PRIVACY POLICY
1.1. This document together Cookie Policy (see below) provides for the information on the processing of personal data, including rights related to the processing of personal data of the users of the web application enabling the selection and configuration of products, as well as the creation and sending of non-binding order for configured or other products, which is located on the website [WWW.czconfigurator.com/ph/] (the “Configurator”).
1.2. Personal data in relation to the Configurator are processed in accordance with applicable laws, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 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) (“GDPR”).
1.3. Česká zbrojovka a.s., with its registered office at Svat. Čecha 1283, 688 01 Uherský Brod, Czech Republic, company identification number (IČO): 463 45 965, registered in the Commercial Register maintained by the Regional Court in Brno, Section B, Insert No. 712 (the “Operator”), ensures the technical operation of the Configurator for the territory of Philippines and does not have any influence on determination of the purposes and means of the processing of personal data of the users of the Configurator (the “Users”), unless the personal data of the Users are processed on a basis of a consent granted to the Operator (Article 6(1)(a) of the GDPR) for marketing purposes. Only in such cases, the Operator acts as a data controller (or joint controller; see below).
1.4. P.B. Dionisio and Company with its registered office at PBD Building, 27 Don Alejandro Roces Avenue, 1103 Quezon City, Philippines ID No. Sec. Registration Number 5486, Municipal license, 97-067334, PNP license NO. FA-07, VAT no.: TIN 000-390-372-000. Registered in Securities and Exchange Commission Registration no.:5486 maintained by Maria Antonia D. Dacanay. (the “Distributor”) distributes the products of the Operator within the territory of Philippines via its contractual partners listed in the Configurator (the “Dealers”); the contact details of the Dealers are available in the Configurator directly in the selection process of the Dealers by the User. The purposes and means of the processing of personal data of the Users (if not processed on the basis of the consent granted to the Operator under Article 1.3 of this Privacy Policy above) are determined by the Distributor together with the Dealers (the Distributor and the Dealers collectively as the “Controllers”).
1.5. Therefore, the Controllers are joint data controllers in relation to the processing of personal data via the Configurator in accordance with Article 26 of the GDPR (except for Article 1.3 of this Privacy Policy above). The mutual relationship governing the rights and obligations of the Controllers in relation to personal data is provided for in separate agreements entered into between the Distributor and each of the Dealers on liability in relation to the processing of personal data; in such cases, the Operator acts as a data processor of the Controllers pursuant to separate data processing agreements.
2.1. The personal data of the Users are processed in the Configurator as follows:
Categories of personal data | Purpose | Legal basis | Data controller |
Identification (name, address), Contact data of the User (e-mail and phone contact) and SIA Number Data on configuration of products by the User (selected customization of the firearm) | Processing is necessary in order to take necessary steps in relation to a non-binding order of the User sent via Configurator to the selected Dealer. Provision of personal data is required in order to enter into the subsequent contractual relationship with the Dealer. | Art. 6(1)(b) of the GDPR | Distributor and Dealer selected by User as joint controllers |
Identification (name, address) and Contact data of the User (e-mail and phone contact) | Sending a commercial communication and informing the User about the other sale offers based on the consent of the User. Granting a consent is voluntary and is not a legal requirement, a contractual requirement nor a requirement necessary to enter into any agreement. | Art. 6(1)(a) of the GDPR | Operator |
Identification (name, address) | Processing is necessary for compliance with a legal obligation (e.g., accounting laws or applicable firearm legislation). Provision of personal data is a legal requirement. | Art. 6(1)(c) of the GDPR | Distributor and Dealer selected by User as joint controllers |
Contact data of the User (e-mail and phone contact) and Identification (name, address) for sending mail | Sending a commercial communication and informing the User about the other sale offers in respect of the similar products and/or services based on the legitimate interest of the Dealer selected by the User legislation). If the User has not initially opted-out of receiving marketing. | Art. 6(1)(f) of the GDPR | Dealer selected by User |
Operating data (Cookies) | Setting up a website and improvement of functions of the Configurator via processing of cookies (the text of the Cookie Policy is available below). If the legal basis is a consent, granting a consent is voluntary and is not a legal requirement, a contractual requirement nor a requirement necessary to enter into any agreement | Art. 6(1)(f) of the GDPR (essential cookies) OR Art. 6(1)(a) of the GDPR (other cookies) | Operator |
Data on configuration of products by the User (selected customization of the firearm) Email address of the User | Saving the results of the configuration of products in the Configurator. Provision of personal data is required in order to save the results of the configuration of products in the Configurator. | Art. 6(1)(b) of the GDPR | Distributor and Dealers listed in Configurator as joint controllers |
2.2.
2.2. Personal data of the Users are not intended to be transferred to a third country or international organization outside the EU/EEA. Automated decision-making including profiling is not applicable in relation to data processing in relation to the Configurator. The Operator also does not use the data for profiling or analysis purposes.
3.1. The personal data of the Users are only made available to the authorised employees of the Operator’s Controllers.
3.2. The personal data of the Users may be anonymised and on the basis of these anonymised data aggregated reports may be generated and sent primarily to companies in the group of the Operator and the Joint Controllers for statistical purposes.
3.3. In statutory cases, certain personal data may be disclosed to public authorities on the basis of applicable legislation.
4.1. Personal data will be stored securely in electronic or paper form. Personal data may be processed manually or by automated means.
4.2. Personal data will be processed and stored for the period of time stipulated in generally binding legal regulations or for the period of time for which the User has granted their consent to the processing of the data.
4.3. Overview table showing the retention period of personal data:
Category of data Purpose | Retention period |
Identification data of the User, Contact data of the User, Data on configuration of products by the User and SIA Number Processing in order to take necessary steps in relation to a non-binding order of the User sent via Configurator to the selected Dealer. | For the period of 6 months following a delivery of the non-binding order of the Users to the selected Dealer unless the applicable laws provide for a shorter period. |
Contact data of the User Processing is necessary for compliance with a legal obligation. | For the period stipulated pursuant to the applicable laws. For instance, for tax and accounting purposes, the legislation sets a minimum retention period of 5 years. |
Operating data Setting up a website and improvement of functions of the Configurator via processing of cookies | For the period of the granted consent and/or until the consent was revoked by the User. If Operating data are processed based on legitimate interest of the Operator, then for the period necessary to fulfil the purpose of the processing. |
Identification data of the User and Contact data of the User Sending a commercial communication and informing the User about the other sale offers based on the consent of the User. | For the period of the granted consent and/or until the consent was revoked by the User. |
Identification data of the User and Contact data of the User Sending a commercial communication and informing the User about the other sale offers in respect of the similar products and/or services based on the legitimate interest of the Dealer selected by the User. | For the period of 1 year following a delivery of the non-binding order of the Users to the selected Dealer unless the applicable laws provide for a shorter period. |
Data on configuration of products by the User and Contact data of the User Saving the results of the configuration of products in the Configurator. | For the period of 30 days following a day on which the last save of the configuration of products was performed by the User. |
4.4.
5.1. The data subject shall have rights in relation to the processing of personal data which arise under the law and which he or she may exercise at any time with any Controller. These are the right (a) to withdraw consent to the processing of personal data, (b) to access personal data, (c) to have inaccurate personal data rectified and incomplete personal data completed, (d) to have personal data erased if they are no longer necessary in relation to the purposes for which they were collected or otherwise processed or if it is established that they have been unlawfully processed, (e) to restriction of the processing of personal data, (f) to data portability, and (g) the right to object, upon recognition of which the processing of personal data will be terminated, unless it is demonstrated that there are compelling legitimate grounds for the processing which override the interests or rights and freedoms of the data subject, in particular where the ground is the possible exercise of legal claims; and (h) the right to have recourse to a supervisory authority, which is in Philippines, National Privacy Commission, https://privacy.gov.ph/. [1]
(a) Right to withdraw consent to the processing of personal data: if your personal data are processed on the basis of your consent, you may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent prior to its withdrawal. You can withdraw your consent by using the contact details specified in Articles 5.3 and 5.4 of this Privacy Policy or the hyperlink embedded in the footer of the marketing communication.
(b) Right to access personal data: you have the right to obtain information about whether your personal data are being processed and the right to access your personal data.
(c) Right to have inaccurate personal data rectified and incomplete personal data completed: if you believe that your personal data processed are inaccurate or incomplete, you have the right to request their rectification and completion. The rectification or completion will be carried out without undue delay, but always taking into account the technical possibilities.
(d) Right to erasure: if you request erasure of your personal data, your personal data will be erased if (i) they are no longer necessary in relation to the purposes for which they were collected or otherwise processed, (ii) the processing is unlawful, (iii) you object to the processing and there are no overriding legitimate grounds for the processing of your personal data, or (iv) if such processing is imposed by a statutory obligation.
(e) Right to restriction of the processing of personal data: if you request a restriction of processing, your personal data will be made inaccessible, temporarily deleted or stored, or other processing operations will be carried out that are necessary for the proper exercise of the asserted right.
(f) Right to data portability: if you want your personal data which are processed on the basis of your consent or on the basis of taking a pre-contractual measure, to be transferred to you or to a third party, you can exercise your right to data portability. If the exercise of such a right may adversely affect the rights and freedoms of third parties, your request will not be granted.
(g) Right to object: you have the right to object to the processing of personal data that are processed for the purposes of protecting the legitimate interests of the Joint Controllers. If the Joint Controllers do not demonstrate a compelling legitimate interest in the processing that overrides the interests or rights and freedoms of the Users, they will terminate the processing without undue delay on the basis of the objection. If the essence of the Users’ objection is against the sending of commercial communication, please use the link at the end of the last commercial communications (newsletter) you received from the Joint Controllers to unsubscribe from commercial communications and the processing of personal data for that purpose.
5.2. In the event of repeated or manifestly unfounded requests to exercise the rights referred to above, the controller may, in accordance with Article 12(5)(a) of the GDPR, charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested. You will be informed of that procedure.
5.3. The point of contact in relation to the processing of personal data in the Configurator is the registered office of the Distributor or an email address of the Distributor: [email protected]. or the registered of office of the Dealer selected by the User or its email address listed in the Configurator or DPO of the Dealer selected by the User (if DPO was appointed, contact details of DPO are available in the selection process of the Dealer in the Configurator).
5.4. The point of contact in relation to the data processing based on the consent of the User granted to the Operator (see Article 1.3 of this Privacy Policy above) is the registered office of the Operator or an email address of the Operator [email protected].
5.5. You may also use the contact details under Articles 5.3 and 5.4 of this Privacy Policy to exercise your rights. The Controllers and the Operator reserve the right to reasonably verify the identity of the data subject exercising the aforementioned rights.
5.6. The Joint Controllers and the Operator may unilaterally amend or supplement this Privacy Policy at any time. In the event of substantial changes to this Privacy Policy affecting the rights of data subjects or the processing of their data, such changes will be communicated to data subjects in good time and in an appropriate manner.
5.7. This Privacy Policy forms an integral part of the non-binding orders sent by the Users from the Configurator to the Dealer selected by the User.
6.1. This Privacy Policy becomes valid and effective from 15. 11. 2023.
6.2. This Privacy Policy was last updated on 15. 11. 2023.
COOKIES POLICY
1.1. This document governs the cookies policy of Česká zbrojovka a.s.,., with its registered office at Svat. Čecha 1283, 688 01 Uherský Brod, Czech Republic, company identification number (IČO): 463 45 965, registered in the Commercial Register maintained by the Regional Court in Brno, Section B, Insert No. 712 (the “Operator”) applicable to users - natural persons who browse, read or enter their data on the website https://www.czconfigurator.com/ph/ (the “Website”) or provide their data to the Operator through third party websites (the “Policy”).
1.2. The purpose of this Policy is, inter alia, to duly inform the Website users about the use of cookies, the possibility of granting consent to the use of cookies, and the possibility of disabling the use of cookies.
1.3. This Policy, together with the Privacy Policy (see above), describe how the data of the Website users are obtained, collected, processed and used, and how the Operator obtains and processes information about the Website users by means of cookies.
2.1. For the purposes of this Policy, ‘cookies’ mean cookie files and other similar technologies (such as pixel tags, web beacons or device identifiers) that may automatically collect information when you visit the Website. Information collected in this way may include browser type, operating system, referring URL, information about activities on the Website, and the dates and times of individual visits to the Website. Cookies thus help to provide, protect and improve the services offered.
2.2. Cookies in particular:
(a) serve for efficient navigation on the Website, personalisation, saving preferences and generally improving the user’s experience of the Website; and
(b) allow to distinguish whether a particular user has visited the Website in the past or is a new visitor and to assist in recording statistics about visitors to the Website.
2.3. Operators will only use some of the cookies if a visitor to the Website has granted their consent to the use of cookies in accordance with Clause 5.1 of this Policy.
2.4. The specific purposes for which cookies are used are set out below in Clause 4 of this Policy.
3.1. In general, cookies can be divided on the basis of a number of criteria:
(a) According to who creates and processes cookies, cookies can be divided into:
(i) first party cookies, which are created directly by websites or scripts on the same domain. They are most often used to provide the basic functionality of the website;
(ii) third party cookies are created by other websites. These websites own some content on the website you visit, such as advertisements, images or videos.
(b) According to their durability, cookies can also be divided into:
(i) session cookies are temporary and are stored on the device only until the user finishes working with the web browser, and are deleted after closing it. These cookies are essential for the proper functionality of the website or associated applications;
(ii) permanent cookies are used for easier and more convenient navigation on the website (e.g. easier and faster navigation). These cookies remain in the browser for a longer period or until they are manually deleted. The length of this period may depend on the selected web browser settings.
(c) According to their intended use, cookies can be divided into:
(i) strictly necessary cookies (essential), which are necessary for the operation of the website. These include, for example, cookies that allow the user to log into secure parts of the website. These cookies do not collect information about users that could be used for marketing purposes or to remember what websites users have visited in the Internet environment;
(ii) performance/statistical cookies are used to improve the functioning of the website. These cookies collect information about how visitors use the website, e.g. which websites visitors go to most often and whether they receive error messages from the website. Performance cookies allow us to record and count the number of visitors to the website, which allows us to track how visitors use the website. These cookies do not collect personally identifiable information about the user. The information collected by these cookies is aggregated and anonymous;
(iii) functional cookies facilitate the control and improve the functions of the website. They are used to activate specific website functions (e.g. video playing) and to set them according to the user’s preferences (e.g. language). Functional cookies are also used to remember preferences for the next time the user visits the website. However, they do not collect information that can identify the user;
(iv) targeted and advertising cookies (profiling) are used to track preferences and to send advertising messages in accordance with those preferences.
4.1. The following types of cookies are used on the Website:
Name | Publisher | Purpose | Expiry |
_dc_gtm_UA-xxxx9325-1 | This cookie anonymously collects statistical data for Google Tag Manager about how visitors behave on the Website. To disable the cookie click here. | 1 minute | |
_ga | This cookie anonymously collects statistical data about how visitors behave on the Website. To disable the cookie click here. | 730 days | |
_gid | This cookie anonymously collects statistical data about how visitors behave on the Website. To disable the cookie click here. | 1 day | |
_hjIncludedInSample | HotJar | This cookie anonymously collects statistical data about how visitors behave on the Website, while anonymously tracking mouse movements, clicks, etc. during a visit to the Website. To disable the cookie click here. | During a session |
_first_pageview | This cookie offers you information about cookies on the first page of the Website. To disable the cookie click here. | 10 minutes | |
leady_session_id | Leady | This cookie can recognize corporate visitors. This cookie can also identify your company, but not you personally, and works exclusively with public data. | During a session |
4.2.
4.2. Further information about our cookies and an up-to-date list of cookies is available within individual web browsers, most often in the Developer Tools section.
5.2. Users may change their browser settings at any time and reject/remove or allow the use of cookies. The specific procedure differs from browser to browser, so please refer to your browser’s help for further information. For the most common browsers these are:
(a) Chrome
(b) Firefox
(c) MS Internet Explorer / Edge
(d) Safari
(e) Opera
5.3. Rejecting or removing cookies may lead to the Website or some of its services not functioning properly and may have an adverse effect on your user experience. Areas of the Website that could use third party content and related cookies will not be available.
6.1. In order to manage the Website or to carry out marketing activities on behalf of the Operator, the Operator may share information obtained through cookies with third parties. Personal data may be provided to the following categories of recipients:
(a) IT companies administering the Website;
(b) Other companies from the business group of the Operator.
7.1. Many third-party applications allow users to block or manage cookies. Users can also delete cookies that were previously stored on their device by deleting their browsing history or through third party applications.
7.2. For more information about applications that allow users to block or manage cookies and other useful information about cookies, please see, for example, the following websites:
(a) www.aboutcookies.org;
7.3. If you have any questions about cookies, you can contact us by e-mail at [email protected].
8.1. The Operator may unilaterally amend or supplement this Policy at any time. In the event of any amendment to this Policy, the Operator shall notify the users of such amendment in sufficient time and in an appropriate manner so that the users have an objective opportunity to familiarise themselves with such amendment.
8.2. This Policy comes into force and effect on 15. 06. 2023.
8.3. This Policy was last updated on 15. 06. 2023.
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