I. Basic Provisions

The controller of personal data within the meaning of Article 4(7) of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”) is Hoang Long Le, a sole trader under the Czech Trade Licensing Act, identification number (IČO) 222172258, not registered for VAT, selling goods via the online store located at https://spoonringz.com/, with its registered address at Bedřicha Nikodema 4483/5, 708 00 Ostrava, Czech Republic (the “Controller”).

Controller’s contact details:
Address: Bedřicha Nikodema 4483/5, 708 00 Ostrava, Czech Republic
E-mail: hello@spoonringz.com

“Personal data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to that natural person’s physical, physiological, genetic, mental, economic, cultural or social identity.

The Controller has not appointed a Data Protection Officer.

II. Sources and Categories of Personal Data Processed

The Controller processes personal data that you provide to the Controller and/or personal data that the Controller obtains in connection with fulfilling your order.
The Controller processes your identification and contact details and other data necessary for performance of a contract.

III. Legal Bases and Purposes of Processing

Legal bases for processing are:

• Performance of a contract between you and the Controller pursuant to Article 6(1)(b) GDPR;
  
• The Controller’s legitimate interest in carrying out direct marketing (in particular sending commercial communications and newsletters) pursuant to Article 6(1)(f) GDPR;
  
• Your consent to processing for the purposes of direct marketing (in particular sending commercial communications and newsletters) pursuant to Article 6(1)(a) GDPR in conjunction with Section 7(2) of Czech Act No. 480/2004 Coll., on certain information society services, where no order for goods or services has been placed.
  

Purposes of processing are:

• Processing your order and exercising rights and obligations arising from the contractual relationship between you and the Controller; when placing an order you are required to provide personal data necessary for successful processing of the order (name and address, contact details). Providing personal data is a necessary requirement for entering into and performing the contract; without providing personal data, the contract cannot be concluded or performed by the Controller;
  
• Sending commercial communications and carrying out other marketing activities.
  

The Controller uses automated individual decision-making within the meaning of Article 22 GDPR. You have given your explicit consent to such processing.

IV. Retention Periods

The Controller retains personal data:

• For the period necessary to exercise rights and obligations arising from the contractual relationship between you and the Controller and to assert claims arising from such relationships (for 15 years from termination of the contractual relationship);
  
• Until consent is withdrawn with respect to processing for marketing purposes, but for no longer than 2 years where processing is based on consent.
  

After the expiry of the retention period, the Controller will erase the personal data.

V. Recipients of Personal Data (Processor/Sub-processors)

Recipients of personal data may include persons:

• Participating in the delivery of goods/services and payment processing under a contract;
  
• Providing e-shop operation services (Shopify) and other services related to operating the e-shop;
  
• Providing marketing services.
  

The Controller does not intend to transfer personal data to a third country (outside the EU) or to an international organisation.

VI. Your Rights

Under the GDPR, you have the right to:

• Access your personal data (Article 15 GDPR);
  
• Rectification of personal data (Article 16 GDPR) and/or restriction of processing (Article 18 GDPR);
  
• Erasure of personal data (Article 17 GDPR);
  
• Object to processing (Article 21 GDPR);
  
• Data portability (Article 20 GDPR);
  
• Withdraw consent to processing at any time, in writing or electronically to the Controller’s postal or e-mail address indicated in Section I of this Policy.
  

You also have the right to lodge a complaint with the Office for Personal Data Protection (Úřad pro ochranu osobních údajů) or with another competent supervisory authority if you believe your data protection rights have been infringed.

VII. Security of Personal Data

The Controller declares that it has adopted all appropriate technical and organisational measures to secure personal data.
The Controller has implemented technical measures to secure data repositories and personal data stored in paper form.
Access to personal data is granted only to authorised persons designated by the Controller.

VIII. Final Provisions

By submitting an order through the online order form, you confirm that you have been acquainted with this Privacy Policy and that you accept it in full.
You agree to this Privacy Policy by ticking the consent box in the online form. By ticking the consent box, you confirm that you have been acquainted with this Privacy Policy and that you accept it in full.
The Controller may amend this Privacy Policy. The new version will be published on the Controller’s website and will also be sent to your e-mail address provided to the Controller.