Information for SUPPLIERS in accordance with Articles 13 and 14 of the GDPR Regulation
In accordance with Articles 13 and 14 of the GDPR Regulation and on the basis of the relevant provisions of the Privacy Policy (https://www.jazykovka.cz/Ochrana‑soukromi/), ASPENA Language School s.r.o., ID: 255 94 877, with its registered office at Brno, Veveří, Gorkého 64/15, Postcode 602 00, registered in the Business Register under File No. C 36646 kept by the Regional Court in Brno, as a personal data controller (hereinafter the “Company”), informs the suppliers who offer or provide their goods or services to the Company (hereinafter referred to as the “Supplier”) about the processing of personal data:
1. Name and contact information of the Company
ASPENA Language School s.r.o., ID: 255 94 877, with its registered office at Brno, Veveří, Gorkého 64/15, Postcode 602 00, e‑mail: gdpr@aspena.cz.
2. Personal Data Protection Officer
The Company is not obligated to have a Personal Data Protection Officer.
3. Purposes and legal grounds for the processing of personal data
• The Company obtains personal data from the Supplier via e‑mail or the form on the Company’s website.
• The Company processes the obtained personal data of the Client automatically as well as manually.
• A Supplier whose personal data is processed by the Company in accordance with the GDPR Regulation may be a natural person who:
a) offers or provides teaching services to the Company (hereinafter the “Contractor”),
b) another person doing business (hereinafter “Other Supplier”), or
c) a natural person authorised to act on behalf of the legal entity of the Supplier ad a) or ad b), (hereinafter the “Other Supplier”).
3.1 Contractor ‑ Purposes and legal grounds for the processing
The Company processes the personal data of the Contractor in accordance with the GDPR Regulation for the following purposes, proceeding on the basis and within the scope of the following legal titles for the processing of personal data:
• performance of a contract to which the Supplier is a contracting party ‑ in particular identifying and contacting the Supplier, conditions of performance of the contract, information necessary to change the content of the contract, rights and obligations within the liability for defects (legal title in accordance with Article 6, par. 1, point b) of the GDPR Regulation),
• fulfilment of legal obligations applicable to the Company, who is an accounting and taxable entity and, for this reason, retains accounting and other documents that may contain the personal data of the Contractor; and also the fulfilment of legal obligations of the Company within the liability for defects (Article 6, point c) of the GDPR Regulation),
• fulfilment of the legitimate interests of the Company ‑ in particular the judicial or extrajudicial recovery of receivables from the Contractor, sending newsletters to the Contractor, evaluation of the services provided by the Contractor, subsequent order of services from the Contractor (Article 6, point f) of the GDPR Regulation).
3.2 Other Supplier ‑ Purposes and legal grounds for the processing
The Company processes the personal data of the Other Supplier in accordance with the GDPR Regulation for the following purposes, proceeding on the basis and within the scope of the following legal titles for the processing of personal data:
• performance of a contract to which the Other Supplier is a contracting party ‑ in particular identifying and contacting the Other Supplier, conditions of performance of the contract, information necessary to change the content of the contract, rights and obligations within the liability for defects (legal title in accordance with Article 6, par. 1, point b) of the GDPR Regulation),
• fulfilment of legal obligations applicable to the Company, who is an accounting and taxable entity and, for this reason, retains accounting and other documents that may contain the personal data of the Other Supplier (Article 6, point c) of the GDPR Regulation),
• fulfilment of the legitimate interests of the Company ‑ in particular the judicial or extrajudicial recovery of receivables from the Other Supplier, evaluation of the services provided by the Other Supplier, subsequent order of services from the Other Supplier (Article 6, point f) of the GDPR Regulation).
4. Legitimate interests of the Company
The Company applies in particular the following legitimate interests in the processing of personal data:
• education ‑ sending newsletters to the Contractor for the purpose of their awareness and improving qualification,
• recovery of receivables ‑ the judicial or extrajudicial recovery of any receivables from the Supplier,
• evaluation of the services provided by the Supplier ‑ appropriate setting of Supplier priority, evaluation of the Supplier in order to protect the Company's assets,
• subsequent order of services from the Supplier.
5. Recipients of personal data
The Company reserves the right to make the personal data of the Supplier available to the employees of the Company, if it is necessary for the performance of their duties, and also to processors with whom the Company has a contract for the processing of personal data (e.g. for accounting, IT, and marketing services), and any other persons and institutions in accordance with the legal regulations, in particular to state authorities and other public administration bodies on the basis of the legal obligation to provide personal data.
6. Transfer of personal data to a third country or international organisation
The company does not intend to transfer personal data to a third country outside the EU or to an international organisation.
7. Period for retaining personal data
The Company shall retain the personal data of the Supplier for the duration of the contract with the Supplier, or for a period of 10 years from entering the personal data of the Supplier into the IS of the Company. After the termination of the contract with the Supplier, the personal data of the Supplier will be retained to fulfil the legal obligations under the applicable laws (in particular regarding accounting and taxation) and, at the same time, for 10 years from the termination of the contract for the purpose of pursuing the above legitimate interests of the Company.
8. Rights of the Supplier to their personal data being processed
The Supplier may exercise the following rights with the Company in relation to their personal data by e‑mail at gdpr@aspena.cz:
• right to access personal data,
• right to rectification,
• right to erasure,
• right to restrict processing for a certain period of time,
• right to portability,
• right to object to the processing due to a legitimate interest.
9. Right to withdraw consent
If the processing of personal data is based on consent, the Supplier has the right to withdraw this consent at any time by e‑mail at gdpr@aspena.cz.
10. Right to file a complaint
The Supplier has the right to file a complaint with the Office for Personal Data Protection if the Supplier believes that the processing of their personal data has violated the GDPR Regulation.
11. Legal/contractual requirement to provide personal data
The provision of personal data by the Supplier is primarily a contractual requirement. The non‑provision of personal data by the Supplier will result in the non‑conclusion of the contract.
12. Automated decision making, including profiling
The personal data of the Supplier is not the subject of automated decision making or profiling.