Generally for the processing of personal data
In this document, we would like to acquaint you with how we use personal data when using Foxentry functions, what rights and obligations in the field of personal data are associated with the use of these functions, what measures you are obliged to take in connection with the use of Foxentry functions, and what measures we have taken.
At the beginning, a few basic concepts need to be explained:
GDPR is Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC, which from 25 May 2018 regulates the rights and obligations of persons processing personal data.
Personal data is all information that can be used to identify a specific person.
It does not only have to be specific data such as name and surname, e-mail address or telephone number; it is any data that relates to a specific person and on the basis of which it is possible to identify a person (e.g. address of residence, network identifiers - IP address, cookies and/or location data, etc.).
On the other hand, a mere name, surname, e-mail address, residential address or telephone number does not automatically have to be personal data if it is not possible to identify a specific person based on this data.
E.g. registration of the e-mail address [email protected] without any further connection is not personal data, as it is not possible to know this person's address. However, if in connection with other data (e.g. employment, address of residence or name and surname) it is possible to identify a specific person, it will be personal data.
It is necessary to take into account whether it is possible to assign this specific data to a specific person.
Anonymized personal data is personal data that has been modified so that the person is no longer identifiable, and this data cannot be recovered in order to determine which specific person it was.
The processing of personal data is any operation that is performed on personal data, from collection, storage and use to the disposal of data.
The data subject is a person who can be identified through personal data.
The controller of personal data is a person who determines for what purpose and in what way personal data will be processed.
The processor of personal data is a person who, on behalf of the administrator and for the administrator, works with personal data in a certain specified way.
Foxentry functions work with your form, in which you can use several types of Foxentry functions. A detailed description of all functions is available at www.foxentry.cz. Below is just a brief description.
Autocomplete and validation
The basic functions of Foxentry are autocomplete and validation of entered data. These features help you fill in your first and last name, address, phone number, and e-mail within the form by checking this information and, if necessary, offering help or the option to fill in the field in the form. They can also provide you with additional information (e.g. as part of extended validation about a completed telephone number).
Autocomplete and validation functions work with each piece of data entered into the form individually without interrelationship with other entered data so as to limit our ability to identify a specific natural person based on this data as much as possible.
In the event that the above data is still assignable to a specific individual in a certain case and would be personal data, we will process this personal data only for the use of your activated functions and will not store this personal data for a long time.
Furthermore, if you activate the "Company Autocomplete" function, we will search for and provide identification and contact information from publicly available sources based on your request (especially by entering the name, surname, name or identification number in your form) to the entrepreneur you entered within this function. We will search for economic data (in particular information on activity restrictions, debts, information on whether he is a reliable VAT payer, information on insolvency or liquidation proceedings). We will only process this personal data again in connection with the provision of this function. After we provide you with this personal information, we will not store this personal information for a long time.
Cookies and IP addresses
We also use the network identifiers (such as IP address and cookies) of the form users for Foxentry functions to work properly. We will again use these network identifiers only to provide individual functions and will not store these network identifiers for a long time.
You pay for using Foxentry functions by purchasing credits. For each use of our service, which we call a request, the relevant number of credits will be deducted. Therefore, in order to record credit withdrawals, we record these individual requests.
These requests are automatically anonymized and further encrypted before being stored on our server, so there is never a personal record of personal data entered in the form. E.g. if the user of the form chooses to correct the name Thomas, this request is registered as: Tho***.
For more information on the technical operation of Foxentry's features, see the "Our Data Code" document.
Our position according to GDPR
You are always the administrator of the personal data entered in the form using the Foxentry function.
You are the administrator because personal data is handled for your purposes (especially to obtain the necessary identification, contact and possibly economic data about the persons) and through your form. You are also the one who, after submitting the form, has access to all the personal data of the person entered in the form.
We would like to inform you that if we use our "Company Autocomplete" function, then you must have a legal reason to obtain identification, contact and economic information about the entrepreneur through this function. This reason will be, in particular, the negotiation of a contract with this entrepreneur or the protection of your rights and claims against this entrepreneur (e.g. checking whether the entrepreneur is not insolvent).
Our company is then a processor of personal data and works with personal data for you and only for the purpose of providing Foxentry functions.
In particular, we work with the network identifiers (cookies, IP address) of the form user; in certain cases we can process personal data within the functions of autocomplete and data validation, and we also obtain identification, contact and economic data about your entered data within the "Company Autocomplete" function.
According to GDRP, as a personal data controller you have several obligations towards persons whose personal data are entered in your form. Below are your responsibilities for using Foxentry features:
One of the basic obligations is to provide information to the person whose personal data you are processing regarding the processing of their personal data pursuant to Article 13 or 14 of GDPR.
To fulfill this information obligation, you should have a document in place to inform the persons whose personal data you process about how you process their personal data. You can then enter the information below into this document.
In connection with the use of Foxentry functions, you must provide the following information to data subjects:
Why and on what basis are you processing data (purpose and legal basis of processing)
In terms of Foxentry's features, you will most often need to obtain and use identification and contact information from your customers or business partners through your form to enter into and perform a contract (e.g. to know who you are contracting with and how you can contact them).
You will also use this personal data to fulfill legal obligations (especially accounting and tax obligations - i.e. invoicing, accounting records).
You can inform the subjects about the purpose and legal basis of processing according to the above as follows:
We may process personal data obtained in connection with the inquiry and ordering of our goods or services without your express consent on the basis of and for the purpose of concluding and fulfilling the contract. Furthermore, we may process this data on the basis of and for the purpose of fulfilling our statutory obligations (especially registration obligations, archiving of tax documents, etc.)
If you use Foxentry's functions to obtain economic information about entrepreneurs, you should do so most often to protect your legal claims (e.g. to know if the person you want to sign a contract with or your business partner is not insolvent, etc.).
You can inform data subjects about this purpose and the legal basis of the processing as follows:
We may further process your personal data on the basis of our legitimate interest for the purpose of protecting our rights and claims.
Identification of recipients of personal data
You must also inform the persons whose personal data you process about whom you are providing their personal data to and who is further handling their personal data.
As part of the provision of Foxentry functions, we are the recipients of personal data, and therefore you must provide the following information:
Your personal data is processed for us by AVANTRO, s.r.o. (Foxentry service provider).
You should also inform data subjects about how long you will process their personal data. You can indicate this obligation by providing the following information:
We use personal data entered within the request and/or ordering of services only for the time necessary for the fulfillment of the contract and the fulfillment of legal obligations, or to protect our rights and claims.
Contract on personal data processing
Another basic obligation is that we take appropriate technical and organizational measures to ensure that the personal data we process is sufficiently secure.
As a processor of personal data, we have other obligations; in particular, we are obliged to provide you with cooperation and assistance in working with personal data if needed. We also undertake confidentiality, we will inform you about the persons to whom we pass on personal data, etc.