Policy on the Processing of Personal Data by the Video Surveillance System with Recording

Information Provided When Collecting Personal Data from the Data Subject Pursuant to Article 13 of the General Data Protection Regulation

We are EMOS spol. s r.o., with its registered office at Lipnická 2844, Přerov I – Město, 750 02 Přerov, Company ID No. 19014104, registered in the Commercial Register maintained by the Regional Court in Ostrava, Section C, file 1167, and as the data controller, we process your personal data in accordance with applicable and effective legislation, which, as of May 25, 2018, consists primarily of Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation, or “GDPR” for short), which is supplemented in the Czech Republic by the accompanying Act No. 110/2019 Coll., on the Processing of Personal Data, as amended.

We would therefore like to inform you about the processing of your personal data by our video surveillance system.

What personal data will we process?
Individual cameras capture the movement of individuals in the monitored area, thereby recording their physical appearance and visual information about their behavior and actions. Personal data will therefore consist of visual footage of the data subject without sound.

Why do we process your personal data?
We process your personal data for the purpose of protecting property, preventing vandalism, ensuring safety, and protecting the life and health of individuals entering the monitored areas, that is, to enable your potential subsequent identification in the event of an emergency directly or indirectly related to your presence in the monitored areas (e.g., property damage or a security incident). The legal basis for processing your personal data is therefore our legitimate interest [Article 6(1)(f) of the General Data Protection Regulation (GDPR)].

How will we handle your personal data?
We process your personal data using a video surveillance system with recording capabilities. Individual cameras are positioned to monitor only those areas designated for this purpose, where people move about in a normal manner, and where the video recording does not infringe on the data subject’s privacy in any way. EMOS spol. s r.o. directly processes personal data on a 24/7 basis. Within this framework, access to your personal data is restricted to a strictly limited number of people: selected employees of the Technical Department, the Logistics Department, and the Director’s Office, or, if necessary, the Legal Department (in the event of an emergency). 

We guarantee the protection of the personal data being processed through security measures specified in Article 32 of the General Data Protection Regulation. The recording device is located in a room with restricted access (access credentials, limited number of authorized individuals, and restrictions on the circumstances under which the recording may be viewed) and operates on its own separate computer network. A written record is kept of every access to camera footage and every transfer of footage, specifying the date and purpose of the viewing or transfer. No third-party processors process your personal data on behalf of our company. We do not disclose your personal data to any third party (it is not transferred to any third country or international organization), except for possible disclosure to law enforcement authorities, courts, bailiffs, insurance companies, or cooperating law firms, should an extraordinary event occur that is directly or indirectly related to your presence in the monitored premises and is being addressed through a complaint procedure, criminal proceedings, civil litigation, enforcement proceedings, or in the event of an insurance claim. We do not disclose your personal data in any way.

How long will we process your personal data?
We will process your personal data only for as long as is strictly necessary to fulfill the purposes for which it was collected. In the event of a security incident, property damage, a threat to human health or life, etc., we will process your personal data until the situation is resolved (e.g., until the conclusion of a complaint, court, criminal, or enforcement proceeding, or an investigation by the police or an insurance company).

You will always have control over your personal data

You have the right to request the erasure of your personal data that we process. As the processor of your personal data, we are obligated to erase it without undue delay if:

• it is no longer necessary for the purposes for which it was collected or otherwise processed;
• you object to the processing (see below) and there are no overriding legitimate grounds for the processing;
• the personal data has been processed unlawfully;
• the personal data must be erased to comply with a legal obligation under EU law or the law of a Member State to which the controller is subject.

We cannot erase personal data if its processing is necessary to comply with a legal obligation, for reasons of public interest, for reasons of public interest in the area of public health, or for the establishment, exercise, or defense of legal claims.

You have the right to access your personal data that we process. Upon your request, we will provide you—even in the future (for as long as we process your personal data)—with information regarding:

• the purpose for which your personal data is processed;
• the category of personal data concerned;
• the recipients or categories of recipients to whom the personal data has been or will be disclosed;
• the planned period for which the personal data will be stored by us;
• the existence of the right to request the correction or erasure of personal data concerning you, or the restriction of its processing, or the right to object to such processing;
• the right to lodge a complaint with a supervisory authority.

You have the right to have your personal data that we process corrected. Upon request, we will correct any inaccurate personal data concerning you that we process.

You have the right to have us restrict the processing of your personal data. We will restrict the processing of your personal data if:

• you contest the accuracy of the personal data, for the period necessary for us to verify its accuracy; 
• the processing of personal data is unlawful and you oppose the erasure of the personal data and instead request the restriction of its use;
• we no longer need the personal data for the purposes of processing, but you require it for the establishment, exercise, or defense of legal claims;
• you object to the processing (see below), until it is determined whether our legitimate grounds override your legitimate grounds.

If the processing of personal data has been restricted, it may, with the exception of storage, be processed only with your consent or for the purpose of establishing, exercising, or defending legal claims, for the purpose of protecting the rights of another natural or legal person, or for reasons of an important public interest of the EU or of a Member State.

You have the right to object to the processing of your personal data. If you object, we will no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

You may exercise all of the above rights by submitting a request (for information, erasure, rectification, or objection) with your verified identity, which means that you must submit the request either

• in person at our address listed above, with your identity verified using an ID card,
• by sending a written request with your identity verified through CzechPoint or a notary,
• by sending an electronic request via a data box,
• by sending an electronic request accompanied by a guaranteed electronic signature (see Act No. 297/2016 Coll., on Trust Services for Electronic Transactions) to gdpr@emos.cz.

We will process your request without undue delay, no later than 1 month after receiving it. In exceptional cases, depending on the complexity and number of requests, we may extend this deadline by an additional 2 months (we will inform you of this immediately). Given the nature of personal data processing by the video surveillance system, information specifying the exact time and location will most likely be required to fulfill the data subject’s right.

We will process your request free of charge. Only if the requests submitted are manifestly unfounded or excessive, particularly because they are repeatedly submitted without justification, we would charge you a reasonable fee reflecting the administrative costs associated with providing the requested information or communication, or with taking the requested actions; or we may refuse your request (as permitted by Article 12(5) of the General Data Protection Regulation).

What options do you have if you are not satisfied with the way we process your personal data?

If you are not satisfied with the way we process your personal data—that is, if you believe that we are processing it unlawfully or that any of your rights listed above have been violated—you have the option to file a complaint with the supervisory authority. In the Czech Republic, this is the Office for Personal Data Protection, located at Pplk. Sochora 27, 170 00 Prague 7; https://www.uoou.cz.

However, we would appreciate it if you would first discuss your complaint with us. You can always easily contact us using the following contact information:

• EMOS spol. s r.o., Business Process Manager, Lipnická 2844, 750 02 Přerov, Czech Republic
• Email: gdpr@emos.cz
• Phone: +420 581 261 111

This Privacy Policy is valid and effective as of July 1, 2020.