Privacy Policy | Vzajemne

Purple P2P (“Purple P2P”, “we”) process personal data of their users of vzajemne.cz food and goods ordering services (“Vzajemne.cz App”) and the visitors of the website vzajemne.cz .

In this Privacy policy, the word “Vzajemne.cz Services” refers jointly to the Website vzajemne.cz and the Vzajemne.cz App. In this Privacy policy, the word “User” or “you” refers jointly to our current and prospective customers, couriers and food and goods provides.

Our Privacy policy explains, for example, the types of personal data we process, how we process the personal data and how you may exercise your rights as a data subject (e.g. right to object, right of access).

Some of our services might be subject to a separate privacy policy. If a separate privacy policy applies to a particular service, we will post it in connection with the service in question.

This Privacy policy may be updated from time to time in order to reflect the changes in data processing practices or otherwise. You can find the current version on the Website. We will not make substantial changes to this Privacy policy or reduce the rights of the Users under this Privacy policy without providing a notice thereof.

This Privacy Policy uses certain terms in the same sense as the Terms and Conditions.

DATA CONTROLLER(S)

This Privacy policy applies to processing of personal data carried out by Purple P2P, reg.n: 09110127, company incorporated and registered by Regional court in Brno file n.: C 117301, registered office Masarykova 409/26, Brno-city, 602 00 Brno, Czech Republic.

Email: podpora@vzajemne.cz

PERSONAL DATA PROCESSED AND SOURCES OF DATA

The personal data collected and processed by us can be divided into two general data categories: User Data and Analytics Data.

User Data

We primarily process User Data collected directly from you during registration. We may collect User Data from our Users, including those subscribed to a newsletter or fill out other form. Further, please note that we also collect details of any transactions and payments you carry out through the Vzajemne.cz Services.

User Data that is necessary in order to use the Vzajemne.cz Services

The following personal data collected and processed by us is necessary in order for a proper performance of the contract between you and us as well as for our legitimate interest whilst fulfilling our contractual obligations towards Users and for the compliance with our legal obligations.

When you register to the Vzajemne.cz Services and create a user account, you need to provide us with the following information:

full name
telephone number
email address
information relating to your payment instrument(s) such as the number of your payment instrument(s) and the expiration date of your payment instrument(s) (required for the purposes of ordering food products via the Vzajemne.cz Services, however not stored by Purple P2P, since Purple P2P uses a third party payment service provider for processing of payments)

User Data you give us voluntarily

Other Information. We may also process other information provided by you voluntarily such as:

information you provide when rating our services, event. your rating of other Users
marketing opt-ins and opt-outs
information you provide by phone or in email or chat correspondence with us, including call recordings of your calls with our customer service

In addition to User Data collected from you and the Customer Organization, we process certain personal data third party service providers provide about you.

Analytics Data

Although we do not normally use Analytics Data to identify you as an individual, you can sometimes be recognized from it, either alone or when combined or linked with User Data. In such situations, Analytics Data can also be considered personal data under applicable laws and we will treat such data as personal data.

We may automatically collect the following Analytics Data when you visit or interact with the Vzajemne.cz Services:

Device Information. We collect the following information relating to the technical device you use when using the Vzajemne.cz Services:

device and device identification number, device IMEI
country
IP address
browser type and version
operating system
Internet service providers
advertising identifier of your device
visitor identifier

Usage Information. We collect information on your use of the Vzajemne.cz Services, such as:

time spent on the Vzajemne.cz Services
interaction with the Vzajemne.cz Services
information on your orders made through the Vzajemne.cz Services
the URL of the website you visited before and after visiting the Vzajemne.cz Services
the time and date of your visits to the Vzajemne.cz Services
the sections of the Vzajemne.cz Services you visited
the products you searched for while using the Vzajemne.cz Services

We use various technologies to collect and store Analytics Data and other information when the Users visit the Vzajemne.cz Services, including cookies and web beacons.

Cookies are small text files sent and saved on your device that allows us to identify visitors of the Vzajemne.cz Services and facilitate the use of the Vzajemne.cz Services and to create aggregate information of our visitors. This helps us to improve the Vzajemne.cz Services and better serve our Users. The cookies will not harm your device or files. We use cookies to tailor the Vzajemne.cz Services and the information we provide in accordance with the individual interests of our Users.

The Users may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. For example, the following links provide information on how to adjust the cookie settings on some popular browsers:

Please note that some parts of the Vzajemne.cz Services may not function properly if use of cookies is refused.

A web beacon is a technology that allows identifying readers of websites and emails e.g. for identifying whether an email has been read.

Web analytics services

The Vzajemne.cz Services use Google Analytics and other web analytics services to compile Analytics Data and reports on visitor usage and to help us improve the Vzajemne.cz Services. For an overview of , please visit Google Analytics. It is possible to opt-out of Google Analytics with the following browser add-on tool:

Advertising and visitor identifiers

The Vzajemne.cz Services use pseudonymized identifiers to track and predict your app and service usage and preferences.

You can opt-out of the use of these identifiers by changing your operating system settings as follows:

Advertising identifiers can be disabled on iOS mobile devices by turning on the Limit Ad Tracking tab (Settings → Privacy → Advertising → Limit Ad Tracking). For an overview and more information on the advertising identifier, please see

Purple P2P visitor identifiers can be disabled on iOS and Android mobile devices by changing your settings (for iOS: Settings → Purple P2P → Purple P2P settings → Limit Tracking, and for Android: Purple P2P application → Profile tab → Settings icon in the top-right corner).

Social Media Fanpages

We have profiles on various social media platforms on which we advertise our products and interact with customers. Since we operate these profiles on third-party platforms, each time you visit these social media channels the operators collect different personal data from you.

Responsibilities We and the respective operators of the social media platforms act as joint controllers. Where two or more controllers jointly determine the purposes and means of processing, they shall be joint controllers.

The social media platforms Facebook and Instagram are operated by Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland.

We are responsible for all interactions on our own platforms. The operators of the social media platforms themselves are data controllers for general interactions and interactions outside our profiles. An exception applies to the data processing described below for the usage analysis (page insights); we are jointly responsible with Facebook for this. The following links will show you exactly which data is collected by the respective social media operators:

PURPOSES AND LEGITIMATE GROUNDS FOR THE PROCESSING OF YOUR PERSONAL DATA

Purposes

There are several purposes of the processing of your personal data by Purple P2P:

To provide the Vzajemne.cz Services and carry out our contractual obligations (legal ground: performance of a contract and legitimate interest)

Purple P2P processes your personal data to be able to offer the Vzajemne.cz Services to you under the contract between you and Purple P2P

We use the data for example

to handle your payments or any refunds (where applicable) and to provide our partners (the Vendors and our courier partners) with the information necessary for the preparation or delivery of your order. If you contact our customer service, we will use the information provided by you to answer your questions or help otherwise
to enable the offer of services and the identification of food or goods that the seller offers through the Vzajemne.cz Services
to offer a courier service related to the customer’s order

For our legal obligations (legal ground: compliance with a legal obligation)

Purple P2P processes data to enable us to administer and fulfil our obligations under law. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities such as tax authorities.

For claims handling and legal processes (legal ground: legitimate interest)

Purple P2P may process personal data in relation to claims handling, debt collection and legal processes. We may also process data for the prevention of fraud, misuse of our services and for data, system and network security.

For customer communication and marketing (legal ground: legitimate interest)

Purple P2P processes your personal data to contact you regarding the Vzajemne.cz Services and to inform you of changes relating to them. Your personal data are also used for the purposes of marketing the Vzajemne.cz Services and Vendor’s offers.

For quality improvement and trend analysis (legal ground: legitimate interest)

We may also process information about your use of the Vzajemne.cz Services to improve the quality of the Vzajemne.cz Services e.g. by analyzing any trends in the use of the Vzajemne.cz Services. In order to ensure that our services are in line with your needs, personal data can be used for things like customer satisfaction surveys. When possible, we will do this using only aggregated, non-personally identifiable data.

Legal grounds for processing

Purple P2P processes your personal data to perform our contractual obligations towards you and to comply with legal obligations. Furthermore, we process your personal data to pursue our legitimate interest to run, maintain and develop our business and to create and maintain customer relationships. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and e.g. provide you with easy to use opt-out from our marketing communications and use pseudonymized or non-personally identifiable data when possible.

In some parts of the Vzajemne.cz Services, you may be requested to grant your consent for the processing of personal data. In this event, you may withdraw your consent at any time.

TRANSFER TO COUNTRIES OUTSIDE EUROPE

Purple P2P stores your personal data primarily within the European Economic Area. However, we have service providers and operations in several geographical locations. As such, we and our service providers may transfer your personal data to, or access it in, jurisdictions outside the European Economic Area or the User’s domicile.

We will take steps to ensure that the Users’ personal data receives an adequate level of protection in the jurisdictions in which they are processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers based on the or through other appropriate safeguards, such as the

More information regarding the transfers of personal data may be obtained by contacting us on any of the addresses indicated above.

RECIPIENTS

We only share your personal data if and as far as reasonably necessary for the purposes of this Privacy policy.

We do not share your personal data with third parties unless one of the following circumstances applies:

For the purposes set out in this Privacy policy and to authorized service providers

To the extent that third parties (such as the Vendors which prepare your order, our courier partners who deliver your order and Customer ordering your services) need access to personal data in order for us to perform the Vzajemne.cz Services, we provide such third parties with your data. Furthermore, we may provide your personal data to our affiliates or to authorized service providers who perform services for us (including data storage, accounting, legal assistance, sales and marketing) to process it for us and to payment service providers to process your payments to us.

When data is processed by third parties on behalf of Purple P2P, Purple P2P has taken the appropriate contractual and organizational measures to ensure that your data are processed exclusively for the purposes specified in this Privacy policy and in accordance with all applicable laws and regulations and subject to our instructions and appropriate obligations of confidentiality and security measures.

Please bear in mind that if you provide personal data directly to a third party, such as through a link in the Vzajemne.cz Services or within separate communication with counterparty, the processing is typically based on their policies and standards.

For legal reasons and legal processes

We may share your personal data with third parties outside Purple P2P if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, crime, security or technical issues; and/or (iii) protect the interests, properties or safety of Purple P2P, the Users or the public as far as in accordance with the law. When possible, we will inform you about such processing.

For other legitimate reasons

If Purple P2P is involved in a merger, acquisition or asset sale, we may transfer your personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all the Users concerned when the personal data are transferred or become subject to a different Privacy policy.

With your explicit consent

We may share your personal data with third parties when we have your explicit consent to do so. You have the right to withdraw this consent at all times free of charge by contacting us.

STORAGE PERIOD

Purple P2P does not store your personal data longer than is legally permitted and necessary for the purposes of providing the Vzajemne.cz Services or the relevant parts thereof. The storage period depends on the nature of the information and on the purposes of processing. The maximum period may therefore vary per use.

Personal data relating to a User’s user account with the Vzajemne.cz Services will be processed accordingly to its purpose even after the User has deleted its user account with the Vzajemne.cz Services. It is allowed to processed only personal data relating to a User’s user account with the Vzajemne.cz Services only as long as such processing is required by law or is reasonably necessary for our legal obligations or legitimate interests such as claims handling, bookkeeping, internal reporting and reconciliation purposes etc.. All personal data relating to a User’s user account with the Vzajemne.cz Services will be deleted within a period of 10 years after the User has deleted its user account with the Vzajemne.cz Services, with the exception of personal data required in certain rare situations such as legal proceedings.

We will store Analytics Data of Users that do not have an account with the Vzajemne.cz Services for a period of 90 days.

YOUR RIGHTS
Right of access

You have the right to access and be informed about your personal data processed by us. We give you the possibility to view certain data through your user account with the Vzajemne.cz Services or request a copy of your personal data.

Right to withdraw consent

In case the processing is based on a consent granted by the User, the User may withdraw the consent at any time free of charge. Withdrawing a consent may lead to fewer possibilities to use the Vzajemne.cz Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to rectify

You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us. You can correct or update some of your personal data through your user account in the Vzajemne.cz Services.

Right to erasure

You may also ask us to delete your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.

Right to object

You may have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of the Vzajemne.cz Services or for compliance with a legal obligation. If you object to the further processing of your personal data, this may lead to fewer possibilities to use the Vzajemne.cz Services.

Right to restriction of processing

You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use the Vzajemne.cz Services.

Right to data portability

You have the right to receive the personal data you have provided to us yourself in a structured and commonly used format and to independently transmit those data to a third party.

How to use your rights

The abovementioned rights may be used by sending a letter or an e-mail to us on the addresses set out above, including the following information: the full name, address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm the identity of the User. We may reject or charge requests that are unreasonably repetitive, excessive or manifestly unfounded.

DIRECT MARKETING

The User has the right to prohibit us from using the User’s personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the functionalities of the Vzajemne.cz Services or the unsubscribe possibility offered in connection with any direct marketing messages.

LODGING A COMPLAINT

In case the User considers our processing of personal data to be inconsistent with the applicable data protection laws, the User may lodge a complaint with the local supervisory authority for data protection in Czech Republic, the officer for personal data protection. Alternatively, the User may lodge a complaint with the local supervisory authority for data protection of the User’s country of domicile.

INFORMATION SECURITY

We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, pseudonymization, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability to restore the data. We regularly test the Vzajemne.cz Services, systems, and other assets for security vulnerabilities.

Should despite of the security measures, a security breach occur that is likely to have negative effects to the privacy of the Users, we will inform the relevant Users and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.