Principles of processing personal data for customers according to GDPR

1. Who processes your data?

Personal data is processed by TOPWET s.r.o., with its registered office at Namesti Viléma Mrštíka 62, 664 81, ID number: 273 77 377, as controller of personal data according to GDPR. We will process your data in accordance with the conditions set out below.

2. What is personal data?

Personal data is any information relating to a designated or identifiable natural person to whom the personal data relate. It is considered to be determined or determinable if a natural person can be identified, directly or indirectly, in particular on the basis of a number, code or one or more elements specific to his physical, physiological, psychological, economic, cultural or social identity. The processing of such data may be restricted due to the right to privacy, and the protection of personal data is regulated by the GDPR.

According to the law on sales registration, the seller is obliged to issue a receipt to the buyer. At the same time, he is obliged to register the received sales with the tax administrator online; in the event of a technical failure, then no later than 48 hours.

3. What personal data do we process about you?

Buyer's consent to the processing of business data

We only process personal data that you provide to us in connection with your interest in our products and their purchase (e.g. within the framework of registration, order or granting consent to the processing of personal data and granting consent to sending information about news and promotional offers, etc.), or entering into a contract for the purchase of goods.
This is most often the data that you provide to us during registration and/or purchase of goods:

1) Basic personal identification and address data

These data are necessary for the conclusion and performance of the contract. In particular, these are:

a) Email
b) First and last name
c) Telephone
d) Contact and/or delivery address
e) Payment data (credit card number) that we do not/store in your account (only when using paid services such as shopping in our e-shop, etc.)
f) Other data voluntarily filled in by you in the note when filling out the order.

2) Other data processed on the basis of your consent, which we obtain from you by using our services

a) IP address
b) Cookies (in the case of online services)
c) Records of behavior on websites managed by TOPWET obtained from cookies if cookies are enabled in the web browser. Records are processed to improve the traffic of websites operated by TOPWET and Internet advertising
d) Alternatively, another online identifier

3) Data on purchased goods and payment morality

a) On the TOPWET e-shop you will find a list of your orders and favorite products.

4. Why do we process your personal data?

Personal data is any information relating to a designated or identifiable natural person to whom the personal data relate. It is considered to be determined or determinable if a natural person can be identified, directly or indirectly, in particular on the basis of a number, code or one or more elements specific to his physical, physiological, psychological, economic, cultural or social identity. The handling of such data may be restricted due to the right to privacy, and the protection of personal data is regulated by the GDPR.

Compliance with statutory tax obligations (fulfilment of legal obligations)
Operation of camera and monitoring systems in TOPWET brand stores and TOPWET premises for the purpose of preventing damage and ensuring the safety of TOPWET customers and protecting TOPWET's interests and property (TOPWET's legitimate interest)
Recording and monitoring of calls with the customer line (performance of the contract)
Debt collection for customers as buyers and other customer disputes (legitimate interest of TOPWET)
Register of debtors (TOPWET's legitimate interest)
Marketing Purposes (Customer Consent)

5. Provision of personal data

The provision of personal data necessary for the performance of the contract, the fulfilment of TOPWET's legal obligations and the protection of TOPWET's legitimate interests is mandatory. Without the provision of personal data for these purposes, it would not be possible to ensure the fulfilment of TOPWET's obligations towards customers. We do not need consent to process personal data for these purposes. Here we use the legal title arising from the contract for the processing of personal data.
Personal data for these activities are processed to the extent necessary for the performance of these activities and for the period necessary to achieve them or for a period directly stipulated by the legislation.

1) Processing of personal data for marketing purposes

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2) Processing of cookies from websites operated by TOPWET

6. What are cookies and what types of cookies do we use?

Cookies are small data files that allow visited websites to remember the actions and settings of individual users that they have performed on them, so that this data does not need to be entered repeatedly. Cookies are stored on individual computers using a web browser. Cookies do not pose a danger, do not serve to collect any sensitive personal data, but they are important for the protection of privacy. We do not use cookies to identify website users or misuse login data.

Cookies allow us, for example, to recognize the user as an existing user (e.g. when logging into their email account, when authorizing a payment, etc.) or to customize the website to the user's preferences. We also use cookies to display so-called behaviorally targeted online advertising on and off TOPWET's website, more simply to show only such advertising that is relevant to a particular user, without the user being bothered by advertising that does not interest them.

Another group is represented by third-party cookies (e.g. Google Analytics to analyze the traffic of a particular website or certain services or cookies of the operators of advertising systems that are operated on our site).

You as a user have the option to refuse the use of cookies. However, it is possible that in some cases it will not be possible to display our particular product without the use of cookies. If your browser allows the use of cookies, we will assume that you agree to the use of standard cookies by our websites. If you do not want to store these cookies, you can block their use. You can find more information about the types of cookies and their use in our services hereunder

7. Who will have access to your personal data?

TOPWET uses the professional and specialized services of other entities in the performance of its obligations and obligations under contracts. If these suppliers process personal data transmitted from TOPWET, they have the status of personal data processors and process personal data only within the scope of instructions from TOPWET and must not use them otherwise

We carefully select our partners to whom we entrust your data and who are able to ensure such technical and organizational security of your data so that unauthorized or accidental access to your data or other misuse of your data cannot occur. Protecting your data is our priority. All our partners are bound by confidentiality obligations and may not use the data provided for any purpose other than for which we have disclosed it to them.

Third parties that may have access to your personal data are:

Persons to whom we provide data for the purpose of analyzing traffic to our websites;
Persons who provide us with the technical operation of a particular service or the operators of the technologies we use for our services;
Persons who deliver purchased goods, printed promotional materials, or gifts to you as part of marketing events;
Persons who provide us with adequate security and integrity of our services and websites, and regularly test this security
Collection agencies for the purpose of collecting or collecting TOPWET claims;
Advertising system operators in relation to targeted advertising;
Operators of technical solutions that allow us to show you only relevant content and advertising
Operators of CCTV and surveillance systems in TOPWET premises

Under certain, well-defined conditions, we are then obliged to transfer some of your personal data on the basis of applicable legislation e.g. Police of the Czech Republic, or other law enforcement agencies, including specialized departments (IOOZ, Customs Administration, etc.) and other public administration bodies.

8. How long do we process your data?

We will process your data for the entire period of use of our services (i.e. the duration of the contractual relationship between us) and subsequently, on the basis of your consent, for a further 24 months, unless your consent to the processing of personal data by you is revoked.
However, we would like to draw your attention to the fact that we must process those personal data that are necessary for the proper provision of the products ordered by you, or for the fulfillment of all our obligations, whether these obligations arise from a contract between us or from generally binding legal regulations, regardless of your consent, for a period stipulated by the relevant legislation or in accordance with them, even after the possible withdrawal of your consent.
Cameras from TOPWET premises and the surroundings of TOPWET buildings or establishments are kept for a maximum of eight days from the date of the capture of the CCTV footage.

9. Can we process your personal data without your consent?

Yes, we may process your personal data without your consent, but only for the purpose of:

Provision of the product (fulfillment of the contract concluded between you and TOPWET);
Fulfilment of legal obligations arising from generally binding legal regulations for us;
Processing that is necessary for the purposes of our legitimate interests (e.g. direct marketing, ensuring the security of our websites)

10. Why can we process your personal data?

As already mentioned, we may process your personal data on the basis of your consent, but also, for example, on the basis of our legitimate interest (in particular processing for direct marketing purposes) or for the fulfillment of a contract concluded between us, to the extent that personal data is necessary for such fulfillment. Last but not least, it is the reason that allows us to process your personal data even without your consent to fulfill the obligations imposed on us by law. For what specific purposes we carry out the individual processing of your personal data is set out above.

11. How is my personal data secured?

Any personal information you provide to us is secured by standard procedures and technologies. However, it is not objectively possible to fully guarantee the security of your personal data. Therefore, it is not even possible to 100% ensure that the personal data provided cannot be accessed by a third party, cannot be copied, published, altered or destroyed by breaching our security measures
In this context, however, we assure you that we regularly check that the system is free of vulnerabilities and has not been exposed to attacks and that we use such security measures to prevent unauthorized access to your personal data as far as possible and that provide sufficient security in view of the current state of technology. The security measures taken are then regularly updated.
In order to improve the security of your personal data, access to this data is password protected and sensitive data is encrypted when transmitted between your browser and our website.

However, without your help and responsible behavior, we cannot fully ensure the security of your data. Therefore, help us ensure the security of your data by keeping your unique passwords and access details confidential and adhering to basic security principles. Please always keep in mind that emails do not need to be encrypted. Therefore, we strongly recommend that you refrain from using these forms of communication when providing confidential information.

12. How and when can you withdraw your consent to the processing of personal data?

You can revoke your voluntarily granted consent to the processing of personal data at any time, free of charge, by sending an email to: gdpr@pfgroup.cz Withdrawal of consent does not affect the possibility of continuing to process your personal data on the basis of your consent given before its withdrawal. Withdrawal of consent also does not affect the processing of personal data that we process on a legal basis other than consent (i.e., in particular, if the processing is necessary for the fulfillment of a contract, legal obligation or for other reasons specified in applicable law)

I'm 13. Am I required to provide my personal data? What if I do not provide personal data?

You provide us with your personal data voluntarily (however, for some services, the transfer of some personal data is required to make the service available, i.e. if you do not provide it to us, you will not be allowed to use this service).
The processing of your personal data, often only in anonymised form, without us being able to identify you as a specific user, allows us to provide you with our products and constantly improve and develop new ones. If you do not give us your consent or withdraw it, we may not be able to provide you with some of our products in full. However, it is not your responsibility to use our free services.

14. What rights do you have in relation to the protection of personal data?

In particular, you have the following rights in relation to your personal data:

Right to information
Right of access to personal data
The right to rectify or supplement inaccurate personal data;
The right to erasure of personal data (the right to be “forgotten”) in certain cases;
Right to restriction of processing
Right to notice correction, erasure or restriction of processing
The right to request the transfer of data;
The right to object or complain against processing in certain cases;
withdraw your consent to the processing of personal data at any time;
withdraw your consent to the processing of personal data at any time;
Other rights provided for in the Data Protection Act and in the GDPR after its entry into force.

I'm 15. What does it mean that you have the right to object?

If you no longer like the fact that you receive from us from time to time some commercial communication or other information about news in our product portfolio, you have the opportunity to object to the further processing of your personal data for direct marketing purposes. If you do so, we will no longer process your data for this purpose and we will no longer send you further commercial communications and newsletters.

More information on this right is contained in Article 21 of the GDPR.

I'm 16. How can you contact us?

In case of any question about personal data protection or withdrawal of consent to further processing of your personal data, please use e-mail gdpr@pfgroup.cz

In this context, we would like to point out that we may require you to prove your identity to us in an appropriate manner so that we can verify your identity. This is a precautionary security measure to prevent unauthorized persons from accessing your personal data. In order to improve the quality of our services and keep records of the fulfillment of our obligations under the law, all communications with you are monitored.

TOPWET Ltd.

In our company, we value the privacy of our customers and business partners. Therefore, regardless of whether you are interested in any product from our wide range, we will process your personal data in accordance with the relevant legislation and these policies adopted to protect them.

Below you will find information about the scope, purpose and forms of processing.

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Controller of personal data

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The controller of your personal data is the company CEMVIN s. r. o., Company ID 05604842, registered office Černousy no. 62, 463 73 Černousy, under registration no. C 49296 filed at the Regional Court in Ústí nad Labem (hereinafter referred to as “we” or “administrator”).

You can contact us at the contacts below:

Data box: jid7ppc

E-mail: gdpr@cemvin.eu

Address: Blackbeard No.62, 463 73

The method of processing your personal data, or the privacy policy, can be found on all our pages. :

CEMVIN: https://www.cemvin.eu

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In general to the processing of personal data

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Our website is primarily used to present our products and establish contacts with business partners — usually entrepreneurs.

The above also corresponds to the scope of processing of personal data, which occurs mainly when using contact data, inquiry form or direct purchase.

In order to know if our sites and products have reached you, cookies are also stored on your device. We use the statistical data obtained in this way to optimize this site and our offer.

Details of the processing of personal data are given below for the individual purposes of processing.

In any case, however, you can rely on us to secure your data adequately and not sell it to any other person to use it for their own purposes.

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Transfer of personal data

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In cases stipulated by law, we may be obliged to transfer your personal data to public authorities, in particular in connection with tax regulations.

In addition, we may also transfer your data for processing to processors — our carefully selected partners, whom we involve in the processing mainly on the basis of their ability to handle your data in a lawful and secure manner.

We use processors mainly in the accounting and tax fields, in legal consultations and in data storage.

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Contacting

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Whether you choose to contact us by email, in writing, by phone or by using the enquiry form on our website, the data provided by you will be saved.

This is done on the basis of the necessity of such processing for the implementation of measures taken prior to the conclusion of any contract between us.

We will use the data in order to handle your inquiries and, where appropriate, to establish contractual cooperation if our products reach out to you.

We will process the data to the extent that you provide it to us. Of course, the more we learn about you, the easier it can be to communicate with each other and the better we will be able to offer you the optimal solution.

If we do not agree on further cooperation, we will delete the collected data no later than five years after the last communication.

If you contact us by phone on our customer service line, we will also record our conversation based on our legitimate interests in improving our services. You will always be notified of the recording in advance even during a phone call. We will keep the recording of the call for 3 months so that we have time to evaluate it. You can object to this form of processing at any time.

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Purchase in the e-shop

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If you decide to purchase our products on our site, it will be necessary to process the data provided by you in order to fulfill your order. The processing will therefore take place as this is necessary for the fulfillment of our contractual obligations.

Within the order, you have the option to choose the shipping method. If you do not choose a personal subscription, we will transfer your data to the selected carrier, which will process it for the purpose of shipping the goods to the address provided by you.

When ordering goods, you can also choose one of the payment methods. If you do not pay by cash on delivery or in person, your payment information will be processed by a payment gateway provider or other online payment method. In this case, we will not access your payment information at all for security reasons.

The provision of mandatory data within the order is our contractual requirement — it is impossible to complete the order without filling them out.

We will process your personal data further in our accounting, for a period resulting from the applicable legislation. This is due to the necessity of processing to fulfill our legal obligations.

Based on our legitimate interests, we will retain personal data for the duration of the limitation period in order to protect our legal claims. You can object to this form of processing at any time.

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Business cooperation

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If we, as a wholesale customer or supplier, agree on any form of business cooperation, we will process the personal data provided by you in order to fulfill our contractual obligations. The processing of personal data is a necessary condition for our cooperation.

If you are a legal entity, we process the personal data of your authorized personnel, in particular employees or members of statutory bodies for this purpose.

We also process some of the personal data obtained in this way in order to fulfill our legal obligations, especially in the accounting and tax fields. Processing for this purpose will be carried out for a period resulting from the legislation.

We will retain personal data for a reasonable period of time after the end of our cooperation based on our legitimate interests to protect our claims. You can object to this form of processing at any time.

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Sending business messages

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We do not want to bother you with any spam, but from time to time we would like to send you information about our new products.

If you establish business cooperation with us and do not refuse to send commercial communications, we will send you commercial communications based on our legitimate interests in promoting our products.

If you do not want to receive commercial communications, there is nothing easier - just sign out using the link that will be at the end of every email you receive from us.

You can object to this form of processing at any time, either through the link mentioned above, or feel free to write us a message saying that you do not wish to contact us again.

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Storing cookies on your device

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We use cookies that allow us to recognize your device the next time you visit. They are small text files placed on your device, there are many kinds of them and they serve different purposes. Some of these files are strictly necessary for the operation of the site, if this is not the case, we will ask you for your consent before storing them.

Details of individual cookie files can be found in our cookie bar. In general, we use the following categories of cookies:

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Necessary

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Their storage is essential for the functionality of our site. These files store, for example, information enabling navigation on our site, information about whether you have given us consent to the storage of other types of cookies, how user accounts work, etc. The processing of necessary cookies is not subject to your consent. However, these cookies do not collect any information about you that can be used for marketing purposes.

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Analytical

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Analytical cookies collect information about the browsing of our site. From their anonymised outputs, we are then able to understand how you visit our site. We use the information collected to make it easy for you to find what you are looking for on our site.

We only use this type of cookie if you have given us your consent on your first visit.

We use the tool to perform the analysis Google Analytics from Google, which processes some of the data in the USA; and Clarity from Microsoft Corporation. In order to completely minimize the risks associated with this, we use these tools that are configured to minimize the intrusion into your privacy — that is, with anonymized IP addresses and disabled features that, although theoretically, could lead to your identification.

For more information about the processing and use of your data, please refer to the privacy policies of Google and Microsoft.

If you do not want to provide anonymous data about the use of the website to these services, that is, not only to us, but on all the pages you visit, you can use, for example, an extension of your browser, which will not allow your data to be sent to Google or Microsoft.

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Marketing

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Marketing cookies collect information about which information on our site has attracted you and allow us or our advertising partners to display advertising on this or other sites that may reach you. These cookies also allow us to limit the number of impressions of our advertising on your device and measure the effectiveness of our advertising campaigns.

We only store advertising cookies if you give us your consent when you first visit our site. If you do not give us your consent, of course nothing happens, unfortunately, less advertising will not be displayed to you on the site, just most likely it will not relate to services that you may be really interested in.

We use the following tools to display and analyze advertising:

Google Ads by Google
Slick from Seznam.cz, a.s.

Their involvement allows us to serve ads on the Google ad network and List.

We use remarketing features, i.e. serving ads on the content network based on products already viewed, enhanced demographic insights (reporting anonymous demographic data), and in the case of Google Ads, their user id function, which allows us to measure and analyze user behavior across devices. However, as a user id, we only use a random string of characters, which does not allow third parties to identify a specific person.

You can change or withdraw your consent at any time.

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Rights of data subjects

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With the processing of personal data, the relevant legislation combines a number of rights of data subjects — that is, you.

These include in particular Right to information, that is, your right to ask us for information about the categories of personal data processed, the purpose, time and nature of the processing and about the recipients of personal data. This information is listed above, but we will be happy to explain everything to you in more detail if you are interested in doing so. You also have the right to request the provision of a copy of the processed personal data — some of which can be accessed on your profile if you create it on the site.

If any of your data changes, or if you find that we are processing inaccurate personal data, you have the right to have it repair. We will be happy to correct the inaccuracy of your data without undue delay, you can also edit it on your profile.

If you meet certain conditions, you have the right to erasureor possibly the right to restriction of processing of your personal data. If the statutory conditions are fulfilled, we will delete or restrict the processing of your data upon request.

Finally, you have the right to file objection chi grievance against the processing of your data. The objection is sent to us and may be directed against processing carried out on the basis of legitimate interests or any form of direct marketing. You can file a complaint at any time with the Office for Personal Data Protection.

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Efficiency

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We will update this policy on an ongoing basis as necessary. The last time we did so was effective November 1, 2024.

CEMVIN Ltd.