Privacy policy

Personal data processing policy

This Policy has been prepared under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, the General Data Protection Regulation, and other related, generally binding legislation in force.

Dear clients and business partners,

protecting your personal data is important to us and is our obligation. The Policy below explains how impuestos s.r.o., registration number 07864051, tax ID CZ07864051, with its registered office at Veletržní 674/5, 603 00 Brno, protects your personal data when processing it, not only when providing accounting services.

Our employees and other people involved in our activities are required to maintain confidentiality about any facts they learn in the course of their work or when providing other services connected with accounting services. This duty of confidentiality covers all information concerning our clients, as well as all confidential or sensitive information obtained in connection with any activities carried out by our company. Put simply, we take your secrets to the grave.

If you have any questions, please contact us by phone on +420 530 506 222 or by email at ucto@luciekocmanova.cz.

Now, let us get to the point.

1. What is personal data?

• The scope of personal data processed always depends on the category of data subject whose data is being processed. In particular, this includes: title, first name, surname, business name, date of birth, personal identification number, company registration number, tax ID, permanent residence address, residential address, registered office address, contact details (email address and phone number), account number, bank details, the number and validity of identity documents, and similar information.
• Personal data is always processed only to the extent necessary to fulfil the purpose for which it was provided or obtained.
• Personal data is primarily obtained directly from the data subjects concerned, or from publicly available sources (public lists and registers). In justified cases, personal data may also be obtained in other ways, for example from a court file or a similar record.
• The GDPR also recognises a special category of personal data that requires particularly sensitive handling. Special category data includes, in particular, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data such as fingerprints used to identify you, data concerning your health, or data concerning your sex life or sexual orientation.

2. Why do we process personal data?

• Processing personal data means any operation or set of operations performed on personal data, such as collecting, organising, storing, retrieving, consulting, using, disseminating, erasing or destroying it, regardless of whether this is done by automated or non-automated means.
• Our company needs to process your personal data mainly for the following reasons, so that we can:
  • provide accounting services to our clients,
  • meet various statutory and contractual obligations,
  • protect the legitimate interests of our clients, our company and other related parties.

3. For what purposes and on what legal bases do we process your personal data?

We need your personal data for:	We are entitled to process your personal data on the basis of:	When processing your personal data, we consider in particular:
Providing accounting services	performance of a contract or compliance with a legal obligation	the GDPR, the Civil Code, the Business Corporations Act, the Accounting Act, the Income Taxes Act, the VAT Act and other legislation (Czech Accounting Standards and decrees implementing the Accounting Act)
Ensuring that our activities comply with legislation	compliance with a legal obligation, the legitimate interests of our company or third parties, the public interest, or the defence of legal claims	the GDPR, the Accounting Act and other legislation (for example, Czech Accounting Standards and decrees implementing the Accounting Act)
Purposes relating to the protection of our company's legitimate interests	the legitimate interests of our company or the interests of third parties	the GDPR, the Civil Code, the Business Corporations Act, the Criminal Code, the Code of Criminal Procedure, the Code of Civil Procedure, the Administrative Procedure Code, the Code of Administrative Justice, the Accounting Act and other legislation (for example, Czech Accounting Standards and decrees implementing the Accounting Act)
Marketing purposes	consent to processing, but only if you choose to give it, or, in certain cases, the legitimate interests of our company or third parties	the GDPR, the Civil Code, the Electronic Communications Act, the Advertising Regulation Act and the Consumer Protection Act
Statistical purposes, archiving in the public interest, and historical and scientific research	archiving in the public interest, scientific or historical research, or statistical purposes	the GDPR and the Archives and Records Management Act
HR and payroll	compliance with a legal obligation, legitimate interests or performance of a contract; for special categories of personal data, additional conditions may apply where processing is necessary to fulfil obligations and exercise specific rights of our company or the person concerned in employment law and social security and social protection law, provided that it complies with collective agreements under Czech law and appropriate safeguards are established for the fundamental rights and interests of data subjects	the GDPR, the Labour Code, the Employment Act and the Social Security Act
Accounting purposes	compliance with a legal obligation	the GDPR and specific legislation on accounting and tax administration

4. To whom do we disclose your personal data?

• We disclose the personal data of our clients and other individuals only exceptionally, to the extent necessary to provide our services and meet legal obligations. The recipients are also required to maintain confidentiality.
• For example, we disclose personal data to people whom we engage to perform individual tasks in the provision of legal services, our accountants and tax advisers, providers of software for our company, and employees of those parties.
• Personal data may be transferred to third parties only in very exceptional cases and only when strictly necessary. Examples include meeting statutory obligations towards public authorities or other offices, using the services of external associates or suppliers (accountants and tax advisers, auditors, lawyers, experts, IT consultants and similar professionals), or fulfilling the contractual relationship under an agreement with a client (tax offices, the social security administration, health insurance providers, labour offices, the statistical office and so on).

5. To which countries do we transfer your personal data?

• We do not transfer your personal data to third countries outside the European Economic Area (the EU, Iceland, Norway and Liechtenstein). We use secure cloud services from a verified provider whose servers are located in the EU.

6. How long do we retain your personal data?

• We retain personal data for no longer than is necessary for the purposes for which it is processed, or for as long as required by law, such as accounting and employment legislation or the AML Act defined below.
• When processing personal data, we also follow statutory retention periods. The retention period:
  • is at least 10 years for the obligation to retain financial statements or annual reports,
  • is 5 years for the obligation to retain accounting documents, accounting books, depreciation schedules, inventory lists, charts of accounts or reports,
  • is 5 years for the obligation to retain accounting records with which accounting entities substantiate their accounts,
  • is 10 years for the obligation to retain tax documents, starting from the end of the tax period in which the transaction took place.

7. How do we obtain personal data from you?

• If you are a client of our company, we usually obtain personal data directly from you. Depending on the circumstances, a client's failure to provide personal data can significantly affect our ability to provide quality accounting services and, in exceptional cases, may oblige us to refuse to provide those services. We may also obtain personal data about our clients from publicly available sources, public authorities or other persons.
• If you are not a client of our company, please note that we most often obtain your personal data from our clients or from other public or lawful sources, for example by requesting personal data from public authorities, obtaining extracts from public registers, gathering evidence in a client's favour, or using other methods in accordance with Czech law.
• If you are an employee of our company or a person working with us, you have mainly provided your personal data to us directly. Its processing is governed primarily by employment and accounting legislation, and we inform you of the rules for processing your personal data whenever a contract is concluded.

8. What rights do you have as a data subject?

• If we process your personal data on the basis of your consent, you have the right to withdraw that consent at any time.
• Regardless of the above, you have the right to object at any time to the processing of personal data concerning you.
• As a client of our company, you have the right to request access to your personal data and to have it corrected if it is inaccurate.
• If the personal data concerns a client, third parties do not have a right of access or a right to data portability because of our statutory duty of confidentiality, in particular with reference to Article 15(4) and Article 20(4) of the GDPR.
• As a data subject, you of course have the right to lodge a complaint with the Office for Personal Data Protection at any time.

9. Cookies and website traffic data

• Our company's website does not use analytics or marketing cookies, and we do not measure website traffic.
• Through the contact form, we process only the data you send us yourself for the purpose of handling your enquiry and subsequent communication.

10. Changes to this privacy policy

• Protecting personal data is not a one-off matter for us. The information we are required to provide in relation to our processing of personal data may change or become outdated. We therefore reserve the right to amend and change this policy at any time and to any extent. If we make a substantial change to this policy, we will announce it on this webpage or in a separate notification by email.

11. Legislation referred to in this policy

• “AML Act” means Act No. 253/2008 Coll., on Certain Measures against the Legalisation of Proceeds of Crime and Terrorist Financing;
• “GDPR” means Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation);
• “Code of Civil Procedure” means Act No. 99/1963 Coll., the Code of Civil Procedure;
• “Civil Code” means Act No. 89/2012 Coll., the Civil Code;
• “Code of Administrative Justice” means Act No. 150/2002 Coll., the Code of Administrative Justice;
• “Administrative Procedure Code” means Act No. 500/2004 Coll., the Administrative Procedure Code;
• “Code of Criminal Procedure” means Act No. 141/1961 Coll., on Criminal Court Proceedings (the Code of Criminal Procedure);
• “Criminal Code” means Act No. 40/2009 Coll., the Criminal Code;
• “Accounting Act” means Act No. 563/1991 Coll., on Accounting;
• “Income Taxes Act” means Act No. 586/1992 Coll., on Income Taxes;
• “VAT Act” means Act No. 235/2004 Coll., on Value Added Tax;
• “Archives Act” means Act No. 499/2004 Coll., on Archives and Records Management;
• “Electronic Communications Act” means Act No. 127/2005 Coll., on Electronic Communications and on Amendments to Certain Related Acts;
• “Business Corporations Act” means Act No. 90/2012 Coll., on Business Companies and Cooperatives;
• “Consumer Protection Act” means Act No. 634/1992 Coll., on Consumer Protection;
• “Advertising Regulation Act” means Act No. 40/1995 Coll., on Advertising Regulation and on Amendments and Additions to Act No. 468/1991 Coll., on the Operation of Radio and Television Broadcasting, as amended;
• “Social Security Act” means Act No. 582/1991 Coll., on the Organisation and Implementation of Social Security;
• “Employment Act” means Act No. 435/2004 Coll., on Employment;
• “Labour Code” means Act No. 262/2006 Coll., the Labour Code.