PRIVACY POLICY

Company Wultra s.r.o., ID no.: 03643174, registered office at Bělehradská 858/23, Vinohrady, 120 00 Praha 2, registered in the Commercial Register administered by the Municipal Court in Prague, section C, insert 235343 (hereinafter as “Wultra”), as a personal data controller, hereby informs Wultra’s clients (hereinafter as “Clients”), people acting on behalf of the Clients, Wultra’s vendors and other business partners (hereinafter as “Partners”) business leads and potential clients, and visitors of Wultra’s website, how their personal data is processed by Wultra.

The document includes information about the rights the data subjects have in connection with processing of their personal data.

For any questions regarding privacy and to exercise your rights in relation to personal data processing, please contact: Wultra Operations department, e-mail: privacy@wultra.com.

1. PURPOSES, LEGAL GROUNDS, CATEGORIES OF PERSONAL DATA PROCESSED AND DURATION OF PROCESSING

1.1. Conclusion and performance of a contract on provision of Wultra’s products and services

Wultra provides its products and services to the Clients based on the respective contract with the Client (hereinafter as “Contract”). To be able to negotiate and conclude the Contract with the Client and to perform the Contract, Wultra processes the following personal data:

• identification and contact data of the people acting on behalf of the Client with Wultra (employees, executives or other representatives of the Client, who themselves are not a party to the Contract, however they communicate and act on behalf of the Client with Wultra), information about their relationship to the Client and information from communication with them,
• in case the Client is a natural person - Client’s identification data (title, names, surname, registration number (business ID), tax ID number, date of birth, address of registered office), Client’s contact information (e-mail address, delivery address, phone number), information included in the Contract, about its performance, termination, communication with Wultra, billing information (bank account number, invoices issued, billing address).

Without the above data, the Contract cannot be concluded and performed. Legal grounds for processing the above data:

• in case of the people acting on behalf of the Client: legitimate interests pursued by Wultra (to be able to enter into Contracts with Clients, communicate and perform Wultra’s obligations towards the Clients).
• in case of a Client – natural person: performance of the Contract and taking steps at the request of the Client prior to entering into the Contract.

For this purpose, the personal data is processed for the duration of the negotiation, conclusion and performance of the Contract.

1.2. Wultra's partners

To negotiate, enter into and perform an agreement on cooperation with a Partner (hereinafter as “Cooperation Agreement”), Wultra processes the following personal data:

• identification and contact data of the people acting on behalf of the Partner with Wultra (employees, executives or other representatives of the Partner, who themselves are not a party to the Cooperation Agreement, however they communicate and act on behalf of the Partner with Wultra), information about their relationship to the Partner and information from communication with them,
• in case the Partner is a natural person - Partner’s identification data (title, names, surname, registration number (business ID), tax ID number, date of birth, address of registered office), Partner’s contact information (e-mail address, delivery address, phone number), information included in the Cooperation Agreement, information about its performance, termination, communication with Wultra, billing information (bank account number, invoices issued, timesheets, billing address), information about Partner’s commission or other remuneration and details necessary for its calculation.

Without the above data, the Cooperation Agreement cannot be concluded and performed. Legal grounds for processing the above data:

• in case of the people acting on behalf of the Partner: legitimate interests pursued by Wultra (to be able to enter into Cooperation Agreements with Partners, communicate and perform Wultra’s obligations towards the Partners).
• in case of the Partner – natural person: performance of the Cooperation Agreement and taking steps at the request of the Partner prior to entering into the Cooperation Agreement.

For this purpose, the personal data is processed for the duration of the negotiation, conclusion and performance of the Cooperation Agreement.

1.3. Participation in workshops and seminars

In case you participate in Wultra’s workshop or seminar, Wultra processes the following personal data:

• participant’s identification data (title, names, surname), contact information (e-mail address, phone number), information from communication with Wultra, billing information (bank account number, invoices issued, billing address), information about participation in the event.

Without the above data, Wultra is not able to organize the event and enable you to participate. Legal grounds for processing the above data:

• performance of a contract with the participant and taking steps at the request of the participant prior to entering into the contract.

For this purpose, the personal data is processed until the workshop or seminar ends.

1.4. Case studies, testimonials

In case a person representing the Client or Partner voluntarily provides Wultra a testimonial regarding Wultra’s products or services, or agrees to be mentioned in Wultra’s case study, Wultra will process their personal data to collect, publish and otherwise use the testimonial or case study for Wultra’s presentation and propagation (especially in Wultra’s marketing materials, business presentations, offers etc.). For this purpose, the following personal data will be processed:

• names, surname, titles, relationship to Wultra or a particular Client or Partner, their photograph and the testimonial or other statement about Wultra’s products or services.

Legal grounds for processing the above data:

• consent of the data subject.

The consent may be granted in writing (by consenting via e-mail or other communication channels).

The consent is voluntary. If you choose not to grant the consent, it will not affect you or the Client of Partner which you represent in any way.

The consent is granted for 10 (ten) years. You can choose to withdraw the consent sooner, as described below.

The consent may be revoked any time for free via contact e-mail stated above in this document.  

Once the testimonial is no longer relevant for Wultra, you choose to withdraw your consent, or the duration of the consent terminates, Wultra will cease the processing of your personal data processed based on the consent. Some personal data may be processed longer based on other legal grounds, as specified in this document.

1.5. Business leads

Wultra keeps records of business leads (potential customers, Partners etc.). For this purpose, Wultra may process especially the following personal data:

• identification and contact data of potential Clients or Partners, relevant contact persons of the potential Clients and Partners,
• information about previous interactions with these business leads.

Legal grounds for processing the above data:

• legitimate interests pursued by Wultra (Wultra’s business development).

For this purpose, the personal data is processed generally for 5 years from the last interaction with the lead.

1.6. Communication with public, web contact form

To process questions, requests, queries or other communication from public made via Wultra’s publicly available contact details, social media profiles and web contact forms available at Wultra’s website, Wultra processes the following personal data of people who decide to contact us:

• identification and contact details provided, content of the communication.

Legal grounds for processing the above data:

• taking steps at the request of the data subject prior to entering into a contract,
• legitimate interests pursued by Wultra (to be able to process the questions, requests and queries).

For this purpose, the personal data is processed for the time necessary to process the question, request or query.

1.7. Sending commercial messages (newsletters)

Wultra may send newsletters (commercial messages) to the Clients, Partners or participants in Wultra’s events to whom Wultra provided its products or services and in connection with this obtained their e-mail and/or telephone number, or to other persons who actively and voluntarily subscribed to Wultra’s newsletter (e.g. via Wultra’s website). For this purpose, Wultra processes the following personal data:

• e-mail address, telephone number, names, surname, title.

Legal grounds for processing the above data:

• in case of the Clients, Partners and participants in Wultra’s events: legitimate interests pursued by Wultra (to promote Wultra and Wultra’s products and services),
• in other cases: consent of the recipient.

If you do not wish to receive these newsletters, you can unsubscribe any time for free. The option to unsubscribe is always included in each of the newsletters sent, or you can contact Wultra via the contact e-mail stated above in this document.

For this purpose, the personal data is processed, and the newsletters are sent until you unsubscribe.

1.8. Cookies

Wultra uses cookies (or similar tracking technologies) on Wultra’s website (www.wultra.com). The data collected by cookies is further processed by Wultra for the following purposes:

• Analysis of website traffic to improve the user experience and relevance of Wultra’s website content.
• Personalized advertising: Wultra tracks visitors’ behavior to display ads that are relevant based on previous activity of the visitor on Wultra’s website. Information about the interaction of the visitor with the ads and activity after clicking on an ad is processed to evaluate the effectiveness of ad campaigns. Based on the data from marketing cookies, visitors are clustered into segments to understand the target audience and to target Wultra’s marketing strategy.

In relation to that, the following personal data may be processed:

• information on cookie consent and cookie preferences set by the visitor (consent ID of the visitor, date and time of the consent, cookies allowed),
• information collected by the respective cookies allowed, including traffic sources, pages visited, time spent on each page, clicks and navigation paths, information about the interaction of the visitor with the ads and activity after clicking on an ad, segmentation of the visitor for purposes of ad targeting, visitor’s device and location information (IP address, device type, operating system and general geographic location).

Legal grounds for processing this data:

• legitimate interests pursued by Wultra (evidence of compliance with Wultra’s legal obligations, analysis of traffic and usage of Wultra’s website, display of relevant targeted ads, evaluation of ad campaigns).

Further, based on the data collected by cookies or similar tracking technologies, Wultra compiles and further processes and anonymized aggregated information about Wultra’s website traffic and usage.

More about the purposes of the use of cookies, legal grounds for collection of cookies and other details can be found directly in Wultra’s cookie pop-up banner available at www.wultra.com.

1.9. Accounting and tax obligations and other legal obligations

Wultra also processes personal data where required by law.

To fulfil obligations arising from law in the field of accounting and tax obligations, Wultra is obliged to process the following personal data:

• personal data contained in the billing information of the Clients, participants in Wultra’s events and Partners, issued invoices, and other information required by relevant legislation.

Legal grounds for processing the above data:

• compliance with legal obligations of Wultra, especially as set out by the acts on accounting and tax regulation.

For this purpose, the personal data is processed for the duration of the periods set out by the relevant legal regulation. In case of the accounting and tax obligations, it is generally 5 years from the end of each accounting year, and in the case of documents relevant for VAT 10 years from the end of the tax period in which the respective transaction took place.

1.10. Protection of rights and claims

In order to be able to defend Wultra’s rights and claims in any legal disputes or legal proceedings (in particular to prove, if necessary, that Wultra has acted in accordance with its contractual and legal obligations), Wultra processes personal data, which includes especially:

• identification and contact data of the Clients, people acting on behalf of the Clients, Partners, people who contacted Wultra via publicly available contacts, business leads,
• information about the conclusion and performance a contract concluded with Wultra (the Contract, Cooperation Agreement or other), including its violations and related communication,
• other records of Wultra’s compliance with its contractual and legal obligations.

Legal grounds for processing the above data:

• legitimate interests pursued by Wultra (protection of Wultra’s rights and claims, defense against claims of others).

For this purpose, the personal data is processed generally for 4 years, or for the duration of the respective contractual relationship and 4 years after its termination. If relevant proceedings are initiated within this period, Wultra will process the relevant personal data longer, for the whole duration of the relevant proceedings.

2. ABOUT DURATION OF THE PERSONAL DATA PROCESSING

The duration of processing of the personal data depends on the purpose of processing of the personal data, and the respective periods are described above in this document for the individual purposes of processing. Wultra may process personal data for a certain purpose for a longer period than that set out above where there is other purpose for further processing, typically for purposes of compliance with legal obligations or for protection of Wultra’s rights and claims.

3. Who do we get the personal data from and who do we hand them to?

Wultra collects personal data primarily from the data subjects. The data subjects are obliged to provide true and correct information and in case of any changes of their personal data during their interaction or cooperation with Wultra, the data subjects are kindly asked to notify Wultra.

Some personal data may be handed over to us by the Client (especially in case of people representing the Client), our Partners (especially business leads or people representing the Partner) or collected by Wultra from public sources (such as business registers, LinkedIn or others).

Wultra’s authorized employees or other coworkers have access to the personal data processed by Wultra. However, Wultra makes sure that access to personal data is granted strictly on a need-to-know basis, all authorized employees and coworkers always process the personal data only as necessary to fulfil the purposes described above and are all bound by the obligation to maintain confidentiality about the personal data as well as security measures the disclosure of which could compromise the security of personal data.

Wultra uses the following data processors to process personal data for Wultra and based on Wultra’s instructions:

• IT service providers (including cloud infrastructure and operators of software used by Wultra, operator of website platform, provider of software tools for online marketing and related analytics and others),
• provider of accounting services,
• administrator of online marketing campaigns,
• Wultra’s contractors providing IT and other services.

Personal data may be transferred to a third country (outside of the EU) in connection with transfer of the data to our data processors who are settled in third countries. Personal data is only transferred to a third country if conditions set out by law for such a transfer are fulfilled (e.g. appropriate safeguards are in place, typically the Standard Contractual Clauses approved by the Commission of the EU are concluded, or the transfer is based on an adequacy decision issued by the Commission of the EU).

Detailed information about data processors and transfers to third countries can be requested via the contact above in this document.

Wultra may hand certain personal data to other data controllers, typically to providers of transport and post services, tax, legal or other advisors or to providers of payment services. Furthermore, Wultra may hand personal data to state and other public authorities for the purposes of exercise of their legal duties and competencies, if required by law or by a decision or act of the competent state or other public authority. These entities process the personal data in accordance with their own privacy policies.

4. wultra as data processor

All the information in this Privacy Policy relates to cases where Wultra processes personal data as data controller (i.e. Wultra decides on the purposes and means of the processing).

In certain cases, Wultra acts also as data processor for the Clients, which means that Wultra processes certain personal data for the Clients, based on their instructions. Such data processing is governed by a Data Processing Agreement (or Addendum), which is part of the Contract concluded between Wultra and the Client.

5. WHAT RIGHTS DO YOU HAVE IN RELATION TO PERSONAL DATA PROCESSING?

If you wish to exercise any of the rights, please contact Wultra via the e-mail provided above in this document.‍

Right ofaccess: You have a right to obtain confirmation asto whether Wultra processes your personal data, and if so, you have the right to access that data, including the right to obtain a copy of the data. Further, you may request information about the details of the data processing, especially about:

• the purposes of processing,
• personal data or, where applicable, categories of personal data subject to processing, including any available information about their source,
• the nature of the automated decision-making, including profiling and information relating to the procedure used, as well as the relevance and expected consequences of such processing for the data subject, if such processing takes place,
• recipients of your personal data and, where appropriate, categories of these recipients,
• the planned period during which the personal data will be stored or, if it cannot be determined, the criteria used to determine that period,
• all available information about the source of personal data unless the data is collected from you,
• information whether the personal data are transferred to a third country and if so, also information about appropriate safeguards relating to the transfer.

Your other rights:

• to ask us for an explanation regarding the processing;
• to request rectification, i.e. correction of inaccurate or incomplete personal data;
• right to erasure (to be forgotten) – in certain cases, you may request us to delete your personal information (for example, if the data is no longer necessary for the purposes for which it was collected);
• right to restriction of processing - you have the right to ask us to limit how we can use your personal data (for example if your data is inaccurate or the processing is unlawful);
• right to data portability - to request personal data relating to you in a structured, commonly used, and machine-readable format and transfer this data to another controller without hindering it in any way;
• to object to the processing of your personal data in case the data is processed (i) to perform a task carried out in public interest or in the exercise of official authority vested in the controller, (ii) for legitimate interests pursued by the controller or by a third party, or for purposes of direct marketing;
• to withdraw consent to processing – if your personal data is processed on the basis of your consent, you can withdraw your consent to the data processing at any time freely and free of charge;
• to submit a question or complaint to the Office for Personal Data Protection (Úřad pro ochranu osobních údajů), website: www.uoou.cz.

This Privacy Policy was updated on November 8, 2024.

‍

‍