations. In this context, the Company processes identification data, contact data, payment data, basic and professional profile data, property data, data on rights and legal claims, health data, criminal records, and audio/visual data.
  • Tax agenda, for preparing, processing, and submitting tax returns, reports, and other tax filings, communicating with tax authorities, and fulfilling other obligations under tax regulations.
    In this context, the Company processes identification data, contact data, property data, and data on rights and legal claims.
  • Accounting agenda, for conducting audits, fulfilling registration and reporting obligations, communicating with financial authorities, and fulfilling other obligations under accounting regulations.
    In this context, the Company processes identification data, contact data, payment data, property data, and data on rights and legal claims.
  • Archiving agenda, for fulfilling archiving obligations under relevant legal provisions, including the Archives Act, tax, and accounting regulations.
    In this context, the Company processes identification data, contact data, basic profile data, professional profile data, property data, and data on rights and legal claims.
  • Interaction with government authorities, for fulfilling various information, notification, and other obligations towards state authorities (including courts, administrative bodies, tax authorities, and criminal justice bodies). In this context, the Company processes identification data, contact data, payment data, basic profile data, property data, data on rights and legal claims, and criminal data.
  • Company management and administration, for ensuring the efficient operation, management, and functioning of the Company.
    In this context, the Company processes identification data, contact data, payment data, basic and professional profile data, property data, and data on rights and legal claims.
  • Marketing and promotion, for marketing the Company and its products and services (including sending promotional communications).
    In this context, the Company processes identification and contact data.
  • Protection of legal interests (claims), for the purpose of determining, exercising, and protecting the rights and claims of the Company and third parties.
    In this context, the Company processes identification data, contact data, payment data, property data, data on rights and legal claims, and health data.
  • Security and protection, for ensuring security within the Company and protecting its property and that of third parties, including through the use of security cameras.
    In this context, the Company processes identification data and audio/visual data.
  • Employee recruitment, for recruiting new employees and collaborators, including processing and recording CVs, selecting candidates, conducting interviews, and offering positions within the Company. In this context, the Company processes identification data, contact data, basic and professional profile data, and audio/visual data.

If the Company processes your personal data for additional purposes not listed above, you will be informed about such processing in accordance with legal requirements and these Principles.

LEGAL GROUNDS FOR DATA PROCESSING

The Company processes your personal data based on the following legal grounds:

  • Fulfillment of obligations under legal regulations;
  • Fulfillment of a contract between you and the Company;
  • Legitimate interests of the Company and/or third parties; and
  • Your consent to processing.

DATA RECIPIENTS (CATEGORIES OF RECIPIENTS)

Your personal data may be transferred by the Company to third parties, referred to as data recipients, in accordance with the purposes for which the Company processes your data:

  • Contractual agenda – personal data may be shared with business partners involved in fulfilling contracts with the Company.
  • Tax agenda – personal data may be shared with tax advisors and financial authorities.
  • Accounting agenda – personal data may be shared with accounting service providers and financial authorities.
  • Archiving agenda – personal data may be shared with public authorities in the field of archiving.
  • Interaction with government authorities – personal data may be shared with relevant state authorities (courts, administrative bodies, tax authorities, and criminal justice authorities).
  • Marketing and promotion – personal data may be shared with advertising agencies, graphic studios, and other entities involved in marketing and promotion.

TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

Your personal data is not typically transferred to third countries, meaning countries outside the European Union, Switzerland, Iceland, Norway, and Liechtenstein. Personal data may only be transferred to third countries in exceptional cases and under the following conditions:

  • If the European Commission has issued a decision on the adequate protection of personal data for that country;
  • If suitable safeguards for data protection have been provided by the data recipient;
  • If required by law, including necessary conditions for fulfilling a contract or if explicit consent is given by you.

STORAGE PERIOD OF PERSONAL DATA

Your personal data is retained only for as long as necessary for the relevant processing purposes. For processing based on legal obligations, personal data is retained for the duration specified by applicable laws, including tax and accounting regulations.

YOUR RIGHTS

Regarding the processing of your personal data by the Company, you have the following rights:

  • Right to withdraw consent – You can withdraw your consent to processing at any time.
  • Right to access personal data – You have the right to confirm whether the Company processes your data and to access your data.
  • Right to rectify and complete personal data – You have the right to have inaccurate personal data corrected or incomplete data supplemented.
  • Right to erasure (“right to be forgotten”) – You have the right to request the erasure of your personal data.
  • Right to restrict processing – You can request the restriction of processing in specific circumstances.
  • Right to data portability – You have the right to receive your personal data and transfer it to another data controller.
  • Right to object – You can object to the processing of your data for legitimate interests.
  • Right to compensation – You are entitled to compensation for any damage caused by the violation of your data protection rights.
  • Right to lodge a complaint – You can file a complaint with the data protection authority if you believe your rights have been violated.

CONTACT DETAILS

For any questions regarding the processing and protection of your personal data, or to exercise your rights, you can contact the Company through the following communication channels:

• Email: info@1918.eu

DFNC GROUP s.r.o. (Ltd.)

ID number: 220 82 841 Registered office: Revoluční 1082/8, Nové Město, 110 00 Prague 1, Czech Republic

email: info@1918.eu Web: https://1918.eu

Register Entry: The company is registered under file no. C 410692

Commercial Register of the Municipal Court in Prague.