Principles of personal data processing[1] 

Administrator contact details

Name: Promogen s.r.o

Registered office address: Petržílkova 13, 158 00 Prague 5

ID number: 09954830


Phone: +420 775 505 477

The processing of personal data takes place in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons in connection with the processing of personal data and on the free movement of such data and on the repeal of Directive 95/46/EC ( hereinafter "Ordinance"), of the Personal Data Processing Act and Act No. 480/2004 Coll., on certain information society services, as amended.

  1. Concepts

Data subject: Natural person (consumer and self-employed person) to whom the personal data relate (hereinafter also "You" or "customer");

Personal data: Any information about an identified or identifiable customer; an identifiable customer is a natural person who can be directly or indirectly identified, in particular by reference to a certain identifier, for example a name, identification number, location data, network identifier or to one or more special elements physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person (hereinafter also "data" or "information");

Administrator: The entity that determines the purpose and means of personal data processing, carries out the processing and is responsible for this processing. The administrator of personal data is Promotion (and also "we");

Processor: An entity that, on the basis of the law or on the authority of the administrator, processes personal data for the administrator, based on a contract on the processing of personal data (hereinafter also "business partner" or "partner");

Website: Website available at

Purpose of personal data processing: Reason why personal data is processed. Such a reason can be, for example, the fulfillment of a contract, the administration of user accounts, the handling of suggestions and complaints, the sending of business communications (newsletters) or the display of advertisements based on the interests of customers;

Cookies: Short text files stored by your web or mobile browser. Most cookies contain a unique identifier, the so-called cookie ID. This is a string of characters assigned by websites and servers to the browser that stored the cookie. This allows websites and servers to distinguish and identify individual browsers. Cookies are used to improve the functioning of the website, to evaluate its traffic and to better target marketing activities. If you browse our website, we assume that you agree to the use of these files.

Third country: States outside the European Economic Area, which mainly includes the member states of the European Union and Iceland, Liechtenstein and Norway.

  1. What personal data is processed?

Based on the relevant legal title and purpose of processing, we and its contractual processors process the following personal data, respectively categories of personal data:

  1. identification and address data: e.g. name, surname, delivery or other contact address, address of the collection point, registered office, ID number, VAT number;
  2. electronic contact details: e.g. phone number, email address;
  3. other electronic data: IP address, cookies;
  4. other personal data associated with the contractual relationship: bank account number, order history;
  5. other personal data: typically data provided by the customer in the order form or in other documents and when communicating with us, including later updates.
  • What is the origin of personal data?

We process data that you give us, for example, when ordering our services, registering a user account, communicating with us or signing up for a newsletter. Typically it is about

  • identification and address data;
    • electronic contact details;
    • other personal data associated with the contractual relationship.

And further data that we obtain automatically based on the fact that you browse our website. Typically these are:

  • other electronic data:
    • cookies
    • the website from which you came to our website;
    • IP address;
    • date of access and time of access;
    • search queries;
    • http and https response code;
    • transmitted groups of data;
    • browser and computer operating system information.
  1. Why are personal data processed?

Your personal data may be processed for the following purposes:

  • Performance of the contractual relationship
  • Managing customer accounts
  • Communication with customers, satisfaction evaluation, publication of reviews, book recommendations, handling of suggestions, complaints and complaints
  • Sending business messages and offering our products
  • Direct marketing and creation of personalized content and advertising
  • Improving the quality of our goods and services, analyzing traffic to our website and your behavior on the website
  • Running a customer competition and delivering prizes
  • Protecting our rights, property or safety or the rights, property or safety of others
  • Accounting and tax purposes
  • Fulfillment of other legal obligations

Your personal data may be processed on the basis of the following legal grounds:

  • Performance of the contract
  • Compliance with legal obligations
  • The administrator's legitimate interest in sending commercial messages
  • Consent to sending commercial messages

The processing of personal data for the purposes of fulfilling the contractual relationship, accounting and tax purposes and the fulfillment of other legal obligations are legal or contractual requirements. If you intend to place an order through our website, you are obliged to provide us with your personal data for these purposes.

  1. How long are personal data processed?

Your personal data is processed:

  • for the period necessary to exercise the rights and obligations arising from the contractual relationship between you and us and the exercise of claims from these contractual relationships (4 years);
  • for the period necessary to fulfill a legal obligation (accounting documents 5 years, tax documents 10 years);
  • for the duration of our legitimate interest in sending commercial communications (2 years from the last opening of a commercial communication);
  • for the duration of your consent (no longer than 4 years from its granting, or 4 years from the last order).
  1. To whom is personal data made available?

The following categories of our partners (recipients) may have access to your personal data:

  • Providers of accounting and tax advice
    • Providers of the security and integrity of our services and website
    • Analytics service providers
    • Partners who provide direct marketing for us and partners and operators of technical solutions thanks to which we can show you personalized content and advertising
    • Public administration bodies
  1. Is personal data transferred outside the EU?

The administrator does not intend to transfer personal data to a third country (outside the European Economic Area) or an international organization. Recipients of personal data in third countries are:

  • Partners to whom we provide data for the purpose of analyzing traffic to our website, your behavior on the website and business conversions
    • Providers of IT services and hosting, incl. cloud services
    • Mailing service providers
  • How are personal data processed?

Personal data is processed manually and automatically. We keep proper records of all processing activities in accordance with the relevant legal regulations.

You are not the subject of any decision based solely on automated processing, including profiling, which would have legal effects for you or would similarly significantly affect you. We do not create/create profiles from your personal data for the purpose of analyzing or predicting your preferences, interests, economic situation, reliability, where you are or your movements (a typical example of profiling is monitoring the behavior of website visitors in order to track their preferences so that could approach the merchant in the future with a tailor-made offer).

  • What are the rights of data subjects?

To exercise your rights, please contact us via our contact details, which are listed at the beginning of this policy.

In connection with the processing of your personal data, you have the following rights (Articles 15 to 21 GDPR):

  • Right of access to personal data
  • The right to correct inaccurate and supplement incomplete personal data
  • The right to erasure of personal data
  • The right to restrict the processing of personal data
  • Right to data portability
  • The right to object to processing
  • The right to information about automated decision-making, including profiling

If we process your personal data based on your consent, you have the right to revoke this consent at any time.

Furthermore, you have the right file a complaint with the supervisory authority, which is the Office for the Protection of Personal Data, with headquarters in Plk. Sochova 27, 170 00 Prague 7, phone: 234 665 111, website:

  1. How are cookies processed?

The processed cookies can be divided according to validity into:

  • temporary cookies (so-called session cookies), which remain stored in your browser only until you close your browser,
  • permanent cookies (so-called persistent cookies), which remain stored in your browser for a long time until their lifetime expires or until you manually delete them (the storage time of cookies in your browser depends on the settings of the cookie itself and your browser settings).

And by functions on:

  • essential, which are necessary for the functionality of our website,
  • preferential, which allow our website to remember information that changes how the website behaves or looks (eg your preferred language or the region you are in), these cookies are not strictly necessary for our website to work, but they increase the functionality and the practicality of their use,
  • analytical, which help us analyze your experience on our website (so-called User Experience = user experience) and through which we understand how you use our website,

We do not use third-party cookies that track multiple websites in order to provide you with personalized content and advertising on third-party websites and other sales channels.

  1. Are data about children also processed?

Our website is not intended for children under the age of 16. We therefore do not intentionally collect their personal data. If we discover that we have inadvertently obtained personal information about children under the age of 16, we will take steps to delete that information as quickly as possible, except where we are required by applicable law to retain it.

  1. Conclusion

Legal regulations as well as our business strategy and related methods of processing your personal data may change. If we decide to update this policy, we will post the changes on our website and notify you of the changes. In cases where there is to be a more fundamental change to these principles, or in the case where the law requires us to do so, we will inform you in advance. We ask that you read these policies carefully and check them regularly when you continue to communicate with us or use our website.