INFORMATION ON THE PROCESSING OF PERSONAL DATA

TOP Visa Consulting, i.e. Hana Vanerová, with its registered office at Karpatská 858/3, Vršovice, 100 00 Prague 10, Czech Republic (also “we“), consider the responsible processing and protection of collected personal data to be very important for building trust with our customers. In this document we therefore describe what personal data we process, why we do so, to whom we transfer your data, what rights you have against us and how you can exercise them.

We recommend that you read this information carefully. If you have any questions, you can contact us at any time using the contact details below.

Our goal is to ensure maximum transparency in the processing of your personal data. We have divided this document into the following sections:

our commitment to data protection (part B);
the personal data processed, including examples of the data processed (part C);
the purposes of the processing of personal data, as well as the legal bases and periods of processing (part D);
sharing of personal data (part E);
Your rights in data processing and how to exercise them (part F);
the possibility to lodge a complaint (part G); a
amendments to this document (part H).

Information on the use of cookies and similar technologies is contained in the separate Cookies Policy (EU). Whenever we refer to processing on our website, we also refer to processing in our other online presentations.

OUR COMMITMENT TO DATA PROTECTION

We take care of the security of the processed data. In order to prevent unauthorized access or disclosure of data, to ensure the accuracy of the data and the proper processing of the data, we have taken a number of technical and organizational measures to ensure the protection of the data we collect. We also ensure that data is encrypted during data transmission and storage.

PERSONAL DATA PROCESSED

In particular, we process data that you yourself have provided to us or that we have obtained from your use of the website, our services, communication with us, etc., as well as data derived from these data.

For the sake of clarity, we have divided the data processed by us into several categories, to which we refer in this document:

Identification data such as first name, last name and photo. These are required for the proper provision of our services and to be able to contact you on your behalf.
Contact details such as address, telephone number, postal address and email address. These are needed to communicate with you and to be able to provide our services.
Application data such as information from and copies of official documents (passport, identity card, excerpt from criminal record), residency documents (rental agreement, approval from landlord, accommodation confirmation form, proof of residence), income and wealth documents (ownership deed, trade license, utility bills, income and expenses data, proof of funds, , monthly income proof), employment and trade documents (employment contract, job vacancy number), qualification documents (driver’s license, education certificate, Czech language certificate), insurance, proof of health proof of family status, marriage certificate. These are usually needed by government authorities for successful applications.
Purchase details such as order number, payment method, invoices, and orders.
Communication data, i.e. information about communications with you, such as emails, chats, etc.
Site usage data, i.e. information about your use of our site and your behavior on the site such as IP addresses and HTTP logs of site usage obtained via your device used to access the site.
Cookie data, i.e. data obtained from cookies and similar technologies that we use. For more information about their use, please read our Cookies Policy.
Service provision data, i.e., information about the provision of our services, such as about the services ordered, date of services provision, scope of our actions, result of services provision, information from governmental authorities etc.

Some of these information may also relate to the third parties, typically your relatives, spouses, employers, landlords etc. You are liable to inform these persons about processing of their data according to this document.

PURPOSES OF THE PROCESSING OF PERSONAL DATA

We process your personal data as a data controller for the processing purposes set out below, on the basis of the legal bases set out here, for a limited period of time and only to the extent described here.

In the first part of this section, we describe the processing of your data related to the provision of our services. In the second part we further describe the processing related to the use of our website.

Processing related to the provision of services

Continuous support for staying and working in Czechia

We primarily process personal data to support you for staying and working in Czechia, in particular when you order our service, contact us for further information, communicate with us during the services usage or provide us with information and documents requested. As part of this, we may also send you messages about the conclusion and performance of a contract, possible or recommended steps to be taken (for example, applying for permanent residency, renewing authorization etc.), payment reminders and others.

For this purpose, we process your Identification data, Contact details, Application data (related to the specific service requested), Purchase details, Communication data, Site usage data and Service provision data.

The legal basis for this processing is the performance of the contract between you and us and the need to take steps at your request before entering into the contract or, where you are not directly party to the contract (if you are, for example, a third person whose data are processed), our legitimate interest in the performance of any contract entered into with our customer.

In case we are processing information from your passport, identification card or excerpt from criminal record, we will collect consent with processing of such data and making copy of these documents from you or the document owner, if necessary. You are not obliged to give us this consent, but without it, we are unable to provide you our services.

The data are processed until the expiry of 5 years from the completed provision of our last service.

Provision of virtual business address

We further process personal data to provide you with virtual address for the seat of your business. As part of this, we may also send you messages about the conclusion and performance of a contract, possible or recommended steps to be taken, payment reminders and others.

For this purpose, we process your Identification data, Contact details, Application data (related to the provision of virtual business address), Purchase details, Site usage data, Service provision data, and Communication data.

The data are processed until the expiry of contract for provision of our service.

Internal records, statistics, and protection of our rights

We may process your data for the purposes of keeping internal records within our company, recording payments made, producing statistical reports, protecting our rights and legal claims, and to ensure that only you use our services in accordance with their terms.

The legal basis for this processing is our legitimate interest in keeping internal records, statistics, and the protection of our rights. The data is processed until a maximum of 16 years after the termination of the concluded contract (or longer in the event of a dispute), or for a maximum of 5 years after the collection of personal data if no contract has been concluded.

Fulfilling legal obligations

We may also process your personal data in order to comply with our legal obligations, particularly in the area of tax. At the same time, we need to be prepared to provide cooperation to state authorities if we are required to do so by law.

The legal basis for this processing is the fulfilment of our legal obligations. The data is processed for the period of time required by law.

Processing related to the use of the website

Site operation and security (a necessity)

We process your personal data for the operation of the website and its security, i.e. for the presentation of information on the website, the internal functioning of the website, your identification as a user when browsing and repeated visits to the website, and for ensuring your security.

For this purpose, we process your Site usage data and Cookie data.

The legal basis for this processing is our legitimate interest in the proper functioning and safe operation of our website. ÚU data are processed, as a rule, for the duration of your visit to the website, for a maximum of 2 years from the date of collection.

Analysis of website traffic (statistics)

We process your personal data to understand how visitors use our website. As part of this, we can monitor traffic to our website, optimize it and generally make your visit to the website smoother and more user-friendly.

For this purpose, we process your Site usage data based on our legitimate interest in obtaining information about the use of our website for its further development. The personal data is processed until a maximum of 2 years after your visit to the website.

With your consent, we may also process Cookie data for this purpose, which facilitates us to make more detailed analyses of your visits to the website (statistical cookies), in which case your personal data may also be transferred to third parties. The legal basis for processing here is thus your consent given via the cookie bar. The personal data is processed until your consent is withdrawn, but in any case, until a maximum of 2 years after your visit to the website.

Web support and promotion (marketing)

We process your personal data to obtain information about your personal preferences and to display relevant advertising. In doing so, we may promote and offer products and services on the site and show you marketing communications relating to the products and services you have enquired about and promote our brand online.

For this purpose, we process your Site usage data based on our legitimate interest in promoting and selling our products and services. Personal data is processed until a maximum of 2 years after your visit to the website.

With your consent, we may also process Cookie data for this purpose, which facilitate our ability to get to know you better and to better target advertisements (marketing cookies), in which case your personal data may also be transferred to third parties. The legal basis for processing here is thus your consent given via the cookie bar. The personal data is processed until your consent is withdrawn, but in any case, until a maximum of 2 years after your visit to the website.

SHARING OF PERSONAL DATA

As a data controller, we determine the purposes for which we obtain and process your personal data, choose the means of processing your data and are responsible for any processing of such data.

At the same time, we may share personal information with third parties who help us provide our products and services to you, such as provider of the Asana tool, APCO Worldwide entity. These parties act as our data processors and will only process personal data for us, within the scope of our processing purposes set out above.

In addition to this, we may share your personal data with certain third parties as data controllers. This happens primarily for the purposes of “Continuous support for staying and working in Czechia” and “Provision of virtual business address” for the purpose of “Fulfilling Legal Obligations”, where we cooperate with government authorities to provide you with the service requested. We also share your data with third parties here we are obliged to do so under applicable legislation (in particular, administrative authorities, police authorities and judicial authorities).

Where we share your personal data with controllers and processors in third countries (outside the EEA), we only do so where there is a decision by the European Commission that a particular country outside the EEA provides an adequate level of data protection, including where controllers or processors have adopted additional data protection measures such as Binding Corporate Rules (BCRs) or Standard Contractual Clauses (SCCs).

YOUR RIGHTS IN PROCESSING AND THE POSSIBILITY OF EXERCISING THEM

Just as we have rights and obligations when processing your personal data, you have certain rights when processing your personal data as set out in the following paragraphs. You have the right to (i) request access to your personal data; (ii) withdraw your consent; (iii) request rectification of your personal data; (iv) request erasure of your personal data; (v) request restriction of the processing of your personal data; (vi) request portability of your personal data; (vii) object to the processing of your personal data; or (viii) lodge a complaint with the relevant supervisory authority.

In all matters related to the processing of your personal data, whether it is a question, the exercise of rights, sending a complaint to our hands, etc., you can contact us at info@top-visa.cz.

Your request will be processed without undue delay, at most within 1 month. In exceptional cases, in particular due to the complexity of your request, we are entitled to extend this period by a further 2 months. We will, of course, always inform you of any such extension and the reason for it.

You also have the right to lodge a complaint with the supervisory authority as described below.

Right of access

You have the right to obtain confirmation from us as to whether or not we are processing your personal data.

If we process your personal data, you also have the right to request access to information about the purpose and scope of the processing, the recipients of the data, the duration of the processing, the right to rectification, erasure, restriction of processing and to object to the processing, the right to lodge a complaint with a supervisory authority and the sources of the personal data (this information is already provided in this document).

You can also ask us for a copy of the personal data we process. We provide the first copy free of charge; further copies may be subject to a fee. The scope of the data provided may be limited so as not to interfere with the rights and freedoms of others.

Right to withdraw consent

You have the right to withdraw your consent to the processing of personal data at any time. However, the withdrawal of consent does not affect the lawfulness of the processing prior to such consent, nor does it lead to the termination of the processing of personal data that has already been anonymized.

Right to repair

You have the right to request us to correct inaccurate personal data concerning you. Depending on the purpose of the processing, you may also have the right to have incomplete personal data completed, including by providing an additional declaration.

Right to erasure (right to be forgotten)

You have the right to request the deletion of your personal data in cases where:

We no longer need your personal data for the purposes for which it was collected or processed;
you withdraw the consent on the basis of which the personal data was processed and there is no further reason for processing it:
you object to processing and there are no other overriding reasons for processing, or you object to processing for direct marketing purposes;
personal data is processed in violation of the law.

However, you cannot exercise this right where the processing is necessary for compliance with our legal obligations or tasks entrusted to us in the public interest or for the establishment, exercise, or defense of legal claims.

Right to restriction of processing

You have the right to request restriction of the processing of your personal data in cases where:

you contest the accuracy of your personal data; in this case, you may request a restriction of processing until the accuracy of the personal data has been verified;
the processing is contrary to the law and instead of erasure, you request a restriction of the processing of personal data;
We no longer need your personal data for the purposes for which it was collected or processed, but you require it for the establishment, exercise, or defense of legal claims;
you have objected to the processing of your personal data; in this case, you may request a restriction of processing until it is verified that our legitimate interests prevail.

Right to portability

You have the right to obtain a copy of your personal data that we process by automated means on the basis of your consent or for the performance of a contract. We will transmit this data in a commonly used and machine-readable format to you or to a controller designated by you, if technically feasible. The scope of the data provided may be limited so as not to interfere with the rights and freedoms of others.

Right to object

You have the right to object to the processing of your personal data that we process on the basis of our legitimate interest. We will stop processing your data if there are no other overriding reasons for processing or if the processing is not necessary for the establishment, exercise, or defense of legal claims or if you object to processing for direct marketing purposes.

RIGHT TO FILE A COMPLAINT

In addition to the possibility of exercising your rights with our company, you can also file a complaint with the relevant supervisory authority, which is the Office for Personal Data Protection located at Pplk. Sochora 27, 170 00 Prague 7.

CHANGES TO THIS INFORMATION

This processing information is effective as of 1 May 2023. We are entitled to change this processing information from time to time, so please check it regularly. We will post any changes to this document on our website.