Adentech, s.r.o., with its registered office at Lindnerova 1610/4, 180 00 Praha 8, Company ID No.: 054 44 233
(the “Adentech, s.r.o. Company”) pays close attention to personal data protection. This document explains what personal data we process about you as a User, whether processing is based on consent or another legal basis, the purposes for which we use the data, to whom it may be disclosed and your rights in connection with its processing.
1) Identification of the personal data controller
We at Adentech, s.r.o. determine the purposes and means of processing your personal data, including its collection, recording, organisation and, where applicable, disclosure. We are also responsible for ensuring that such processing is carried out properly. We act as the personal data controller because we operate the online dating application available at https://www.hledammilence.cz (the “Application”) and control the processing of your personal data.
2) What personal data do we process?
It is important that you know how and for what purposes we process your personal data. The categories below, with examples, are also referred to in the following sections.
a) Contact details
In particular, your email address and telephone number are needed so that we can deliver communications to you.
b) Identification data
In particular, your username, password and verification photograph help us ensure that we are communicating with the correct person. During registration, you provide your full date of birth, primarily so that we can verify that you have reached the age of majority, which is a condition for using our Services.
In exceptional cases where we suspect that the identification data supplied is incorrect, we may process data contained in your identity card or another identity document.
c) Service usage data
When you use the internet and log into the Application’s web interface, your device automatically sends its IP address. We can therefore identify the network and subnet in which the device is located.
For security reasons, logs record information about your activity in the Application, login times, actions performed and information entered into forms, including reports of illegal or other content. We also record interactions with other Users, such as contacts made, communications and Negative Experiences and Warnings as defined in the Application’s Terms. To display and protect the Application and Services properly, we use information about your operating system, such as Windows, macOS, Android or iOS, its version and technical data about the devices used to log in, such as the type of smartphone. Most system and device data is not retained for long and, without additional information, cannot be linked to you. Processing this data helps us improve our Services and adapt them to your technical capabilities.
We further anonymise the above service usage data and use it to develop our Services. After anonymisation, we can no longer determine that it relates to you.
d) Profile data
All information you enter in your profile, in particular physical characteristics such as height and weight, marital status, interests, education and personal photographs.
e) Geolocation data
If you voluntarily enable location sharing in the Application and also permit it in your browser, we receive your latitude, longitude and an indication of location accuracy from the browser. We do not disclose exact coordinates to other Users. We use them to calculate the distance between Users and display only a distance rounded according to the Application settings, currently to whole multiples of 1 km.
f) Information about interactions with us
To avoid contacting you repeatedly for the same reason, we record contacts between you and us, including the date and, where applicable, time and reason for contact, and whether it was initiated by you or us. This applies to all channels, especially telephone, chat, post and email.
g) Transaction and order data
Data obtained in connection with paid Services, such as your bank account number, payment time and amount and details of the Service provided, including its duration.
h) Sexual orientation and preference data
Information concerning sexual orientation and preferences that you voluntarily enter into your profile. If you enter this information anywhere other than the designated profile field, we may be unable to distinguish it from other data and will process it together with that data.
3) From what sources do we obtain personal data?
The personal data we process comes from you and is generated mainly through registration, use of our Services and Application, and communication with us. We also obtain data directly from you by monitoring your behaviour in the Application. Geolocation data is obtained from your device through the browser interface only after you enable location sharing and authorise the browser to provide it.
Please note that we do not routinely monitor or process the content of messages you send to other Users. Another User may, however, disclose such a message to us, for example when reporting illegal content or making a complaint concerning our Services. In that event, the message will be used solely to assess the reported content and take possible measures, or for the relevant complaint procedure. To protect our rights, we delete the information after expiry of the standard limitation period.
4) Why do we process personal data and what authorises us to do so?
If you register in the Application, we process your personal data on the basis of your consent, performance of the Agreement, our legitimate interests or compliance with a legal obligation, depending on the particular purpose.
Without your consent, we process personal data for the following purposes:
a) Enabling use of the Services
This processing is necessary for performance of the Agreement under which we provide the Services. If you create an account, we process contact and identification data, service usage data, profile data, information about interactions with us and transaction and order data to perform the Agreement. Your username, photographs and other profile data are made available to other Users when they view your profile. You may also disclose personal data directly to other Users in Application messages.
For this purpose, we process personal data for the duration of the contractual relationship, meaning while you use the Application and until the relationship ends and your account is cancelled.
b) Protection of our rights and interests
Processing contact details, identification data including date of birth for proof of majority, service usage and profile data, information about interactions with us, transaction and order data, browser data, information obtained from reports or complaints, and your device’s IP address is necessary for our legitimate interest in protecting our rights and legal claims. For this purpose, we may also process sexual orientation and preference data which you consented to or supplied while using the Services, to the extent necessary even after withdrawal of consent.
We process this data for no longer than the applicable limitation period, including any suspension or interruption, and typically no longer than 16 years after the contractual relationship ends. If judicial, administrative or other proceedings begin, we process the necessary data throughout those proceedings to establish, exercise and/or defend legal claims.
c) Compliance with legal obligations
Processing contact and identification data, transaction and order data and data relating to reports of illegal information is also necessary to comply with legal obligations, particularly tax, accounting, record-keeping and digital-service-provider obligations. These duties may require us to collect, assess and retain data for statutory periods. To the necessary extent, we may also process sexual orientation and preference data which you consented to or supplied while using the Services, even after consent is withdrawn.
For these purposes, personal data is processed for the periods prescribed by applicable law.
d) Promotion of the Application and information about news
Processing contact and identification data, service usage data, information about interactions with us and transaction and order data is necessary for our legitimate interest in promoting the Application to Users and informing them about Application news, both generally and in a targeted manner.
We use this data when preparing and sending informational and promotional communications about our products and Services and optimising offers in the Application. Service usage information helps us monitor and improve quality and maintain Users’ interest.
You may stop informational and promotional communications sent by email or SMS at any time through the link in each communication. We process data for this purpose during the contractual relationship and for three months afterwards, or until you object to the processing.
With your consent, we process personal data for the following purposes:
a) Maintaining User profile data
We process sexual orientation and preference data so that it can be displayed in your profile and made available to other Users who view it.
You may withdraw consent at any time. Further information and the procedure are in Section 6, “Your rights in connection with personal data processing”. We process this data from the time consent is given until it is withdrawn or the contractual relationship ends and the account is cancelled.
b) Voluntary location sharing
On the basis of your consent, we process geolocation data to calculate and display approximate distances between Users and to sort profiles by distance. Location sharing is not required for registration or use of other Application features. You give consent by enabling location sharing in the Application and allowing location access in your browser. While sharing remains enabled, the Application may update the saved location when you visit it.
The stored exact coordinates and accuracy value are not shown to other Users. Only a location no older than 168 hours is used to calculate distance. We retain geolocation data until location sharing is disabled, consent is withdrawn, the account is erased or the data is otherwise no longer necessary for this purpose. Disabling location sharing in the Application withdraws consent and immediately deletes the stored geolocation data.
5) Who processes your personal data and to whom do we disclose it?
Only employees of Adentech, s.r.o. who need the data to administer the Application and User profiles have access to it.
Your personal data is not transferred to third parties, but is made available to other Users where necessary to enable the Services and maintain profile data, including when they browse your profile or when you disclose data directly through the Application.
If location sharing is enabled, other Users may see only the calculated and rounded distance between profiles. Exact coordinates and the location accuracy value are not disclosed to them.
If we use a third party as a processor, processing will be governed by a written agreement meeting all statutory requirements. Such processors include:
- Google
Where required by law, we must disclose personal data to law-enforcement or other public authorities.
Your personal data is not transferred to a third country or international organisation.
6) Your rights in connection with personal data processing
As an Application User, you have the following rights:
a) Withdrawal of consent
All consents are voluntary and you are not required to provide them. Refusal or withdrawal does not affect lawful processing based on another legal basis, including marketing communications based on our legitimate interest.
You may withdraw consent in all cases of consent-based processing using the procedure in Section 7, “How can individual rights be exercised?”. Withdrawal does not affect the lawfulness of processing before withdrawal. Location-sharing consent may also be withdrawn directly by disabling location sharing in the Application; the stored geolocation data will then be deleted.
b) Right of access
You have the right to know what data we process, why and for how long, where it comes from, to whom it is disclosed, who processes it besides us, and what other rights you have. This information is set out in this document. If you are unsure, you may ask us to confirm whether we process personal data concerning you and, if so, request access and a copy. The first copy is free; additional copies may be subject to a fee.
c) Right to rectification
If your personal data is inaccurate or out of date, you may request correction. We will correct it without undue delay after you provide the correct information.
d) Right to erasure
This is also known as the right to be forgotten. We must erase your personal data where:
- it is no longer necessary for the purposes for which it was collected or processed;
- you withdraw the consent on which processing was based and there is no other legal ground;
- it has been processed unlawfully; or
- erasure is required to comply with EU or Czech law.
Erasure will not take place where it would breach an obligation imposed by EU or Czech law or where processing is necessary to establish, exercise or defend our legal claims. If the conditions are not met, we will inform you without undue delay and explain why the request cannot be granted.
e) Right to restriction of processing
You may request restriction where:
- you contest the accuracy of the data, for the time needed to verify it;
- processing is unlawful and you oppose erasure;
- we no longer need the data, but you need it for a possible legal claim; or
- you have objected and it has not yet been determined whether our legitimate grounds prevail.
We will inform you before a requested restriction is lifted.
f) Right to data portability
You have the right to receive personal data which you provided and which we process on the basis of consent or performance of the Agreement, in a structured, commonly used and machine-readable format. This applies only to data processed by automated means in our electronic databases.
g) Right to object
You may object to processing based on our legitimate interests. For marketing, we will stop processing without further conditions. In other cases, we will stop unless we have compelling legitimate grounds to continue.
h) Right to lodge a complaint
Exercising the above rights does not affect your right to complain to the competent supervisory authority, particularly if you believe that processing is unlawful. A complaint concerning our processing may be lodged with the Office for Personal Data Protection (Úřad pro ochranu osobních údajů), Pplk. Sochora 27, 170 00 Prague 7, Czech Republic; further information is available at https://uoou.gov.cz/en.
7) How can individual rights be exercised?
For all matters concerning personal data processing, including questions, exercise of rights or complaints, you may contact our data protection officer at info zavináč hledam tečka cz. We will deal with your request without undue delay and no later than one month. In exceptional cases, particularly because of complexity, we may extend the period by two further months. We will inform you of any extension and the reasons for it.