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 The P3 Logistic Parks group (hereinafter “P3”) puts great emphasis on adherence to the principles and rules of the protection of individuals with regard to the processing of their personal data.

 

This Privacy Policy covers operations of the following joint data controllers belonging to P3 which are listed here: 

 

 P3 deems all personal data to be confidential and processes it in accordance with the generally binding data privacy laws as well as any other implementing rules and regulations applicable to the processing of personal data, their protection and security, in particular Regulation 2016/679 of the European Parliament and of the Council dated 27 April 2016 on the protection of individuals 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) (the “Regulation”).        

 

P3, as a personal data controller, provides the natural persons, who are in contact with P3 and whose personal data is obtained by P3, with the below information concerning the processing of their personal data for specified purposes.

Types of processing of personal data

NEGOTIATION, CONCLUSION AND PERFORMANCE OF THE CONTRACT

Purpose of processing

P3 processes the personal data of its business partners (including potential business partners) for the purposes of the negotiation, conclusion and performance of the contracts concluded between P3 and the business partners, including carrying out various due diligences and identifying the business partners in terms of anti-money laundering legislation as well as in terms of P3's internal KYC policy.

Legal basis for processing

The data processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;

Legitimate interest of P3 - for carrying out due diligences (personal data of business partners may be transferred to third party entering into a contract with P3, including its negotiation)

Legitimate interest of P3 - for the identification of the business partners in order to prevent P3 from being involved in any kind of illegal activity and facing a reputation risk (as per P3's internal KYC policy).

Compliance with a legal obligation to which P3 is subject - identification of the business partners in case anti-money laundering legislation requires to do so.

Scope of personal data processed

Business partners and P3 persons - natural persons: name, surname, date of birth, address of residence or business, contact address, e-mail address, phone number, personal Identification number (not applicable to Italy), citizenship.

Business partners - legal person: contacts details and role of the natural persons acting on behalf of the legal persons or the contact persons such as name, surname, e-mail address, phone number, citizenship/ nationality, address, domicile, PEP's information, UBO and his/her: personal identification number, residency, type and number of identification document, domicile.

Reason for providing data

P3 cannot negotiate the contract and, thereafter, enter into the contract and perform it without the relevant personal data (provided above).

Processing time

During the negotiation of the contract and thereafter for 1 year after the termination of the negotiation in case the contract is not concluded or for a longer period if so required or allowed by applicable law.

In case of conclusion of the contract, also during the term of the contract and thereafter for (i) a limited period according to the applicable law in case of any potential legal dispute with the counterparties arising from the contract or longer period allowed for such purpose by applicable law or (ii) longer period if so required or allowed by applicable law.

CONTACT FORM

Purpose of processing

Answering queries and processing and handling requests from visitors of the P3 website.  

Legal basis for processing

Legitimate interest of P3 (request / query handling).

Scope of personal data processed

Name, surname, title, company name, country of origin, language, e-mail address, voluntary telephone number or other personal data voluntarily communicated by the data subject in the contact form.

Reason for providing data

P3 cannot handle a query / request without the relevant personal data provided above.

Processing time

For the time required to complete the query / request and the time needed for the purposes of evaluating queries, as well as for other related communications in the matter.

SUBSCRIBING TO P3 NEWSLETTERS

Purpose of processing

Processing the data subject’s online subscription application to P3 newsletters announcing news and events of P3 Logistic Parks group.

Legal basis for processing

Consent.

Scope of personal data processed

If the request is sent via the subscription link for subscribing to the newsletter at https://www.p3parks.com or when sent via e-mail: name, surname, e-mail address, company name (employer), country of origin, language.

Reason for providing data

P3 cannot send the newsletters to its subscribers without their contact details.     

Processing time

For a maximum period of 3 years or until revocation of consent.

Unsubscribing

The data subject may at any time unsubscribe from the P3 newsletters by clicking on the link marked "unsubscribe" in any newsletter or via email at p3data@p3parks.com.     

PHOTOGRAPHS AND AUDIO-VISUAL RECORDINGS[1]

Purpose of processing

P3 takes photographs and / or audio-visual recordings (and, as a result, processes the image and voice of data subjects) during events organized by P3 inter alia for its presentation on the market via www.p3parks.com, social networks and the promotional materials. P3 also uses the image and voice (captured in photographs and audio-visual recordings) from the events for internal administration, reporting, planning of future events and development of marketing strategy. P3 further uses CCTVs in some of P3's parks, in which the monitoring of the park by CCTV is being indicated on the information board by the entrance to the park.

Legal basis for processing

Consent (in case of P3 internal administration, reporting, planning of future events and development of marketing strategy).

Legitimate interest (in case of CCTV the protection of P3’s assets, prevention of crime and security and protection of the property and health of the monitored persons).

Scope of personal data processed

The images and voices of data subjects (captured in photographs and / or audio-visual recordings).

Reason for providing data

P3 cannot take photographs and / or audio-video visual recordings and process the images and voices of the data subjects where they can be easily identified during events organized by P3 without the data subjects providing their consent for these purposes.

Recording of CCTVs cameras ensures the protection of the P3´s assets, the security and protection of the property and health of persons and prevent crime.

Processing time

In cases where the data subject has given his/her consent to the processing of personal data -  for the duration of the P3’s marketing campaign or for a period for which the personal data are up to date or until the data subject withdraws his/her consent for such processing. Even if such processing is not terminated according to the previous sentence, this data will be processed for a maximum period of 5 years as of the date of the event where photographs and / or audio-visual recordings were taken.

CCTVs recordings are stored for a period necessary for property protection or preservation of evidence (120 hours unless CCTVs recordings are needed to build or defend a legal claim, plus for the period necessary to handle such legal claim).

BUSINESS-TO-BUSINESS (B2B) MARKETING

Purpose of processing

P3 processes the personal data of its business partners and potential clients for the purposes of direct marketing.

Legal basis for processing

Consent (in case of potential business partners/clients).  

Consent (in case of processing personal data of present and former business partners/clients in the Republic of Austria and Serbia).

Legitimate interest of P3 (in case of present and former business partners/clients).

 

Scope of personal data processed

Name, surname, e-mail, work details, position, phone number

Reason for providing data

P3 cannot contact the clients/business partners or potential clients in relation to the promotion of its services without their personal data.

Processing time

For the duration of P3’s marketing campaign (potential clients) or for the term of the contract and thereafter for 1 year after the termination of the contract concluded between P3 and its clients/business partners or until the data subject withdraws his/her consent for such processing, when processing is performed based on consent. The data subject may at any time unsubscribe from P3 B2B marketing by clicking on the respective link in any promotion e-mail

 

COOKIES

Purpose of processing

P3 processes the personal data contained in the cookies in order to make its online services more user friendly, efficient and secure, and to implement certain user features, in addition to provide statistical information to site administrators or promotional purposes. P3 also processes the personal data in order to personalize the navigation experience of remembering a visitor (such as remembering the language a visitor has chosen, recognizing a visitor's account logging information etc.).

 

Legal basis for processing

Consent to personal data processing for setting up non-functional cookies.

Legitimate interest in the case of functional cookies (due administration and optimization of P3's online services).

 

Scope of personal data processed

IP address, browser configuration, computer settings and other metadata.

Reason for providing data

P3 cannot duly administer and optimize its online services without processing of the personal data contained in the cookies.

Processing time

 P3 websites mostly use cookies which are automatically removed after the website visitors close their web browser (session cookies).

P3 also occasionally uses “persistent cookies”, which remain in the device of the website user until they expire or are deleted manually. The period of the processing of such persistent cookies depends on the current cookie settings of the website users as well as their computer / internet browser settings.

Further detailed information regarding processing of personal data contained in the cookies are to be found in P3's cookie policy.

CAREERS

Purpose of processing

P3 processes the personal data of job applicants for the purposes of conducting the recruitment process concerning the new/open job positions and the related administration performed in the course of evaluating the results of the recruitment and closing of the personal files in connection to the recruitment.

Legal basis for processing

Legitimate interest (conducting the recruitment process)

Scope of personal data processed

Name, surname, academic title, date of birth, address of residence, contact address, e-mail address, phone number, image, identification of former employers and duration of the employment relationship therewith, education, language skills, IT skills, other personal data voluntarily communicated by the job applicants in their CV.

Reason for providing data

P3 cannot assess the qualification of the job applicants and cannot proceed with recruitment without a CV being provided by the job applicant.

Processing time

During the recruitment process and thereafter P3 may keep the data of unsuccessful job applicants until the lapse of the trial period under a local legislation of recruited job applicants for the case that these recruited job applicant’s employment would terminate prior to the lapse of the trial period and P3 would need to replace them immediately.

 

Transfers of personal data

The companies belonging to P3 use external vendors, service providers, legal advisors or other companies from P3 for personal data processing.

The external vendors, service providers and legal advisors  are the personal data processors who process personal data based on data processing agreements.

The companies from P3 might be for specific purposes joint personal data controllers. In accordance with the Article 26 of the Regulation the companies belonging to P3 being joint personal data controllers concluded a joint controller agreement with each other (hereinafter the “Agreement”), through which the companies define among themselves the responsibility for fulfilling the obligations arising from the Regulation. The Agreement defines for all joint personal data controllers their share of the responsibilities for the fulfilment of personal data processing obligations under the Regulation, which the companies obtain from data subject´s to fulfil the rights and obligations arising from the intragroup agreements.

  1. The company P3 Logistic Parks s.r.o., ID No.: 28215061, with its registered address at Na Florenci 2116/15, Nové Město, 110 00 Prague 1, is responsible for fulfilling the information obligation within the meaning of Articles 13 and 14 of the GDPR towards data subjects and at the same time acts as a contact point for data subjects.
  2. The data subjects may exercise their rights pursuant to Articles 15- 22 of the Regulation with each joint controller of personal data independently.
  3. Each joint controller of personal data is obliged to:
    • request the consent of the data subject covering all processing purposes provided for by the joint controllers, if consent to the processing is necessary;
    • keep, continuously review and update processing records in accordance with Article 30 of the Regulation;
    • put in place appropriate technical and organizational measures within the meaning of the Regulation to ensure and be able to demonstrate that the processing of personal data is carried out in accordance with the Regulation, as well as to review and update these measures;
    • duly and in a timely manner report any breaches of personal data security to the supervisory authority and cooperate with that supervisory authority to the extent necessary;
    • duly and timely report possible breaches of personal data security to data subjects.

Further detailed information on external or P3 recipients will be provided upon the data subject's request.

Within the business activity of P3, the personal data might be transferred to the countries outside European Union or European Economic Area. To render certain products and services provided by P3, including services associated with them and their promotion, in certain cases requires that P3 will transfer the personal data for the processing outside of European Union or European Economic Area. However, P3 always takes care that such a transfer will be in line with applicable legal regulations governing personal data protection and that in each individual case adequate protection and safety of the personal data will be secured. P3 ensures safety while transfers personal data to the third countries by using appropriate safeguards, stated by respective laws, specifically for such transfer(s) P3 uses valid decisions adopted by the European Commission on an adequate level of protection or the standard data protection clauses. For more information on the personal data transfers please do not hesitate to contact us using contact details below.

 

Information about IP address, browser, device, and operating system of visitors of P3 website are under certain conditions shared with the Internet Service Providers or social networking service companies (e.g. Facebook, Google, LinkedIn, Twitter) based on the data subject's consent. Information about computer and/or track on activity while using the P3 websites may also be recorded. Further detailed information regarding sharing of your personal data with the Internet Service Providers or social networking service companies are to be found in P3's cookie policy.

 

Rights of natural persons related to processing of their personal data

If processing is based on the consent of the natural persons, these persons have the right to revoke their consent to personal data processing at any time by sending an e-mail to p3data@p3parks.com, by sending a letter in writing to the P3’s address stated below or by communicating this to P3 in person.

 

Revocation of consent does not have retroactive effect and the processing of personal data based on granted consent prior to its revocation shall remain unaffected; processing of personal data which is carried out prior to such revocation is lawful.   

 

If personal data are processed based on P3’s legitimate interest, the natural person also has the right to raise an objection against having his/her personal data processed on grounds relating to his/her particular situation and which is described in the relevant objection. [2] When P3 receives an objection, it will cease to process the personal data (retaining it only) and it will make an assessment as to whether there are significant legitimate reasons for processing it that outweigh the interests and rights and freedoms of the data subject, or for determining, enforcing or defending legal claims. If P3 concludes that such grounds exist, it will inform the person of such fact and advise him/her of the possibility of further protection and then continue to process the personal data. However, if, on the contrary, P3 concludes that there are insufficient reasons for processing, then the data subject will be informed thereof, processing will be terminated and the personal data erased. 

 

Natural persons also have the right to access the personal data which are processed by P3, i. e. individuals can submit subject access requests, which oblige P3 to provide a copy of any personal data they hold concerning the individual. P3 has in principal one month to produce this information whereas this term may be extended if legally allowed, although there are exceptions for requests that are manifestly unfounded, repetitive or excessive.

Furthermore, natural persons have the right to rectification. If individuals discover that the information P3 holds on them is inaccurate or incomplete, they can request that it to be updated. As with the right of access, P3 has in principal one month to do this whereas this term may be extended if legally allowed, and the same exceptions apply.

Natural persons also have the right to erasure ("right to be forgotten"). Individuals can request that P3 erases their data in certain circumstances – for example, when the data is no longer necessary, the data was unlawfully processed, or it no longer meets the lawful ground for which it was collected. This includes instances where an individual withdraws consent.

 

Based on the right to restrict processing, individuals can request that P3 limits the way it uses personal data. It is an alternative to requesting the erasure of data and might be used when an individual contests the accuracy of his/her personal data. An individual can also exercise this right when they no longer use the product or service for which it was originally collected, but P3 needs it to establish, exercise or defend a legal claim.

Individuals also have the right to data portability based on which individuals are permitted to obtain and reuse their personal data for their own purposes across different services.  An individual has the right to move, copy, or transfer personal data from one data controller to another, in a safe and secure way, in a commonly used and machine-readable format.

P3 does not perform an automated processing, including profiling, which produces legal effects concerning the data subjects or similarly significantly affects the data subjects. 

You may assert and exercise these rights by sending an e-mail to p3data@p3parks.com, by calling P3, or in writing by sending your request to the address of P3 mentioned below. Moreover, the data subject also has the right to file a complaint with the national supervisory authority for the processing of personal data listed below or another relevant supervisory authority in connection with the processing of his/her personal data.

 

Homepages of National Supervisory Authorities:

Czech Republic - https://www.uoou.cz/

Federal Republic of Germany - https://www.bfdi.bund.de/EN/Home/home_node.html

French Republic - https://www.cnil.fr/en/home

Grand-Duchy of Luxembourg - https://cnpd.public.lu/en.html

Italian Republic - https://www.garanteprivacy.it/home_en

Kingdom of Belgium - https://www.dataprotectionauthority.be/citizen

Kingdom of Spain - https://www.aepd.es/es

Netherlands - https://autoriteitpersoonsgegevens.nl/en

Republic of Austria - https://www.data-protection-authority.gv.at/

Republic of Poland - https://uodo.gov.pl/en

Republic of Serbia - https://www.poverenik.rs/en/o-nama/authority.html

Romania - https://www.dataprotection.ro/index.jsp?lang=en&page=home

Slovak Republic - https://dataprotection.gov.sk/uoou/en

 

Contact details for P3 regarding personal data processing

P3 Logistic Parks s.r.o.

Correspondence address: Na Florenci 2116/15, Nové Město, 110 00 Prague 1

Contact person in charge of personal data processing: Kristýna Spalová

Phone: +420 225 987 400

E-mail: p3data@p3parks.com

 

[1] The images and voices of data subjects (captured in photographs and audio-visual recordings) constitute personal data within the meaning of the Regulation. The images and voices (captured in photographs or audio-visual recordings) where a person cannot be clearly identified may be processed without consent of a person or any other legal basis for personal data processing under the Regulation.

[2] In Serbia: Irrespective of the legal ground for personal data processing, the natural person has the right to raise an objection to Serbian Commissioner for Information of Public Importance and Personal Data Protection.