TLV s.r.o., Company ID: 26106191, with its registered office at Pitterova 2855/7, Žižkov, 130 00 Prague 3, registered in the Commercial Register maintained by the Municipal Court in Prague, section C, insert 161155 (hereinafter referred to as the “Seller”), as the controller of personal data, hereby informs about the processing of personal data conducted in connection with the operation of the online store available through https://www.findeekids.com (hereinafter referred to as the “E-shop”), the conclusion and fulfillment of purchase contracts or service provision contracts with E-shop customers (hereinafter referred to as the “Purchaser”) and with the registration of Purchasers in the E-shop, and in connection with the operation of the Findee Kids application (hereinafter referred to as the “Application”) by the Seller as the operator and used by Purchasers and other users (hereinafter referred to as the “User”). This document also includes information on the rights that data subjects have in connection with the aforementioned processing.
For any questions regarding privacy protection and the exercise of your rights, please use this contact:
email: support@findeekids.com
To enter into and conclude a purchase agreement regarding goods or a service provision contract offered in the E-shop (hereinafter referred to as the “Purchase Contract”) with the Purchaser, the Seller needs the following personal data of the Purchaser – a natural person:
Identification data of the Purchaser (name, surname, if an entrepreneur also Company ID, VAT ID, registered office address),
Contact details of the Purchaser (email, phone number, delivery and possibly billing address),
Depending on the chosen method of payment for the ordered goods, also the bank account number and other payment details of the Purchaser,
Information from communication with you, information about the conclusion and fulfillment of the Purchase Contract.
Without the aforementioned data, it is not possible to conclude or fulfill the Purchase Contract. The legal basis for processing these data is the conclusion and fulfillment of the Purchase Contract at the request of the Purchaser.The Seller allows Purchasers to register and create a user account in the E-shop. If a Purchaser registers and creates a user account, a contract for registration and management of the user account is concluded (hereinafter referred to as the “E-shop Registration and Account Contract”). For the purposes of fulfilling this contract, we process the data mentioned above and, in addition, access data of the Purchaser – a natural person (username and password in encrypted form).The aforementioned data are necessary for the registration of the Purchaser and the establishment and management of his user account; without them, it is not possible to conclude or fulfill the E-shop Registration and Account Contract. The legal basis for processing these data is the conclusion and fulfillment of the contract at the request of the Purchaser.
The Seller concludes a contract with the User for the use of the Application (hereinafter referred to as the “Application Use Contract”).
Users are required to register in the Application. To enter into and conclude the Application Use Contract with the User, the Seller needs the following personal data of the User necessary for his registration and the establishment and management of his user account in the Application:
User ID (email address and password in encrypted form)
IP address,
Information from communication with the User and other information about the contractual relationship with the User.
Without the aforementioned data, it is not possible to conclude or fulfill the Application Use Contract. The legal basis for processing these data is the conclusion and fulfillment of the contract at the request of the User.
Paid Access is available in the Application, which the User may purchase through the Application; in this case, a Contract for the Purchase of Paid Access (hereinafter referred to as the “Paid Access Purchase Contract”) is concluded between the Seller and the User. To enter into, conclude, and fulfill the Paid Access Purchase Contract with the User, the Seller needs the personal data of the User mentioned in section 1.2.2 of this document. Without these data, it is not possible to conclude or fulfill the Paid Access Purchase Contract. The legal basis for processing these data is the conclusion and fulfillment of the Paid Access Purchase Contract at the request of the User.
For providing Paid Access and fulfilling the associated obligations, the Seller processes the following personal data of the User:
User's contact details (email),
Data on the payment made for Paid Access (payment identifier, date of transaction),
Photographs and videos,
Phone number,
Information about the device from which the User accesses the Application,
Geolocation data and data from the pedometer,
Recordings of voice messages and text messages,
Information about calls made.
The Seller must process personal data in cases where it is mandated by legal regulation. For this purpose, the Seller processes personal data mainly in the scope required by the relevant legal regulations in connection with the Seller's obligation to handle complaints from Purchasers or Users, keep accounting records, and fulfill related tax obligations, or then for fulfilling obligations imposed by the archiving law.
In justified cases, the Seller may process personal data based on the legal basis of protecting its legitimate interests. However, the Seller always carefully assesses and ensures that the interest in processing your data for this purpose does not disproportionately infringe upon your privacy.Identification of persons acting on behalf of the Purchaser – a legal entity: Typically, these are members of statutory bodies, employees, or other authorized persons who are not the contractual party with the Seller but conclude contracts with the Seller, communicate with the Seller, and otherwise act on behalf of the Purchaser. We need the personal data of these persons to communicate and act with the Purchaser for the purpose of concluding the Purchase Contract or the E-shop Registration and Account Contract with the Purchaser, its further fulfillment, or the exercise of the Purchaser's rights. For these persons, we typically process name, surname, email, phone number, delivery address, information about their job position or other relation to the Purchaser, and data from communication with them.
Proof of consent to the terms and conditions: In the case of concluding a contract with the Purchaser or User online (by electronic means), we retain data necessary to identify the Purchaser or User as a contractual party, so that we have a timestamp as evidence of contract conclusion and consent to our terms and conditions in a specific wording for any later doubts or disputes.
Defense and enforcement of legal claims: We process personal data for the purposes of protecting our legitimate interest, which is to ensure our defense in potential legal disputes, court proceedings, or during inspections by state authorities or other public administration bodies (typically the Czech Trade Inspection Authority, etc.). We process data so that we can prove, if necessary, that we acted in accordance with our contractual obligations and legal regulations. In this context, we typically process identification and contact data of the Purchaser or User, or persons acting with us on behalf of the Purchaser or User, data on concluded contracts, their fulfillment, and communication with the Purchaser or User, respectively, persons acting on behalf of the Purchaser or User.
In the case of Purchasers with whom we have concluded a Purchase Contract or who have registered in the E-shop and created a user account and in connection with this, we have obtained their email and/or phone number, or in the case of other persons who have actively and voluntarily subscribed to our newsletters, we process the personal data of these persons in the scope of email and phone number for the purpose of sending information and news about our services and products (commercial communications).
The legal basis for processing personal data for the purpose of sending commercial communications in the case of Purchasers with whom we have concluded a Purchase Contract or who have a user account is the legitimate interest of the Seller in informing about the latest offers of the Seller.
The legal basis for processing personal data for the purpose of sending commercial communications in the case of persons who have actively subscribed to the newsletter themselves without us having concluded a contract with them is their consent, which was given precisely by subscribing to commercial communications. The conditions of consent can be found at www.findeekids.com.
If you no longer wish to receive these messages from us, you have the option to unsubscribe from them at any time for free, by following the procedure stated in each commercial communication sent, within the user account, or by contacting us at any time using the contact email mentioned above in this document.
Personal data are primarily obtained from data subjects (Purchasers or Users). Unless stated otherwise, we do not collect any additional data about you, except for those you provide to us yourself, or those generated by your activity within the E-shop or Application. Some personal data – especially contact and payment data of data subjects – we may obtain from independent controllers – providers of payment methods available in the E-shop or in the Application (Apple Pay, Google Pay). Information on how these providers process your personal data can be found directly with these providers.
Personal data may be transferred under conditions established by legal regulations to public administration bodies, where required by legal regulation, or if such a body requests it within its competencies.
For data processing, we use these processors:
providers of accounting services,
contractors – natural persons providing IT programming services,
providers of hosting services.
Personal data may also be transferred to our business partners, who act as independent controllers of personal data concerning your personal data. These are especially:
operators of the payment gateway, through which payments online are enabled in the online store,
cooperating carriers used for delivering goods.
Information on how these partners process your personal data can be found directly with these partners.
Personal data may be transferred to countries outside the EU (specifically to the USA). In such a case, personal data are transferred to the USA in accordance with the decision of the European Commission that the USA provides an adequate level of protection in terms of Article 45(3) of Regulation (EU) No 2016/679 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 (General Data Protection Regulation) under the EU-US Data Privacy Framework and in accordance with the Data Privacy Framework List.
We primarily process your personal data in electronic form using automated means in our IT systems, or possibly in the systems of our individual processors. Personal data may also be processed manually in accordance with the relevant purpose, where manual processing is necessary or appropriate.
In managing your data, our employees or other persons working for us may act, among other things, to eliminate errors, inaccuracies, etc. However, these persons may only process personal data under the conditions and to the extent mentioned above and are bound by the obligation to maintain confidentiality about personal data and security measures, the disclosure of which would threaten the security of personal data.
We always process personal data in accordance with the relevant legal regulations and ensure due care and protection. We take care to ensure that you do not suffer harm to your rights, especially the right to human dignity and your private and personal life.
We process personal data for the purposes of concluding and fulfilling the contract with the Purchaser or User for the duration of concluding and fulfilling the contract (i.e., for the time necessary to fulfill the obligations arising from the contract, or for the duration of your registration in the E-shop or for the duration of using the Application).
Even after that, we may process personal data for the following purposes:
Personal data processed on the basis of our legal obligations are processed within the deadlines set by these laws.Personal data required by the legal regulation governing the tax and accounting obligations of the Seller (typically billing data and information about the provided performance) must be processed for accounting purposes and fulfilling tax obligations. The processing period is 5 (five) years from the end of the accounting period, in the case of documents relevant to VAT payments it is 10 (ten) years from the end of the tax period in which the performance took place. Relevant personal data are archived in accordance with the requirements of the archiving law for the periods specified there. Data processed for the purposes of handling complaints are kept for the duration of the period for asserting rights from defective performance, or for the warranty period.
Even after the termination of the contract with the Purchaser or User, we process personal data for the protection of our legitimate interests (i.e., defense against possible claims of the Purchaser or User or third parties, including in court) for the duration of the relevant limitation periods. If the relevant proceedings are not initiated, we keep these data for 5 (five) years from the termination of the contractual relationship with the Purchaser or User.
We send commercial communications, as stated above, and process personal data for these purposes until you unsubscribe from them by following the procedure stated in section 1.5 of this document.
Personal data may be processed for longer than stated above, in case a relevant reason for further processing arises, typically the initiation of administrative or judicial proceedings, for which personal data are relevant.
First and foremost, you have the right to ask us for access to your personal data, including the creation of a copy of all your personal data. You can do this using the email mentioned at the beginning of this document.
Withdrawal of consent to processing: If we process your personal data based on your consent, you can freely and free of charge revoke your consent to their processing at any time, through your user account, the contact email mentioned above, or otherwise, as stated elsewhere in this document. In such a case, we will no longer process your personal data processed based on consent.
For personal data that are not processed based on consent, it is not possible to revoke consent to processing. However, based on your request, we will always assess whether it is necessary to continue processing your personal data for any of the purposes mentioned above.
Your other rights:
We will always inform you about:
the purpose of processing personal data,
personal data, or categories of personal data that are the subject of processing, including all available information about their source,
the nature of automated decision-making, including profiling, and information concerning the used procedure, as well as the significance and envisaged consequences of such decision-making for the data subject,
recipients, or categories of recipients, to whom personal data have been or will be disclosed, and in case of transferring personal data to a third country, also about appropriate safeguards relating to the transfer to ensure the security of personal data,
the planned period for which personal data will be stored, or if it is not possible to determine, the criteria used to determine this period,
all available information about the source of personal data if they are not obtained from you.
Among your other rights are:
ask us for an explanation,
require us to rectify the arisen situation, especially it may involve blocking, making corrections, supplementing, restricting processing, or deleting personal data (the right to be forgotten),
request a copy of the processed personal data, or request personal data concerning you in a structured, commonly used, and machine-readable format and to transmit these data to another controller without hindrance from us,
submit an inquiry or complaint to the Office for Personal Data Protection,
object to the processing of personal data concerning you.
We protect your data. To this end, we primarily use the following security measures: implementation and enforcement of internal regulations on personal data protection, antivirus protection, firewalls, encryption, access control to personal data and authorization data, backup, physical security measures, and more.
This wording of the Information on the Processing of Personal Data is effective as of November 23, 2023.
