PRINCIPLES OF PERSONAL DATA PROCESSING

Torch Entertainment s.r.o. is a company operating in the entertainment industry with a focus primarily on virtual reality. We always try to act fairly, transparently and within the limits of legality towards you, our customers and business partners, including in relation to the protection of personal data, including the consistent implementation of Regulation 2016/679 of the European Parliament and of the Council of the European Union of 27 April 2016 on individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (hereinafter referred to as GDPR).

1. Who will process your personal data?

The controller of personal data within the meaning of Article 4 of the GDPR is an entity that determines the purpose and means of processing your personal data, processes them and is responsible for them. The processing of personal data may authorize or entrust a processor who performs certain tasks related to the processing of personal data on behalf of the controller.

The administrator of the personal data you provide to us is the company Torch Entertainment s.r.o., Company Identification Number: 05852242, with its registered office at Václavské náměstí 782/22, Nové Město, 110 00 Prague.

If you have any ambiguities or questions regarding the processing of your personal data, do not hesitate to contact us at tel: +420 607 044 123, e-mail: info@torchvr.cz.

2. For what purposes will the personal data provided by you be processed?

We process your personal data for the following purposes:

• Pre-contractual negotiations and subsequent performance under a contract that you may conclude with us, where the legal basis for this processing is Article 6, paragraph 1, letter b) GDPR;


• legitimate interests of the administrator - for this purpose we process primarily personal data in connection with the exercise of our rights (eg direct marketing of our products and services to our customers and debt collection), the legal basis for this processing is Article 6 (1) (a). f) GDPR;


• processing of personal data on the basis of your express consent, which we need especially in situations where we would like to offer you products and services of our company, beyond the scope of mutual performance. For this purpose, we primarily use the contact details provided by you for the purpose of sending business messages by electronic means. You can revoke your free consent at any time.

3. Where do we obtain your personal data?

We process personal data that we have obtained from you, the users of our services, including potential future customers and business partners in the negotiation of the contract. We obtain your personal data both from the forms you have filled out, which are available on our website, as well as from cookies, which store information about your activity on our website and help to personalize them in order to ensure better user comfort of their users.

4. What personal data do we process?

We mainly process the following categories of personal data:

4.1. Identification data

• Name, surname, title, date of birth, ID number;

4.2. Contact information

• Permanent residence address, delivery or other contact address, telephone, email address;

4.3. More information

• Cookies, location data and other personal data resulting from the performance of a specific contract or relevant legislation.

We will process your data only for the time strictly necessary for the fulfillment of obligations under the contract. The period for which we will process your personal data is linked to the duration of our contractual obligations, ie the duration of the warranty period of the subject of the contract and the duration of the general limitation period pursuant to Section 629 of Act No. 89/2012 Coll., The Civil Code, as amended. later regulations, reported 3 years after the termination of the contract. The time of processing of personal data may also be determined by the fulfillment of the controller's obligations on the basis of special legal regulations pursuant to Article 6 (1) (a). c) GDPR.

5. For how long will we process personal data?

We will process your data only for the time strictly necessary for the fulfillment of obligations under the contract. The period for which we will process your personal data is linked to the duration of our contractual obligations, ie the duration of the warranty period of the subject of the contract and the duration of the general limitation period pursuant to Section 629 of Act No. 89/2012 Coll., The Civil Code, as amended. later regulations, reported 3 years after the termination of the contract. The time of processing of personal data may also be determined by the fulfillment of the controller's obligations on the basis of special legal regulations pursuant to Article 6 (1) (a). c) GDPR.

6. How will your data be stored?

Your personal data will be processed automatically in the information systems of the programs, but also manually by our employees.

7. To whom do we pass personal data?

We also transfer your personal data to external personal processors, always on the basis of a personal data processing agreement. In particular, your personal data may be passed on to the following entities:

• Marketing agencies, in particular for the purpose of providing advertising and marketing services;


• Our suppliers or service providers, if you choose to use these services;


• Collection companies for the purpose of enforcing our legal claims;


• Other persons in connection with the conclusion, administration and archiving of contracts and related documents;


• Persons who provide or receive services in connection with the performance of our contractual or legal obligations, and an up-to-date list of personal data processors will be provided upon request by the customer.

Your personal data may also be passed on to other administrators solely in connection with the performance of our legal obligations, in particular the transfer of data to state administration bodies, courts and law enforcement authorities.

Your personal data is not passed on to other administrators without your consent in order to offer trade and services. Your consent applies exclusively to Torch Entertainment s.r.o.

We do not transfer your personal data to third countries.

8. What are your rights in relation to the processing of your personal data?

As the subject of personal data, ie the person who provided us with their personal data, you have certain legal rights. These rights are:

8.1. Right of access to personal data

• You have the right to know what personal data we process about you, for what purpose, for how long, to whom we transfer it, who processes it outside of us and what other rights you have related to the processing of your personal data; you can ask us to confirm whether or not the personal data concerning you is being processed by us; you also have the right to request a copy of your personal data that we process about you .;

8.2. The right to correct personal data

• If you believe that the personal information we hold about you is inaccurate or incomplete, we will update or supplement it at your request.

8.3. The right to object to the processing of personal data pursuant to Article 21 of the GDPR

• You have the right to this objection if the processing of your personal data takes place on the basis of our legitimate interests pursuant to Article 6, paragraph 1, letter f) GDPR. If you raise this objection, we will not process your personal data further unless we have good reasons to continue processing. If the objection only concerns the processing of personal data for the purposes of direct marketing, we will no longer process your personal data for these purposes.


• The right to restrict the processing of personal data under Article 23 of the GDPR You have the right to exercise this right if the processing of your personal data is inaccurate or even illegal, but you do not want to delete such personal data, and if some personal data selected by you in your should be processed even after they are not necessary for the purpose for which they were provided, in connection with the determination, exercise or defense of your rights and if you have objected to the processing, it is not clear whether our legitimate interest outweighs your legitimate interests. hobbies.

8.4. The right to withdraw consent to the processing of personal data pursuant to Article 7 of the GDPR

• You have the right at any time to revoke your previously given consent to the processing of personal data, provided that such refusal is effective in the future and does not apply to the processing that took place before the revocation of the consent.

8.5. The right to the portability of personal data under Article 20 of the GDPR

• You have the right to provide you with the personal information we process about you in the manner and in the form we agree upon. It will be a machine-readable format that allows you to pass this personal information to another administrator. You may also request that we pass on your personal information directly to another administrator, provided that it is technically feasible.

8.6. The right to delete personal data or the right to be forgotten under Article 17

• You can exercise this right if:

1. You have revoked your consent to the processing of the personal and there is no other legal title for the processing;


2. Your personal data is no longer needed for the purposes for which it was collected or otherwise processed;


3. You object to the processing and there are no overriding legitimate reasons for further processing;


4. Your personal data must be deleted in order to fulfill a legal obligation stipulated by a special legal regulation or the law of the European Union; Your personal information has been collected in connection with the offer of information society services;


5. Your personal data has been processed illegally.

8.7. Right to lodge a complaint with the Authority pursuant to Article 77 of the GDPR

• If you feel that the rules for the processing of personal data have been violated, you can contact the personal data controller through the contact listed in point 1 of this document. If you are not satisfied with our response, you are of course legally entitled to lodge a complaint with the supervisory authority, which for this purpose is the Office for Personal Data Protection (ÚOOÚ).

9. How can you exercise your rights?

To exercise your rights, please do not hesitate to contact us through the contact details provided in this document. If you contact us, please do not forget to identify yourself in a sufficient way, which is necessary for the protection of your personal data, where we cannot risk disclosing it to an unauthorized person.

In Prague on 01.09.2020