Dear Clients,

The objective of this document is to summarize for you the basic principles for the handling of your personal data in connection with the business of the company Trigema a.s. (including group subsidiary units). Trigema a.s. respects the privacy of its clients, business partners and other visitors to its internet pages and that is also the reason for the creation of this document, in which we want to inform you as to how and why we handle your personal data.

In opening, we wish to state that all collected, processed and stored data pertain exclusively to the subject matter of our business activity, i.e. primarily to the carrying out of construction and structures, changes and removal thereof, design activity in construction, sale or lease of real estate properties, apartments and nonresidential premises.

We take care to ensure that you are sufficiently informed, under all circumstances, regarding the processing being conducted in regard to your personal data. The provision of your personal data is indeed voluntary on your part, but, nevertheless, the provision thereof is necessary for certain legal acts.

1. Definition of the Basic Terms That We Are Operating with Here.

(i) (i) Client: We understand a client to be a person who has entered into or intends to enter into a purchase agreement or other relevant agreement with us, the object of which is real estate properties. A client is understood to also mean a person who has (in regard to his/her interest in entering into a relevant agreement) expressly granted us consent to the processing of personal data for marketing purposes (such as sending commercial messages), and has done so primarily while browsing through the internet pages www.trigema.cz.

(ii) (ii) Personal Data: In accordance with the provisions of Art. 4(a) of Act No. 101/2000 Coll., on the Protection of Data and on Changes to Certain Laws, “personal data is any information pertaining to an identified or identifiable data subject. A data subject is considered to be identified or identifiable if the data subject can be directly or indirectly identified primarily on the basis of a number, code or one or more elements, specific for his/her physical, physiological, mental, economic, cultural or social identity”. Thus, in practice, this is primarily the following: name and surname, residence address, telephone number, email address and all other non-public information entered by you.

(iii) (iii) Client Section: The client section enables clients to access, upon entering an access name and password, the pages pertaining to the apartment being purchased. By way of such pages, clients can easily communicate with the sales team and other company staff members, monitor the course of payments, inspect executed agreements and amendments, evaluate their satisfaction with the company’s services, as well as to be informed of other news relating to the construction of the apartment being purchased.

2. What We Abide by When Handling Your Personal Data.

2.1. We proceed in full accordance with Act No. 101/2000 Coll., on the Protection of Data and on Changes to Certain Laws (hereinafter the “Personal Data Protection Act”), which also implements the Directive of the European Parliament and of the Council 95/46/EC dated 24 October 1995, on the protection of individuals with regard to the processing of personal data and on the free movement of such data. In accordance with the terminology of such Act, we are the so-called controller. We of course also comply with the entire law of the Czech Republic.

3. Purpose, Scope, Term and Manner of Data Processing.

3.1. As stated in the introduction to these Principles, the purpose of processing your personal data always relates to the object of our activity. The purpose thus always pertains either to executed purchase agreement or other relevant agreement between clients as purchasers and us as sellers, or actions leading to such execution. For the processing of data for such purpose, the client’s express consent is not necessary. The processing of such data is necessary for the performance of mutual contractual relations.

3.2. And of course, the implicit purpose of processing data is also ensuring the greater quality of our services and timely reactions to your requests and needs.

3.3. Besides that which is set out in section 3.1., Trigema a.s. processes clients’ personal data on the basis of their voluntary consent for the following purposes:
a) creation and administration of a client database;
b) registration and management of a user account on the client section electronic portal;
c) contacting the client for the purpose of monitoring satisfaction;
d) sending commercial messages.
The purpose of processing such data is primarily the opportunity to inform you as much as possible about matters that truly interest you.

3.4. In cases where the Personal Data Protection Act categorically requires consent for the processing of personal data, we always expressly require such consent, and clients are thus alerted to such fact in advance and have the option of deciding whether to voluntarily grant consent or not.

3.5. The scope of processed data fundamentally corresponds to the purpose of their processing in such a way so that it can be adequately fulfilled.

3.6. For the purposes of entering into and performing an agreement with the client, we process all of the data that the client has provided or provides specifically in connection with the agreement that has been or is being executed, and which pertain to the object of performance of the agreement. These include primarily: the client’s name and surname, personal identification number /date of birth, address of permanent or other residence, telephone number, email address, if applicable the registered address of an individual entrepreneur, his/her business name, identification number, as well as necessary identification information regarding the relevant real estate properties (designation, layout, number of rooms, floor number, surface are, etc.).

3.7. For the Client Section service, the client can also voluntarily provide data such as: interests, family status, gender, language, number of persons living within a common household, data on utility consumption, etc. When utilizing the Client Section service, data on page browsing, discussion entries, calendar events, embedded photographs, saved documents, etc. are stored.

3.8. By visiting our internet pages, www.trigema.cz, clients and other visitors consent to the processing of entered personal data. Further, when visiting the pages, information transmitted within the scope of the internet connection, such as IP address etc., is collected automatically.

3.9. Information on cookie files is published separately on our internet pages.

3.10. For the purposes of sending commercial messages and contacting the client for the purpose of monitoring satisfaction, only the most essential data are processed, primarily the name and surname, residence address, email address and telephone number.

3.11. As a matter of principle, we store collected and processed personal data for the term of the validity and effectiveness of the executed agreement and, upon the termination of the executed agreement, for the necessary period of time thereafter, i.e. after the fulfillment of all contractual obligations by both parties or upon any other termination of the contractual relationship.

3.12. Other collected personal data, i.e. data not pertaining to an executed agreement, primarily data collected for the purposes as described in section 3.2., are stored only for the period of time for which they serve and for which the purpose of their collection is being fulfilled. The client is entitled to withdraw the granted consent to the processing of personal data at any time, and to do so by telephone, email or a written message.

3.13. Clients’ personal data are obtained primarily from the clients themselves, within the scope of uskutečněných mutual jednání or projevením of their interest o toto jednání na internetových stránkách www.trigema.cz or in connection with registering on the client section electronic portal.

3.14. We process clients’ personal data both manually, as well as in an automated manner with the use of corresponding technical and organizational measures in order to ensure the protection of personal data.

3.15. Access to collected and stored personal data is only had by our selected employees, who need such access in order to perform their work tasks. Such employees have a contractual obligation to maintain confidentiality regarding information obtained in connection with the processing of personal data.

3.16. The processing of clients’ personal data can also occur with the possible use of third party support and information systems under the conditions as set out by the Personal Data Protection Act and the law in general, whereby such occurs primarily in the area of marketing and information support. Relations with third parties arisen in such manner are always contractually secured in such a way so that the principles for handling personal data are not breached. Furthermore, we choose our business partners carefully.

3.17. The personal data of clients who have entered into a purchase agreement as purchasers with us as sellers, the object of such agreement being a real estate property, will be further provided within the necessary extent for further processing for the purposes of the performance of obligations under an agreement on building administration to a relevant building administrator.

3.18. We process clients’ personal data within the territory of the Czech Republic.

4. Further Rights and Obligations:

4.1. The client has the right at any time to request information pertaining to the processing of his/her personal data, in the same manner in which he/she can withdraw his/her granted consent to the processing thereof (see section 3.12.). The required information will be provided to the client without undue delay, whereby compensation of the actually expended costs can be required for the provision thereof.

4.2. In the event of any doubts or ambiguities regarding the correctness of the procedure in the collecting, processing or storing of personal data, the client has the right to require an explanation, both from us, as well as from any other entities that may take part in the processing in some way. If it is indeed ascertained that a breach has occurred of the principles of handling personal data, the client can demand for the defective situation to be eliminated immediately.

4.3. Besides the purpose, manner and scope as described in these Principles, we will not further process or transmit your personal data to other entities in any way, unless it is our obligation under public law to do so.

4.4. In the event of a refusal to grant consent to the processing of personal data, it will not be possible to undertake mutual legal contact to the full extent.

5. Contact Information

5.1. You can always find the current text of these Principles on the internet pages at www.trigema.cz and at our company headquarters at the following address: Bucharova 2641/14, Praha 5, Explora Business Centre –Jupiter Building.

5.2. In the event of any questions or requests for additional information, contact us at the telephone number 227 355 211, through the email address trigema@trigema.cz or in writing at the address of our headquarters.

These Principles have been last updated on the date of 20th September 2016