Principles of Processing Personal Data

O2 Czech Republic a.s. prepared this guide regarding personal customer data processing and protection for your information. We begin with a summary of the main topics of the Privacy Policy, which you’ll find in more detail later in the guide. 1. Beginning of the Contractual Relationship
2. Subscriber Database
3. Traffic and Location Data
4. How Do We Work with the Data?
5. Telephone Directories and Information Lines
6. SOLUS Association
7. Data Processing for Marketing Purposes and Sending Commercial Communications
8. How Long Will We Retain Your Data?
9. How Can You Revoke Your Consent?
10. When You Are Speaking to Us
11. How Can You Access Your Personal Data?

1. Beginning of the Contractual Relationship

We must obtain your personal details in order to initiate and perform a contractual relationship with you. Therefore, it is important that you provide us with complete, correct and truthful personal data.

We reserve the right to verify the personal data and ask you for proof of their correctness. Correctness will be checked at the point of contract conclusion by a third party authorized by us and bound by secrecy (a specialized courier, a trained employee of a postal license holder). In this way we protect not only our company, but also our customers. Verification and proof of personal data reduces the risk of an unauthorized person ordering services using someone else’s personal data.

The scope of data required may differ due to the nature of the individual service(s) requested. For example, for services provided via a fixed network we need to have the exact address of the line (service) location, whereas this is irrelevant for mobile services.

For a list of what personal data is required to be submitted with the application for service, please refer to the Service Specifications – our contract (CZ only) for mobile voice services.

Should you wish to use O2 services and prefer not to provide or verify any personal data, you can still get our prepaid mobile network services at great rates. You can recharge the credit at your discretion and control your own expenses. For prepaid services we do not require a credit history and will not check your details in the SOLUS register (see Item 6), or in our internal records of tariff customers.

If a contractual relationship is concluded, you can specify whether and in which way you wish to be informed about our current service offers, whether you wish to be listed in a telephone directory and moreover – if you are listed in the telephone directorywhether other companies may call you with marketing offers. Your choices are recorded in the Service Specification. You may change the contact options at any time by e-mail, letter or specific forms. Unless you opt otherwise, the applicable terms will be those specified in the General Terms and Conditions. (CZ only)

2. Subscriber Database

By law we are bound to keep a database of our customers (in legislation, referred to as subscribers).

Personal and identification data are:

  • Academic title
  • Name and surname
  • Address of permanent residence and billing address (where you wish to have the bill sent)
  • Birth Certificate No., if no Birth Certificate No. has been allocated for any reason, then the date of birth
  • Trading name of the company, registered office, place of business, Company Registration No.
  • Number of submitted documents
  • Telephone numbers and e-mail contact
  • Banking details

3. Traffic and Location Data

In the course of providing services our networks process data connected with the actual provision of services. Without these it would not be possible to render services (the network would not know where to connect the call), or it would not be feasible to properly bill you, or possibly to deduct a credit correctly.

This information is called traffic and location data. They are not included in the subscriber database, and the legislation imposes on providers the duty to erase them as soon as they are not necessary for the rendering of the service, its billing, dealing with a complaint or payment collection.

The traffic data necessary for billing includes:

  • Number of the caller
  • Number of the party called
  • Date and time of the connection
  • Duration of the connection
  • Type of service provided
  • Volume of data used during a data connection
  • For certain content services (e.g. O2 TV video library), including information about which titles were ordered

The location data are: Data processed in the electronic communication networks which specify the geographical location of your end device (in particular the number, name and place of the network’s point of termination etc.).

We consider it important to draw your attention to the fact that legislation imposes on all providers not only that they retain the traffic data for their own purposes, but also retain traffic and location data for the purposes of criminal proceedings and other purposes defined by law. The extent of these data is stipulated in Decree No. 357/2012 Coll.

We would like to assure you that we try to protect all of your personal details as much as possible and we handle the acquired information only in compliance with the relevant legal regulations, particularly Act No. 127/2005 Coll. and Act No. 101/2000 Coll., on Personal Data Protection.

4. How Do We Work with the Data?

By deciding to use our services you simultaneously agree with us being able to do the following with respect to your data:

  • Process them manually and automatically, either through our own means or via authorized parties
  • Collect them
  • Process them in accordance with the Personal Data Protection Act
  • Use them for purposes:
  •      - Arising from relevant legal regulations
         - Of network security and protection
         - Of rendering services and payment transactions including the related operational activities
         - Of billing for the services and services of third parties
         - Of carrying out activities connected with the above, at the scope necessary to accomplish the hereinbefore specified purposes and for the period necessary to accomplish the said purposes, however for no longer than the period of the contract validity or until the complete settlement of the rights and obligations arising from the contract or for the period prescribed by the relevant legal regulations.

      Our company reserves the right to co-operate with specialists in certain fields (e.g. for the purposes of debt collection, IT administration, contracted call centers), who as our sub-contractors will also process your personal data for our company. We carefully choose these companies and enter into an agreement on personal data processing with each of them in accordance with law.

      Network operators and electronic communication service providers may supply one another with the acquired data and information connected with the rendering of services, in particular for the purpose of us being able to:

      • ensure interconnection and access to networks of other operators
      • handle the mutual billings within the framework of other networks
      • prevent the misuse of networks and electronic communication services

      5. Telephone Directories and Information Lines

      We protect your personal data to the maximum degree and we do not disclose them.

      If you wish to be listed in a telephone directory, allowing other subscribers to find contact details for you, we will pass on these data to telephone directory publishers and information line operators who provide such services. Subsequently, your contact details will become publicly accessible. In this instance, telephone directory publishers and line operators will assume full responsibility for the correct handling of your data and for keeping their commercial telephone directories and information lines updated.

      The following essential data are provided in electronic or printed form, or possibly via an information service:

      • Name and surname
      • Address
      • Telephone number
      • Possibly the trading name of the company, its registered office or place of business
      • Electronic mail address
      • Other agreed data and information, for example relating to not wanting to be contacted for marketing purposes

      6. SOLUS Association

      Prevention and protection. Nowadays many people sign various credit, leasing and similar agreements at such a quantity and volume that they are subsequently unable to keep repaying their debts. Similarly, also with respect to telecommunication services certain people find themselves in a situation when they are not capable of paying for the ordered and provided services. The following collection processes burden the company and subsequently reflect unfavorably not only in the prices for the majority of customers who duly pay their bills, but also in the life situation of those customers who cannot honor their debts (“debt spiral”).

      O2 Czech Republic a.s. together with other renowned companies operating in the banking and non-banking sectors, is a member of the SOLUS Association.

      Before concluding a contract with you, on the basis of your consent we will check the register kept by the SOLUS Association to determine whether you have a derogatory payment history with any of the association members. You can refuse this check; however, we reserve the right to ask you for a financial deposit to cover potential debts.

      O2 will enter data in the SOLUS register only if you are considerably overdue (longer than 30 days and/or, at least two invoices) in settling your liabilities due to our company. Rendering of services provided on the basis of post-paid (tariff) billing is conditioned by the consent to such an entry of the data. For pre-paid services, procedures are different. Since in this case you can easily keep a check of your expenses and you cannot be overdue, data are not entered in the SOLUS register and moreover the rendering of these services is not subject to your consent concerning the SOLUS register.

      Upon signing the contract you provide us with consent to the provision of your data, specifically with the validity as from the effective date of the contract and further for the period of three years from the payment date of the last financial liability.

      A list of SOLUS Association members can be found at www.solus.cz.

      7. Data Processing for Marketing Purposes and Sending Commercial Communications

      We consider commercial communications to be a suitable tool for informing you about new services or special offers from O2, or possibly in cooperation with our contractual partners.

      In order to be able to prepare relevant offers that may be of interest to you, we need to process your data. In regards to targeted offers you will receive only information that we believe you may find interesting. We do not intend to send offers that you would find irrelevant.

      If, subject to our General Terms and Conditions, you gave us your consent to process your personal data for marketing purposes and commercial communications, we will review the nature of your use of services. That is to say, which services you use (e.g. calling, SMS, MMS, internet etc.), at what volume and structure (e.g. number of minutes, SMS etc. into individual networks), and during which periods (weekdays, weekends, peak, off-peak).

      We may inform you about offers of O2 services or services of other contractual partners by telephone, in bill enclosures, on website banners, and by way of commercial communications sent via SMS, e-mail or MMS.

      We believe that in this way we can offer you better services and special deals.

      Nevertheless, you have the right to opt-out of commercial communications being sent to you or from being contacted via telephone. If your number is listed in the telephone directory, you can get your telephone number listed in the public telephone directory with a note stating that you do not wish to be contacted for marketing purposes by telephone.

      If you do not want to be sent commercial communications from O2, or be contacted by us by telephone, call us at 800 02 02 02 and we will stop these communications.

      8. How Long Will We Retain Your Data?

      Your personal data are safely stored with us for the entire contract duration, until all the liabilities have been settled, or possibly until the time when debts can be recovered or appealed. You can check at any time in which form the data exist, specifically in accordance with Sections 11 and 12 of the Act on Personal Data Protection.

      After the settlement of the rights and obligations from the contract we can process your name, surname, address and the stipulated contact details for the purposes of offering business offers and services.

      Traffic data for the purposes of billing and handling complaints are retained for the period in which it is possible to make a complaint about the billing and deal with the complaint. The provisions of Section 64 of Act No. 127/2005 Coll. set the period for making a complaint at a duration of 2 months and specify a period of 1 month for dealing with the complaint. If an objection is raised to the handling of the complaint with the Czech Telecommunication Office or the bill has not been settled, in accordance with law it is necessary to continue processing traffic data until the full settlement of the matters under dispute.

      Traffic and location data for bodies involved in criminal proceedings and for other purposes prescribed by law are retained for a period of 6 months in accordance with Section 97 of Act No. 127/2005 Coll. and Decree No. 357/2012 Coll.

      9. How Can You Revoke Your Consent?

      You can also revoke your consent to the processing of your data for marketing purposes as well as your consent to being listed in the telephone directory (Articles. 6.4 and 6.6 of the General Terms and Conditions) at any time after proving your identity, namely with:

      • An explicit,
      • Clear,
      • And definite manifestation of your will, for example by way of:
      •      - A registered letter
             - An e-mail from the address, which is shown in our records as a contact e-mail address
             - A telephone call to a customer line

      Moreover:

      • When using value-added services you may temporarily refuse the processing of location data for each network connection or transfer of message
      • You may also revoke your consent to the use of electronic contact in connection with sending individual messages

      Similarly, you may revoke your consent to being sent commercial communications (Article. 6.7. of the General Terms and Conditions).

      Other types of processing are included in the terms and conditions for provision of our services.

      10. When You Are Speaking to Us

      Because you can conduct a variety of services via O2 customer care, we need to be able to record our conversation.

      The recording can provide a means of proof, if necessary. Then such a recording is filed similarly as a contract, because together with other source materials it represents proof of the contractual relationship having been concluded.

      We also need call recordings to help us improve the quality of our services. We want to know how our operators speak to our customers; if the telephone conversation progressed in a standard way and if relevant information was given and provided in the correct manner. This type of recording is kept for the period of at least 3 months.

      Without the ability to monitor our customer care lines we would not be able to maintain and improve the level of our services. For this reason, we inform you at the beginning of each telephone conversation whether the call is subject to recording.

      11. How Can You Access Your Personal Data?

      When concluding the contract, whether at a retail outlet, outside of a retail outlet or by means of remote communication tools, we will send you a copy of our contractual form - Service Specification. Keep this document safe. It is for your own needs.

      If a problem arises and the contract is the subject of a review by any state body whatsoever, at the call of such a state body we will submit a copy, or possibly the original. However, without good reason we usually do not print or send additional copies in any form.

      In accordance with Sections 11 and 12 of the Act on Personal Data Protection each person is entitled to access his/her personal data and information.

      Therefore, you may inquire with us about what personal data we have on record for you. As with any other entity, we are obliged to keep current and truthful information. However, we cannot manage this without your cooperation. We wish to ask you to comply with your obligation and inform us if there is a change in your personal data (most often a change in surname, address of permanent residence, billing address etc.), please notify us about these changes with the appropriate proof.

      Should you suspect that a breach of the obligations specified in the legislation has occurred, you may contact us requesting:

      • To have the matter explained
      • That we rectify the improper situation by correcting, adding or erasing the data

      We will erase or correct the data within an appropriate period of time, which corresponds to the technical and administrative possibilities of O2.

      If our course of action is not sufficient in your opinion, you may contact the Office for Personal Data Protection (www.uoou.cz) requesting a remedial measure.

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