PRIVACY POLICY

Last Updated: 14^th February 2024

SECTION 1 – GENERAL CONDITIONS

We want you to understand what personal data we collect, use, and store. Our Privacy Policy governs the privacy terms of using the Website (alvla.cz, hereinafter the Website) and general rules of User’s Personal Data processing by the Website Owner.

EACH USER MUST CAREFULLY READ THIS PRIVACY POLICY.

BY USING THE WEBSITE YOU CONFIRM THAT YOU AGREE TO THE TERMS OF OUR PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY IN GENERAL OR ANY PART OF IT, YOU SHOULD WITHHOLD FROM USING THE WEBSITE.

SECTION 2 – DEFINITIONS

2.1. In this Privacy Policy the following terms have meanings as described in the Definition section below:

2.1.1. “Website” shall mean the website maintained at alvla.cz and/or all its subdomains. The Website gives Users an opportunity to get information about the products and services we provide.

2.1.2. “User” (“Users”) means a person who uses the Website and/or otherwise has an access to the functionality of the Website.

2.1.3. “Personally identifiable information” (hereinafter – “Personal Information” or “Personal Data”) shall mean any information that can be directly associated with a specific person and can be used to identify that person (including the information about Your activities, such as information about Your use of the Website, when directly linked to personally identifiable information, including automatically collected). We do not consider Personal Data to include information that has been anonymized so that it does not identify a specific User.

2.1.4. “Controller” means a person, which determines the purposes and means of the processing of personal data.

2.1.5. “Processor” means a person, which processes personal data on behalf of the Controller.

2.1.6. “Owner” (“Website Owner”) or “we”, (“us”, “our”) means a legal person – Alvla s.r.o. (K zahrádkám 2605/5 Praha 13 PSČ 155 00 Česká republika), which owns the exclusive rights for the Website.

2.1.6.1. The Website Owner is also a person, who determines the purposes and means of the processing of personal data and who processes personal data. Accordingly the Website Owner is Controller and Processor in the meaning which is specified in paragraphs 2.1.4. and 2.1.5. of this Privacy Policy. However, there may also be another person (persons) which processes personal data on behalf of the Website Owner.

2.2. The other terms and notions used in this Policy shall be understood in accordance with the Terms of Use (if available), unless other specified in this Privacy Policy.

SECTION 3 – INFORMATION WE COLLECT AND PROCESS

3.1. THE USER HEREBY EXPRESSLY CONSENTS TO THE PROCESSING OF HIS / HER PERSONAL DATA SPECIFIED IN SECTION 3 OF THIS PRIVACY POLICY FOR THE PURPOSES SPECIFIED IN SECTION 4 OF THIS PRIVACY POLICY.

3.2. Technical (programmatic) means of our Website can collect such Personal Data: name, e-mail and contact phone number. To implement functions of the Website, we also process such data as: history of active User sessions in the Website Information system.

3.3. The User (You) hereby expressly consents, represents and warrants that any and all information provided to Us is valid, current, complete and accurate.

3.4. We also collect and store such information as: User requests in support regarding the work of the Website, its related services and other issues. Such requests can be processed through our official communication channels indicated on the Website (e-mail, incoming phone calls).

3.5. Data Collected from all the Users, including non-registered. We collect the data from running the Website and use information, provided to Us by You, sent to Us by Your computer, mobile phone, or other access device, which may include Your IP address, device information including, but not limited to, identifier, name, and type, operating system, mobile network information and standard web log information, such as Your browser type, and the pages You accessed on Our Website. You (as a user) give your voluntary and undoubted consent for the collection and processing specified data and its transfer to third parties in order to implement functioning of the Website and its appropriate work.

3.6. Cookies and similar technologies. When You access the Website and/or use Our services We (or Google Analytics or similar service provider on our behalf) may place small data files called cookies on Your computer or other device. We use these technologies to recognize You as our User; customize our Website and advertising; measure promotional effectiveness and collect information about Your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety.

3.6.1. Most browsers are initially configured to accept cookies. You may control the use of cookies within your internet browsers’ settings. You should refer to the instructions of your browser, the „Help” section or similar resource to learn more about how to manage cookies and possibly reset your browser settings to refuse all cookies. Or, you could specify in your browser settings that you want to be notified when cookies are sent. However, if you do not accept cookies, some pages on our Website may not display correctly and/or some functions may be impaired. If you have any questions regarding the rules of disabling cookies, please check with your browser vendor or manufacturer.

3.6.2. Types and purpose of “cookie files” that We use:

SECTION 4 – PURPOSES OF PERSONAL DATA PROCESSING

4.1. We use Your Personal Data only for the purposes established in this Privacy Policy. We use Your Personal Data to:

• administer our Website and/or provide services;
• personalize our Website for You;
• send You technical notices, support and administrative messages;
• communicate with You about products, services, promotions, events and other news and information we think will be of interest to You;
• monitor and analyze trends, usage and activities in connection with our Website and/or services;
• provide third parties with statistical information about our Users (but those third parties will not be able to identify any individual User from that information).

SECTION  5 – PERSONAL DATA PROTECTION AND STORAGE

5.1. The Website Owner will do any and all efforts and actions prescribed by Applicable Law to store any of Your Personal Data in secrecy by means of, including but not limited to firewalls and data encryption, physical access controls to Our data centers, and information access authorization controls (which are designed to comply with Applicable Law and regulations), authorization of access to Personal Data only for those employees or contractors who require it to fulfill their job or service responsibilities.

5.2. Personal Data of Our users is stored and processed on servers in Czech Republic. However, Your Personal Data may be temporarily stored and processed in other jurisdictions.

5.3. We reserve the right to store, process and transfer Your Personal Data to Our servers in various jurisdictions, where Our facilities and/or Our service providers are located. It may also be processed by staff operating who work for Us and/or for one of Our service providers. Staff may be engaged in the fulfillment of Our services and/or the processing of Your data and/or the provision of support services. By submitting Your Personal Data, You agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that Your Personal Data is treated securely and in accordance with this Policy.

SECTION  6 – THIRD PARTIES

6.1. We may share your personal information with:

• service providers under contract who help with parts of our business operations;
• our banking partners and payment processing systems;
• companies that we plan to merge with or be acquired by (should such a combination occur, we will require that the newly combined entity follow these terms with respect to Your Personal Data);
• law enforcement, government officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure; or we believe in good faith that the disclosure of Personal Data is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of any of our policies;
• our Personal Data processing counterparties or agents, hired by or cooperating with us, whose services are required by us from the practical point of view.

SECTION 7 – INTEGRATING THIRD PARTY SERVICES AND LINKS TO OTHER WEBSITES

7.1. Our Website may, from time to time, contain links to and from the websites and/or mobile applications of Our partner networks, advertisers, and affiliates (including, but not limited to, websites on which the Website is advertised). If You follow a link to any of these websites and/or mobile applications, please note that these websites and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any Personal Data that may be collected through these websites or services, such as contact and location data. Please check these policies before You submit any Personal Data to these websites or use these services.

SECTION  8 – PROTECTING CHILD’S PRIVACY

8.1. Our Website are not designed for use by anyone under the age of 25. If you are a person under the age of 25 years, you should withhold from using Our Website. If you are a parent or guardian and believe your child (a person under the age of 18 years) is using Our Website, please contact us to remove your child’s account. We reserve the right to ask you for verification of your relationship to the child before we honor such a request. However, as parent, you should understand that you are legally liable for any actions of your child.

SECTION  9 – RETAIN INFORMATION

9.1. In accordance with applicable laws and as needed to provide services to our Users, we may hold Users` Personal Data. This requirement is conditioned by the need of complying with legal obligations and resolving possible disputes. We may retain Your Personal Data for as long as Your account is active. Moreover, Your Personal Data may be hold beyond the abovementioned period till it is indispensable for Us to have relevant information to respond to any issues that may arise later.

SECTION  10 – SECURITY

10.1. We use relevant electronic and procedural safeguards to protect the Personal Data you provide to Us from loss, misuse, disclosure, alteration and destruction.

10.2. PLEASE NOTE THAT TRANSMISSION OF DATA OR INFORMATION (INCLUDING COMMUNICATIONS BY E-MAIL) OVER THE INTERNET OR OTHER PUBLICLY ACCESSIBLE NETWORKS IS NOT ONE HUNDRED PERCENT SECURE.

SECTION 11 – PRIVACY POLICY UPDATES AND AMENDMENTS

11.1. We reserve the right to modify or amend this Privacy Policy at any time. You should review this Privacy Policy frequently. Your continued usage of the Website shall mean your acceptance of those amendments and updates.

SECTION 12 – YOUR RIGHTS AS THE DATA SUBJECT

12.1. You as the Personal Data subject have the rights in accordance with the provisions of the General Data Protection Regulation (EU) 2016/679, including the right to:

• Access, update or delete the information we hold about you;
• Correct your information if this information is inaccurate or incomplete;
• Object to our processing of your Personal data;
• Restrict the processing of your personal information;
• Transfer data. You have the right to receive a copy of your Personal data in a structured, printed format;
• Withdraw consent. You also have the right to revoke your consent at any time.

You also have the right to lodge a complaint to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority in the European Economic Area (EEA). We recommend you contact us to resolve all your questions and inquiries to the extent permitted by law, and we will reply promptly.

12.2. You agree that the way of implementation of your rights is subject to the terms of this Privacy Policy. The following paragraphs (12.3. and 12.4.) are the way to implement some of your rights under the provisions of the General Data Protection Regulation.

12.3. ACCESS TO PERSONAL DATA

You have the right to access your personal information so that you can review what we have stored, as well as make corrections to your Personal data. You can request access to the information or make corrections by writing to us at the email address provided in the Contact information section below. If the information is not available or changed, we will inform you of the reasons for that. Please note that we may ask you to verify your identity before responding to such requests.

12.4. DATA DELETION

How to remove (delete) your personal data? You have the right to require deletion of your Personal data by sending us an email to at the email address provided in the Contact information section below. Please mind that we will not be able to provide our Services without some of the required data.

You also can revoke your consent to Personal data processing at any time. In the event that you withdraw your consent to Personal data processing and we will have no legal basis to continue processing your data, we will stop processing your Personal information. If we have legal grounds for processing your information, we have the right to continue using Personal data within the limits provided by law.

Please mind that We may retain part or all of the User’s data and not delete it until a later stage, when all possible requirements related to the User’s Personal data have been met (for example, in relation to the provision of services, prevention of fraud, compliance with any legal obligations, dispute resolution, agreement enforcement, etc.). In the event that We delete any user-generated content, including Personal data, this content will be removed from the active database but may remain in Our archives. This archived version is in no way and under any circumstances intended to be used as a backup and is not available to any user.

SECTION 13 – CONTACT US

13.1. If you have questions regarding this Privacy Policy, please contact us at the contact information indicated below:

Alvla s.r.o.

K zahrádkám 2605/5 Praha 13 PSČ 155 00 Česká republika

alvla@seznam.cz

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