We would like you to feel safe when browsing our websites. Let us therefore assure you that in Grow Trails we take the protection of personal data seriously. If you are our customer, news subscriber or website visitor, you entrust us with your personal data. We are responsible for their protection and security. Please familiarize yourself with the personal data protection, policies and rights you have in relation to their protection (GDPR).
I. Purpose of this document
This document contains information concerning the protection of personal data provided by visitors to the website www.growtrails.com, clients and those interested in our services (affected persons). The purpose of this document is to acquaint you (the persons concerned) with your rights and to provide clear information on how personal data will be handled.
II. Data operator
I am Zuzana Masárová (hereinafter referred to as the “Operator/We/I”) who runs the webpage growtrails.com. The contact e-mail is: hello”at”growtrails”dot”com.
We process your personal data as an operator, i.e., we determine how personal data will be processed and for what purpose, for how long and we select any other intermediaries who will assist us with the processing.
We declare that, as the operator of your personal data, we fulfill all legal obligations required by the applicable legislation, in particular the Personal Data Protection Act and the GDPR, and therefore that:
- we will process your personal data only on the basis of a valid legal reason, in particular a legitimate interest, performance of the contract, legal obligation or granted consent,
- we fulfill according to Article 13 of the GDPR the information obligation even before the start of the processing of personal data,
- we will enable and support you in exercising your rights under the Personal Data Protection Act and the GDPR.
III. What personal data do we process and how do we obtain it?
We process data that you yourself provide to us. In most cases, it will be providing data to us by filling out one of the forms on our website. Personal data then travels to an electronic database, to an application for preparing and sending e-mails. Thanks to the database we will ensure that you will only receive from us the e-mails and electronic products (e-books, possibly online or video courses) that you want.
Next, your data will reach us also if you enter it in an established user account on our website or elsewhere in a closed member section of one of the online products or in the Facebook group. In those exceptional cases, the data will be provided via personal contact, by telephone, e-mail or other means of communication (SMS messages, messages in applications such as Skype, Facebook Messenger, Whatsapp, Viber, etc.).
If we have to have your consent for the processing of certain personal data for specific processing purposes, then we process such data for that purpose only with your consent.
Personal data we process:
Name, surname, address, ID/VAT number (only if you order as an entrepreneur), e-mail, telephone number, IP address, cookies, information about ordered and purchased products and services.
IV. For what purposes do we process personal data, for how long and what entitles us to do so (legal basis of processing)?
A. Processing personal data for the purpose of concluding a contract and fulfilling contractual obligations.
In order to be able to conclude a contract with you and deliver the products or services ordered by you and to maintain the related communication with you, we process the following personal data: name, surname, address, ID/VAT number (only if you order as an entrepreneur), e-mail, information about ordered and purchased products and services.
The right to process this data comes directly from the fulfillment of contractual obligations under the contract concluded between us. Note that it does not have to be a contract concluded in the classic printed form, signed by hand. It will usually be a contract concluded by filling in and sending the order form on our website and by our confirmation of such an order.
We process personal data for the purpose of concluding and fulfilling the contract for the duration of the contractual relationship between us. Upon termination of the contractual relationship, certain data is then retained for the purpose of fulfilling legal obligations or for the purposes of a legitimate interest, as you will read in the following sections of this document.
B. Processing personal data for the fulfillment of obligations from accounting, tax and other legal regulations
In order to fulfill the obligations arising from valid legal regulations, especially in the field of accounting, tax law and archiving, we process the following data: name, surname, address, ID/VAT number and data on the purchased product / service (i.e., the data stated on invoices).
The period for which the data are collected is determined by legal regulations that impose on us the obligation to process the data.
C. Processing personal data for the purposes of our legitimate interests
A legitimate interest can cover a wide range of situations. Therefore, we inform you of the legitimate interests for which we process personal data:
- A legitimate interest is the protection and proof of our rights and legal claims, in particular from concluded contracts or caused damage. For these purposes, we process personal data for a period of 4 years after the termination of the contractual cooperation or our last contact, if the contract has not been concluded. This period is determined with regard to the limitation periods of the claim, taking into account the fact that we do not have to find out about a possible claim in court immediately at the moment of its exercise by the other party. For these purposes, data from contracts and our mutual communication are stored.
- Direct marketing also counts as legitimate interest, i.e., informing about various news, promotions, products or other facts related to the business of the operator. We may also process your personal data (name, e-mail, what you click on in the e-mail, and similar e-mail statistics) in order to provide information about goods or services that may be of interest to you. In the event that a contractual relationship has been established between us, we may, on the basis of our legitimate interest contact you by e-mail, or SMS with information about goods and services similar to those that were the subject of our previous sale or sale negotiations, unless you have previously refused such use of data. We will not share your personal information with third parties for marketing purposes without your prior explicit consent. We will process the following personal data of our clients for sending business announcements: name, surname, address, e-mail. You can always easily stop receiving business notifications to your e-mail by clicking on the link provided in the e-mail. If in order to send out our offers or news information we used the classic printed postal form or a telephone call or one of the communication applications such as skype, or messenger, we will respect it here as well if you let us know that you no longer wish another contact. For the purpose of direct marketing, we will process your personal data for as long as we offer our services, or until you unsubscribe.
- In order to be able to offer you tailor-made products and services and send you only such offers and information that will not unnecessarily overwhelm you and will be of benefit to you, we have our database of contacts and personal data divided into several lists. For example, if you want to receive information about our news, your e-mail address will automatically be included in the “newsletter” database. Likewise, when you send us an order from the website, your contact will be included in the “ordered” list and after payment in the “paid” list, at which time the system will automatically send you the ordered electronic product. Part of this automated processing thus serves directly to fulfill our contractual obligations, part is used for routine marketing (i.e., falls into the category of legitimate interest). If this “sorting” of data was done on a large, very “specialized” scale, then we could only do it with your consent (and you can then revoke it at any time, as described later in this document).
D. Processing personal data based on your consent for marketing purposes
If you are not yet our customer, we will send you our offer of services and products, information about new articles and other similar announcements only if you give us your consent (by clicking the button on the web form or the respective link in the e-mail).
Only with your consent do we process (publish for the purpose of presenting our services and products) the data written in your references (or the data spoken if the reference takes the form of a call or video), as well as photos and videos from live events organized by us.
Before you give us your consent, we will always inform you of the data and the specific purpose of the processing to which your consent would relate. Unless explicitly stated otherwise in the given consent, you grant it for as long as we offer our services.
Advanced consent marketing: only with your consent we can send you inspiring offers from third parties or to use your email address for example for remarketing and targeting ads on Facebook, for a period of 4 years from granting the consent.
You can revoke your consent at any time. If we also process some of your personal data on the basis of another legal title (see letters A to C above), we will process personal data for these purposes even after revoking your consent, as consent for such specific purposes is not required.
V. Personal data security and protection
We protect personal data to the maximum extent possible using modern technologies that correspond to the level of current technical development. We protect them as if they were our own. We have taken and maintain all possible (currently known) technical and organizational measures that prevent the misuse, damage or destruction of your personal data.
We process data exclusively in the European Union or in countries that provide an adequate level of protection based on the decision of the European Commission.
VI. Disclosure of personal data to other persons (recipients of personal data)
Other persons who are in the position of intermediaries or coworkers help us to secure some of our contracts or legal obligations. These include, in particular, the accountant, the administrative assistance, the providers of data storage and software applications and, in the case of the sending of a book or other physical products, also the contract carrier. We enter into written agreements with intermediaries in which it is agreed to fulfill the obligations in the field of personal data protection in order to keep your data secure.
Personal data may be shared with state and / or law enforcement authorities if required by applicable law or if the protection of our legitimate interests (including the legitimate interests of third parties) so requires in accordance with applicable law.
Currently, to provide specific processing operations that we cannot provide on our own, we use the services and applications of intermediaries who can protect data better than we do and specialize in the processing.
It is possible that in the future we will decide to use other applications, or intermediaries, to facilitate and improve processing. However, we promise you that in such a case we will place at least the same demands on intermediaries for the security and quality of processing as on ourselves.
VII. Information about your other privacy rights
A. Right of access to personal data
This is the right to confirm whether we process your personal data and, if so, to access this data and information about its processing.
B. Right to correct personal data
This is your right at us correcting inaccurate personal data related to you without undue delay. Considering the purposes of the processing, you have the right to supplement incomplete personal data, including by providing an additional statement (in which you provide the data completely).
C. Right to erase personal data (right to “be forgotten”)
In cases provided by law or the GDPR, you have the right to request that we delete your personal data without undue delay (in the GDPR, the reasons are set out in Article 17, including the exceptions where the deletion will not take place).
D. Right to restrict processing
In the cases set out in Article 18 of the GDPR, you have the right to request that we restrict the processing of your personal data.
E. Right to data portability
Under the conditions set out in Article 20 of the GDPR, you have the right to obtain your personal data and transfer them to another operator. If technically feasible, you have the right to request a transfer directly to another operator.
F. Right to object to processing
In cases where we process personal data for legitimate interests, you have the right to object to such processing and then we will no longer process the data unless our legitimate interest outweighs your interests or your rights and freedoms. If direct marketing is the legitimate interest, then raising an objection always results in the termination of further data processing for direct marketing purposes.
G. Right to lodge a complaint with the authority
If you believe that your rights in the field of personal data protection are being violated, you have the right to file a complaint with the Office for Personal Data Protection. In such a case we would appreciate if you can first inform us of your intention so that we can correct any potential mistakes.
Unsubscribing from newsletters and business messages
We send you inspirational e-mails, articles or products and services if you are our customer based on our legitimate interest. If you are not a customer yet, we send them only based on your consent. In either case, you can unsubscribe from emails by pressing the unsubscribe link in each email you receive.
VIII. Other important information for exercising your rights
If you have further questions about our processing of your personal data, you can contact us at hello”at”growtrails”dot”com. By sending an e-mail, you can also directly exercise your rights, about which we write in Article VII. We would just like to point out that for the purpose of verifying that the request is indeed applied directly by you, we may then contact you and verify your identity and request in an appropriate manner. The same applies to any telephone and similar communication.
We would like to assure you that our employees and co-workers who will process your personal data are obliged to maintain the confidentiality of personal data and security measures, the disclosure of which would jeopardize the security of your personal data. This secrecy continues even after the end of the contractual relations with us. Your personal data will not be disclosed to any other third party without your consent.
You can always find the current version of this document on the website www.growtrails.com. This text is effective from 12.4.2021.