Information on the Processing of Personal Data



Dear Customers,


With this document, we would like to inform you onthe manner in which we handle the personal information you have communicated tous in connection with the selection of the services provided by First ClassPublishing a.s., with its registered office at Praha 1, Washingtonova 5,Postcode: 110 00, registered in the Commercial Register maintained by theMunicipal Court in Prague, File Reference B 16356, Company ID: 24713252(hereinafter referred to as “we” or “our company”).


With this document, we comply with our obligationto provide you with the information required under Articles 12, 13 and 14 ofRegulation (EU) 2016/679 of the European Parliament and of the Council on theprotection of individuals with regard to the processing of personal data and onthe free movement of such data, and repealing Directive 95/46/ES (General DataProtection Regulation) (hereinafter referred to as the "GDPR") andthe obligations under Act No. 101/2000 Coll., on the protection of personaldata, as amended. The content of the GDPR may be consulted at:




A.        Who is thecontroller of the personal data you have provided and how can you contact them?


The controller of the personal data you haveprovided is First Class Publishing a.s..


You can contact us with queries regarding theprocessing of your personal data personally at our offices at Praha 1,Washingtonova 5, Postcode: 110 00,during our opening hours indicated at our website (


You can also contact us by phone at +420 607 975171 or by e-mail at


You may also appoint a representative to consult usregarding the personal data you have provided, who will produce a written powerof attorney when interacting with us.



B.        Data protectionofficer and how you can contact them?


In accordance with the relevant legislation, ourcompany has appointed an officer who is ready to provide you with details as towhy and how we process your personal data, how we handle them, and what actionshave been put in place to protect the data from misuse or loss.


You can contact our personal data officer by e-mailat








C.        Whatcategories of my personal data do you process?


For data subjects who have entered intoa service or goods contract with us via our website or at the company'sheadquarters, we generally process the following personal data:


·       name,

·       surname,

·       address,

·       phone number(s),

·       email address(es),

·       account socialnetwork account(s),

·       IP addressassociated with you,

·       cookies.


For data subjects who have not enteredinto a service contract with us, we generally process the following personaldata:


·       name,

·       surname,

·       gender,

·       email address(es),

·       account socialnetwork account(s),

·       cookies.



D.        How do we process personal data? Forwhat purposes do we process your personal data and what is our legal basis forprocessing your personal data? What are our legitimate interests whenprocessing your personal data?


We process your personal data in order to fulfilthe purpose of the contract you have entered into with us or under which weare about to provide you with services or goods, and in order for us to be ableto provide you with the agreed services or goods (processing underArticle 6(1)(b) of the GDPR).



Considering the nature of our services, wecannot provide you with our services unless you transmit the following personaldata to us:


(a)        Your name and surname,

(b)        Your permanent residential address.


We further process your personal data on account ofthe legitimate interests of our company. We define these legitimateinterests as (a) protecting our rights inherent in the contract concluded ifthe same is violated by you or (b) if, in connection with the contractconcluded, you apply any of your claims with us. Therefore, we process yourpersonal data for the purpose of using them during court or enforcementproceedings relating to our claims and rights in the event you violate thecontract, and for the purposes of our legal defence in the event you apply anyclaim with us in relation to the contract (processing under Art. 6(1)(f) ofthe GDPR). As for data subjects who have entered into a service contractwith us, we will also use their email address for direct marketing to informthem of our new services they may be interested in, on the discounts offered orother benefits. In this context, please note that under Article 21 of the GPRDyou have the right to object to such processing of your personal data onaccount of our legitimate interests as defined above. You can address theobjection to our data protection officer (see section B above).


In addition, we process your personal data onthe basis of the consent you have granted to us in writing (if you haveindeed done so) (processing under paragraph 1(a) of the GDPR). The scopeof the personal data processed in this way is detailed in Part B. of thisinformation. This Part applies primarily to data subjects who have not enteredinto a service or goods contract with us.


On the basis of your consent (presumingyou have granted it) we process your personal data for our company's marketingpurposes in the form of our company’s offers sent to you. You may also requestmore details from our data protection officer.


Your consent is also provided forprofiling purposes so that we could offer you the discounts or other benefitsprovided by our company that will be most relevant to your customer profile.And again, for more information on profiling, please contact our dataprotection officer.



E.        Who is the recipient of your personaldata?


The primary recipient of your personal datais our company.


Considering the nature of the services and goodsthat will be provided by us under our contract, we will also transmit yourpersonal data, within the necessary extent, to:


(a)          operators providing or arranging for postalservices,

(b)       our legal counsels for the purpose ofcollecting our receivables and/or protecting our rights in the event you breachthe contract and/or for us to defend ourselves against any claims you mayraise,

(c)       entities engaging in and/or mandated tocollect any receivables,

(d)       state and administrative authorities, attheir request, in connection with the exercise of the powers of suchauthorities.



F.        Will your personal data be transmittedabroad?


Considering the nature of the services provided byus, your personal data will not be transmitted to other Member States of theEuropean Union or to third countries (i.e., countries outside the EuropeanUnion).



G.        For how long will your personal data beprocessed by the company?


As for the personal data regarding which you havegranted your consent to the processing (where relevant), as such personal dataare described in your consent, these will be processed for as long as for howlong your consent has been granted. For information on for how long yourconsent to the processing of your personal data has been granted, you maycontact our data processing officer at


As for the personal data we process under therelevant provisions of the GDPR (see Part C above), these will be processed forthe period necessary for us to provide you with the agreed services or goods ofthe company, the period necessary for us to demonstrate having provided theservices to competent Czech authorities in accordance with the accounting andtax regulations, and for the period of time necessary for us to protect ourrights in the event of your breach of the contract, yet in any case at leastfor the period of limitation regarding any claims, either yours or ours,inherent in or associated with any contract concluded. The length of thelimitation period is set out in the Civil Code (Act No. 89/2012 Coll.).



H.        How will your personal data beprocessed? How will your personal data be protected?


Your personal data will be processed in electronicformat within the company's electronic system or within the electronic systemof the persons to whom the personal data will be transmitted.


Your personal data may also be processed in theform of physical documents (paper documents or similar material carriers) to bekept in the company's filing cabinet.


Please rest assured we have put in place suchcontrols as are necessary to ensure that your personal data are alwaysprotected against misuse or loss to the maximum extent.


All persons on the part of our company who are incontact with the personal data have been instructed and tested for the givenpurpose. The archive where paper documents are kept is secured againstunauthorised access. The archive is secured by locks and other physicalsecurity controls. Electronically processed personal data are kept in a secureddatabase.




I.          What are your rights in relation tothe processing of personal data?


Your rights in relation to the processing of yourpersonal data are as follows:


(a)       If you have agreed to the processing ofyour personal data by granting a consent, you have the right to revoke theconsent. You may revoke your consent by serving a written notice by post tothe address of our headquarters (see Section A above) or electronically, indicating your name, surname, date of birth andyour permanent residential address in the letter of revocation. The letter ofrevocation only needs to state "I hereby revoke my consent granted toFirst Class Publishing a.s. to processing my personal data.”


           In the context of the revocationof your consent to the processing of your personal data, we would like toinform you that our company is still authorised to process your personaldata to the extent that the purpose for the processing is based on a reasonforeseen by the GDPR other than your consent.


           At the same time, we would like toremind you that the revocation of your consent is without prejudice to thelawfulness of the processing of your personal data based on the consent youhave granted. Therefore, even after you revoke your consent, the processingof your personal data as carried out by us during the term of validity of yourconsent shall still be regarded as lawful.

(b)       You have the right to request accessto your personal data within the scope defined under Article 15 of theGDPR.

(c)       You have the right to rectification ofthe personal data you have provided as per Article 16 of the GDPR.

(c)       You have the right to request erasure ofyour personal data as per Article 17 of the GDPR.

(e)       You have the right to request restrictionof the processing of your personal data under Article 18 of the GDPR.

(f)        You have the right to portabilityof your personal data to another controller under Article 20 of the GDPR, may ask us to transmit your personal data to another controller.

(g)       You have the right to lodge a complaintagainst us as the controller of your personal data to a supervisory authority,namely the Office for Personal Data Protection ( (Article 77 of theGDPR).


If you decide to apply any of the aforementionedrights, we are obliged to check your identity, i.e. to verify whether theenforcement is requested by a person to whom the personal data we processactually apply.



J.         Do you process my sensitive personaldata?


As for sensitive personal data, we onlyprocess such data if you have provided us with, or disclosed, such data,or if the processing of such data is necessary to protect your vitalinterests or vital interests of another individual. We generally do not processsensitive personal data.


In other cases, we process suchsensitive personal data only if you have granted your consent to suchprocessing.




K.        Is the provision of your personal data anecessary prerequisite for entering into a contract with our company?


As stated in Part D. above, with regardto the nature of your company’s services and the type of services agreed underthe contract, we cannot provide our services to you unless you provideus with the data described in Part D. These data are necessary to enter into acontract with us (identification of the contracting parties, identification ofthe persons to whom the service is to be provided, actual provision of theservice) and the contract cannot be concluded unless the data have beenprovided.



L.        What does the processing of personaldata entail?


Processing of personal data denotes anyoperation or a set of operations involving personal data or files with personaldata, whether by mechanical means or automated means. The processing includescollecting, recording, arranging, structuring, storing, customising oraltering, searching, viewing, using, making the data available throughtransmission, spreading or otherwise making the data available, sorting orcombining, restricting, erasing or destroying personal data.



M.        Other information


If we change the purpose of processingyour personal data, we will notify you in advance.


If we receive your personal informationfrom a third party, we will inform you thereof.


If anything in this information isunclear to you, we are ready to respond to your concerns. If you have anyqueries, you can consult our data protection officer. For contact information,see Parts A. and B. above.


We will inform you if we make anychanges to this information.


This information is available inphysical or electronic form from our headquarters and in electronic form at ourwebsite at



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Thank you for the attention you paid to thisinformation.


Prague, 1 May 2018


For First Class Publishing a.s.