Personal data protection

We process your following personal data:
1. identification data, which means in particular your first name and surname, username and password, ID number, and VAT number if you are an entrepreneur;
2. contact data, which means personal data that allows us to contact you, in particular your email address, telephone number, delivery address, billing address, and your contact details on social networks;
3. your newsletter settings;
4. data on your orders, which include, in particular, data on the goods and services you have ordered, including the payment method and payment terms, and data on the exercise of your rights;
5. data about your behaviour on the website, including when you view it from a mobile device, in particular the goods and services you view, the links you click, how you move around our website and scroll the screen, as well as data about the device from which you view our website, such as the IP address and derived location, device identification, its technical parameters, such as the operating system and its version, the screen resolution, the browser used and its version, as well as data obtained from cookies and similar technologies for device identification;
6. data about your reading behaviour when reading the messages we send you, in particular the times the messages are opened, as well as data about the device on which you read the messages, such as the IP address and the derived location, the identification of the device, its technical parameters such as the operating system and its version, the screen resolution, the browser used and its version;
7. derived data, which means personal data derived from your settings, data about the goods and services we provide to you, data about your behaviour on the website and the messages we send you; in particular, data on your gender, age, financial situation, shopping behaviour, and your relationship to various goods and services.

Why do we process personal data and what entitles us to do so?
We process your personal data in different situations for different purposes. If you use our website, where we also use cookies, we use your data mainly to monitor traffic and improve our services. If you enter into a contract with us, we use your data to process your order, to protect our legal claims, and to comply with our legal obligations. We also use your contact details and other data to show and send you our customised offers. With your consent, we transfer data to third parties in order to display offers on other websites and also to make certain additional services available to you. We are entitled to process personal data either for the preparation or performance of a contract with you, for compliance with legal obligations, for our legitimate interests, or because you have given your consent. As part of our activities, we process personal data for various purposes and to varying extents, and we do so either: ∙ without your consent on the basis of the performance of a contract, our legitimate interest, or due to compliance with a legal obligation, or ∙ on the basis of your consent.

What processing can we carry out without your consent?
It depends on the purpose of the processing and the position you hold in relation to us – whether you are just a visitor to our website, or you have entered into a contract with us. We may also process your data if you are the recipient of goods or services ordered from us, if you communicate with us.

Information on the processing of personal data through cookies
The operator of this website is the company Agentura Foxy.cz s.r.o., with its registered office at Veselá 169/24, Brno-město, 602 00 Brno, ID 06739792, registered in the Commercial Register under file no. No. C 104000 at the Regional Court in Brno (hereinafter referred to as the “Controller”), which uses cookies on this website for the following purposes:

• To measure the number of visitors to the website and to create statistics regarding traffic and visitor behaviour on the website;
• For the functioning of the website;
• To target advertising and marketing and display it to users who consent to it. The collection of cookies for the purpose specified in par. 1 can be considered as the processing of personal data.

Such processing is possible on the basis of a legal reason – the legitimate interest of the Controller and is allowed by Article 6 (1) f) of the 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, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as the “Regulation”). The website can also be used in a mode that does not allow the collection of data on the behaviour of website visitors – this mode can either be set within the browser settings, or it is possible raise an objection to such collection on the basis of a legitimate interest under Article 21 of the Regulation by sending it to our contact address. Your objection will then be evaluated without delay, no later than 30 days from receipt. Cookies necessary for the functionality of the website will be stored only for the time necessary for the functioning of the website. If you object to the processing of technical cookies necessary for the functioning of the website, the full functionality and compatibility of the website cannot be guaranteed. Cookies which are collected for the purpose of measuring website traffic and creating statistics regarding traffic and visitor behaviour on the website are assessed in the form of a collective whole and in pseudonymised form, which allows the identification of an individual only after considerable and expert effort. Cookies for targeting advertising (marketing cookies) are processed on the basis of your consent. You give your consent for the below-specified period below for individual marketing cookies. Consent to the collection of cookie data for marketing purposes can be withdrawn at any time by changing the settings of the relevant internet browser.

For more detailed information about this option, see the end of this document.
Cookies are stored for the below-specified period for each type of cookie. Please note that according to the Regulation, you have the right to:

• request information from the Controller about the processing of your personal data, or request a copy,
• request access to this data from the Controller and have it updated or corrected, or restrict its processing,
• request the Controller to erase such personal data – they will erase it if the deletion is not in conflict with applicable legal regulations and the Controller’s legitimate interests,
• in the case of processing personal data on the basis of consent, request the transfer of such data,
• Collected cookie files are processed by other processors.

What are cookies?
Cookies are small text files that store information in your browser and are commonly used to distinguish individual users. Cookies can be thought of as the memory of a website that recognises the user of the same computer the next time they visit. However, the person of the user is not identifiable on the basis of this information. Cookies take up almost no space on your computer’s hard drive and are usually several kilobytes in size. Cookies are not used to collect any sensitive personal data. Standard web browsers support cookie management. For more detailed information, please use the help function of your browser. If your browser allows the use of cookies, we will assume that you agree to the use of standard cookies by our servers.

What cookies do we use?
The cookies used on our website can be divided into two basic types in terms of their lifespan. Short-term, so-called “session cookies”, which are only temporary and remain stored in your browser only until you close the browser, and long-term, so-called “persistent cookies”, which remain stored on your device for much longer or until you manually delete them (the time for which cookies remain on your device depends on the settings of the cookie itself and your browser settings).
In terms of the function that individual cookies perform, cookies can be divided into:

• conversion cookies, which allow us to analyse the performance of different sales channels
• tracking cookies, which, in combination with conversion cookies, help analyse the performance of various sales channels
• marketing cookies, which we use to personalise the content of advertisements and target them correctly, and remarketing (or retargeting) cookies
• analytical, which help us to improve the user experience of our website by understanding how users use it
• necessary cookies, that are essential for the basic functionality of the website.
Some cookies may collect information that is then used by third parties and that, for example, directly supports our advertising activities (so-called “third-party cookies”). For example, information about services or products purchased by visitors to the site may be displayed by an advertising agency so that we can better tailor the display of Internet advertising banners on the websites you view. However, you cannot be identified from this data.

The following cookies are used on our website:
Essential cookies. They allow you to move around the website and use all its features.
Functional cookies. They record information about the choices you have made.
Analytical cookies. They help to improve the performance of the website.
• Cookiebot: necessary
• Google Analytics: Statistical and marketing cookies
• LinkedIn: Necessary, statistical and marketing
• Google AdWords: Marketingové cookies
• AdForm: Marketing
• Facebook: Marketing
• Seznam.cz: Necessary & Marketing
• TikTok: Marketing
• Facebook Pixel – marketing.

How do you set up cookie management in your browser?
It is all about your internet browser settings. Most browsers automatically accept cookies by default. You can use your web browser to refuse cookies, or to set the use of certain cookies. You can find out more information about cookies and how they are used at https://www.aboutcookies.org/ website.

Processing on the basis of legitimate interest
If you enter into a contract with us, we process your identification and contact data, your settings, data about your orders or contracts, and data about your behaviour on the website also on the basis of our legitimate interest (i.e. without your consent) in order to:
• obtain information on the basis of which we can improve our services for you in the future in order to make your shopping with us even better, in particular to determine your satisfaction with our services; our legitimate interest here is to improve our services for you.
• provide you with tailored offers and targeted advertising, which we may send to you by email, text message, social media, telephone or other electronic means, mail, or display on our website; our legitimate interest here is the effective promotion of our products and services.
• protect claims and for our internal records and checks, we process data for the duration of the limitation period of 3 years and one year after its expiry with respect to claims made at the end of the limitation period. In the event of the initiation of judicial, administrative or other proceedings, we process your personal data to the extent necessary for the entire duration of such proceedings and the remaining part of the limitation period after their termination. For all other purposes, we use personal data for a maximum of 6 months. You have the right to object to such processing carried out on the basis of our legitimate interest.

If you enter into a contract with us.
In order to be able to inquire about our goods or services, you must visit our website, which makes you subject to the processing described in the section. If you visit our website. If you inquire about goods or services from us, we also carry out the following processing: Processing on the basis of the performance of a contract.
If you, as a natural person, inquire about goods or services from us, we process the necessary personal data, i.e. your identification and contact data – in other words, data on your orders.
If you inquire about goods or services from us as a representative of a legal entity, we process the same data for the same purpose on the basis of our legitimate interest consisting in concluding and performing a contract with the person you represent.
The fact that we use this data for the purpose of handling your enquiry via the contact form means that we will use it in particular:
• for you to be able to complete your inquiry on the website, for example, to prevent the deletion of data from a message you are working on;
• for us to communicate with you about your inquiry;
• to pay for goods or services;
• in connection with a complaint about an ordered service;
• in connection with any other requests you send us;
• For this purpose, we use personal data for the period necessary to handle your inquiry or to handle a contractual request, such as a complaint. Processing on the basis of compliance with legal obligations, we also have to comply with certain legal obligations. If we process your personal data for this very reason, we do not need to obtain your consent for such processing. On this legal basis, we process your identification and contact data, and order data, in order to comply in particular with the following laws: Act No. 89/2012 Coll., the Civil Code; Act No. 634/1992 Coll., on Consumer Protection; Act No. 235/2004 Coll., on Value Added Tax; and Act No. 563/1991 Coll., on Accounting. For these purposes, we use personal data for a maximum period of 10 years from the issuance of the last receipt for your order. If you are the addressee of goods or services that are ordered from us.
If you are the addressee of a service ordered from us, we process your identification and contact data:
• on the basis of our legitimate interest for the purpose of preparing, concluding, and performing a contract with our customer. The performance of this contract is also in our legitimate interest;
• on the basis of our legitimate interest in obtaining information on the basis of which we can improve our services in the future or information for the creation of our internal statistics and reports; our legitimate interest here is to improve our services to our customers;
• for the purpose of fulfilling legal obligations, in particular pursuant to Act No. 235/2004 Coll., on Value Added Tax, and Act No. 563/1991 Coll., on Accounting;
• to protect legal claims and for our internal records and checks; our legitimate interests here are the protection of legal claims and the control of the proper provision of our services. For the preparation, conclusion, and performance of the contract with our customer, we use personal data for the time necessary to process the order. After the expiry of this period, we will continue to store the data on the basis of our legitimate interest for the purpose of protecting legal claims and our internal records and checks, for the duration of the limitation period of 3 years and one year after its expiry with regard to claims made at the end of the limitation period. In the event of the initiation of judicial, administrative or other proceedings, we process your personal data to the extent necessary for the entire duration of such proceedings and the remaining part of the limitation period after their termination. Our legitimate interests here are the protection of legal claims and checking the proper provision of our services. For the purposes of fulfilling legal obligations, we use personal data for a maximum of 10 years for the relevant order. You have the right to object to this processing based on a legitimate interest.

If you interact with us through different channels
If you communicate with us through a range of channels, in particular via telephone, email, chat tools, and social networks, we will process your identification and contact data and records of the communication on the basis of our legitimate interest (i.e. without your consent) for the purpose of:
• handling your requests; if you have entered into a contract with us and your request relates to an order, we may carry out this processing on the basis of the performance of a contract with you;
• keeping track of your requests so that we can check that we are fulfilling them properly and on time;
• proving that we have accepted and processed your request, e.g. when you order services from us in this way or make a complaint;
• their analysis to improve the quality of our services. For these purposes, we store personal data for a period of 3 months. If you place an order with us through one of these channels, we may retain the data for the duration of the limitation period of 3 years and one year after the expiry of the limitation period with respect to claims made at the end of the limitation period.
In the event of the initiation of judicial, administrative or other proceedings, we process your personal data to the extent necessary for the entire duration of such proceedings and the remaining part of the limitation period after their termination. You have the right to object to processing based on our legitimate interest.

Who processes your personal data and to whom do we transfer it?
In most cases, we process your data for our own purposes as a data controller. In this case, we will pass on your data to our partners to arrange payment and satisfy other requirements for your inquiry. We also transfer the data to our processors, who process it according to our instructions. With your consent, we may also transfer data to advertising and social networks to display tailored advertising to others.
All of the above-mentioned personal data is processed by us as the controller. This means that we determine the purposes for which we collect your personal data as set out above, we determine the means of processing, and are responsible for their proper implementation. We may also transfer your personal data to other entities that operate in the role of controllers, namely:

• in connection with the processing of your order to our employees and partners who are involved in this processing,
• to specialists in the given fields, who become your personal advisors and are subject to a non-disclosure agreement,
• based on your consent to advertising and social networks, as described in the section Use of cookies and other technologies, transfer of data to advertising and social networks, namely:

Google Ireland Limited (registration number: 368047), with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland; This company’s privacy policy is available here: https://policies.google.com/technologies/ads

Facebook Ireland Limited, with its registered office at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, D02 X525, Ireland; This company’s privacy policy is available here: https://cs-cz.facebook.com/about/privacy

Adform, Wildersgade 10B, 1408 Copenhagen, Denmark; This company’s privacy policy is available here: https://site.adform.com/privacy-policy-opt-out/

Seznam.cz, a.s., ID 26168685; Radlická 3294/10, Smíchov, 150 00 Praha 5, conditions available here: https://o.seznam.cz/ochrana-udaju/


From what sources do we obtain personal data?
Most of the time, we obtain personal data directly from you through our website or when we communicate with you. In most cases, we process the personal data that you provide to us as part of ordering services or communicating with us. We also obtain personal data directly from you by tracking your behaviour on our website and when you read messages or via telephone calls.

What are your rights regarding the processing of personal data?
You have a number of rights in relation to your personal data. These are the right of access, rectification, erasure, restriction of processing, portability, objection, and complaint. Just as we have rights and obligations when processing your personal data, you also have certain rights when processing your personal data. These rights include:

• Right of access. Simply put, you have the right to know what data we process about you, for what purpose, for how long, where we obtain your personal data, to whom we transfer it, who processes it outside of us, and what other rights you have related to the processing of your personal data. You can find out all this in this “Customer Privacy Policy” document. However, if you are unsure about what personal data we process about you, you can ask us to confirm whether or not the personal data concerning you is being processed by us and, if so, you have the right to access that personal data. As part of the right of access, you can ask us for a copy of the personal data being processed, the first copy of which will be provided to you free of charge and subsequent copies will be subject to a fee.
• Right to rectification. To err is human If you find out that the personal data we process about you is inaccurate or incomplete, you have the right to have it corrected or supplemented without undue delay.
• Right to erasure: In some cases, you have the right to have us erase your personal data. We will delete your personal data without undue delay if one of the following grounds applies:

• we no longer need your personal data for the purposes for which we processed it; • you withdraw your consent to the processing of your personal data which concerns data for the processing of which your consent is necessary and we have no other reason why we need to continue processing this data; • you exercise your right to object to processing (see ‘Right to object to processing’ below) in respect of personal data that we process on the basis of our legitimate interests and we find that we no longer have any such legitimate interests that would justify such processing.

• you believe that the processing of personal data carried out by us is no longer in accordance with generally binding regulations. But please keep in mind that even if one of these reasons applies, it does not mean that we will immediately delete all of your personal data. This right does not apply if the processing of your personal data is still necessary for compliance with our legal obligation or for the establishment, exercise, or defence of our legal claims (see the section ‘Why do we process personal data and what entitles us to do so?’).

Right to restriction of processing
In some cases, in addition to the right to erasure, you may exercise the right to restrict the processing of personal data. This right allows you to request that your personal data be labelled in certain cases and that the data is not subject to any further processing operations – in this case, however, not for ever (as in the case of the right to erasure), but for a limited period of time.

We need to restrict the processing of personal data when:
• you contest the accuracy of the personal data before we agree on what data is correct;
• we process your personal data without a sufficient legal basis (e.g. beyond what we need to process), but you prefer to restrict such data rather than erase it (e.g. if you expect that you will provide us with such data in the future anyway);
• we no longer need your personal data for the above-mentioned processing purposes, but you require it for the establishment, exercise, or defence of your legal claims, or
• you object to the processing. (The right to object is described in more detail below in the section ‘Right to object to processing’). For the period during which we investigate, if your objection is justified, we are obliged to restrict the processing of your personal data. You have the right to obtain from us all your personal data that you have provided to us and that we process on the basis of your consent (see the section ‘If you give us your consent’) and on the basis of the performance of a contract. We will provide you with your personal data in a structured, commonly used, and machine-readable format. In order for us to be able to easily transfer data at your request, this may only be data that we process automatically in our electronic databases.

You have the right to object to the processing of personal data that is based on our legitimate interest (see the section ‘Why do we process personal data and what entitles us to do so?’).
In the case of marketing activities, we will cease processing your personal data without further action; in other cases, we will do so unless we have compelling legitimate grounds to continue such processing.

Right to lodge a complaint. Exercising your rights in the manner described above is without prejudice to your right to lodge a complaint with the competent supervisory authority. You can exercise this right in particular if you believe that we are processing your personal data unlawfully or in violation of generally binding legal regulations. You can file a complaint against our personal data processing with the Office for Personal Data Protection.

How can individual rights be exercised?

Simply write to our email account info@foxy.cz. If your request is for your credit card details, we will forward your request to the bank, which will take care of its processing. We will process your request without undue delay, but within a maximum of one month. In exceptional cases, in particular due to the complexity of your request, we are entitled to extend this period by another two months. We will, of course, inform you of any such extension and the reasons for it.

Updated on: 1.1.2022