Privacy Notice
Website and E-mail Privacy Notice.
1. Introduction
When visiting our website, Rubena, s.r.o., Českých bratří 338, 547 01 Náchod, Czech Republic (“Rubena”, “we”, “us”) may collect and process personal data (“Personal Data”) about you.
This privacy notice (“Privacy Notice”) sets out which Personal Data that we collect on our websites and for which purposes the Personal Data are processed. Throughout this Privacy Notice the term “processing” is used to cover all activities involving your Personal data, including collecting, handling, storing, sharing, accessing, using, transferring and disposing of information.
“Applicable Data Privacy Laws” means all legislation and regulations, including regulations issued by relevant supervisory authorities, protecting the fundamental rights and freedoms of individuals and, in particular, their right to privacy with respect to the processing of Personal Data that from time to time apply to Rubena, including without limitation data protection laws and regulations implementing the Data Protection Directive 95/46/EC and as of 25 May 2018 the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 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) (“GDPR”).
“Personal Data” is defined as any information relating to an identified or identifiable natural person.
2. Cookies - why do we collect and process your Personal Data
Rubena uses cookies and other similar techniques to collect information about you and your device (such as phone or computer) when you visit our website. For more information regarding Rubena’s use of cookies and a description of the current purposes your Personal Data may be used for, please view our cookie policy. The purposes for which we use cookies include:
2.1. Personalize our interactions with you - offering relevant products and services
When you visit our websites, landing pages and submit forms on those websites we may collect and process your Personal Data in order to better understand you as a customer and to personalize our interactions with you, for example to show you products and services we think you may like.
We look at your use of the website, for example where you have clicked, your visit frequency, time spent per visit etc.
Personal Data processed for these purposes include:
- IP-address.
- Country or region.
- Areas of interest.
- www.rubena.eu activities such as Document downloads, Video views, contact form submissions, page views, visit frequency etc.
- Original source (“referral”) before visiting www.rubena.eu, such as which email link, website, social media post, advertisement clicks, etc. that led your visit to our website.
The legal basis for the above processing of your Personal Data is that the processing is necessary in order to fulfil our legitimate interest to better understand you as a customer and to personalize our interactions with you to show you relevant products and services, article.
2.2. Identify usage trends and compile statistics
When you visit our websites, landing pages and submit forms on those websites we may collect and process anonymized Personal Data in order to identify usage trends and for statistical purposes. We look at from which geographic regions our users are, such as country and language settings.
The legal basis for the above processing of your Personal Data is that the processing is necessary in order to fulfil our legitimate interest to identify usage trends and to compile statistics.
3. Why do we collect and process your personal data
3.1. Answer your Questions and handle Feedback in general
Most of our websites provide functionality for the visitor to communicate with us to ask questions and give feedback regarding our services and business. Where you use such functionality, Rubena will processes your Personal Data for the purposes of answering your questions and handle feedback from you.
Personal Data processed for these purposes include:
- First name.
- Last name.
- Email address.
- Address.
- Phone number.
- Feedback and comments made by you.
- Website source.
The legal basis for the above processing of your Personal Data is that the processing is necessary in order to fulfil our legitimate interest to answer questions and handle feedback from you. If you do not provide information marked with * on the website form, we will not be in a position to provide you with the requested service.
4. For how long do we keep your personal data
Rubena will retain Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by local law to which Rubena is subject. We are using the following criteria to establish our retention period:
- as long as we have an ongoing relationship with you (either as an individual or in your capacity as employed by one of our corporate customers, suppliers or co-operations partners or media, or as an investor/owner, board member or analyst);
- as required by legal obligations to which Rubena is subject (such as tax and accounting obligations);
- and as advisable in light of our legal position (such as applicable statutes of limitations).
5. Disclosure and transfer of Personal data
5.1. Group companies
Rubena may disclose Personal Data processed to other companies within the KAPRAIN group. Rubena has made sure to apply appropriate safeguards to your Personal Data in case of any such transfer of your Personal Data within the KAPRAIN group by entering into an Intra-Group Data Transfer Agreement, implementing the European Commission Standard Contractual Clauses to any such transfer.
5.2. Other recipients
Courts and outside counsels.
Purpose of transfer: In order to exercise, establish or defend legal claims.
Legal basis: To fulfill ours and yours legitimate interest to have disputes settled by competent courts.
5.3. Data processors acting on behalf of Rubena
Moreover, Rubena may disclose Personal data to external parties, such as vendors and service providers processing Personal data under the instructions of Rubena. Where such disclosure entails transfers of Personal data outside the EU/EEA, Rubena will ensure that European Commission Standard Contractual Clauses have been entered into between the transferring Rubena entity and the receiving external party. Alternatively, other safe guards will be put in place prior to such transfers.
6. Security
We will ensure that the access to your Personal Data is accurately secured by applying appropriate safeguards, depending on the circumstances taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk. In support of this commitment, we have implemented appropriate technical, physical and organizational measures to protect your Personal Data against unauthorized or accidental destruction, alteration or disclosure; misuse; damage; theft or accidental loss; or unauthorized access.
7. Your rights
7.1. Right of rectification
Rubena will take steps in accordance with Applicable Data Privacy Laws to keep your Personal Data accurate, complete and up-to-date. If you identify that any Personal Data related to you is inadequate, incomplete or incorrect, you are entitled to have the Personal Data corrected.
Moreover, you also have the right to request access to the Personal Data that we process about you.
7.2. Further rights as of 25th May 2018
As of 25th May 2018, you may under Applicable Data Privacy Laws also in addition to rectification be entitled to:
7.2.1. Access
You may request confirmation whether or not Personal Data is processed and if that is the case access to your Personal Data and additional information such as the purposes of the processing. You are also entitled to receive a copy of the Personal Data undergoing processing. If the request is made by electronic means the information will be provided in a commonly used electronic format if you do not request otherwise.
7.2.2. Object to certain processing
You may object to processing of your Personal Data processed on the basis of a legitimate interest, on grounds relating to your particular situation and to processing for direct marketing purposes. If you have opted to receive a subscription by email each email will include an easy accessible opt-out function where you may de-register from further communication.
7.2.3. Erasure
You may have your Personal Data erased under certain circumstances such as when your Personal Data it is no longer needed for the purposes for which it was collected.
7.2.4. Restriction of processing
You may ask us to restrict the processing of your Personal Data to only comprise storage of your Personal Data under certain circumstances such as for example when the processing is unlawful, but you do not want your Personal Data erased.
7.2.5. Withdrawal of consent
You have the right to at any time withdraw your consent to processing of Personal Data to the extent the processing is based on your consent.
7.2.6. Data Portability
You may ask to receive a machine-readable copy of the Personal Data processed on the basis of your consent or on the basis that the processing is necessary in order to perform an agreement with you, and which Personal Data have been provided to Rubena by you (data portability) and ask for the information to be transferred to another data controller (where possible).
7.3. Complaints to the supervisory authority
You acknowledge that you always have the right to lodge complaints pertaining to the processing of your Personal Data to the competent data protection authority if so provided under Applicable Data Privacy Laws. The data protection authority can be reached here www.uoou.cz.
8. Contact information
If you have any questions or concerns regarding the processing of your Personal data or wish to exercise any of your rights, or obtain a copy of the safeguard mechanisms put in place to protect your Personal Data in case of any transfer, please contact Rubena on the contact details set forth below.
The data controller for Personal data is Rubena, s.r.o.
Českých bratří 338, 547 01 Náchod, Czech Republic
E-mail: gdpr@rubena.cz
Phone: +420 491 447 511
Camera system
Rubena, s.r.o. operates a camera system with recording, which is designed to protect property, increase personal safety and prevent illegal acts. The recordings from the camera system are automatically stored in accordance with the internal directive.
E-mail: cctv@rubena.cz
Telephone: +420 491 447 179