Principles of Personal Data Protection
Limited liability company DIVR LABS s.r.o., business ID: 05214378, registered seat:
Thámova 166/18, Karlín, 186 00 Prague 8, Commercial Register file no: C 260130,
maintained by the Municipal Court in Prague (Hereinafter also “We“ or “Our Company“)
pays a lot of attention to personal data protection. This document will inform you how weprocess your personal data, i.e. personal data of our customers and users of our services,
whether we process them on the basis of the data subject´s consent or on the basis of anotherlegal reason, for what purpose we use the data, whom we transfer them to and what yourrights are in connection with your personal data processing.
These principles are formulated in compliance with the data processing legislation, including
but not limited to the Regulation of the European Parliament and of the Council (EU)2016/679 of 27 April 2016 on the protection of natural persons with regard to the processingof personal data and on the free movement of such data, and repealing Directive 95/46/EC(General Data Protection Regulation) (hereinafter “GDPR“)

1. Initial Provisions and Terms and Definitions
1.1. Our company operates the www.golemvr.com web site and you enter this web site as its
user, or if you are interested in products, services or information offered/provided by ourcompany.
1.2. As you provide your personal data to us we are your personal data controller.
1.3. The terms "Controller", "Processor", "Personal Data” and "Processing" used hereinshall be understood int he context of the GDPR:
1.3.1. Controller in the sense of Art. 4 (7) of GDPR means a natural person or legal
entity, a public authority, an agency or another entity alone or together with others
specifying the purpose and means of personal data processing.
1.3.2. Processor in the sense of Art. 4 (8) of GDPR means a natural person or legal
entity, a public authority, an agency or another entity processing personal data for
a Controller.
1.3.3. Personal Data mean any information about an identified or identifiable natural
person (the data subject).
1.3.4. Personal Data Processing in the sense of Art. 4 (2) of GDPR means any
operation or a set of operations with personal data or personal data files performed

with /without the help of automated procedures such as collection, recording,sorting, structuring, storage, adaptation or amendment, retrieval, consultation, use,accessibility facilitation by transfer, dissemination or any other disclosure, listingor combination, limitation, deletion or destruction.

2. What is the purpose of your personal data processing?
2.1. We only process your personal data for purposes notified to you by our company. The
type of personal data we process and the purposes of the processing depend on how you
communicated your personal data to us. You can communicate your personal data to usas follows:
2.1.1. When you visit our web site
When you visit our web site www.golemvr.com, we process some of your personal data
automatically within the scope, for the purpose and for the period and on the basis of thelegal reason (title) specified below:
PurposeScope ofLegal title

processed data
Improvement of our web site

Processingperiod

Data on your web

Legitimate interest

For 2navigationof our company inweeks(through cookies)

improvement of ourweb site

Compilation of statistics andData on your web

Legitimate interest

For 2reports on the use of our webnavigationof our company inweeks

site(through cookies)

measurement ofeffectiveness of ourweb site, including
advertising on thesiteYou are entitled to object against our processing of your personal data for the purpose offulfillment of our legitimate interest in improvement and measurement of effectiveness of
our web site. Unless we have legitimate reasons for continuing your personal dataprocessing despite your objection we will stop processing your personal data for thispurpose.
2.1.2. When you communicate with us via various channels
If you communicate with us by means of various channels, especially by asking a question
via our web site, email, chat instruments or social media. Then we process your personal
data within the scope, for the purpose and for the legal reason (title) specified below:
PurposeScopeof Legal title

processed data

Processing
periodRecording andName, surname,Our legitimate interest is

For the period

settlement of youre-mail contact,to keep contact with youof duration ofrequests,

records of yourour legitimate

confirmation that we requirement(s)interest,

have accepted andand the related

maximum forsettled yourcommunication

3 years fromrequirement.

the lastcommunication
with you

You can file an objection against this processing on the basis of our legitimate interest (see Art.
4.9.8.).

2.1.3. In the context of acquisition and use of admission tickets and vouchers for
GOLEM VRBy filling out the order form on our web site www.golemvr.com you disclose your personal

data to us for the purpose of our settlement of your order. Then we process your personal
data within the scope, for the purpose and for the legal reason (title) specified below:

Purpose

Scope

Legal titleofProcessing periodprocessed data
Ordersettlement,including
goods
delivery andpayment(including but
not limited toadmission
tickets orvouchers for
GOLEM VR)

Name,surname, e-mailand accountnumber(disclosed by
you for the
purpose ofpurchase pricerefund in caseof your
withdrawal
from thevoucher
purchase
contract)

Necessary forthe contract
implementation

Name,surname, email andaccountnumberIn 3 years
from ourlegal
relationshiptermination(goodsdelivery andpurchasepricepayment)

Basic data on
the legalrelationshipand itsexistence(name,surname, email contact)

For 10 years
from thecontracttermination

If you decide to order anything from us these data will be necessary for us to be able tosettle your order, to execute a contract with you for the purpose of the goods or service
provision to you, and to implement the executed contract for you.
2.1.4. When you are addressed with our offers of products and services, including tailormade offers according to your preferences
We want to keep further contact with you. Then we process your personal data within thescope, for the purpose and for the legal reason (title) specified below:
PurposeScopeof Legal titleProcessing period

processed data
When you are

Name, surname, e-

Our legitimate

For the period of duration ofaddressed with

mail and orderinterest is to

our legitimate interest,

our offers ofhistory

keep contact

maximum for 3 years fromproducts andwith you andyour last orderservices,offer youincluding tailor-

products andmade offers

services

according totailored to

youryour needs

preferences
As for addressing you with our offers of our products and services, including offers
tailored to your preferences, we will be happy to be in continued contact with you. So as
not to send you offers of no interest for you we use information from our records of yourrequirements and past communications with us.
At the same time we do not want to bother you with this and that is why you can use theprocedure described below or every e-mail sent to you for exclusion of further sending ourcommercial information to you (see Art. 4.9.).
You can object against our processing your personal data for the purpose of delivery of
our commercial communications to you on the basis of which we will stop this processingof your personal data for this purpose immediately.

3. Who we forward your personal data to?
3.1. We do not know to whom we may provide your personal data in future. That is why welist here categories of potential recipients with justification why they may be provided
with your personal data processed by us:
Recipient

Reason for provision

Entities operating payment systems for

Necessary for the contract implementation

the purpose of payment implementation,
especially in the case of card payment
Our accountant and tax accountant

We need a provider of accounting and tax
services to us as a data processor to keep
our accounts and fulfill our tax liabilities forus

An entity assuring our web site run, ourWe need the entity as a data processor toapplications and our software

provide to us software equipment, tofunctioning (computer systems)

perform servicing of our web site and toincluding persons providing cloudassure operation of our information systems

services
A person assuring our direct e-mailing

We may authorize a third party todisseminate our e-mail information and wemay provide your e-mail address to thisperson for that purpose

3.2. We would like to inform you that we will always provide you information about to whomand for what purpose we provide your personal data in this context on your request.

4. What are your rights?
4.1. S our company processes your personal data, you are endowed with certain rights which
this section wants to inform you about. You can ally your rights with us in any mannerconvenient for you and allowing us to check whether it is you who applies (to check youridentity). Then we will try our best to satisfy you. In order to be able to meet yourrequests as completely as we can we would like to ask you to apply your rights in writingon e-mail address bookings@golemvr.com.
4.2. Right for consent withdrawal - we process some of your personal data on the basis ofyour consent. You are entitled to withdraw your consent with your personal dataprocessing, including your consent with commercial information receipt. You can
withdraw your consent on bookings@golemvr.com.
As for processing of your personal data for the purpose of commercial information
distribution you can withdraw your consent with your data processing for that purpose
simply by clicking on the relevant link at the end of every commercial information e-mailsent to you or change your user profile setting.
4.3. Right of access - you are entitled for access to your personal data processed about you by
us and for information what personal data we process about you, for how long, for what
purpose, for what recipients, and whether we use them for automated decision-making(including how this automated decision-making works).
We will provide a copy of your processed personal data free of charge to you. in the caseof a request for more copies we will ask for their payment.
4.4. Right for correction - if you find out that your personal data processed by us are incorrect
or incomplete, you are entitled to ask for their correction or completion if required by thepurpose of their processing.
4.5. Right for deletion - You are also entitled to ask for deletion of your personal data ourcompany processes and saves about you. The request for deletion must be justified by oneof the following reasons:•Your personal data are no longer needed for the purpose for which they wereobtained and processed;•Your personal data are processed illegally by our company;•You have withdrawn your consent with your personal data processing and we haveno other authorization (legal title) to continue to do so;•You file an objection against your personal data processing for the purpose of direct
marketing (direct mail);•The file an objection against your personal data processing on the basis of ourlegitimate interest which we are unable to prove to govern over your right for datadeletion;•There is a legal reason for your personal data deletion;•Our company processes personal data of a child without its parents´ consent.

We would like to note that there are situations when your personal data cannot be deleted
on your request or after withdrawal of your consent with their processing This is mainly
when continued processing of your personal data is required by law. When this happens
our company will inform you about the reason why your personal data cannot be deleted
despite your explicit request for the deletion.
4.6. Right for portability - another right vested onto you is the right for the data portability.
On the basis of this right you can ask for provision of your personal data provided to us
on the basis of your consent and processed by automated procedures by us. Your personal
data meeting these conditions will be provided to you on request in the standard
structured and machine-readable format, or forwarded to another controller of yourchoice on your request if technically feasible.
4.7. Right to limited processing - if you believe that your personal data processed by ourcompany are incorrect, you can request limitation of our processing of your data for theminimum period necessary for review of accuracy of your personal data and theirpotential correction.
You are endowed with this right also in the following cases:•Processing of your personal data by our company is illegal but you do not wish yourpersonal data to be deleted;•Our company no longer needs your personal data for the purpose for which they
were provided but you insist on their processing (archiving) by our company for thepurpose of specification, execution or defense of your claims;•You have filed an objection against processing of your personal data on the basis oflegitimate interest of our company. The limitation of processing for this reason will
be limited for the period needed for specification whether our legitimate interest
prevails over your right to withdraw from further processing of your data.

4.8. Right for complaint about processing of your personal data on the basis of a legitimate
interest - as some of your personal data are processed on the basis of our legitimate
interest, you are entitled to file an objection on the basis of which we will assess whether
it is really our legitimate interest that prevails over your wish to have your personal datadeleted or whether your right for immediate stop of your personal data processing
prevails.
4.9. Right for objection against your personal data processing for the purpose of direct
marketing - you are entitled to protest against processing of your personal data by ourcompany for the purpose of direct marketing (for example for the purpose of commercial
information sending). In such case our company will stop processing your personal data
for that purpose.
4.10. Right for complaint - if all of the above rights are insufficient from your point of view,r if you believe that our company violates your rights you can file a complaint with thesupervisory board. The complaint may be raised via the contact to the Personal Data
Protection Office, available on https://www.uoou.cz/podatelna-uradu/os-1006 .