(hereinafter referred to as “IMUNI”)
According to Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons concerning 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 “GDPR”), we hereby fulfil our information obligation within the meaning of Article 13 et seq. of the GDPR.
Personal data controller and contact details
The personal data controller or, where applicable, its processor is the company IMUNI s.r.o., registered office at Bezručova 1863/58, 692 01 Mikulov, CIN 09715541, registered in the Commercial Register kept at the Regional Court in Brno, Section C, File 120465.
Should any data subject wish to contact the data controller, i. e., IMUNI, in the course of data processing, the data controller can be contacted by telephone at +420 604 257 007, by e-mail at firstname.lastname@example.org, or at the data controller’s headquarters IMUNI.
Statement of IMUNI
IMUNI hereby declares that as a personal data controller within the meaning of the GDPR and Act No. 110/2019 Coll., On the processing of personal data, they comply with all legal obligations required by the applicable legislation, particularly the already referred GDPR Regulation. All personal data of data subjects shall only be processed based on a valid legal ground (performance of a contract, legitimate interest, legal obligation or consent to processing).
Scope of processing
In connection with the performance of its business activities, IMUNI processes and stores personal data of its clients or potential customers to the following extent:
Customer’s name and surname, title
Customer’s name and surname, title
Address of place of permanent residence, correspondence address
Registered customers with user accounts and distributors
Customer’s name and surname, title
Place of permanent residence, correspondence address
Date of birth
Photographs, audiovisual records
Purpose of processing and its legal basis for processing
IMUNI uses the personal data of data subjects for:
Ensuring the proper performance of the contractual relationship – processing for the purpose of the adequate performance of the contract within the meaning of Article 6(1)(b) of GDPR,
The processing of all personal data listed in points 3(b) and (c) of this document is necessary for the proper performance of the contract. If the data subject does not consent to provide their data for this purpose, the contract cannot be concluded. IMUNI is entitled to process this range of personal data further to protect its rights in a dispute with the customer.
Bookkeeping – processing based on law within the meaning of Article 6(1)(c) of GDPR
To the extent necessary, personal data can also be processed to fulfil IMUNI’s legal obligation to keep records of its income and expenses, payments received and management, as required by tax and accounting regulations.
Direct marketing – processing based on a legitimate interest within the meaning of Article 6(1)(f) of GDPR
IMUNI is entitled to use the customer’s electronic address and telephone number to disseminate commercial communications concerning its own services similar to those already provided to the customer, according to Section 7(3) of the Act on Certain Information Society Services. The legitimate interest, in this case, is IMUNI’s intention to advance its business.
Direct marketing – processing based on consent within the meaning of Article 6(1)(a) of GDPR
IMUNI may also process personal data of individual data subjects, namely name and surname, e-mail address and telephone number, based on the explicit consent of a data subject who is not a customer and voluntarily subscribes to commercial communications related to IMUNI’s business activities.
Advertising – processing based on the legitimate interest of the controller within the meaning of Article 6(1)(f) of GDPR
IMUNI processes distributors’ personal data in the form of photographs or audiovisual footage for marketing, advertising, promotional and commercial purposes to raise awareness of the controller’s activities and, by extension, distributors and to maximise profits. IMUNI expressly states that this data may be published on the controller’s website and social networks on the IMUNI profile.
Overview of distribution networks – processing based on the legitimate interest of the controller within the meaning of Article 6(1)(f) of GDPR
IMUNI processes distributors’ personal data, namely name, e-mail address, and telephone number, to provide this information to superior distributors within the same IMUNI distributor branch, improve the sales performance of individual distributors, and coach and motivate distributors at lower positions to grow and move up to higher levels.
When you visit the IMUNI website, the IMUNI server sends a small amount of data to the data subject’s device and stores it there. It sends the data back to the server on each subsequent visit. This short text file contains a specific string of characters with unique information about the data subject and is known as cookies.
The law stipulates that cookies can be stored on a device if they are strictly necessary for the website’s operation in question. For all other cookies, the device owner’s consent is required. Most browsers are set up to accept cookies. However, data subjects can set their browser to block cookies or inform them when cookies are sent. Without cookies, however, some services or functions will not function properly.
The IMUNI website uses various types of cookies, in particular, “first-party” cookies, i. e., cookies used only by the IMUNI website, and “third-party” cookies (i. e., cookies originating from third party websites).
First-party cookies store user preferences and data needed during the data subject’s visit to the website. Third-party cookies track user trends and behaviour patterns, target advertising with the help of third party web statistics providers.
Third-party cookies that track trends and behaviour patterns are only used by the IMUNI website and the web statistics provider. They are not shared with any other third party.
Visited sites can store in cookies any information they find out about a particular data subject so that the interests and preferences of the data subject can be monitored.
IMUNI uses the following cookies: Google Analytics, Google AdWords, Facebook Pixel and Sklik. More information about the cookies used can be obtained at https://policies.google.com/technologies/cookies?hl=cs#types-of-cookies; https://www.seznam.cz/reklama/cz/obsahovy-web/pravidla-reklamy/gdpr/; and https://www.facebook.com/business/help/471978536642445?id=1205376682832142.
Security and protection of personal data
The personal data of data subjects are protected with the highest level of security, both in physical form and in electronic form.
IMUNI shall retain the personal data for a maximum period of ten (10) years since the specific performance or termination of the contract. After that, IMUNI will dispose of all personal data.
Transfer of personal data to third parties
IMUNI employees and collaborators have access to the personal data of data subjects.
IMUNI would also like to inform you that to ensure specific processing operations, which the company cannot provide, IMUNI uses services and applications of third parties that act as processors in relation to IMUNI. These are the following categories of processors.
Contractual partner supplying accounting/tax services, and
Contractual partner providing IT services.
IMUNI further advises that, as part of its network marketing business, the data subject’s personal data – distributors- may be shared with members and cooperating entities in the upline sponsorship in which the member is registered.
Transfer of personal data outside the European Union
IMUNI processes personal data exclusively in countries of the European Union or in countries that provide an adequate level of protection based on a decision of the European Commission.
Rights of data subjects concerning the personal data protection
Data subjects have several rights concerning data protection, as set out below. If the data subject wishes to exercise any of these rights, they should contact IMUNI using the contact details as set out above in section 1 of this document.
In particular, data subjects have the following rights:
(A) The right to information: is fulfilled by the following principles of processing and protection of personal data;
(B) The right of access: if the data subject so requested, they will be informed within one (1) month what personal data IMUNI processes about them and why;
(C) The right to supplement and amend personal data: if the data subject requests to amend or supplement personal data, IMUNI will amend the personal data held by IMUNI;
(D) The right to restriction of processing: where the data subject considers that IMUNI is processing inaccurate data concerning them, where they believe that IMUNI is processing the data unlawfully, but the data subject does not wish to have all the data erased, or where the data subject has objected to the processing. The data subject may also limit only the scope of the personal data or the purpose of the processing;
(E) The right to portability: if the data subject requests, IMUNI will inform them within one (1) month which of their personal data it processes and why, in machine-readable form, so that the data subject can take their personal data and transfer it to someone else;
(F) The right to erasure (to be forgotten): if the data subject legitimately requests so, IMUNI shall erase all of their personal data from its system and the system of all sub-processors and backups within one (1) month, or the data subject shall communicate which data have been erased and justify which data could not be erased and why;
(G) Complaint to the Data Protection Authority: if the data subject considers that IMUNI has not handled their data in accordance with the law, they have the right to lodge a complaint with the Data Protection Authority at any time.
The possibility to withdraw consent
IMUNI hereby informs the data subjects that if the data subject provides some of their personal data for a specific purpose of processing based on their consent, the data subject is entitled to withdraw this consent at any time free of charge in accordance with Article 7 of GDPR.
The data subject shall validly withdraw their consent when they inform IMUNI, using any means and through the contact details mentioned in Article 1, that they withdraw their previously given consent. Such communication must be made available to IMUNI.
At the same time, IMUNI hereby points out that the withdrawal of consent does not affect the lawfulness of processing based on consent given before its withdrawal.
IMUNI hereby assures all customers and potential customers that its employees and collaborators who will be involved in any way in the processing of personal data of data subjects are obliged to maintain the confidentiality of such information and security measures, the disclosure of which would compromise the security of personal data. This duty of confidentiality shall continue even after the end of the respective employment or other contractual relationship with IMUNI.
Without the data subject’s explicit consent, their personal data will not be released to any third party other than those specifically named in this document.