GDPR

For questions about the handling of personal data, privacy and GDPR matters, you can contact:

Michal Hudeček
gdpr@levebee.com

Data subprocessors:

• Wedos hosting / Wedos Internet, a.s. (EU)
• Active24 hosting /  ACTIVE 24, s.r.o. (EU)
• SendInBlue (EU)

Information about the processing of personal data and privacy policy

In this document we introduce you to the principles and principles of processing your personal data and also provide you with clear information about the following

1. Who will have access to your personal data and in what capacity?
2. For what purposes do we process personal data and what authorizes us to do so?
3. What kind of personal data will it be? 
4. How long will your personal data be stored? 
5. How is the processing carried out and how is your personal data protected?
6. How can you verify or influence the processing of your personal data? 
7. How can you exercise your right, how much will it cost you?

Basic concepts

• Personal data: is any information about a natural person who can be directly or indirectly identified
• Data subject: the natural person whose personal data is processed
• Controller: is the person who determines the purposes and means of the processing of personal data and is responsible for its lawful processing
• Processing: is any operation or set of operations on personal data or sets of personal data (e.g. collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, dissemination, alignment, combination, restriction, erasure, destruction, ...)
• Processor: is the person who processes personal data for the controller
• Recipient: is the person to whom the personal data are provided

Where else, apart from this document, can you find the issue of personal data?

• Antispam Act: Act No. 480/2004 Coll., on certain information society services;
• Civil Code:Act No. 89/2012 Coll., Civil Code, as amended;
• GDPR: Regulation (EU) No 2016/679 of the European Parliament and of the Council of
• 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC;
• VAT Act: Act No. 235/2004 Coll., on value added tax, as amended;
• Personal Data Protection Act: Act No. 101/2000 Coll., on the protection of personal data, as amended;
• Consumer Protection Act: Act No. 634/1992 Coll., on Consumer Protection, as amended;
• Act on Accounting: Act No. 563/1991 Coll., on Accounting, as amended

1. Who will process your personal data and in what capacity?
Your personal data will be processed primarily by us, the company Levebee s.r.o., with its registered office at Na Pankráci 322/26, Prague, Postal Code 14000, ID No.: 03362078, registered in the Commercial Register maintained by the Municipal Court in Prague, Section C, Insert 230690 (hereinafter referred to as "Levebee"), which will also be the administrator of your personal data. Further contact details are provided on the website.

One of our obligations as the controller of your personal data is to provide you as data subjects with information to the extent and in the manner specified in particular in Articles 12 and 13 of the GDPR, which we do through this website. 

Our services are provided in cooperation with other entities outside our company, which leads to the need to exchange information with these entities, including your personal data. Thus, your personal data may be disclosed to our contractual partners, including persons forming business groups with us, in addition to our employees, as well as to their employees or contractual partners who contribute to the fulfilment of the purposes of processing set out below. This is always to the extent appropriate to the relevant purpose. 

In order to enter into a contractual relationship with you and to take pre-contractual measures, in particular if you decide to take advantage of the possibility to enter into a contract with us on the basis of an individual offer, it is necessary to provide your personal data to the person who will contact you, prepare an offer for you, enter into the relevant contract with you and further communicate with you, all to the extent appropriate for the performance of the aforementioned activities. The performance of the contractual relationship with you generally involves the provision of any personal data that may be considered relevant in the circumstances of the case to experts in the relevant fields or other persons designated as your contact persons so that they are able to answer any questions you may have and provide you with consultation.

These are entities that we have carefully selected and that are able to ensure sufficient protection of your personal data. 

Where we are required by law to do so, we are also obliged to transfer your personal data to various state and international authorities, e.g. the tax office in the case of a tax audit, a request from the Police of the Czech Republic. In such a case, your personal data may also be transferred to the relevant state administration authorities.

In other cases, we will transfer your personal data outside our company only if you allow us to do so.

2. For what purposes do we process personal data and what authorizes us to do so?
We process your personal data for the following purposes:

• to enter into and perform a contractual relationship with you or to take pre-contractual measures at your request;
• performance of legal obligations imposed on us by Czech or EU legislation, e.g. performance of accounting and tax obligations to regulatory and state authorities imposed on us by the Accounting Act, the VAT Act, or performance of obligations imposed on us by the GDPR and other legislation;
• ensuring the protection of our rights and legally protected interests consisting in the possible necessity to establish, exercise or protect our legal claims, whether in court or other proceedings or in out-of-court proceedings, including the necessity of related steps including, as a rule, the transfer of data to a selected lawyer for the preparation of legal analyses, the proposal of an appropriate procedure and its implementation, the submission of the relevant proposal and evidence to the court or other authorities in the course of litigation or other proceedings (e.g. etc.;
• scientific research for the purpose of improving the application and the quality of services, in particular through machine learning, i.e. the ability of the application to recognise the quality of reading as automatically as possible on the basis of the outputs of individual users within the application, their teaching practices and audio recordings of the reading of words and sentences by individual users;
• evaluating the success of marketing campaigns as well as customer satisfaction in order to improve the quality of the services we provide and adjust products accordingly;
• marketing and other business communications, in particular to inform you about other Levebee and third party products and services.

The purposes for which we process your personal data can be divided into two categories. Purposes for which we are entitled to process your personal data without your consent and purposes for which we are entitled to process your personal data only with your consent. 

The first category includes the processing purposes listed under (a), (b) and (c) above, which themselves also constitute the legal basis for processing your personal data. On the other hand, the processing of your personal data for the purposes set out in (d), (e) and (f) above is only possible with your consent. 

Without the processing of personal data for the purpose of concluding and performing a contractual relationship with you, or accepting the controller pursuant to point b) and exercising the controller's legitimate interests pursuant to point c), the respective contractual relationship cannot be concluded or performed. <However, you are entitled to withhold your consent to the processing of your personal data for the purposes of scientific research for the purpose of improving the application and quality of services, in particular by means of machine learning pursuant to (d), for the evaluation of the success of marketing actions as well as customer satisfaction pursuant to (e) and for marketing and other business communication pursuant to (f), or to withdraw your consent at any time or to ask us to restrict the processing of your personal data without this affecting the possibility of concluding or performing a contractual relationship. This means that together we can conclude and perform the contract without processing your personal data for these purposes. However, the withdrawal of consent does not affect the lawfulness of the processing of personal data carried out by us prior to such withdrawal.

3. What kind of personal data will be involved?

We only process adequate, relevant, accurate personal data to the extent necessary in relation to the purpose for which it is processed. We will subsequently update this data based on your suggestions sent via email to update your personal data. The personal data provided is accurate and you have the right to request the rectification of personal data if you believe that the personal data processed is inaccurate or incomplete. 

All your personal data, whether or not we process it with or without your consent, will only be kept for as long as necessary to fulfil the relevant purpose for which it was processed. Thereafter, they may only be processed by Levebee in a form that no longer permits your identification.

We process any personal data you provide to us that may be relevant to fulfilling any of the stated purposes of the processing. This includes your basic personal data, data about the contract and the service you order from us, data from our communication with you, records of individual users' outputs in the application and other data listed below.

We process the largest amount of personal data for the purpose of concluding and fulfilling a contractual relationship with you, as well as for scientific purposes and machine learning. This is due to our desire to provide the best possible service and maximum cooperation in a professional manner, the long-term development of our services, and to keep to a minimum the need to burden you with additional questions about facts you have already communicated to us or documents you have already submitted to us. 

For the purpose of fulfilling our legal obligations and ensuring the protection of our rights and legally protected interests consisting in the possible necessity to establish, exercise or protect our legal claims, we only process personal data envisaged by the relevant legislation. For the purpose of marketing and other personal communications, we only process your identification and contact data.

We do not process data that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, biometric data for the purpose of uniquely identifying you, data about your health, sex life or sexual orientation, except for voice recordings of reading words and sentences, which we process only for the performance of our rights and obligations under the contract. We only process recordings of your voice in pseudonymised form for scientific purposes via machine learning.  

Categories of personal data we process include:

a) Identification data
The basic data on the basis of which we are able to uniquely identify you include your:

First and last name, if applicable, the Customer's name, the Customer's email address and the Customer's IP address.  

If you are entering into a contract as an entrepreneur, the identification data also includes your:

Home address and identification number. 

b) Contact details
Details on the basis of which we are able to contact you if necessary include your:

delivery address (which may be the same as your permanent home address), telephone number and email address.

c) Information relating to the performance of a contract between us and other personal information provided by you under a contract, other document provided to us, or in a face-to-face meeting or remote communication, including subsequent updates

As appropriate, this may include, but is not limited to,

Other information about your customer account, Outputs of individual users in the context of their use of the application, teaching practices, audio recordings of word and sentence readings by individual users, details of operations taking place on devices used by users under contract, records of communications with us, records of the due and proper performance of legal obligations under the relevant contract, e.g. Invoices, bank account numbers, proof of payment, etc.

4. How long will your personal data be stored?
We will only keep all personal data, whether or not we process it with or without your consent, for as long as is necessary to fulfil the relevant purpose for which it was processed. Thereafter, they may only be processed by us in a form that no longer allows your identification.

For the purpose of entering into a contractual relationship with you, we only process your personal data until you expressly refuse to enter into a contract or it otherwise becomes apparent that a contract will not be concluded between us. 

For the purposes of the performance of the contract concluded between us and to ensure our related rights and legally protected interests, we process your personal data for the duration of the rights and obligations under the contract you have concluded with us, as a rule until the customer account is cancelled. 

Performance of the legal obligations imposed on us by the legal regulations of the Czech Republic and the EU requires the processing of your personal data in accordance with the legal time limits set by these regulations, even after the termination of the contract between us. This is, for example, the VAT Act, which requires us to keep tax documents and records detailing the services provided for ten (10) years from the end of the tax period in which the transaction took place, or the Accounting Act, which requires us to keep all accounting documents for five (5) years. 

Personal data that we process on the basis of your consent, we process until your consent is withdrawn. If you do not withdraw your consent, then for a period of ten (10) years from the date of termination of the rights and obligations under the relevant contract. We will extend this period for data processed for marketing and other business communication purposes in the event that you respond positively to one of the offers sent to you, e.g. you tell us that it was useful to you or you express interest in the details, for a period of five (5) years from such response. In the case of data processed for the purposes of scientific research and machine learning, we will only retain such data after the expiry of the aforementioned period in a form that no longer allows your identification.

The aforementioned periods will always be shortened if, based on other circumstances of the case, we conclude that the relevant purpose for which your personal data was retained has already been fully fulfilled.

5. How is the processing carried out and how do we protect your personal data?
The controller processes your personal data in a fair, lawful and transparent manner for the purposes set out above and in a manner compatible with those purposes. 

We process your personal data both automatically, within our information systems, and manually. Manual processing is carried out by our employees or third parties. All persons who come into contact with personal data are bound by a duty of confidentiality. 

In order to protect against unauthorised or unlawful processing, accidental loss, destruction or damage to data, we use appropriate technical and organisational measures that take into account the nature, scope, context, purposes of the processing as well as the differently likely and differently serious risks to your rights and freedoms, as well as the state of the art and the cost of implementation. We regularly review and update these measures.

6. How can you verify or influence the processing of your personal data?
We process personal data transparently and fairly as required by applicable and effective legislation. If you have any questions or requests regarding the processing of your personal data, you can contact us at any time in the way you normally use in your communication with us, e.g. via web form, email, telephone or by visiting our headquarters (see section 7 below for more details). 

In particular, you have the following options to verify or influence the processing of your personal data

a) Right to access your personal data
If you are unsure (i) whether we are processing your personal data, (ii) to what extent, (iii) for what reason, (iv) how long we intend to process it, (v) to whom it is disclosed, (vi) what other rights you have in relation to your personal data, or (vi) from what source we obtained your personal data (unless we obtained it directly from you), you may ask us for this information. 

At your request, we will also provide you with a copy of your personal data that we process. If you request more than one copy, we are obliged to inform you that we are entitled to charge you a reasonable fee corresponding to our administrative costs.

If you request us electronically, we will also reply to you electronically, unless you request another method of communication at the same time. 

The details are set out in Article 15 of the GDPR.

b) Right to rectification of your personal data
If you believe that the personal data we process about you is incorrect, inaccurate or incomplete, you have the right to ask us to correct, update or complete it. 

Details are set out in Art. 16 GDPR.

c) Right to erasure of your personal data
If you consider that your personal data (i) are being processed unlawfully, (ii) some of them are no longer necessary for the purposes for which they were processed, (iii) are being processed despite your withdrawal of consent (and at the same time there is no other legal ground, (iv) an objection to the processing is to be positively dealt with (see below), (v) the need for erasure arises from Czech or EU law, you have the right to ask us to erase your personal data to which this relates. <However, we will not be able to comply with your request if it is unjustified, or if the processing of your personal data is necessary for the exercise of the right to freedom of expression and information, to comply with a legal obligation with which we are required to comply, or for archiving purposes in the public interest, scientific or historical research, or for statistical purposes, which we may be required to do, for example by the Czech Statistical Office, or for the establishment, exercise or defence of legal claims. 

The details are set out in Article 17 of the GDPR.

d) Right to restriction of processing
If you consider that (i) the personal data we process is not accurate, (ii) the processing is unlawful and you prefer to restrict its use instead of erasure, (iii) we no longer need to process your personal data to fulfil any of our stated purposes but you require it for the establishment, performance, or defend legal claims, or (iv) you have objected to the processing (see below), you have the right to ask us to restrict the processing of the relevant personal data until we are able to verify the accuracy, lawfulness of the processing or the validity of your objection, or until we provide you with your personal data for the purposes of your legal claims.

e) Right to data portability
If we process your personal data by automated means, you have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format to another controller of your choice to that extent, if technically feasible. 

f) Right to object to processing
You have the right to object to the processing of your personal data where we process your personal data for the purposes of (i) direct marketing, or (ii) on the grounds of our legitimate interests and those interests do not override your interests or rights and freedoms. In this case, we will no longer process your personal data for these purposes. 

g) Right to withdraw consent
Without certain personal data that we process for the purpose of concluding or performing a contract, it is not possible to conclude a contract. However, if we require your consent to process your personal data (in particular for marketing and commercial purposes), you have the right not to provide this consent or to withdraw it at any time without affecting the possibility of concluding or performing a contract. You may also withdraw your consent to the processing of your personal data only partially (in respect of specific personal data) in any of the forms set out below.

7. How can you exercise your right, how much will it cost you?
Exercising your rights is free of charge. <However, if your request is manifestly unfounded or unreasonable by reason of repetition, we are entitled either to charge you a reasonable fee taking into account the administrative costs of providing the information, communication or action requested or to refuse to comply with your request. 

If we have reasonable doubt about your identity or the identity of the person exercising their right, we may ask you for additional information necessary to confirm your identity. 

You can exercise your rights, including the withdrawal or restriction of your consent to the processing of your personal data

• by sending your request in writing to our Levebee s.r.o., Na Pankráci 322/26, Prague 4, 140 00 ;
• electronically
• by e-mail sent to support@levebee.com
• by telephone by calling +420 799 512 123
• or in any other way that you still use to communicate with us.

If you exercise any of your rights, you can expect our response without undue delay, within one month at the latest from the time your request was received or communicated to us in person or by telephone. 

We would like to inform you that due to the complexity and number of requests we may extend this period by a further two months. We will, of course, inform you of this extension within one month of receipt of your request, including the reasons for it. 

If you choose to communicate with us electronically to exercise one of your rights, we will also provide you with information about your request electronically. If you prefer a different method of providing information about your request (for example, in writing or orally) and you tell us, we will try to communicate with you in the way you choose, provided that we are able to prove your identity unambiguously. 

We will inform you of the processing of your request, even if we do not take the action you have asked us to take, as well as the reasons why we have done so.

We will notify all recipients to whom we disclose your personal data of any rectification, restriction or erasure of personal data, except where this proves impossible or requires disproportionate effort.

If you disagree with either the way we process your data or believe that we have breached data protection rules in processing your data, you can contact the supervisory authority, the Data Protection Authority, at any time by

electronically at: https://www.uoou.cz/vismo/o_utvar.asp?id_u=10
by phone: +420 234 665 111
in writing to the Office for Personal Data Protection, Pplk. Sochora 27, 170 00 Prague 7


Translation of this page is provided for your convenience. In case of conflicts of interpretation the Czech version prevails.