Privacy Policy
Protecting your privacy is of the utmost importance to us. Within the Trigema Group, i.e. all persons directly or indirectly controlling or controlled by Trigema a.s., with its registered office at Prague 5 – Stodůlky, Bucharova 2641/14, postcode 158 00, Czech Republic, company registration number: 614 66 123, and/or entities in which Trigema a.s. holds a direct or indirect equity interest (hereinafter referred to as the “Trigema Group”), we pride ourselves on long-term, trustworthy relationships with our clients, business partners, and prospects. Part of this approach is also the responsible handling of personal data and respect for your privacy.
Introduction and approach to privacy
This privacy policy explains to you clearly and comprehensibly:
- What personal data we process about you,
- For what reasons we do so,
- How we handle it,
- And what control you have over it.
We aim to ensure that you always know why we are communicating with you, on what lawful basis, and how you can modify or stop this communication at any time.
For us, personal data protection is not just a legal obligation, but a natural part of a professional and fair approach to clients.
Who is the data controller
Your personal data is processed by joint controllers, namely Trigema a.s., with its registered office at Bucharova 2641/14, Prague 5 – Stodůlky, postcode 158 00, Czech Republic, company registration number: 614 66 123 and other companies within the Trigema Group, a current list of which can be found at https://www.trigema.cz/skupina-trigema/ (hereinafter referred to as the “Controllers”).
The Controllers (acting as joint controllers) jointly determine the purposes and means of the selected processing of personal data, in particular in the areas of client relationship management, marketing communications, preference management and related internal processes. The Controllers have agreed amongst themselves on the allocation of responsibility for fulfilling their obligations in relation to the processing of personal data, whereby each Controller is liable to the other Controllers for any breach of the obligations imposed on it in connection with the processing of personal data, as well as for cooperating in handling complaints and requests relating to such processing.
The Controller with whom you first made contact is obliged to provide you with information regarding the processing of your personal data in accordance with the GDPR, if such data is to be processed under a joint controller agreement. You may also exercise all your rights under the GDPR with this Controller; this is without prejudice to your right to exercise your rights in relation to the processing of personal data against any Controller.
All personal data is processed jointly by the Controllers as part of their business activities, i.e. in particular, the preparation and implementation of property development projects within the Czech Republic, including the provision of related products and services, including the management and/or operation (including letting) of property, as well as in connection with other products and services provided by the Controllers in the leisure sector.
Key roles in the processing of personal data
- Controllers — decide why and how personal data is processed.
- Processor — processes personal data on the instructions of the Controllers and on their behalf (e.g. technology and IT partners).
- Data subject — a natural person whose personal data is being processed.
What personal data do we process
The scope of personal data we process about you always depends on your relationship with the Trigema Group and how you communicate with us.
In all cases, the following applies:
- We process in particular the personal data you have provided to us, which is necessary for a specific purpose, and we take great care to protect it,
- We process personal data only in accordance with legal regulations, for specified purposes and to a reasonable extent,
- We continuously review the scope of processing and limit it to data that is strictly necessary for the given purpose; at the same time, we respect your chosen preferences regarding marketing communications.
Below is an overview of typical situations and the types of personal data we process.
a. When you communicate with us as a prospect or client
If you express interest in our projects or services, or if you become our client, we may process the following personal data about you in particular:
- Identification and contact details, such as first name, surname, email address, or telephone number,
- Data relating to your enquiry or your use of our services,
- Information that you voluntarily provide to us when communicating with our representatives and during mutual communication.
Purposes of processing:
- Handling your enquiries and requests,
- Communication prior to entering into a contract and preparation of a quotation,
- Improving the quality of services,
- Recording communications and protection of legal claims.
Lawful bases for processing:
- Taking steps at your request prior to entering into a contract,
- Our legitimate interest in recording communications and protecting legal claims,
- Where applicable, compliance with legal obligations if imposed on us by law.
We retain personal data only for as long as is necessary for the given purpose, and thereafter for a maximum of 6 months following our last mutual communication, unless a contractual relationship is established or unless legislation requires a longer period.
Providing this data is voluntary; however, without it, we may not be able to respond to your request or prepare a quotation.
b. When we provide our services to you
If we provide our services to you, we may further process the following about you in particular:
- Information required to provide our services, such as first name, surname, date of birth, company registration number, VAT number, bank account number, address, personal identification number, email address, or telephone number,
- Where necessary for client identification under AML, also place of birth, nationality, gender, data stated on your identity document, sources of your income,
- Information that you voluntarily provide to us in the course of providing our services and during mutual communication.
Where required by legal regulations in a specific case, we may also process additional identification data necessary to comply with obligations under anti-money laundering and counter-terrorist financing regulations.
Purposes of processing:
- Entering into and performance of a contract,
- Keeping client records and managing the contractual relationship,
- Compliance with accounting, tax, archiving, and other statutory obligations,
- Protection of legal claims,
- Sending information about our own similar products or services to existing customers in cases permitted by law.
Lawful bases for processing:
- Performance of a contract,
- Compliance with legal obligations,
- Our legitimate interest in protecting legal claims, keeping records and appropriate communication with customers,
- For direct marketing to existing customers, also a legitimate interest to the extent permitted by law.
We retain personal data for the duration of the cooperation, and for a further 5 years after it ends, unless legislation stipulates a longer period.
Providing the data necessary to enter into and perform a contract is a contractual requirement; without providing it, we cannot enter into or properly perform the contract.
c. When you sign up for information or marketing communications
If you decide to receive information about the Trigema Group’s projects, news, or activities, we also process data relating to marketing communications, in particular:
- Identification and contact details, such as first name, surname, email address, or telephone number,
- Information on whether you have given your marketing consent,
- Login details for a user account operated by the Controllers.
We place particular emphasis on protecting data relating to your marketing consent. We consider this data to be essential for respecting your privacy and meeting your expectations.
If you decide to limit or completely stop marketing communications at any time, we will fully respect your decision.
Purposes of processing:
- Sending marketing communications and information about the Trigema Group’s projects, services, and activities,
- Management and recording of marketing consents, opt-outs, and objections,
- Demonstrating that your choice has been respected.
Lawful bases for processing:
- Your consent, where required for the given method of communication,
- Our legitimate interest in sending information about our own similar products or services to existing customers, to the extent permitted by law.
If you are our customer and we have obtained your electronic contact details in connection with the sale of a product or service, we may send you commercial communications relating to our own similar products or services even without your separate consent, provided that you have not previously opted out of receiving them and that each individual communication provides you with a clear and simple option to opt out of further communications.
Marketing consent is voluntary and is not a condition for entering into a contract or using our services. You may withdraw your consent at any time using the unsubscribe link in the commercial communication or by contacting us using our contact details. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. You also have the right to object at any time to the processing of personal data for direct marketing purposes. If you object or opt out of receiving commercial communications, we will no longer process your personal data for these purposes.
Consent is granted for a period of 5 years unless you extend this period or withdraw it. We may also retain data on the withdrawal of consent, opt-out or objection for a reasonable period to demonstrate that your choice has been respected.
d. When you visit our website or use online services
When you visit our website and use online services, we may process in particular:
- Technical data about your device and browser,
- Data on website usage,
- Data relating to logging into user accounts,
- Data collected via cookies and similar technologies, where they are used.
Purposes of processing:
- Ensuring the functionality, security, and management of the website and online services,
- Analysing visitor traffic and improving the user environment,
- Managing your settings and consents to the use of cookies and similar technologies.
Lawful bases for processing:
- Our legitimate interest in the secure and proper operation of the website and online services,
- Compliance with legal obligations,
- Your consent, where required by law, particularly in the case of non-technical cookies and similar technologies.
Detailed information on the use of cookies, their categories, retention periods, and settings options is set out in a separate Cookie Policy.
e. When you express interest in a job within the Trigema Group
If you express interest in a job within the Trigema Group, we may process the following about you in particular:
- Identification and contact details, such as first name, surname, email address or telephone number, and photograph,
- Information about your educational background and work experience,
- Information you provide to us during communication and in your CV (cover letter),
- Data relating to your interest in working with the Trigema Group.
Purposes of processing:
- Assessing your suitability for the vacancy,
- Conducting the recruitment process and communicating with you,
- Protection of legal claims,
- Where applicable, contacting you regarding a similar job opportunity, provided we have an appropriate lawful basis for doing so.
Lawful bases for processing:
- Taking steps prior to entering into an employment or similar relationship,
- Compliance with legal obligations,
- Our legitimate interest in the recruitment process and protecting legal claims,
- Where applicable, your consent if we request it for a specific purpose.
We retain personal data for the duration of the recruitment process and for a period of 12 months after its completion on the grounds of legitimate interest. In the event of entering into an employment contract, we retain personal data for the duration of the employment relationship, unless legal regulations stipulate a longer period. Providing data is voluntary; however, without providing it, we may not be able to assess your application or include you in the recruitment process.
How we obtain personal data
We obtain personal data primarily directly from you during contract negotiations, entering into and performing a contract, registering for online services, or communicating with us, managing marketing consents and preferences, from persons authorised to pass data to us, from publicly available sources, public registries, registers, and lists, and from our own activities in fulfilling contractual and operational obligations.
If we do not obtain personal data directly from you, we will provide you with information regarding the source of such data to the extent required by legal regulations, unless a statutory exception applies.
Lawful bases for processing personal data
a. Performance of a contract and legal obligations
E.g. performance of contractual relationships, accounting and tax obligations.
c. Consent of the data subject
Particularly for marketing communications in cases where consent is required by law, and for other purposes for which we explicitly request consent.
b. Legitimate interest
Particularly for:
- Basic operational communication,
- Protection of property and security,
- Client records (CRM),
- Creating internal statistics and reporting,
- Protection of legal claims,
- Sending information about our own similar products or services to existing customers, where permitted by law.
Purposes of processing personal data
We process personal data primarily for the purpose of:
- Fulfilling contractual and service obligations,
- Communicating with customers and partners,
- Improving the quality of services,
- Marketing communications based on consent,
- Recording, managing, and enforcing marketing consents and preferences,
- Maintaining client and contract records,
- Protecting legal claims,
- Managing user accounts, web services, and system security.
Method of processing personal data and security
We process personal data both automatically and manually.
When processing personal data, we ensure compliance with confidentiality and security in accordance with appropriate standards that ensure protection against unauthorised or accidental access or transmission, alteration, loss, or destruction, as well as against potential misuse. We also ensure the protection of the rights of data subjects, guaranteeing compliance of personal data security with relevant legal regulations and these terms.
There is no automated decision-making on the part of the Controllers, meaning decision-making based exclusively on automated processing that would have legal effects for you or significantly affect you in a similar manner.