Privacy Policy

Dušan Sameliak, owner of the TORVAKO brand and the website www.torvako.com and provider of advisory and development services for management, is the controller of personal data within the meaning of Article 4(7) of Regulation (EU) 2016/679 of the European Parliament and of the Council (the General Data Protection Regulation, “GDPR”).

Data controller

Dušan Sameliak, company ID (IČ) 48863050, registered office at Fryčajova 542/135, Obřany, 614 00 Brno, Czech Republic, registered in the Czech Trade Register. Email: info@torvako.com.

The controller processes personal data in accordance with applicable law, in particular the GDPR, fairly, lawfully and transparently, only to the extent necessary, and protects it in a manner appropriate to its nature.

What personal data is

Personal data means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an email address or an online identifier.

What data we process and why

Newsletter

We process the email address you provide, together with your IP address and the time you gave your consent. The purpose is to send you TORVAKO insights and commentary. The legal basis is your consent under Article 6(1)(a) GDPR. You can unsubscribe at any time using the link in every email, which withdraws your consent.

After you subscribe, we send you a confirmation email. You are added to the list only after you confirm the subscription by clicking the link in it.

Contact form

We process your name, email address, your company name if provided, the content of your message, and your IP address and the time of sending. The purpose is to handle your enquiry and to communicate with you. The legal basis is steps taken at your request prior to entering into a contract and the legitimate interest of the controller under Article 6(1)(b) and (f) GDPR.

Diagnostic on the website

When you complete the diagnostic, we process your answers to the questionnaire, the information about your role and organisation that you provide in it, and a hashed form of your IP address. If you request a report, we also process your email address. The purpose is to prepare and send you the report. The legal basis is your consent under Article 6(1)(a) and steps taken prior to entering into a contract under Article 6(1)(b) GDPR.

We also evaluate diagnostic answers in aggregate and without linking them to a specific person, in order to improve our methodology. The legal basis is the legitimate interest of the controller under Article 6(1)(f) GDPR. We add you to the newsletter list only if you explicitly ask for it in the diagnostic.

Surveys at events

At conferences and workshops we may invite you to complete a short online check. We process your answers, the information about your organisation that you provide in it (such as country, size and the brands you sell) and, if you ask for your results by email, your email address. The purpose is to show you your own results and to prepare an anonymous summary for the participants and the organiser of the event. The organiser never sees individual answers, only summaries covering at least five organisations. The legal basis is your consent under Article 6(1)(a) GDPR. We add you to the newsletter list only if you explicitly ask for it.

Provision of services

When we agree on cooperation, we process the data necessary to conclude and perform the contract and for invoicing. The legal basis is performance of a contract under Article 6(1)(b) and compliance with the controller’s legal obligations, in particular in accounting, under Article 6(1)(c) GDPR.

Using the website and cookies

When you browse the website, we may record your IP address, the length of your visit and where your visit came from. We use cookies that are strictly necessary for the website to work on the basis of the controller’s legitimate interest. We use cookies for measuring traffic only with your consent, which you give in the cookie bar and can withdraw at any time. You can also block cookies in your browser settings.

We use Google Analytics to measure traffic. With your consent, it processes information about which pages you view, for how long and from which device, together with a random browser identifier. The purpose is to understand how the website is used and to improve it. The legal basis is your consent under Article 6(1)(a) GDPR.

We remember your language choice in a cookie for one year, so that the website opens in the language you selected. Your choice in the cookie bar and whether you have already subscribed are stored only in your browser’s local storage, so that the website does not ask you again. If you give your consent in the cookie bar, we also store there the email address you entered in a form, so that it is filled in for you next time. You can delete them at any time by clearing your browser data.

The controller does not carry out automated individual decision-making within the meaning of Article 22 GDPR.

Processors

For some processing we use trusted processors with whom we have concluded a data processing agreement and who are bound by confidentiality. Current processors:

• ACTIVE 24, s.r.o., company ID 25115804: web hosting and website management.
• Google Ireland Limited: email and office tools (Google Workspace) and traffic measurement (Google Analytics).
• ECOMAIL.CZ, s.r.o., company ID 02762943: newsletter delivery.
• Accounting software provider: bookkeeping and compliance with statutory obligations.

Transfers outside the EU

Google may also process data in the United States. Such transfers are based on the EU-U.S. Data Privacy Framework, to which Google has committed, and on standard contractual clauses approved by the European Commission. Our other processors process data within the European Union.

Retention period

We process data for as long as necessary for the given purpose: for the newsletter until you withdraw your consent; for enquiries for the duration of our communication and then for the applicable limitation periods; for diagnostic answers and answers from surveys at events for no longer than three years from completion; for traffic measurement data for no longer than 14 months; for contractual and accounting data for the period required by law. After these periods, we delete the data.

Your rights

In connection with the processing of your personal data, you have in particular the right:

• of access to your personal data under Article 15 and to obtain a copy of the data processed;
• to rectification of inaccurate and completion of incomplete data under Article 16;
• to erasure under Article 17, if the data is no longer needed or you withdraw your consent;
• to restriction of processing under Article 18;
• to data portability under Article 20;
• to object to processing based on legitimate interest under Article 21;
• to lodge a complaint with a supervisory authority under Article 77. In the Czech Republic this is the Office for Personal Data Protection (Úřad pro ochranu osobních údajů), www.uoou.cz. You may also contact the supervisory authority in the EU member state where you live or work.

You can exercise your rights by email at info@torvako.com.

Changes to this policy

We may update this policy if the way we process data changes. The current version is always available on this page, with its effective date shown under the heading.

This is an English translation of the Czech Privacy Policy. In case of any discrepancy, the Czech version prevails.

If you have any question about the protection of your data, write to info@torvako.com. We will reply within two working days.