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Privacy Policy

How we treat your personal data

Who are you?

We are a commercial company called Braiins Systems s.r.o., with its registered office at Křižíkova 148/34, Karlín, Prague 8, Czech Republic, Id. No. 241 47 931, registered in the commercial register kept by the Municipal Court in Prague under file No. C 183056.

We are the company responsible for operation and development of many projects including following:

Braiins Pool

Virtual currency mining pool currently operated by Braiins Mining Limited, incorporated and existing under the laws of the British Virgin Islands, Company No. 2038702, with a registered office at Road Town, Tortola, British Virgin Islands.

Braiins OS

Open source operating system for virtual currency mining devices that is available to public free-of-charge under the GNU General Public License version 3.

Braiins OS+

Proprietary operating system for virtual currency mining devices that is available to public under a proprietary license and is subject to license fees.

Farm Proxy

Proprietary software tool for hash rate (processing power) aggregation and management of large virtual currency mining operations that is available to public under a proprietary license and is not a subject to license fees.

Stratum V2

Next generation protocol for pool mining used by many virtual currency mining pools.

Events

We organize various events, such as workshops, exhibitions, conferences (especially the annual Bitcoin Mining Conference held in Prague, Czech Republic), and other social events (the “Events” or individually as the “Event”).

You may find more information about us and about our work on our website https://braiins.com/ and any subdomains thereof (the “Website”). 

Why should I read this document?

You may have heard about Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the ”Regulation”) more commonly known as GDPR. 

Under the Article 13 and 14 of the Regulation, we must provide our customers and other data subjects with information on the collection, handling, protection and processing of their personal data.

Therefore, in this Privacy Policy you may learn more about these topics regarding among others the personal data that we collect when you access and use our Website and any subdomains thereof.

Please, be aware, that this privacy policy applies only to collection, storage and processing of personal data that are not covered by other privacy policy issued for a particular services or product (such as Braiins OS / OS+ Privacy Policy and Braiins Pool Privacy Policy).


What personal data do you process?

Personal data collected via communication

On our Website we provide you with our contact information, so you can contact us, request information about our products and out company or notify us of any issues with the services that you use. 

If you, during the course of our communication, send us any information that may be considered as personal data (such as first and last name, email address, IP address etc.), we will, as a data controller, collect, store and process such personal data.


Corporate bonds

We offer corporate bonds to public investors. When you buy a corporate bonds from us, we will, as a data controller, collect, store and process any related personal data you have provided to us such as your first and last name, date of birth, address, bank account number, source of your funds, your contact information, amount of corporate bonds you have bought etc.


Cookies

On our Website we use a variety of cookies. Some of the cookies may be used to collect personal data of our customers.

For more information, please see the dedicated section of this Privacy Policy and Braiins Cookie Policy (for Website).


Personal data collected when you subscribe to our newsletter (commercial communications) 

On the Website, you may subscribe to our newsletter by entering your email, clicking on the “Get notified” box. If you subscribe to our newsletter, we will regularly inform you about the latest news about our products and services. 

As a data controller, we collect, store and process the email addresses of users who subscribe to our newsletter. 

Personal data collected in Braiins Merch

When we are selling you the products in Braiins Merch, we will, as a data controller, collect, store and process any personal data communicated to us when making the purchase.

Such personal data include, but are not limited to, your first and last name, personal identification number, date of birth, business address, address of residence, email address, tax identification number, phone number, bank account number etc.

Please note, that the provision of such personal data may be a requirement necessary to enter into a purchase and sale contract.

Farm Proxy

To develop and test Farm Proxy we collect, store and process analytical data related to virtual currency mining that may sometimes be considered as personal data within the meaning of the Regulation. 

Sometimes we use our own materials and sources to obtain necessary data and sometimes we use third party analytical data (obtained from public sources such as internet or via telemetry from customers using our services - for example, when you report an issue and initiate a support procedure, we may use the acquired information for further development of Farm Proxy). 

In all above-mentioned cases some of the information that we collect, store and process for development of Farm Proxy may be considered as personal data. In that event, we will, as a data controller collect, store and process such personal data.

When you use Farm Proxy, we may collect and process telemetric data related to your mining activities. 

If such telemetric data are considered as personal data, we will, as a data controller, collect, store and process such personal data. 

Personal data collected when you join the Event

If you are interested in joining some of our Events, you generally need to buy a ticket online, or, given the limited space, you may be asked to contact us to get on the waiting list. In this regard, you may be required to fill in your first and last name, work e-mail address and possibly other specifications about yourself, as well as optional note or comment. Therefore, in connection with the purchase of a ticket and/or in connection with inclusion on the waiting list, you may send us information that may be considered as personal data. It may also happen that you voluntarily provide us with such information during the Event (for example, you provide us with your non-anonymous feedback).

If any of the information which you provide to us in connection with joining the Event is considered as personal data, we will, as a data controller, collect, store, and process such personal data.

Why do you process my personal data?

Personal data collected via communication and when selling products in Braiins Merch and corporate bonds related personal data

We collect, store and process the personal data collected via communication with you for the purpose of providing you with requested products, services, support or any other information, for the purpose of exercising any rights and fulfilling any obligations related thereto as well as for the purpose of any further communication with you.

As for the information provided when selling the products in Braiins Merch, we collect, store and process such information them for the purpose of exercising any rights and fulfilling any obligations related to the contract of purchase and sale.

As for the corporate bonds, we collect, store and process the personal data collected when selling corporate bonds for the purpose of exercising any rights and fulfilling any obligations related thereto as well as for the purpose of any further communication with you. 

To comply with legal requirements, we must mention that we collect, store and process such personal data mainly pursuant to Article 6 (1) (b) of the Regulation (it means that processing is necessary for the performance of a contract to which you are a party or in order to take steps prior to entering into such contract).

We collect the information provided via communication and when selling the products in Braiins Merch and corporate bonds related personal data also for marketing purposes, for example to inform you about our latest products, services and features, and to establish, exercise or defend any related legal claims.

To comply with legal requirements, we must mention that we collect, store and process such personal data pursuant to Article 6 (1)(f) of the Regulation.

That means that it is in our legitimate interest to collect, store and process such personal data for marketing purposes, since it is in our interest to inform our customers about such news and it is reasonable to expect that the customers (and investors) may be interested in such news. Additionally, the customers may at any time opt out from receiving such news.

It is also in our legitimate interest to collect, store and process such personal data to establish, exercise or defend any related legal claims, since otherwise we could not exercise our legal rights and such use of personal data is foreseeable by data subjects and represents little to no restriction of data subject interests, rights and freedoms. 


Personal data collected when you subscribe to our newsletter (commercial communications) 

As we have stated above, we collect, store and process these personal data because you subscribed to our newsletter. So we are processing your email in order to send you the newsletters. 

To comply with legal requirements, we must mention that we collect, store and process such personal data pursuant to Article 6 (1) (a) of the Regulation. 

That means that you have given us a consent to the processing of your personal data for the commercial communications purpose. 

In order to be able to prove that you have given us your consent to sending our newsletter (and processing your personal data for the commercial communications purposes), we may collect and store the information that you have given us this consent (e.g. the logs). 

We collect and store these data pursuant to Article 6 (1) (f) of the Regulation. That means that it is in our legitimate interest to collect, store and process such personal data, since in case you change your mind and you do not want to receive the newsletter anymore, you can unsubscribe any time for free. We will always indicate within the newsletter how to unsubscribe.


We collect, process and store your personal data only for the above defined purposes and only to the extent necessary to fulfill these purposes. We never conceal the purpose for which the personal data is collected and further processed.

Farm Proxy Development

We collect, store and process the above-mentioned analytical data to develop and test Farm Proxy product.

To comply with legal requirements, we must mention that we collect, store and process such personal data pursuant to Article 6 (1)(f) of the Regulation. 

That means that it is in our legitimate interest to collect, store and process such personal data, since there is no other effective way to address issues of our software and hardware if we cannot use the data acquired when providing you with our services and since we also make sure that it represents little to no restriction of data subject interests, rights and freedoms. 

It is also in our legitimate interest to collect, store and process such personal data to establish, exercise or defend any related legal claims, since otherwise we could not exercise our legal rights and such use of personal data is foreseeable by data subjects and represents little to no restriction of data subject interests, rights and freedoms. 

Farm Proxy Use

We collect, store and process your personal data only so we can provide you services pursuant to the respective license agreement and to further develop our products.

We will specifically process your personal data:

  • to fulfil any of our obligations under the respective license agreement and any applicable law and to protect our own rights thereunder;
  • to secure the quality of our services and to use it for other commercial purposes including informing you of products and services related to Braiins;
  • to use it for marketing purposes (research of quality).

To comply with legal requirements, we must mention that we collect, store and process such personal data mainly pursuant to the Article 6 (1) (b) and (f) of the Regulation.

For the legitimate interest explanation please read the section dedicated to the personal data collected via communication, since the similar legitimate interest rules apply.

Personal data collected when you join the Event

As described above, we may collect, store, and process your personal data because you purchased a ticket to join the Event and/or you contacted us to get on the waiting list and/or you voluntarily provided us with such information in any way during its venue.

As regards of purchasing a ticket and/or inclusion on the waiting list, we collect, store, and process the personal data for the purpose of exercising any rights and fulfilling any obligations related thereto as well as for the purpose of any further communication with you.

To comply with legal requirements, we must mention that we collect, store, and process such personal data mainly pursuant to Article 6 (1) (b) of the Regulation (it means that processing is necessary for the performance of a contract to which you are a party or in order to take steps prior to entering into such contract).

During the Event, we may also collect information about you provided via questionnaires, verbally or in other ways in connection with your participation in such an Event, typically by providing such information to a person who represents us as the organizer of the Event (your non-anonymous feedback). Such personal data may be collected to determine your satisfaction with an individual Event and to evaluate your overall impression of your participation in such an Event.

To comply with legal requirements, we must mention that we collect, store and process such personal data pursuant to Article 6 (1)(f) of the Regulation.

That means that it is in our legitimate interest to collect, store and process such personal data, since it is in our interest to make our Events enjoyable for visitors and to constantly improve the quality of the Events organized by us. 

It is also in our legitimate interest to collect, store and process such personal data to establish, exercise or defend any related legal claims, since otherwise we could not exercise our legal rights and such use of personal data is foreseeable by data subjects and represents little to no restriction of data subject interests, rights and freedoms. 


For how long will you process my personal data?

We process and store your personal data only for the time necessary to meet the purposes of its processing specified above, or for the time consented by you, or for the time that is either necessary to comply with  our obligations under the applicable law or set forth by the applicable law or in accordance therewith. We comply with the mandatory rules for data archiving. 

Once the purpose of the personal data processing disappears, we will destroy the personal data.


Personal data collected via communication

As for the personal data voluntarily provided by you when you communicate with us, we will process and store such personal data until the requested issue is solved and also for the subsequent period thereafter that is either necessary to comply with our obligations under the applicable law or set forth by the applicable law or in accordance therewith, or during which you or any third party may contest that we have broken any of our obligations or have violated any applicable laws in relation to the requested issue.


Personal data collected when selling the products in Braiins Merch

As for the personal data voluntarily provided by you when making a purchase products in Braiins Merch, we will process and store such personal data until all the obligations under the contract of purchase and sale have been fulfilled and also for the subsequent period thereafter that is either necessary to comply with our obligations under the applicable law, or set forth by the applicable law or in accordance therewith, or during which you or any third party may contest that we have broken any of our obligations or have violated any applicable laws in relation to the sale of the products.


Personal data related to corporate bonds

As for the personal data related to the corporate bonds we will process and store such personal data until the due date of the bonds and also for the subsequent period thereafter that is either necessary to comply with our obligations under the applicable law, or set forth by the applicable law or in accordance therewith, or during which you or any third party may contest that we have broken any of our obligations or have violated any applicable laws in relation to the corporate bonds.


Personal data collected when you subscribe to our newsletter (commercial communications) 

We will process and store such personal data (your email) until you unsubscribe to our newsletter. You can unsubscribe any time for free. We will indicate how to unsubscribe within the newsletter. 

We will process and store the information that you have given us the consent (e.g. the logs) to send you newsletter for the duration of the consent and also for the subsequent period thereafter that is either necessary to comply with our obligations under the applicable law or set forth by the applicable law or in accordance therewith, or during which you or any third party may contest that we have broken any of our obligations or have violated any applicable laws in relation to the commercial communications sent to you.


Personal data collected when you join the Event

As for the personal data provided by you in connection with the fact that you have purchased a ticket or contacted us with a request to be included on the waiting list, we will process and store such personal data until the end of the Event and also for the subsequent period thereafter that is either necessary to comply with our obligations under the applicable law or set forth by the applicable law or in accordance therewith, or during which you or any third party may contest that we have broken any of our obligations or have violated any applicable laws in relation to the requested issue.

As for the personal data voluntarily provided by you during the Event along with your non-anonymous feedback, we will process and store such personal data for the time necessary to process the feedback, and also for the subsequent period thereafter until the feedback is converted into an anonymized form. 

Who will have access to my personal data?

We take care of your personal data security and so we choose the partners to whom we entrust your personal data very carefully.

All our partners must be able to provide sufficient security of your personal data to prevent unauthorized or accidental access thereto or other abuse thereof and all our partners must undertake a confidentiality obligation and must not use your personal data for any purpose other than the purpose for which the data were made available to them.

The recipients that may have access to your personal data are following:

  • persons who provide us with the technological services or technology operators that we use to provide our services;
  • persons who provide our services and websites with security and integrity and who regularly test such security and integrity;
  • providers of accounting, legal and administrative services;
  • our staff.

Our aim is and always will be to ensure your personal data are as anonymous as possible and unavailable to all third parties. However, under certain specifically defined conditions we will be under some circumstances required, in accordance with the applicable law, to transfer certain personal data to public authorities.


Do you transfer the personal data outside the EU/EEA?

When collecting, storing and processing personal data we sometimes may use personal data processors such as Google, which under some circumstances transmit your personal data to third countries. In such an event we always make sure such transmission is compliant with the Regulation. 

In particular, we specify that the personal data may be transmitted to the United States of America and in such event the transmission is compliant with the Standard Contractual Clauses (SCCs) mechanism.


How are my personal data protected?

All your personal data is secured by standard procedures and technologies. We provide data protection against unauthorized or accidental access, alteration, destruction, loss, unauthorized transmission or any other unauthorized processing, as well as against any other abuse of records containing the personal data. 

The standard procedures and technologies may include, but are not limited to, the following:

  • education and training of relevant staff to ensure they are aware of our privacy obligations when handling personal data;
  • administrative and technical rules to restrict access to personal data on a ‘need to know’ basis;
  • technological security measures, including firewalls, encryption and anti-virus software;
  • keeping the most sensitive personal data offline;
  • physical security measures, such as staff security passes to access our premises.

We are not able to guarantee the security of your personal data without your help and responsible behavior. Therefore, we ask you to help us ensure the security of your data by keeping in secret and secure your user account login information by following a common security standards.


Do you use cookies?

On our Website we use cookies to analyze traffic and to personalize content and ads. 

We will, as a data controller, collect, store and process any information that are considered as personal data collected by such cookies (the personal data may include your IP address, information about your activity on our Website, information about your advertisement preferences etc.).

To comply with legal requirements, we must mention that we collect, store and process such personal data mainly pursuant to the Article 6 (1) (f) of the Regulation. 

That means that it is in our legitimate interest to collect, store and process such personal data for marketing purposes and for Website traffic analysis, since 

  • it allows us to improve our products and services and to provide you with personalized content and advertisement, 
  • some cookies also allow us to keep our website secure from various attacks and some cookies allow our website to properly function,
  • we do not attempt to identify you using such personal data,
  • there is little to no restriction of your interests, rights and freedoms, and
  • you may at any time delete stored cookies permanently and change your cookie settings to disable or limit storage of any new cookies.

We will process and store such personal data for the period necessary to analyze traffic and to provide any personalized content to you and also for the subsequent period thereafter that is either necessary to comply with our obligations under the applicable law, or set forth by the applicable law or in accordance therewith.

Please, read our Braiins Cookie Policy (for Braiins Website) available on our websites to learn more about the cookies that we use.


What are my rights in relation to personal data protection?

In relation to the personal data you shall have in particular the following rights:

  • a right to withdraw your consent at any time;
  • a right to correct or make additions to the personal data;
  • a right to request restrictions to processing of your personal data ;
  • a right to object or complain against processing of your personal data under certain circumstances;
  • a right to request transfer of your personal data ;
  • a right to access your personal data;
  • a right to be informed of the personal data security breach under certain circumstances;
  • a right to request deletion of your personal data (a right to be „forgotten“) under certain circumstances; and
  • other rights set forth in Act No. 110/2019 Coll., on personal data processing (Personal Data Protection Act) and the Regulation.

You have a right to object, on grounds relating to your particular situation, at any time to processing your personal data which is based on Article 6(1)(f) of Regulation (it means that we have legitimate interest to process such personal data). You have also a right to object to processing your personal data for direct marketing purposes.

Additionally, you have a right to contact the Office for Personal Data Protection with a request for remedial measures in case of any violation of the obligations set forth in the Regulation at the following address: Office for Personal Data Protection, Pplk. Sochorova 27, 170 00 Prague 7, Czech Republic, phone number +420 234 665 111 (central telephone exchange).


How can I contact you?

If you have any questions regarding this Privacy Policy, please do not hesitate to contact us using the contact details below:

Contract address: Křižíkova 148/34, Karlín, Prague 8, Czech Republic

Contact point (support): https://braiins.com/

Email address: info@braiins.com


When is this Privacy Policy effective? 

This Privacy Policy comes into effect on the 1st January 2020. 

We reserve the right to amend and update this Privacy Policy at any time.

The Privacy Policy was last updated on the date below.

 

In Prague on 1st November 2022
Braiins Systems s.r.o.


Who are you?

We are a commercial company called Braiins Systems s.r.o., with its registered office at Křižíkova 148/34, Karlín, Prague 8, Czech Republic, Id. No. 241 47 931, registered in the commercial register kept by the Municipal Court in Prague under file No. C 183056.

We are the company responsible for operation and development of many projects including following:

Braiins Pool

Virtual currency mining pool currently operated by Braiins Mining Limited, incorporated and existing under the laws of the British Virgin Islands, Company No. 2038702, with a registered office at Road Town, Tortola, British Virgin Islands.

Braiins OS

Open source operating system for virtual currency mining devices that is available to public free-of-charge under the GNU General Public License version 3.

Braiins OS+

Proprietary operating system for virtual currency mining devices that is available to public under a proprietary license and is subject to license fees.

Stratum V2

Next generation protocol for pool mining used by many virtual currency mining pools.

You may find more information about us and about our work on our website https://braiins.com/ and any subdomains thereof (the “Website”). 


Why should I read this document?

You may have heard about Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the ”Regulation”) more commonly known as GDPR. 

Under the Article 13 and 14 of the Regulation, we must provide our customers and other data subjects with information on the collection, handling, protection and processing of their personal data.

Therefore, in this Privacy Policy you may learn more about these topics regarding among others the personal data that we collect when you access and use our Website and any subdomains thereof.

Please, be aware, that this privacy policy applies only to collection, storage and processing of personal data that are not covered by other privacy policy issued for a particular services or product (such as Braiins OS / OS+ Privacy Policy and Braiins Pool Privacy Policy).


What personal data do you process?

Personal data collected via communication

On our Website we provide you with our contact information, so you can contact us, request information about our products and out company or notify us of any issues with the services that you use. 

If you, during the course of our communication, send us any information that may be considered as personal data (such as first and last name, email address, IP address etc.), we will, as a data controller, collect, store and process such personal data.


Corporate bonds

We offer corporate bonds to public investors. When you buy a corporate bonds from us, we will, as a data controller, collect, store and process any related personal data you have provided to us such as your first and last name, date of birth, address, bank account number, source of your funds, your contact information, amount of corporate bonds you have bought etc.


Cookies

On our Website we use a variety of cookies. Some of the cookies may be used to collect personal data of our customers.

For more information, please see the dedicated section of this Privacy Policy and Braiins Cookie Policy (for Website).


Personal data collected when you subscribe to our newsletter (commercial communications) 

On the Website, you may subscribe to our newsletter by entering your email, clicking on the “Get notified” box. If you subscribe to our newsletter, we will regularly inform you about the latest news about our products and services. 

As a data controller, we collect, store and process the email addresses of users who subscribe to our newsletter. 

Personal data collected in Braiins Merch

When we are selling you the products in Braiins Merch, we will, as a data controller, collect, store and process any personal data communicated to us when making the purchase.

Such personal data include, but are not limited to, your first and last name, personal identification number, date of birth, business address, address of residence, email address, tax identification number, phone number, bank account number etc.

Please note, that the provision of such personal data may be a requirement necessary to enter into a purchase and sale contract.

Why do you process my personal data?

Personal data collected via communication and when selling products in Braiins Merch and corporate bonds related personal data

We collect, store and process the personal data collected via communication with you for the purpose of providing you with requested products, services, support or any other information, for the purpose of exercising any rights and fulfilling any obligations related thereto as well as for the purpose of any further communication with you.

As for the information provided when selling the products in Braiins Merch, we collect, store and process such information them for the purpose of exercising any rights and fulfilling any obligations related to the contract of purchase and sale.

As for the corporate bonds, we collect, store and process the personal data collected when selling corporate bonds for the purpose of exercising any rights and fulfilling any obligations related thereto as well as for the purpose of any further communication with you. 

To comply with legal requirements, we must mention that we collect, store and process such personal data mainly pursuant to Article 6 (1) (b) of the Regulation (it means that processing is necessary for the performance of a contract to which you are a party or in order to take steps prior to entering into such contract).

We collect the information provided via communication and when selling the products in Braiins Merch and corporate bonds related personal data also for marketing purposes, for example to inform you about our latest products, services and features, and to establish, exercise or defend any related legal claims.

To comply with legal requirements, we must mention that we collect, store and process such personal data pursuant to Article 6 (1)(f) of the Regulation.

That means that it is in our legitimate interest to collect, store and process such personal data for marketing purposes, since it is in our interest to inform our customers about such news and it is reasonable to expect that the customers (and investors) may be interested in such news. Additionally, the customers may at any time opt out from receiving such news.

It is also in our legitimate interest to collect, store and process such personal data to establish, exercise or defend any related legal claims, since otherwise we could not exercise our legal rights and such use of personal data is foreseeable by data subjects and represents little to no restriction of data subject interests, rights and freedoms. 


Personal data collected when you subscribe to our newsletter (commercial communications) 

As we have stated above, we collect, store and process these personal data because you subscribed to our newsletter. So we are processing your email in order to send you the newsletters. 

To comply with legal requirements, we must mention that we collect, store and process such personal data pursuant to Article 6 (1) (a) of the Regulation. 

That means that you have given us a consent to the processing of your personal data for the commercial communications purpose. 

In order to be able to prove that you have given us your consent to sending our newsletter (and processing your personal data for the commercial communications purposes), we may collect and store the information that you have given us this consent (e.g. the logs). 

We collect and store these data pursuant to Article 6 (1) (f) of the Regulation. That means that it is in our legitimate interest to collect, store and process such personal data, since in case you change your mind and you do not want to receive the newsletter anymore, you can unsubscribe any time for free. We will always indicate within the newsletter how to unsubscribe.


We collect, process and store your personal data only for the above defined purposes and only to the extent necessary to fulfill these purposes. We never conceal the purpose for which the personal data is collected and further processed.


For how long will you process my personal data?

We process and store your personal data only for the time necessary to meet the purposes of its processing specified above, or for the time consented by you, or for the time that is either necessary to comply with  our obligations under the applicable law or set forth by the applicable law or in accordance therewith. We comply with the mandatory rules for data archiving. 

Once the purpose of the personal data processing disappears, we will destroy the personal data.


Personal data collected via communication

As for the personal data voluntarily provided by you when you communicate with us, we will process and store such personal data until the requested issue is solved and also for the subsequent period thereafter that is either necessary to comply with our obligations under the applicable law or set forth by the applicable law or in accordance therewith, or during which you or any third party may contest that we have broken any of our obligations or have violated any applicable laws in relation to the requested issue.


Personal data collected when selling the products in Braiins Merch

As for the personal data voluntarily provided by you when making a purchase products in Braiins Merch, we will process and store such personal data until all the obligations under the contract of purchase and sale have been fulfilled and also for the subsequent period thereafter that is either necessary to comply with our obligations under the applicable law, or set forth by the applicable law or in accordance therewith, or during which you or any third party may contest that we have broken any of our obligations or have violated any applicable laws in relation to the sale of the products.


Personal data related to corporate bonds

As for the personal data related to the corporate bonds we will process and store such personal data until the due date of the bonds and also for the subsequent period thereafter that is either necessary to comply with our obligations under the applicable law, or set forth by the applicable law or in accordance therewith, or during which you or any third party may contest that we have broken any of our obligations or have violated any applicable laws in relation to the corporate bonds.


Personal data collected when you subscribe to our newsletter (commercial communications) 

We will process and store such personal data (your email) until you unsubscribe to our newsletter. You can unsubscribe any time for free. We will indicate how to unsubscribe within the newsletter. 

We will process and store the information that you have given us the consent (e.g. the logs) to send you newsletter for the duration of the consent and also for the subsequent period thereafter that is either necessary to comply with our obligations under the applicable law or set forth by the applicable law or in accordance therewith, or during which you or any third party may contest that we have broken any of our obligations or have violated any applicable laws in relation to the commercial communications sent to you.


Who will have access to my personal data?

We take care of your personal data security and so we choose the partners to whom we entrust your personal data very carefully.

All our partners must be able to provide sufficient security of your personal data to prevent unauthorized or accidental access thereto or other abuse thereof and all our partners must undertake a confidentiality obligation and must not use your personal data for any purpose other than the purpose for which the data were made available to them.

The recipients that may have access to your personal data are following:

  • persons who provide us with the technological services or technology operators that we use to provide our services;
  • persons who provide our services and websites with security and integrity and who regularly test such security and integrity;
  • providers of accounting, legal and administrative services;
  • our staff.

Our aim is and always will be to ensure your personal data are as anonymous as possible and unavailable to all third parties. However, under certain specifically defined conditions we will be under some circumstances required, in accordance with the applicable law, to transfer certain personal data to public authorities.


Do you transfer the personal data outside the EU/EEA?

When collecting, storing and processing personal data we sometimes may use personal data processors such as Google, which under some circumstances transmit your personal data to third countries. In such an event we always make sure such transmission is compliant with the Regulation. 

In particular, we specify that the personal data may be transmitted to the United States of America and in such event the transmission is compliant with the Standard Contractual Clauses (SCCs) mechanism.


How are my personal data protected?

All your personal data is secured by standard procedures and technologies. We provide data protection against unauthorized or accidental access, alteration, destruction, loss, unauthorized transmission or any other unauthorized processing, as well as against any other abuse of records containing the personal data. 

The standard procedures and technologies may include, but are not limited to, the following:

  • education and training of relevant staff to ensure they are aware of our privacy obligations when handling personal data;
  • administrative and technical rules to restrict access to personal data on a ‘need to know’ basis;
  • technological security measures, including firewalls, encryption and anti-virus software;
  • keeping the most sensitive personal data offline;
  • physical security measures, such as staff security passes to access our premises.

We are not able to guarantee the security of your personal data without your help and responsible behavior. Therefore, we ask you to help us ensure the security of your data by keeping in secret and secure your user account login information by following a common security standards.


Do you use cookies?

On our Website we use cookies to analyze traffic and to personalize content and ads. 

We will, as a data controller, collect, store and process any information that are considered as personal data collected by such cookies (the personal data may include your IP address, information about your activity on our Website, information about your advertisement preferences etc.).

To comply with legal requirements, we must mention that we collect, store and process such personal data mainly pursuant to the Article 6 (1) (f) of the Regulation. 

That means that it is in our legitimate interest to collect, store and process such personal data for marketing purposes and for Website traffic analysis, since 

  • it allows us to improve our products and services and to provide you with personalized content and advertisement, 
  • some cookies also allow us to keep our website secure from various attacks and some cookies allow our website to properly function,
  • we do not attempt to identify you using such personal data,
  • there is little to no restriction of your interests, rights and freedoms, and
  • you may at any time delete stored cookies permanently and change your cookie settings to disable or limit storage of any new cookies.

We will process and store such personal data for the period necessary to analyze traffic and to provide any personalized content to you and also for the subsequent period thereafter that is either necessary to comply with our obligations under the applicable law, or set forth by the applicable law or in accordance therewith.

Please, read our Braiins Cookie Policy (for Braiins Website) available on our websites to learn more about the cookies that we use.


What are my rights in relation to personal data protection?

In relation to the personal data you shall have in particular the following rights:

  • a right to withdraw your consent at any time;
  • a right to correct or make additions to the personal data;
  • a right to request restrictions to processing of your personal data ;
  • a right to object or complain against processing of your personal data under certain circumstances;
  • a right to request transfer of your personal data ;
  • a right to access your personal data;
  • a right to be informed of the personal data security breach under certain circumstances;
  • a right to request deletion of your personal data (a right to be „forgotten“) under certain circumstances; and
  • other rights set forth in Act No. 110/2019 Coll., on personal data processing (Personal Data Protection Act) and the Regulation.

You have a right to object, on grounds relating to your particular situation, at any time to processing your personal data which is based on Article 6(1)(f) of Regulation (it means that we have legitimate interest to process such personal data). You have also a right to object to processing your personal data for direct marketing purposes.

Additionally, you have a right to contact the Office for Personal Data Protection with a request for remedial measures in case of any violation of the obligations set forth in the Regulation at the following address: Office for Personal Data Protection, Pplk. Sochorova 27, 170 00 Prague 7, Czech Republic, phone number +420 234 665 111 (central telephone exchange).


How can I contact you?

If you have any questions regarding this Privacy Policy, please do not hesitate to contact us using the contact details below:

Contract address: Křižíkova 148/34, Karlín, Prague 8, Czech Republic

Contact point (support): https://braiins.com/

Email address: info@braiins.com


When is this Privacy Policy effective? 

This Privacy Policy comes into effect on the 1st January 2020. 

We reserve the right to amend and update this Privacy Policy at any time.

 

In Prague on 1st January 2020
Braiins Systems s.r.o.