CzechToll s.r.o., registered office at: Argentinská 1610/4, Holešovice, 170 00 Prague 7, Czech Republic, Company Reg. No.: 06315160, registered in the Commercial Register kept by the Municipal Court in Prague under file no. C 280083 (hereinafter referred to as the “company”) hereby in accordance with Article 12 et seq. Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as “GDPR“) shall inform data subjects and other persons on the performed processing of personal data and compliance with the principles of protection of processed personal data.
What is the purpose of this Policy?
Our company places great emphasis on the protection of collected and further processed personal data. In support of this, we inform in this Personal Data Processing Policy (hereinafter referred to as the “Policy“) data subjects and other persons about what personal data we collect and how we handle them. This Policy applies to all data subjects anywhere in the world.
What personal data do we process?
On the basis of the Contract for the Supply and Provision of Comprehensive Services of the ETS Operation concluded on 20 September 2018 with the Road and Motorway Directorate of the Czech Republic, registered office at: Na Pankráci 546/56, 145 05 Prague 4, Czech Republic, Company Reg. No.: 65993390 (hereinafter referred to as the “RMD ” and the “ETS Contract”), our company is the supplier and the provider of comprehensive services for operation of the Electronic Toll System (hereinafter referred to as “ETS”) in the Czech Republic.
In order to fulfil the obligations arising from the ETS Contract, our company is obliged to process a considerable amount of personal data, in particular of owners, operators and drivers of toll-liable vehicles, or of their employees and agents. To ensure an appropriate level of personal data protection, on 11 February 2019 a contract on the processing of personal data was concluded, pursuant to Article 28(3) of GDPR, between the RMD as the personal data controller and our company as the personal data processor.
In order to perform the ETS Contract, we process the following categories of personal data:
In order to ensure fulfilment of the obligations arising from the ETS Contract and to carry out normal operating activities of our company, we further process:
How do we process personal data?
We process automated and manual personal data collected for the purpose of performing the ETS Contract, but we do not profile data subjects. The processing of personal data for the purpose of performing the ETS Contract is primarily in the form of collection and recording of personal data, storage and structuring of personal data, searching, use and deletion of personal data and in the form of transfer of personal data to the RMD.
How do we protect personal data we process?
The processing of personal data is always based on the requirements of effective legal regulations, in particular GDPR and Act No. 110/2019 Coll. on Personal Data Processing (hereinafter referred to as the “Adaptation Act”). All personal data collected and further processed are protected against their accidental or unauthorised destruction, loss, modification or disclosure to a third party. We have implemented and adhere to appropriate technical and organisational measures to protect the processed personal data, in particular all our employees and contractual partners involved in the processing of personal data shall be obliged to maintain confidentiality and we have internally set processes to ensure constant confidentiality, integrity, availability and resilience of our systems. We do not pass processed personal data to a third country or international organisation.
What are the purpose and the legal title of personal data processing?
Personal data collected under the ETS project are generally processed for the purpose of the proper operation of the ETS, in particular for the purpose of registering, charging, collecting and enforcing tolls, deposits and related fees for the use of toll roads, in accordance with the following legal titles:
We do not use personal data collected and processed within the ETS project for any other purpose and do not process it in any other way than in accordance with the ETS Contract.
We process the personal data of our suppliers and customers collected outside the ETS project based on the legal titles of the performance of an agreement concluded with a data subject and the compliance with the obligations stipulated by the law (especially the accounting and tax legislation).
How long do we process personal data?
Personal data collected within the ETS project are processed and stored by our company only for a time that is necessary. The time limit for the processing personal data is when the last of the following events arises:
Personal data collected for other purposes shall be processed for the duration of the contractual relationship with a contractor or a customer (or until the expiry of the limitation period for the possible exercise of rights by the contractual parties ensuing from this contractual relationship), but always for at least the necessary time stipulated by the law.
To whom may personal data be transferred?
The processed personal data may be transferred to:
Websites and Mobile Application
As part of the Mobile Application, we use, among other things, access to the camera, gallery and local storage of your mobile device to insert necessary attachments within selected ETS processes (especially when registering vehicles), solely based on your consent provided during the Mobile App installation. All attachments sent from your mobile device are user-controlled, i.e. the Mobile Application does not send any background data from the repository unless the user provides such data as part of the standard use of the Mobile Application.
Data Protection Officer
If you have questions regarding the processing of your personal data by our company, please contact the Data Protection Officer at the following contact details:
JUDr. Jakub Jeřábek
Data Protection Officer
mailing address: CzechToll s.r.o., Argentinská 1610/4, Holešovice, 170 00 Praha 7
telephone number: + 420 248 248 888
How can you exercise your GDPR guaranteed rights?
According to GDPR, you are entitled to exercise the following rights in relation to the RMD as the personal data controller in respect of the ETS operation: the right of access to personal data, the right of rectification or deletion of personal data, the right to limit personal data processing, the right to portability of personal data. You are also entitled to object to the processing of personal data. If processing personal data for the purpose of performing the ETS Contract, our company is only in the position of a processor of the processed personal data.
You can exercise the rights guaranteed by GDPR with our company in the following ways:
If you believe that the processing of personal data by the company has violated the law, you can file a complaint with the Office for Personal Data Protection, registered office Pplk. Sochora 27, 170 00 Praha 7.
This Policy is valid and effective as of 18 October 2019