Information on the processing of personal data of people within fan pages on social networks
This document summarizes the basic principles of dealing with personal data of fan pages users pertaining to JUDr. Václav Cidlina, advokát a zapsaný mediátor, IČO: 04437292 (hereinafter referred to as the “Attorney”) on social networks Facebook, LinkedIn, Twitter. Attorney thus (in most cases) acts as a personal data administrator (in addition to the above mentioned social network operators who are other personal data administrators).
For what purpose does your Attorney process your data?
In this section, the Attorney gives an overview of the purposes for which your personal data will be used (processed). Usually each data is used for several purposes. The means of processing, processing time etc. depend on the stated purposes. In certain cases stipulated in the Regulation, the Attorney may process your data also for purposes other than those listed below, but these are exceptional and limited cases, which are subject to further conditions by the Regulation . The Attorney does not process personal and other data of fan site visitors in any way other than for the purposes permitted by law, and for purposes for which the users has given their consent. The data is thus used for the following purposes:
- Keeping a fan site of the Attorney on Facebook and Twitter
- the protection of Attorney’s rights (e.g., in the event of a lawsuit regarding the content of fan pages))
- statistical purposes (but in this context your data is usually aggregated so that your identity cannot be identified)
- tracking fan site traffic
- improving the content of fan pages and developing them (but in this context, your data is usually aggregated so that your identity cannot be identified)
- ensuring the security of our systems and network against external attacks or misuse by users
- for the purposes of keeping accounting records and fulfilling other legal obligations (e. g. documenting consent to the processing of personal data, etc.)
Attorney processes your data only to the extent permitted by the relevant social networks, does not copy the data out of the network, unless it is aggregated data (not identifying individuals) or an individual incident (e. g. threatening comment). The Attorney may process the aggregated data in his own systems or external supplier systems, but these data do not allow him to identify you.
Legal basis of processing
Any processing of personal data must be lawful – it must be based on one of the legal bases for processing specified in the Regulation. As with the purpose, each data can be processed for several legal reasons for processing. If all legal reasons are removed, the Attorney will stop processing the data. Possible legal reasons for processing are listed in Article 6 of the Regulation.
The legal basis for processing your personal data is
- the lawful interests of the Attorney
in pursuit of the operation of the fan site, protecting his rights, processing it for statistical purposes, measuring traffic to his site, improving the content of his fan site and developing it, ensuring the security of systems and network and direct marketing; and
- compliance with legal requirements
in particular the prevention of tort, compliance with the requirements of data protection regulations (in particular Act No. 110/2019 Coll. and the Regulation), accounting and fulfillment of obligations under tax regulations.
What data does the Attorney process and what are their sources?
Personal information shall mean all information relating to an identified or identifiable natural person (also called a ‘data subject’); an identifiable natural person is a natural person who can be identified, directly or indirectly, in particular by reference to a particular identifier, such as name, identification number, location information, network identifier or one or more specific physical, physiological, genetic, psychological, economic, cultural or the social identity of this natural person. Personal information that the Attorney will process about you will usually obtain directly from you, or as a part of monitoring your activity within our sites (accounts). In justified cases (especially when recovering amounts due), we may also seek additional information about you from open sources.
Within our fan site the Attorney learns about you only the data that,
- will be provided by the relevant social network or yourself
If you do not comment on or flag any Attorney´s content, or send a message to him, the Attorney will not have any information about you (however, the social network operator may have this information). If you comment on or flag an Attorney’s content, or send a message, the Attorney will usually find out
- Your first and last name
- the set language
- time zone
- time of your reaction and
- text of your comment
However, the Attorney does not copy this data outside of the social network environment and does not process it (except for responding to your comment or answering your question), unless it is a case of an individual incident (e. g. threatening comment on an article). Attorney does not enrich learned data with data from your social network profiles.
How long does the Attorney process the data?
Attorney cannot process your data for any length of time, but the processing time is limited by the time he actually needs your data. Attorney seeks to limit the length of this period to take due account of your interests and his interests.
The Attorney processes data obtained from social networks primarily in aggregated form, so that it is not possible to identify individual users. In such a case, the Attorney may store such data without time limit. Otherwise, Attorney can process data that is accessible within the social network until it is deleted from it (although Attorney usually does not work with such data).
In determining the adequacy of the processing time of personal data, the Attorney shall rely mainly on the following aspects:
- estimated deadlines for detecting attacks on his network or other security breach findings
- usual market practices and recommendations of supervisory authorities and
the probability and significance of the risks involved.
Who can Attorney disclose information about you to?
Not all processing of personal data is carried out by the Attorney himself. Sometimes, Attorney hires third parties, the so-called personal data processors. The Attorney seeks to select only those processors who are sufficiently trustworthy.
As mentioned above, the Attorney only tries to process personal data within the social network in which they are stored. Within social networks, Attorney may use special software tools to better manage his accounts, but they are not usually personal data processors. Should the Attorney process personal data outside the relevant social network, the Attorney may disclose your personal data to the following processors or other recipients:
- external service providers (typically programmer or other support technical services, server services, emailing),
- operators of backup servers or operators of technology used by the Attorney, who process them to ensure the functionality of the relevant services of the Attorney.
Are you obliged to provide the Attorney with the data?
You provide your personal data to the Attorney voluntarily. If, in some cases, you are required to provide personal data for processing under a special law, you will be specifically informed.
The Attorney reminds you that if the legal reason for the processing of your personal data is your consent, you can withdraw such consent at any time free of charge using email email@example.com. The withdrawal of the consent shall not affect the legality of the processing based on the consent given prior to its withdrawal.
Right to object
The right to object is your important right. It allows you to review processing based on our legitimate interest when justified by your particular situation – that is, when processing itself is permissible, but there are specific reasons on your part why you do not want processing to take place. In such a case, the Attorney shall not further process such personal data unless there are serious legitimate reasons for the processing that outweigh your interests or rights and freedoms, or if they are not processed to determine, exercise or defend legal claims. However, the opportunity to object does not apply to all processing cases, e. g. it cannot be used if the Attorney processes data necessary for the performance of the contract or when the processing is required by law. The right of opposition is found in Article 21 of the Regulation.
You can dispute the processing using email firstname.lastname@example.org. Please always state the specific situation that leads you to the conclusion that the Attorney should not process the data. The Attorney points out that even in the cases mentioned above, personal data will sometimes be processed for other purposes, which will justify the Attorney continuing to process such data.
Automated decision making
Under the Regulation, as a data subject, you have the right not to be the subject of any decision based solely on automated processing, including profiling, which has legal effects or affects you in a similar way (Article 22). Although the Regulation provides for a few exceptions to cases where such automated decision making is possible, the Attorney seeks not to carry out such processing.
The Attorney does not make any automated decision making in connection with social networks that would have legal effects or affect you in a similar way within the meaning of Article 22 of the Regulation.
Terms of privacy of relevant social networks
You can find information on how your social network provider handles your personal data here: