Privacy policy

of Packeta International s.r.o.
effective from February 1, 2022

1. INTRODUCTION

Your privacy is very important to us. This document provides information regarding the purpose and reason for personal data processing by our company, the manner in which we process personal data, and the categories of the data processed.
You can also learn about the rights you have in connection with personal data processing and the ways of contacting us should you have any questions concerning the processing of your personal data or should you request rectification or erasure of your personal data.
We process your personal data in the least extensive scope possible which still allows us to reach the primary purpose for which the data was collected, and we observe adequate security rules while doing so.

2. WHO ARE WE AND HOW CAN YOU CONTACT US?

During and with regard to the provision of our services, we – Packeta International s.r.o., a company with its registered office at Českomoravská 2408/1a, Libeň, 190 00 Prague 9, Id. No.: 02018799, registered with the Municipal Court in Prague, Section C, File 301190 (hereinafter “we”, the “controller” or “Packeta”) – collect and process your personal data as their controller.
We process your personal data in compliance with 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; hereinafter the “GDPR”), and with Act No. 110/2019 Coll., on personal data processing.
In personal data processing, we take care to ensure that your personal data are duly protected, in particular to prevent unauthorised handling of personal data or their other misuse. You may ask questions and exercise your rights in relation to personal data processing:
– by e-mail at: privacy@zasilkovna.cz; or
– by presenting your inquiry in printed form at the address of Packeta’s registered office:
Českomoravská 2408/1a, Libeň, 190 00 Prague 9.
For more details on the various options for exercising your rights, see the section Procedure in filing a request concerning personal data protection. Before we respond to any request concerning personal data protection, we are authorised and simultaneously obliged to verify the identity of the one who files the request.

3. WHAT PERSONAL DATA DO WE PROCESS?

As a data controller, we process personal data in the categories listed below. Within these categories, we always process only selected personal data as required for attaining a specific purpose, and primarily so that we are able to provide you with the relevant services or to co-operate with you.

We process the following categories of personal data:
− Identification and authentication data (especially the name, surname, company name, date of birth, Id. No., login details including username and password, nickname, ID FB Messenger, application ID, potentially also a partial ID number where our products or services require it, such as verification of a particular identity or age)
− Address and contact details (especially the e-mail address, telephone number, address for collecting and delivering consignments, registered office)
− Operating data (especially system data on the consignment being transported, data on login to the application and on the payment made, if appropriate, system data on messages sent, IP address, cookies, license plate number, mobile phone IMEI)
− Data on activities(especially personal data comprised in incoming e-mails or recordings of telephone calls received by the call center, and photo documentation or any other documents regarding a claim enforced, or online activity and attitudes expressed publicly in connection with our products or services)
− Localization data (especially data on the course of delivery of a consignment, vehicle’s GPS, or your coordinates when we need them to ensure proper delivery such as when picking up shipment from Z-BOX, or when having shipment delivered to your vehicle)
− Economic and billing data (especially data regarding C.O.D., amount of payment, bank account number, payment card number, billing address)
− Biographical data (especially data contained in the professional curriculum vitae, education attained)
The specific purposes of data processing and categories of personal data that we process for the individual purposes are described in the following part: Purposes and methods of personal data processing.

4. FOR HOW LONG DO WE PROCESS YOUR PERSONAL DATA?

In most cases, we will retain your personal data for the duration of the provider-customer relationship or other contractual relationship, i.e. especially during the existence of the user account and during transportof the consignment, and also until the end of any complaint periods, statutory limitation periods and, if applicable, archiving periods laid down by the legal regulations.
In cases where processing of your personal data is based on your consent, we process your personal data only for the duration of this consent. For this purpose, we keep a database of consents granted. You can revoke your consent anytime. For more detailed information on the duration of personal data processing, see the following part: Purposes and methods of personal data processing.

5. PURPOSES AND METHODS OF PERSONAL DATA PROCESSING

5.1 RECIPIENTS OF E-SHOP CONSIGNMENTS OR CONSIGNMENTS SENT USING THE “BETWEEN US” SERVICE

In cases where we deliver goods from an e-shop or via our Between Us service, we process your personal data for the purposes specified in the table below. We obtain personal data for these purposes directly from you (when you enter them in the Packeta application), or from the senders of consignments (e-shops and users of our Between Us service) or from our own operations. If we obtain your personal information from another source than yourself, such as the sender while using the service “Between Us” we are not able to verify if such information is correct. If you feel your data has been entered incorrectly by someone or abused, please let us know and we will provide assistance in solving it.

Purpose	Description	Personal data category	Legal ground
Delivery of consignments	We process your personal data to the necessary extent in order to be able to deliver to you any goods you have ordered from an e-shop or so that a consignment from a sender using the Between Us service can reach you, and to be able to inform you about the course of delivery. In this respect, we also keep records of consignments sent and any C.O.D. payments. During the process of delivering a consignment, we send notifications to you regarding the course of delivery, using your contact details we obtained from the sender. These notifications are sent by e-mail or as a text (SMS) message, or via the Packeta application or FB Messenger. We track the route of the consignments and analyse it to ensure the most effective delivery. In some cases, we can ask you to share your location coordinates at a given moment for example when you are picking up a delivery from Z-BOX. In such instance we only use your location data to ensure proper delivery, or to provide you with assistance in finding another delivery spot. In case you select delivery into your vehicle, we may process data about your vehicle, such as its location, its registration number, model and make. Such processing is only carried out in order to ensure proper delivery and the scope is properly minimized. We process your data for this purpose for as long as we are arranging and ensuring the transport of the consignment, and also for the period of time required by the applicable legal regulations, if relevant.	Identification and authentication data Address and contact details Operating data Localisation data Economic and billing data	Legitimate interest, specifically the performance of a contract concluded with the consignment’s sender or our contractual partner – Art. 6 (1)(f) of the GDPR Compliance with a legal obligation – Art. 6 (1)(c) of the GDPR
User account in the application	If you create a user account in the Packeta application, we will process your personal data to the necessary extent so that we can provide you with all its functions under the terms of use of the application, and in particular, inform you of the status of a consignment being transported. In this case, we will also process your personal data for the purposes specified in Art. 5.5. We process your data for this purpose during the term of existence of the user account. You can request deletion of the account as well as your data directly in the application.	Identification and authentication data Address and contact details Operating data Economic and billing data	Performance of a contract/steps taken before its conclusion – Art. 6 (1)(b) of the GDPR Legitimate interest in improving our services – Art. 6 (1)(f) of the GDPR
Resolving claims and complaints	If you were dissatisfied with the service we provided to you within delivery of a consignment, we will process your personal data with a view to properly resolving your claim or complaint. We process your data for this purpose for the duration of the complaint procedure and, further, for as long as a claim under the contract concluded with the sender can be exercised.	Identification and authentication data Address and contact details Operating data Data on activities Economic and billing data	Legitimate interest, specifically the performance of a contract concluded with the consignment’s sender or our contractual partner – Art. 6 (1)(f) of the GDPR
Customer support	If you contact our customer support or wish to rate our services, we will record the communication via the communication channels you use, such as e-mail, chat and recorded telephone calls, and we may process such data further so that we can provide you with the services you request and improve our services in general. If your inquiry concerns services provided by our contractual partner, we may transfer your personal data to this partner if suitable with a view to ensuring that support is provided to your satisfaction. We may use tools including weak artificial intelligence to carry out some of these tasks, such as voicebot, or another AI tool to support email classification and other administrative tasks. Before we use any such tool, we carry our respective impact assessments. We process your data for this purpose while processing your inquiry and then for no more than 1 year from the time you contacted our customer support.	Identification and authentication data Address and contact details Data on activities	Legitimate interest in improving our services – Art. 6 (1)(f) of the GDPR
Establishment, exercise or defence of legal claims, internal control and records	We also retain and process your personal data with a view to establishing, exercising or defending legal claims. Whenever we deliver a consignment to you, we retain all the data relevant for any legal claims that may be raised by us or our contractual partners in the future, especially in the form of court and other proceedings, or to resolve any claims based on your authorization. Similarly, if you send us a request concerning data protection, we retain all the data you provide to us in this regard, together with information on the way we resolved the request. We process your data for this purpose for as long as any claim related to the provision of a specific service can be enforced, usually for as long as a claim can be enforced under a contract concluded with the sender of the consignment, or for the period of time laid down by the legal regulations.	Identification and authentication data Address and contact details Operating data Data on activities Economic and biling data	Legitimate interest in protecting our property and due managerial care – Art. 6 (1)(f) of the GDPR

5.2 SENDERS OF CONSIGNMENTS USING THE “BETWEEN US” SERVICE

Whenever a consignment is sent via the Packeta application within the Between Us service, we will arrange for the transport of the relevant consignment and enable you to monitor the status of the transport and delivery. Whenever a consignment is delivered on C.O.D. terms, we will collect the price. In relation to these services, we process your personal data for the purposes specified in the table below. We obtain personal data for these purposes directly from you (in particular, when you enter them in the Packeta application) or from our own operations.

Purpose	Description	Personal data category	Legal ground
Arranging for the transport of consignments	We need to process your personal data which are required for the conclusion and performance of our mutual contract as described in our terms and conditions, or else we will not be able to conclude the contract with you, carry out the agreed transport and properly deliver your consignment. We also require your data to ensure proper payment of the fee for arranging the transport. In this respect, we also keep records of consignments sent and any C.O.D. payments. We use your data for sending the necessary information related to the concluded contract (e.g. an amendment to the T&C or the price list). We process your data for this purpose for the necessary period of time before the conclusion of our contract and then during the term of our contractual relationship, and also for the period of time required by the applicable legal regulations, if relevant. This relates, in particular, to the duties under Act No. 89/2012 Coll., the Civil Code, Act No. 634/1992 Coll., on value added tax, and Act No. 563/1991 Coll., on accounting. If you send us a request concerning personal data protection in order to exercise one of your rights, we will ask you to provide us with certain personal data that we will subsequently process to comply with the applicable legal regulations.	Identification and authentication data Address and contact details Operating data Data on activities Economic and billing data Localization data	Performance of a contract/steps taken before its conclusion – Art. 6 (1)(b) of the GDPR Compliance with a legal obligation – Art. 6 (1)(c) of the GDPR
User account in the application	If you create a user account in the Packeta application, we will process your personal data to the necessary extent so that we can provide you with all its functions under the terms of use of the application, and in particular, inform you of the status of a consignment being transported. In this case, we will also process your personal data for the purposes specified in Art. 5.5. We process your data for this purpose during the term of existence of the user account. You can request deletion of the account as well as your data directly in the application.	Identification and authentication data Address and contact details Operating data Economic and billing data	Performance of a contract/steps taken before its conclusion – Art. 6 (1)(b) of the GDPR
Accepting and making payments and bookkeeping	We accept payments from you for the provision of our services and also in the provision of services in cases where a consignment is delivered on C.O.D. terms, or make payments to you, and we issue accounting and tax receipts that we subsequently archive and use for the needs of proper bookkeeping and performance of our statutory duties. We process your data for this purpose during the term of existence of our contractual relationship. Accounting and tax receipts are further retained for the periods specified by the legal regulations on bookkeeping and VAT	Identification and authentication data Address and contact details Operating data Economic and billing data	Performance of a contract/steps taken before its conclusion – Art. 6 (1)(b) of the GDPR Data necessary for compliance with legal obligations – Art. 6 (1)(c) of the GDPR
Resolving claims and complaints	If you were dissatisfied with the service we provided to you within delivery of a consignment or want to make some other inquiry in this regard, we will process your personal data with a view to properly resolving your claim or complaint. We process your data for this purpose for the duration of the complaint procedure and, further, for as long as a claim under the contract concluded with you can be exercised.	Identification and authentication data Address and contact details Operating data Data on activities Economic and billing data	Performance of a contract/steps taken before its conclusion – Art. 6 (1)(b) of the GDPR Legitimate interest in protecting our property and due managerial care – Art. 6 (1)(f) of the GDPR
Customer support	If you contact our customer support, we will record the communication via the communication channels you use, such as email, chat and recorded telephone calls, and we may process such data further so that we can provide you with the services you request. If your inquiry concerns services provided by our contractual partner, we may transfer your personal data to this partner if suitable with a view to ensuring that support is provided to your satisfaction. We may use tools including weak artificial intelligence to carry out some of these tasks, such as voicebot, or another AI tool to support email classification and other administrative tasks. Before we use any such tool, we carry our respective impact assessments. We process your data for this purpose for a period of 1 year from the time you contacted our customer support.	Identification and authentication data Address and contact details Data on activities	Legitimate interest in improving our services – Art. 6 (1)(f) of the GDPR
Establishment, exercise or defence of legal claims, internal control and records	We also retain and process your personal data with a view to establishing, exercising or defending legal claims (including debt collection). Whenever we arrange for delivery of a consignment for you, we retain all the relevant data for any legal claims that may be raised by us or you in the future, especially in the form of court and other proceedings, or to resolve any claims based on your authorization. Similarly, if you send us a request concerning personal data protection, we retain all the data you provide to us in this regard, together with information on the way we resolved the request. We process your data for this purpose for as long as any claim related to the provision of a specific service can be enforced, usually during the statutory limitation period ensuing from the applicable legal regulations.	Identification and authentication data Address and contact details Operating data Data on activities Economic and billing data Localization data	Legitimate interest in protecting our property and due managerial care – Art. 6 (1)(f) of the GDPR
Direct marketing, regarding our own services or requests for feedback	If we have provided a service to you, we may also send you information on some other similar services and products we offer or ask for your feedback. You may object to the processing of personal data for this purpose and we will stop sending this kind of information to you or will stop asking for your feedback. We process your data for this purpose during the term of existence of our contractual relationship and then for a period of 1 year after its termination.	Identification and authentication data Address and contact details Operating data	Legitimate interest in maintaining and developing business activities and improving our services – Art. 6 (1)(f) of the GDPR
Direct marketing, other offers and services	If you give us your expressed consent, we may send you marketing communications for services that are not directly connected to our own products or services. This consent is valid from the moment is has been given to us and you can revoke it anytime. We process your data for this purpose throughout the duration of the consent validity.	Address and contact details	Legitimate interest in maintaining and developing business activities and improving our services – Art. 6 (1)(f) of the GDPR

5.3 SENDERS OF CONSIGNMENTS – E-SHOPS

If you enter into or wish to enter into a contract with us in order for us to provide services consisting in arranging for the transport of consignments from you to your customers (the Delivery to Delivery Point service or the Best Delivery to Specific Address service, or some other similar service), we will process your personal data for the purposes specified in the table below. We obtain personal data for these purposes directly from you or from our own operations.

Purpose	Description	Personal data category	Legal ground
Arranging for the transport of consignments	In order to be able to conclude a contract with you and make it possible to deliver a consignment from your e-shop to a customer, we co-operate with you and our partners to ensure that the whole process of the provision of our services runs smoothly, and we process your personal data for this purpose. We also require your data to ensure proper payment of the fee for arranging the transport We process your data for this purpose for the necessary period of time before the conclusion of our contract and then during the term of our contractual relationship, and also for the period of time required by the applicable legal regulations, if relevant. This relates, in particular, to the duties under Act No. 89/2012 Coll., the Civil Code, Act No. 634/1992 Coll., on value added tax, and Act No. 563/1991 Coll., on accounting. If you send us a request concerning personal data protection in order to exercise one of your rights, we will ask you to provide us with certain personal data that we will subsequently process to comply with the applicable legal regulations.	Identification and authentication data Address and contact details Operating data Localisation data	Performance of a contract/steps taken before its conclusion – Art. 6 (1)(b) of the GDPR Compliance with a legal obligation – Art. 6 (1)(c) of the GDPR
User account	If you, as an e-shop, create a user account on our website, or we create your account based on your request, we will process your personal data to the necessary extent so that we can provide you with all its functions. We process your data for this purpose during the term of existence of the user account.	Identification and authentication data Address and contact details Operating data Economic and billing data	Performance of a contract/steps taken before its conclusion – Art. 6 (1)(b) of the GDPR
Sending information directly related to our contractual relationship	We also process your personal data in cases where we send you information directly related to our contract (e.g. an amendment to the T&C or price list). We process your data for this purpose during the term of existence of our contractual relationship.	Identification and authentication data Address and contact details	Performance of a contract/steps taken before its conclusion – Art. 6 (1)(b) of the GDPR
Direct marketing related to our products or services, requests for feedback	If we have provided a service to you, we may also send you information on some other similar services and products we offer, or ask for your feedback. You may object to the processing of personal data for this purpose and we will stop sending this kind of information to you. We process your data for this purpose during the term of existence of our contractual relationship and then for a period of 1 year after its termination.	Identification and authentication data Address and contact details Operating data	Legitimate interest in maintaining and developing business activities – Art. 6 (1)(f) of the GDPR
Direct marketing, other offers and services	If you give us your expressed consent, we may send you marketing communications for services that are not directly connected to our own products or services. This consent is valid from the moment is has been given to us and you can revoke it anytime. We process your data for this purpose throughout the duration of the consent validity.	Address and contact details	Legitimate interest in maintaining and developing business activities and improving our services – Art. 6 (1)(f) of the GDPR
Support for eshops	Within the provision of our support services to our contractual partners, we record all communication in all communication channels, such as e-mail, chat and recorded telephone calls, and we may process such data further so that we can provide you with the support you request and improve our services. We process your data for this purpose for a period of 1 year from the time you contacted our customer support.	Identification and authentication data Address and contact details Data on activities	Legitimate interest in improving our services – Art. 6 (1)(f) of the GDPR
Administration of business opportunities	We always strive to maintain and expand the portfolio of our services; we care for our current contractual partners and seek new ones. We may process your personal data for this purpose. We process your data for this purpose for up to 2 years since first contact if there is no contract or during the term of existence of our contractual relationship and then for a period of 4 years after the contract termination.	Identification and authentication data Address and contact details Operating data	Legitimate interest in maintaining and developing business activities – Art. 6 (1)(f) of the GDPR
Acceptance of payments and bookkeeping	We accept payments from you or your customers in the provision of our services and also in the provision of services in cases where a consignment is delivered on C.O.D. terms, and we issue accounting and tax receipts that we subsequently archive and use for the needs of proper bookkeeping and performance of our statutory duties. We process your data for this purpose during the term of existence of our contractual relationship. Accounting and tax receipts are further retained for the periods specified by the legal regulations on bookkeeping and VAT.	Identification and authentication data Address and contact details Operating data Economic and billing data	Performance of a contract/steps taken before its conclusion – Art. 6 (1)(b) of the GDPR Data necessary for compliance with legal obligations – Art. 6 (1)(c) of the GDPR
Establishment, exercise or defence of legal claims, internal control and records	We also retain and process your personal data with a view to establishing, exercising or defending legal claims (including debt collection). Whenever we arrange for delivery of a consignment for you, we retain all the relevant data for any legal claims that may be raised by us or you in the future, especially in the form of court and other proceedings, or to resolve any claims based on your authorization. Similarly, if you send us a request concerning personal data protection, we retain all the data you provide to us in this regard, together with information on the way we resolved the request. We process your data for this purpose for as long as any claim related to the provision of a specific service can be enforced, usually during the statutory limitation period ensuing from the applicable legal regulations.	Identification and authentication data Address and contact details Operating data Data on activities Economic and billing data Localization data	Legitimate interest in protecting our property and due managerial care – Art. 6 (1)(f) of the GDPR

5.4 CONTRACTUAL PARTNERS – CARRIERS, DISTRIBUTION POINTS, ETC.

If you co-operate with us and help us provide our services to our contractual partners and customers, we process your personal data for the purpose of their smooth provision and achieving your and customer satisfaction. In that case, we process your personal data for the purposes specified in the table below. We obtain personal data for these purposes directly from you or from our own operations.

Purpose	Description	Personal data category	Legal ground
Dispatch, transport and handover of consignments	In order to be able to deliver goods from an eshop to the customer or to enable our clients to transport consignments via the Between Us service, we enter into contracts with you as our partners and co-operate with you to ensure that the entire process of providing our services runs smoothly. We process your personal data for this purpose. We process your data for this purpose for the necessary period of time preceding the establishment of our contractual relationship and during the term of existence of this relationship.	Identification and authentication data Address and contact details Operating data Localization data	Performance of a contract/steps taken before its conclusion – Art. 6 (1)(b) of the GDPR
User account	If you, as a distribution point, create a user account on our website, we will process your personal data to the necessary extent so that we can provide you with all its functions. The extent of the personal data processed will change depending on which personal information you enter in your account. We process your data for this purpose during the term of existence of the user account.	Identification and authentication data Address and contact details Operating data Economic and billing data	Performance of a contract/steps taken before its conclusion – Art. 6 (1)(b) of the GDPR
Sending information directly related to our contractual relationship	We also process your personal data in cases where we send you information directly related to our contract (e.g. an amendment to the T&C or price list). We process your data for this purpose during the term of existence of our contractual relationship.	Identification and authentication data Address and contact details	Performance of a contract/steps taken before its conclusion – Art. 6 (1)(b) of the GDPR
Direct marketing connected to our products or services, requests for feedback	If we have provided a service to you, we may also send you information on some other similar services and products we offer or ask for your feedback. You may object to the processing of personal data for this purpose, and we will stop sending this kind of information to you. We process your data for this purpose during the term of existence of our contractual relationship and then for a period of 1 year after its termination.	Identification and authentication data Address and contact details Operating data	Legitimate interest in maintaining and developing business activities – Art. 6 (1)(f) of the GDPR
Direct marketing, other offers and services	If you give us your expressed consent, we may send you marketing communications for services that are not directly connected to our own products or services. This consent is valid from the moment is has been given to us and you can revoke it anytime. We process your data for this purpose throughout the duration of the consent validity.	Address and contact details	Legitimate interest in maintaining and developing business activities and improving our services – Art. 6 (1)(f) of the GDPR
Administration of business opportunities	We always strive to maintain and expand the portfolio of our services; we care for our current contractual partners and seek new ones. We may process your personal data for this purpose. We process your data for this purpose during the term of existence of our contractual relationship and then for a period of 1 year after its termination.	Identification and authentication data Address and contact details Operating data	Legitimate interest in maintaining and developing business activities – Art. 6 (1)(f) of the GDPR
Establishment, exercise or defence of legal claims, internal control and records	We also retain and process your personal data with a view to establishing, exercising or defending legal claims (including debt collection). Whenever we arrange for delivery of a consignment for you, we retain all the relevant data for any legal claims that may be raised by us or you in the future, especially in the form of court and other proceedings, or to resolve any claims based on your authorization. Similarly, if you send us a request concerning personal data protection, we retain all the data you provide to us in this regard, together with information on the way we resolved the request. We process your data for this purpose for as long as any claim related to the provision of a specific service can be enforced, usually during the statutory limitation period ensuing from the applicable legal regulations.	Identification and authentication data Address and contact details Operating data Data on activities Economic and billing data Localization data	Legitimate interest in protecting our property and due managerial care – Art. 6 (1)(f) of the GDPR
Support for contractual partners	Within the provision of our support services to our contractual partners, we record all communication in all communication channels, such as e-mail, chat and recorded telephone calls, and we may process the data further so that we can provide you with the support you request and improve our services. We process your data for this purpose for a period of 1 year from the time you contacted our customer support.	Identification and authentication data Address and contact details Data on activities	Legitimate interest in improving our services – Art. 6 (1)(f) of the GDPR
Accepting and making payments and bookkeeping	We accept payments from you in the provision of our services and also in the provision of services in cases where a consignment is delivered on C.O.D. terms, or make payments to you, and we issue accounting and tax receipts that we subsequently archive and use for the needs of proper bookkeeping and performance of our statutory duties. We process your data for this purpose during the term of existence of our contractual relationship. Accounting and tax receipts are further retained for the periods specified by the legal regulations on bookkeeping and VAT.	Identification and authentication data Address and contact details Operating data Economic and billing data	Performance of a contract/steps taken before its conclusion – Art. 6 (1)(b) of the GDPR Data necessary for compliance with legal obligations – Art. 6 (1)(c) of the GDPR
Performance of legal obligations	We need to process some personal data regarding yourselves in order to perform certain legal obligations applicable to us. Since this is required of us by the law, we need not request your consent in this case. This relates, in particular, to the duties under Act No. 89/2012 Coll., the Civil Code, Act No. 634/1992 Coll., on value added tax, and Act No. 563/1991 Coll., on accounting. If you send us a request concerning personal data protection in order to exercise one of your rights, we will ask you to provide us with certain personal data that we will subsequently process to comply with the applicable legal regulations. We process your data for this purpose for the period specified by the given legal regulation.	Identification and authentication data Address and contact details	Data necessary for compliance with legal obligations – Art. 6 (1)(c) of the GDPR

5.5 DATA OF ALL USERS OF THE PACKETA APPLICATION

If you install our application, we process your personal data in order to simplify as much as possible the dispatch and receipt of consignments and enable you to make use of all the useful functions of the Packeta application. Our app may, from time to time, show you adds and banners on its homefeed. Within such display there is no further data processing of your personal information, we do not track your activity and we do not personalize the adds in any way and do not share your data with 3rd party advertisers. More on how we process your data within the app is below.

Purpose	Description	Personal data category	Legal ground
User account and provision of the application’s functions	If you create a user account via the Packeta application, we will process your personal data to the necessary extent so that we can provide you with all its functions. The extent of the personal data processed will change depending on which personal data you enter in your account and what application’s services you will use in conformity with the terms and conditions of the application. We process your data for this purpose during the term of existence of the user account.	Identification and authentication data Address an contact details Operating data Data on activities	Performance of a contract/steps taken before its conclusion – Art. 6 (1)(b) of the GDPR
Sending information directly related to the application	We process your personal data in cases where we send you information directly related to functioning of the application. We process your data for this purpose during the term of existence of the user account.	Identification and authentication data Address and contact details	Performance of a contract/steps taken before its conclusion – Art. 6 (1)(b) of the GDPR
Direct marketing regarding our goods or services requests for feedback	If you are a user of the Packeta application, we may also send or display information to you via the application regarding some other similar services and products we offer, or ask for your feedback. You may object to the processing of personal data for this purpose and we will stop sending this kind of information to you. We process your data for this purpose during the term of existence of the user account.	Identification and authentication data Address and contact details Operating data	Legitimate interest in improving our services and informing the customers about similar services we offer – Art. 6 (1)(f) of the GDPR
Direct marketing, other offers and services	If you give us your expressed consent, we may send you marketing communications for services that are not directly connected to our own products or services. This consent is valid from the moment is has been given to us and you can revoke it anytime. We process your data for this purpose throughout the duration of the consent validity.	Address and contact details	Legitimate interest in maintaining and developing business activities and improving our services – Art. 6 (1)(f) of the GDPR
Establishment, exercise or defence of legal claims, internal control and records	We also retain and process your personal data with a view to establishing, exercising or defending legal claims (including debt collection). Whenever we arrange for delivery of a consignment for you, we retain all the relevant data for any legal claims that may be raised by us or you in the future, especially in the form of court and other proceedings, or to resolve any claims based on your authorization. Similarly, if you send us a request concerning personal data protection, we retain all the data you provide to us in this regard, together with information on the way we resolved the request. We process your data for this purpose for as long as any claim related to the provision of a specific service can be enforced, usually during the statutory limitation period ensuing from the applicable legal regulations.	Identification and authentication data Address and contact details Operating data Data on activities	Legitimate interest in protecting our property and due managerial care – Art. 6 (1)(f) of the GDPR

5.6 OTHER TYPES OF DATA SUBJECTS AND POSSIBLE PROCESSING OF THEIR PERSONAL DATA

In some cases, we may process your data even if we are not delivering a consignment directly to you or if you have not concluded a contract with us. In that case, we process your personal data for the purposes specified in the table below. We obtain personal data for these purposes directly from you, from third parties (e.g. your employers) or from our own operations.

Purpose	Description	Personal data category	Legal ground
Dealing with other inquiries	If you send us any inquiry not directly related to a service we provide to you (e.g. it does not involve a claim or complaint), we may process your personal data as required for responding to the inquiry. We process your data for this purpose for a period of 1 year from the time you send your inquiry.	Identification and authentication data Address and contact details Operating data Data on activities	Legitimate interest in improving our services – Art. 6 (1)(f) of the GDPR
Brand loyalty evaluation	As a part of analyzing the loyalty and attitudes of our current, perspective or past customers we may view and process your communication on our website or social networking sites, including processing your comments about our services or our company. We may use tools using weak artificial intelligence for such processing, such as voicebot or tools creating charts or conducting communication administration and analytics. Before we use any such tool we carry our impact assessment. Where possible, we aggregate or anonymize your data. We retain your data while the purpose lasts.	Identification and authentication data Address and contact details Data on activities	Legitimate interest in improving our services – Art. 6 (1)(f) of the GDPR
CCTV	If you visit the premises of our depot or our reception area, we retain your personal data in the form of a video recording, carried out by closed circuit cameras, including those that may include weak artificial intelligence functions. doing so in the interest of protecting our property, protecting your safety and health and that of our employees, and for the purpose of proper handling of any complaints. We process your data for this purpose for a period of 3 days in the case of video recordings of our reception area, and for a period of up to 90 days in the case of video recordings of our depots, with a view to conducting any complaint procedure.	Video recordings comprising personal data (especially about a data subject’s activity)	Legitimate interest consisting in the protection of the controller’s property and the safety and health of the controller’s employees and contractual partners – Art. 6 (1)(f) of the GDPR
Sending other commercial communications with your consent	If you wish, you can subscribe on our website, or via email in our application or at any other site related to our services or services of our partners, to receive our newsletters or similar promotional material we prepare for our current and prospective customers. When subscribing to newsletters and similar material, you need to provide us with certain personal data that will be processed with your consent. We process your data for this purpose only for the duration of the consent given to us. For this purpose, we keep a database of consents granted where we differentiate consents for specific purpose.	Address and contact details Operating data	Consent of the recipient of our newsletter provided via the website or application – Art. 6 (1)(a) of the GDPR
Employees and other persons authorized by recipients, senders or our contractual partners	If you are an employee or some other authorized person of the sender, recipient or our contractual partner, we may process your personal data in connection with the proper provision of our services. We process your data for this purpose for as long as we process the data for the sender, recipient or other contractual partner.	Identification and authentication data Address and contact details	Legitimate interest in a proper provision of our service – Art. 6 (1)(f) of the GDPR
Job seekers	If you apply for a job, we process your personal data as required to assess your suitability for the given job and for potential execution of the given labour-law contract. If you give your consent to this effect, we also process your personal data for the set period of time with a view to contacting you with an offer of some other job which we might consider suitable for you, if appropriate. We process your data for this purpose only for the duration of the consent given and, if you do not give such consent, we process your data only for the duration of the selection procedure or decision-making on hiring you. For this purpose, we keep a database of consents granted.	Identification data Address and contact details Biographical data	ta Legitimate interest in assessing the suitability of a job candidate – Art. 6 (1)(f) of the GDPR Performance of a contract/steps taken before its conclusion – Art. 6 (1)(b) of the GDPR Job seeker’s consent to being addressed with an offer of another job – Art. 6 (1)(a) of the GDPR

6. FROM WHAT SOURCES DO WE OBTAIN PERSONAL DATA?

In most cases, we process personal data provided directly by you when ordering our service or when communicating with us. If you are the recipient of a consignment we transport and do not use the Packeta application, we obtain your data from the consignment’s sender. In such case we are not liable for the accuracy of such information. We also obtain personal data directly from you by analysing your behaviour on our website through cookies and similar tools or via the Packeta application. If you visit our depots or the reception area, the data source is a video recording from the CCTV system monitoring our premises in order to help secure safety of people and assets.

7. COOKIES

Cookies may be processed either by us or by third parties as independent data controllers whenever you visit our website. Cookie is a short text file sent by the visited website to the browser. It enables the website to record information on your visit, e.g. your preferred language and other settings. Cookies store, inter alia, information related to your end device you used to display the website. Under certain conditions, this information may be considered personal data within the meaning of the GDPR. An overview of information (including the description and period of storage) contained in cookies is available at:
https://policies.google.com/technologies/cookies.

If you wish to disable cookies, delete them from your device in the internet browser. For more information, use the “help” option in your internet browser.

• Google Chrome:
https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en

• Internet Explorer: https://support.microsoft.com/en-us/topic/how-to-delete-cookiefiles-ininternet-explorer-bca9446f-d873-78de-77ba-d42645fa52fc

• Edge: https://support.microsoft.com/en-us/windows/microsoft-edge-browsing-data-andprivacybb8174ba-9d73-dcf2-9b4a-c582b4e640dd

• Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox

• Safari: https://support.apple.com/en-us/HT201265

• You may also turn on the “DNT“ (Do not track) regime

• (https://support.google.com/chrome/answer/2790761?co=GENIE.Platform%3DDesktop&hl=en-GB)
or the InPrivate regime (https://support.microsoft.com/en-us/microsoft-edge/browse-inprivateinmicrosoft-edge-cd2c9a48-0bc4-b98e-5e46-ac40c84e27e2) on your device, depending on the technology you use.

You can set up your internet browser in such a way that it will not permit saving any cookies whatsoever or that it will enable just selected cookies on your device. In that case, however, our company cannot guarantee the correct and expected functionality of our website and you will not be able to use certain parts and functions of the website. You can also use add-ons in your internet browser that will help you manage cookies, e.g.: https://tools.google.com/dlpage/gaoptout?hl=cs. For more information on cookies, visit:
https://www.aboutCookies.org/ or https://policies.google.com/technologies/types?hl=cs .

On our website www.zasilkovna.cz and www.packeta.com you can fully customize and manage your cookie experience and select cookies you want to allow. You can obtain more information about how we use cookies by clicking on “cookie settings” in the footer of the webpage.

8. JOINT CONTROLLERS AND PROCESSORS

Access to your personal data is limited to properly trained persons on a need-to-know basis, and anyone having access to your personal data is bound to maintain confidentiality.
Your personal data are controlled and processed primarily by Packeta itself. In cases specified by the law and in cases where our legitimate interests need to be protected, we may transfer your personal data, e.g. to governmental authorities, courts, prosecuting bodies, etc.
Packeta International is also a part of the Packeta group of companies. In view of the organisational and economic interconnection and for the purpose of proper transport of consignments and customer services (e.g. handling complaints, efficient provision of services during transport in various EU countries), your personal data may be shared to the necessary extent by group companies that have specified, together with Packeta, the purposes of processing your personal data as set out in this Policy and the means of their processing.

For these purposes, the companies entered in the following list are considered joint personal data controllers, together with Packeta:
– Packeta eCommerce GmbH, with its registered office at Torgauer Str. 231, D-04347 Leipzig, Germany, Id. No.: DE311123303
– Packeta Slovakia s. r. o., with its registered office at Kopčianska 3338/82A Bratislava – mestská časť Petržalka 851 01, Id. No.: 48 136 999,
– Packeta Poland Sp. z o.o., with its registered office at ul. Postepu 14, Warszawa 02-676, Id. No.: 362497885,
– PACKETA HUNGARY Kft., with its registered office at 1044 Budapest, Ezred utca 1-3. B2/11. ép., reg. No. 01-09-202186,
– Packeta Romania SRL, with its registered office at Str. Calusei 21A , Sectorul 2, Bucuresti, Rumunsko, Id. No.: 38132017

Packeta and the companies listed above, as joint controllers, process your personal data in accordance with an arrangement made by the joint controllers regarding personal data processing under Article 26 of the GDPR. Your rights related to personal data protection set out in Art. 9 of this Policy may be exercised at any of the joint controllers. Your request will then be dealt with by the company to which it was presented; other companies will provide that company with all the necessary collaboration as required for proper resolution of the request.
Each company will publish the information under Articles 13 and 14 of the GDPR separately on its own website in the relevant language version according to its registered office. The responsibility for notifying any cases of a personal data breach to a supervisory authority is borne primarily by the company established in the country where the breach occurs. If a breach occurs in several countries at the same time, all the companies concerned will co-operate as required to make a joint notification of the breach to a supervisory authority via the company established in the country where the most serious interference with the rights and freedoms of individuals can reasonably be assumed to have occurred.

Entities having the position of data processors, with whom we have concluded a processing agreement, may also participate in the processing of your personal data to a certain extent. The processors we use include, for example, accounting companies, tax advisors, lawyers, payment service providers, developers and marketing specialists, as well as software and cloud solution providers.

9. YOUR RIGHTS IN RELATION TO PERSONAL DATA PROTECTION

The following rights are guaranteed to you in the area of personal data processing, and you may exercise these rights vis-à-vis our company by e-mail or by submitting your request in printed form at the address of our registered office. You can also contact our data protection officer at: DPO@packeta.com

9.1 Right of access to personal data

Based on the right of access to information, you have specifically the right to:
− request confirmation as to whether or not we process your personal data;
− obtain information on the processing of your personal data, including especially information on the purposes of processing; the categories of the personal data being processed; the recipients (to whom the personal data have been or will be disclosed); the envisaged period of processing; the source of the personal data (if not obtained from you); the existence of automated decision-making, including profiling; and appropriate safeguards in case of a transfer of data outside the EU;
− request a copy of the personal data being processed; the first copy will be provided to you free of charge.

9.2 Right to rectification of personal data

If your personal data that we process are incorrect, inaccurate or have changed, you can request that they be rectified or supplemented.

9.3 Right to erasure of personal data (right to be forgotten)

9.3.1. If the purpose for which your personal data were processed ceases to exist or if you withdraw the consent on the basis of which we processed your personal data, we will erase your personal data without undue delay. We will also erase your personal data if you exercise your right to object to the processing of personal data that we process on the basis of our legitimate interests, and we determine that the legitimate interests that would authorise us to continue such processing have already ceased to exist. If you have any doubts as to the erasure or believe that your personal data have not been erased, you may exercise your right to erasure. In some cases, we are not required to erase your personal data or any of them. These are cases where we continue to need your personal data for a proper performance of our legal obligations or for the establishment, exercise or defence of legal claims.

9.3.2. Deletion of account within the “Between Us” app
The sender of shipments via the Between Us service and recipients of shipments using the Zasilkovna mobile application can request the automatic deletion of their account and related personal data directly from the app. Pressing the „Delete account” button in the PROFILE section starts the account deletion process. After the retention period of 90 days from the delivery of the shipment expires, or 180 days from the dispatch ofyour last shipment, your account in the application and related personal data in the app as well as our other systems will be automatically deleted.
Please note:
• This action will permanently delete the data necessary to pair your application with your historical shipments (sent and received).
• You can manually revoke your request in the application at any time during the remaining countdown of the retention time.
• Any further use of the Zasilkovna application to send or receive a shipment during the countdown is considered revoking of the account cancellation request and the process will automatically stop. Sending or receiving a shipment to which your mobile number or the email address assigned to your account in the app is considered such further use.
• If the shipment is not completed for the given account at the given moment (ie shipment on the way or return), it is not possible to submit a request for account deletion.
• You will be continuously informed about the number of days remaining until the expiration of the given retention period in the Zasilkovna application after submitting and confirming the request for deletion.

9.4. Right to restriction of personal data processing
You have the right to claim that we restrict the processing of your personal data, especially if you contest the accuracy of the personal data being processed or if you have objected to personal data processing, for the period necessary for the relevant assessment.

9.5. Right to data portability
If this is suitable for you in terms of facilitating communication with another service provider, you have the right to be provided with your personal data in a structured, commonly used and machine-readable format, or to have these data transferred directly to another controller. It is necessary that the given processing be based on your consent or performance of a contract and, at the same time, that it take place by automated means.

9.6. Right to withdraw consent to personal data processing
If you have given us a consent to the processing of your personal data, you have the right to withdraw it at any time. Once you have withdrawn the consent, we will stop processing any personal data in respect of which we have no legal ground for processing other than your consent.

9.7. Right to object and automated individual decision-making
If you wish that we do not continue with the processing of your personal data that are processed by us on the basis of our legitimate interest, you may raise an objection to this effect.
The objection should be substantiated and it should be clear from its formulation why you believe that the processing in question unfavourably interferes with your privacy or protection of your rights and legally protected interests. We will then evaluate whether our legitimate interest outweighs the impact on your rights. This does not apply to data processing for direct marketing, which will be terminated automatically once we receive your objection. However, we may contact you even after you have unsubscribed from marketing communication, in order to maintain and exercise our own rights and obligations.
We do not carry out automated decision-making.

9.8. Right to lodge a complaint
The exercise of the above rights does not prejudice your right to lodge an application, complaint or inquiry with the competent supervisory authority. You may exercise this right especially if you believe that we are processing your personal data illegitimately or at variance with the generally binding legal regulations. The supervisory authority in the Czech Republic is the Office for Personal Data Protection, seated at Pplk. Sochora 27, 170 00 Prague 7 (http://www.uoou.cz/).

10. PROCEDURE IN FILING A REQUEST CONCERNING PERSONAL DATA PROTECTION

10.1. Who has the right to file a request?

You may submit a request concerning personal data protection to us if you are a data subject, the data subject’s legal representative or guardian, or a person authorized by the data subject by means of a power of attorney.

10.2 How can a request be filed?

You can file a request concerning your personal data:
– by e-mail at privacy@zasilkovna.cz; or
– by presenting your inquiry in printed form at the address of Packeta’s registered office:
Českomoravská 2408/1a, Libeň, 190 00 Praha 9.
– by clicking on the “delete account” button within the Zasilkovna application.

10.3 What has to be stated in a request?

Your request must include at least your identification details, its subject (description of the substance of the request and what you claim) and your signature (if submitted in printed form). We record a majority of personal data under your telephone number or e-mail address. You should therefore state in your request to which telephone number and e-mail address your request pertains. You can then be asked to prove that you actually use the given telephone number and e-mail address.
If you do not provide information necessary for a quick resolution of your request in the way you want it to be resolved, we will ask you to supplement the information. In that case, the time we have for the resolution of the request will be extended by the time you need to supplement it.
Unless you ask for general information (e.g. concerning the types of personal data and the duration of their processing), your request will only be processed if we are able to verify your identity. Anonymous requests will be disregarded.

10.4. By when and how will your request be resolved?

Once you have submitted your request, you will be notified that the request has been accepted for resolution.
The initial notice may include references to publicly available parts of the documentation concerning personal data processing.
The request will be dealt with based on a proper review of the relevant issues, and we will inform you how the request has been resolved in view of its contents. We will resolve your request without undue delay, but not later than within 30 days of the date of its proper delivery, or of the delivery of all the necessary information. If this is impossible in view of the nature of the request because of its complexity, time demands or technical difficulties or due to the number of requests filed, the above time limit for processing a request may be extended by up to sixty (60) days. We will inform you of any such extension and the reasons for doing so.

10.5. Is any fee charged for submitting a request?

Requests are usually resolved free of charge. In some cases, we may charge a reasonable fee, e.g. when you request information on a CD/DVD or on some other technical data carrier.

10.6. In what cases may a request be rejected?

A request may be rejected in the following cases:
– unreasonable repetition of the request (third and further requests for information or communication that are identical in terms of contents, filed over a period of six months of the first request);
– the request is not justified; or
– the data subject fails to supplement the request in spite of being asked twice to do so or refuses to pay the fee charge by us, if no other agreement is reached.
A request may be considered unjustified in view of our other legal obligations (e.g. if you require erasure of certain personal data that we are required to process based on legal regulations). In that case, we will provide explanation and not deny the request. Furthermore, a request will also be rejected if we need to verify your
identity and you do not allow us to do so. Similarly, a request cannot be satisfied if it does not contain all the information necessary for its resolution, although we have asked you to supplement it. In the refusal of your request, we will advise you about the right to lodge a complaint with the Office for Personal Data Protection
or to apply for judicial remedy.

11. CONCLUSION

We present this information on personal data processing to you on the basis of Articles 12 to 14 of the GDPR and of the Personal Data Processing Act. This information is permanently available at: www.packeta.com.
The information is intended for external data subjects co-operating with Packeta International s.r.o. or using its services.

Privacy Policy Packeta