PRIVACY POLICY – Transfer Money Technologies s.r.o.

We value your privacy.

1.1. The administrator of personal data is Transfer Money Technologies s.r.o., IČO: 24127906, registered seat at Freyova 82/27, Vysočany, 190 00 Praha, registered in the Commercial Register of the City Court in Prague, C 181123/MSPH (hereinafter “Transfer Money Technologies s.r.o.” or “administrator”).

1.2. This privacy policy (hereinafter “Policy”) regulates the processing of personal data of visitors (hereinafter “user”) of Transfer Money Technologies webpages and of other persons that we come into contact on various occasions during our work, be it over the phone or via other communication channels.

2. NEWSLETTERS AND OTHER BUSINESS MESSAGES

2.1. With your consent, we are authorized to process your email address, name and surname, telephone number, information about your profile on social networks (LinkedIn, Facebook, Google, etc.) and other data that you submit to us via a given form for the purpose of sending business messages.

2.2. A business message can be, for example:

newsletter;

event or conference invitation related to Transfer Money Technologies business or attended by Transfer Money Technologies personnel;

offers and messages of our clients and business partners.

2.3. The submission of personal data is voluntary. We keep personal data for the indicated purpose for three (3) years from the date of submission.

2.4. We process personal data on our own and pass personal data onto third parties for further processing, but only for the intended purpose. Other processors of personal data are stated below in this Policy, in section “Recipients of personal data”.

2.5. You can withdraw your consent for the processing of personal data for the purpose of sending newsletters and other business messages by sending an email to tmtlead1@gmail.com or by clicking on the unsubscribe link in the body of the business message.

3. KEEPING RECORDS ABOUT JOB SEEKERS

3.1. For the purpose of keeping records about job seekers and with your consent, we are authorized to process your email address, name and surname, telephone number, information about your profile on social networks (LinkedIn, Facebook, Google plus, etc.), information about your professional history, education, qualifications, experience, photographs, and other data that you submit to us, including the information contained in the attached curriculum vitae.

3.2. The submission of personal data is voluntary. We keep personal data for the indicated purpose for twenty four (24) months from the date of submission.

3.3. We process personal data on our own and pass personal data onto third parties for further processing, but only for the intended purpose. Other processors of personal data are stated below in this Policy, in the section “Recipients of personal data”.

3.4. You can withdraw your consent for the processing of personal data for the purpose of keeping records about job seekers by sending an email to tmtlead1@gmail.com

4. MARKETING AND ADVERTISING PURPOSES

4.1. With your consent, we are authorized to process your email address, name and surname, and information for identification of your profile on social networks (LinkedIn, Facebook, Google plus, etc.) for the purpose of organizing marketing competitions, management of advertising campaigns, and for the purpose of creating a personalized advertisement and remarketing activities. For the same purpose, we are authorized to also process technical data, like Cookies, as stated below in this Policy.

4.2. The submission of personal data is voluntary. We keep personal data for the indicated purpose for six (6) months from the date of submission.

4.3. We process personal data on our own and pass personal data onto third parties for further processing, but only for the intended purpose. Other processors of personal data are stated below in this Policy, in the section “Recipients of personal data”.

4.4. You can withdraw your consent for the processing of personal data for marketing and advertising purposes by sending an email to tmtlead1@gmail.com

5. SECURITY OF PERSONAL DATA

5.1. Security of your personal data is very important to Transfer Money Technologies. Personal data is handled and processed in accordance with all applicable legislation, including the General Data Protection Regulation (GDPR). While processing personal data, Transfer Money Technologies emphasizes technological and organizational safety of the processed data.

5.2. All electronic personal data is stored in databases and systems that can be accessed only by persons who, to the extent necessary, need to access and handle personal data for the purposes stated in this Policy. The security of personal data in Transfer Money Technologies systems is regularly tested and the protection is continuously improved.

5.3. Personal data is processed both automatically and manually. Personal data is stored in an electronic form in data centers located in the EU and, in instances stated below, in the USA. All registration and login processes take place via a secure HTTPS protocol using 128-bit or 256-bit encryption. The Let’s Encrypt SSL certificate is provided by the company Internet Security Research Group, 1 Letterman Drive, Suite D4700, San Francisco, CA 94129, USA.

6. RECIPIENTS AND TRANSFER TO OTHER COUNTRIES

6.1. Personal data is primarily processed by Transfer Money Technologies and its employees. All personnel with access to personal data is bound to confidentiality and this bond persists even after cooperation with Transfer Money Technologies is terminated.

6.2. As an administrator, Transfer Money Technologies authorizes other subjects, called processors, to process personal data. “Processor” means any subject who processes personal data on behalf of Transfer Money Technologies, and for the purposes specified by Transfer Money Technologies.

6.3. Transfer Money Technologies passes onto the processors only data which the processors absolutely need to carry out their services. Among processors that Transfer Money Technologies cooperates with, and by granting your consent for the specified purpose you agree with their involvement, are:

Processor Tool Purpose

Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA Google Adwords,

Google Analytics

Online marketing

Traffic analysis

The Rocket Science Group, LLC. 675 Ponce de Leon, Avenue NE, Suite 5000, Atlanta, GA 30308, USA Mailchimp Sending messages

Facebook Ireland Ltd., 4 Grand Canal Square, Dublin, Ireland Dublin 2 Facebook

Facebook Pixel

Facebook audience Online marketing

LinkedIn Ireland Unlimited Company LinkedIn Sending messages

Online marketing

Seznam.cz, a.s., Sklik Online marketing

Workable Software Limited, 21a Kingly Street, 2nd Floor, London, W1B 5QA Workable Records on candidates

6.4. Transfer of personal data to other countries (outside of the EU or of the European Economic Area) is based on suitable guarantees, standard contractual clauses, and, concerning the USA, on the merit of the “Privacy Shield” certification (https://www.privacyshield.gov).

7. NOTICE OF RIGHTS CONCERNING PERSONAL DATA

7.1. You acknowledge that you have the right to access your personal data. If you discover or presume that the administrator or processors authorized by the administrator process your personal data in violation of the protection of your personal life or in violation of the existing legislation, you have the right to ask the administrator or relevant processor for explanation, correction of the situation, blockage or limitation of the usage of your personal data, correction of your personal data, or for disposal or erasure of your personal data.

7.2. You acknowledge that you have the right to object to the processing of your personal data on the basis of legitimate interest (contract performance and improvement of the website).

7.3. You acknowledge that you have the right to obtain personal data you provided to us in a structured, commonly used and machine-readable format. You have the right to transfer this data to another administrator, and you have the right to ask the administrator to transfer this data to the other administrator directly, if it is technically feasible.

7.4. You acknowledge that you have the right to contact the administrator with any objections via email at tmtlead1@gmail.com, or contact directly the Supervisory Authority, which is the Office for Personal Data Protection (www.uoou.cz).

8. COOKIES, TECHNICAL AND OTHER TOOLS

8.1. You acknowledge that the administrator can use their own and third party technical data and tools to obtain data on websites and other communication channel usage (hereinafter “technical and anonymous data”), for the purpose of ensuring the functioning and quality standard of the website, to increase user comfort, as well as to carry out further analysis and development of the website. You acknowledge that these technical and anonymous data can be processed using third party tools, and can be made accessible to such third parties, even outside of the EU territory. The processing is based on the legitimate interest of the administrator to obtain statistical and technical information about the use of the website, and on the legitimate interest of showing visitors the most suitable advertisement.

8.2. Technical and anonymous data are mainly:

Cookies and other information stored at the User’s end. Cookies are text strings stored in the browser memory on the User’s computer. The saving of cookies can be disabled and the already saved cookies can be deleted via the web browser’s settings. The User can reject the possibility of storing cookies, but such action can decrease the user comfort or restrict some functions of the Service.

General information of the Service usage, such as IP address type, browser type, login and logout times, incoming and outgoing URL addresses etc., or anonymous data about the extent and means of the usage of the Service by the User. Anonymous data should represent data that cannot be connected with a specific user, be it in original or processed form.

8.3. For the purpose of the processing of statistics on website traffic, we use these tools: Google Analytics and AdWords, services provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, California, USA (hereinafter “Google”). Google Analytics uses cookies. Information on Service usage generated by a cookie file is, in this case, transferred and stored on Google servers in the USA. Google is entitled to use this information for evaluation of the website traffic, for reporting on activity of Users intended for the administrator, and also for purposes of providing other services related to activities on the website or to the usage of the internet in general. Google is entitled to provide this information to third parties, if it is required by law, or in the case where this third party processes such data for Google. Google is not entitled to link the IP address of a User to any other data that Google has available. By using the website, you consent to the processing of data by Google, in a manner and for purposes specified above.

8.4. For the purpose of placing relevant advertising, we use Google’s DoubleClick tool, operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter “DoubleClick”). DoubleClick uses cookies for placing relevant advertisements for Users, improving the reports on the campaign performance, or for preventing the User from seeing the same advertisement each time. Google uses the ID of the cookie file for keeping track of the advertisement shown in the browser and thus can prevent the same advertisement from being shown repeatedly.

8.5. On our website, we also use “Facebook Custom Audience” and “Facebook Pixel”, tools of the company Facebook Ireland Ltd., Hanover Reach, 5-7 Hanover Quay, Dublin 2, Ireland (hereinafter ” Facebook”). “Facebook Pixel” creates a direct connection to the Facebook servers. The information about you visiting the website is thus transferred to Facebook. Facebook assigns this information to your personal Facebook user account, if you have such an account and are logged in. If you visit other websites that use “Facebook Custom Audience” and/or “Facebook Pixel”, such information is also assigned to your user account. If you do not have a Facebook account or are not logged in while visiting our website, the information about your visit will not be assigned to any Facebook account. You can find more information about Facebook’s Privacy Policy at https://www.facebook.com/about/privacy/.

9. FINAL PROVISIONS

9.1. This Policy shall be governed by the law of the Czech Republic, including the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.

9.2. Should you have any comments on the processing of personal data or should you wish to exercise your rights, please contact Transfer Money Technologies via email at tmtlead1@gmail.com

9.3. This Policy comes into effect on 1.12.2019.