INFORMATION ON THE PROCESSING OF PERSONAL DATA

T.E Development Group s.r.o., Company ID No. (IČ): 03496147, with its registered office at Strakonická 1199/2d, 150 00 Prague 5 - Hlubočepy, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. C 231831 (hereinafter referred to as “T.E Development Group”) and other companies in the T.E Group that, in addition to T.E Development Group, includes the companies T.E Bleriot s.r.o., Company ID No. (IČ): 04549678, with its registered office at Strakonická 1199/2 d, Hlubočepy, 150 00 Prague 5, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. C 249562, Top.Estates Sakura s.r.o., Company ID No. (IČ): 24202401, with its registered office at Strakonická 1199/2 d, Hlubočepy, 150 00 Prague 5, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. 188214, Top.Estates Carpentry s.r.o., Company ID No. (IČ): 035 14 706, with its registered office at Strakonická 1199/2 d, Hlubočepy, 150 00 Prague 5, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. C 232549, Top.Estates Zahrada s.r.o., Company ID No. (IČ): 041 86 231, with its registered office at Strakonická 1199/2 d, Hlubočepy, 150 00 Prague 5, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. C 243848, Top.Estates Barrandov a.s., Company ID No. (IČ): 277 51 091, with its registered office at Strakonická 1199/2 d, Hlubočepy, 150 00 Prague 5, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. B 5080, Top.Estates Projekt 05 s.r.o., Company ID No. (IČ): 04553217, with its registered office at Strakonická 1199/2 d, Hlubočepy, 150 00 Prague 5, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. C 249609, T.E Construction Management s.r.o., Company ID No. (IČ): 041 86 389, with its registered office at Strakonická 1199/2 d, Hlubočepy, 150 00 Prague 5, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. C 243850, HomeSKR s.r.o., Company ID No. (IČ): 04992784, with its registered office at Strakonická 1199/2 d, Hlubočepy, 150 00 Prague 5, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. C 256726)

(hereinafter referred to as the “T.E Group”)




Dear Sir or Madam,

Thank you for the confidence that you have shown us by granting your approval for the processing of your personal data for its use for information, communication and ensuring the smooth realisation of the product you selected, or the product pursuant to the contract regarding a product we offer, and/or for use for the purpose of offering products and services, i.e. for marketing purposes of the T.E Group and the third parties specified below. In the following text we will bring you detailed information that is important for the proper understanding of the granted approval.

The T.E Group fully respects your right to privacy when visiting our web pages, and if you will be communicating with us personally, by telephone and/or electronically. We use all the necessary measures and do our utmost to secure all the personal information that you give us.

We need this approval from you so that, in light of the requirements of the new European legislation for the area of the protection of personal data (EU Regulation No. 2016/679) and the subsequent and related Czech legislation, we can ensure the information, communication and the smooth realisation of the product you selected, or the product pursuant to the contract regarding a product we offer, and/or for use for the purpose of tailored offers of our products and services and, on the contrary, so that you are not encumbered with offers that might not interest you.


The following is explained in the document:

1. What information do we process for marketing and business purposes?

2. From what sources does this data come?

3. For what purposes do you grant this approval?

4. To whom are you granting the approval?

5. Who can process your data?

6. How long do we store the personal data?

7. How can you withdraw your approval?

8. What are your legal rights during the processing of your personal data?


What information do we process for marketing and business purposes?

We are open to you, and therefore it is important to us that you know how we process your personal data and for what purposes we use it. The data that we will be processing on the basis of your approval contains: name and surname, birth certificate number (for businesses also the company name, company ID No. (IČ) and registered office), date of birth, contact information, socio-demographic data, data on the use of products and services, data from the request for products and services, information from the recordings of telephone calls or other interactions between you and us, transaction data (bank account number and your banking entity), geo-location data, data from the Internet browser that you use and the data that we process for the fulfilment of our legal obligations or for the purpose of our legitimate interests. This is data that we obtain directly from you, from public sources (including information from social networks and the Internet that you publish about yourself), from surveys and user testing or from cooperation with third parties.

In the following section we will explain what personal data this applies to, including examples:

Basic identification data

Primarily your name, surname, birth certificate number and date or place of birth (if you are running your own business, it can also be your Company ID No. (IČ) and address of your place of business) are important for us so that we are sure that we are truly contacting the right person. Plus, we would like to address you by your name.

Contact data

In particular the delivery address, telephone number and e-mail address are necessary so that we are able to deliver our information, offer or communication.

Socio-demographic data

This is classic statistical data, for example your place of residence, sex, marital status (single, divorced…), etc. You inform us of this data when searching for products or we deduce them from other data that we have about you.

Transaction data

Our systems record every payment meant for the purchase of our products, including the account number from which the payment was sent.

Direct channels, data from Internet browser and applications

In addition to visits to the offices of T.E Development Group and/or the T.E Group or telephone contact, you can also contact us through e-mail communication and/or through social networks (e.g. Facebook, Instagram, Twitter, LinkedIn) and also, for example, through contact forms and forms for subscribing to the newsletter on the website and forms on social networks (e.g. FB Lead Ads).

When you log on, you automatically send your computer’s IP Address. Thus we are able to detect the network and subnet numbers in which your computer is located. If you permitted the storage of cookies in your browser, you send us other information through them, e.g. about the pages that you visit, about the user preferences on your computer, etc. For the optimal display of our webpages and services, we use information about your operating system (e.g. Windows or macOS), its version and technical data on the devices from which you log in (e.g. the type of your smart phone). This helps to constantly improve our services and to adapt them to your technical possibilities.

Information on the use of products and services

For better targeting in our campaigns, we use information about which products you have already negotiated with us, when you negotiated them, under which conditions, whether you still use them, or if you have cancelled them. We know how often you log into our web-based application and if you have performed some action in its environment (e.g. setting up a meeting with the advisor) or whether you logged off after a while.

Data on contact with you

In order to avoid contacting you multiple times for the same reason, we record information about contacts between you and us. This is primarily information such as the date (and time) of the contact, its reason and if you initiated the contact or we did. This applies to contacts over all channels – telephone, SMS, chat, mail, e-mail, data box, personal meeting with an advisor at a branch/consultation site or over a web-based or other application. If there was some offer on our part, we always record your reaction – if you liked the offer or not. This is so that we will not once again offer you a product that did not appeal to you. In the application used for this, we make notes from the discussions between you and our advisors for better orientation in your requirements.

Recordings from telephone calls

When you call us or we call you, we have to ask you for your subsequent approval with the recording of the call. In other cases, we must record calls with you in order to satisfy, for example, a legal obligation or so that we can demonstrate to you that we proceeded precisely according to your instructions or that there truly was a valid conclusion to an agreement (or for other reasons falling under the category of “legitimate interests of the administrator”, see below). We will always inform you of this recording in advance. On the basis of your marketing approval, we can then also process these recordings for marketing purposes. We also transcribe the recordings into text form and subsequently perform a “text analysis”. From the analyses we store structured notes, for example what we spoke about together or how you reacted to a product offer – so that you will not have to repeat this to us in the future.

Information from social networks

When realising our marketing campaigns, we work, for example, with Facebook (hereinafter referred to as “FB”), LinkedIn, Instagram and Twitter. We do not store the data that you publish on your main page, but we use it for better targeting in our campaigns.

External sources

Sometimes our own data is not enough for suitable targeting. Thus, in order to be absolutely certain that our offer is suitable for you, we also use information from external sources. These are primarily publicly-available registers, for example the Commercial Register, the register of economic subjects, the register of debtors, professional registries, etc.

Surveys and user testing

When we prepare a new product or we want to know your opinion on our existing products and advertising, or we want to determine what services you would like, we ask you, our clients, directly in various surveys. The output from these surveys is the average results for the entire group of respondents, never on the level of individuals, but we also find inspiration in specific statements. For the development of new offers and/or services it is a bit different – apart from the fact that we ask the respondents how they like the new application proposals, we also perform user testing with them. These tests enable us to determine whether the application is interesting, but also if it is easy to use.

Data that we process about you for the purpose of fulfilling our legal obligations

This is data that we primarily have to collect, evaluate and store for a specified period, because it regards the fulfilment of our legislative obligation. This includes the archiving obligation according to various laws regulating the area of our business, acquiring and evaluating data for the needs of the fulfilment of obligations when preventing money laundering (e.g. KYC, “Know Your Client”) and a wide range of other laws. Examples include: the source and origin of income, capital links, citizenship, place of residence, subject of activities, etc. Based on your approval, we will also be able to process this data for marketing purposes.

From what sources does this data come?

The data processed as part of the approval comes from various sources. Most frequently it is provided by the client himself/herself. In a wide range of cases, the data for further processing is created by the T.E Group (analyses, reports, etc.). We also use other information that we get about the client as part of our activities, from public sources (e.g. public lists and registers, Internet applications, social networks, other public information sources) or from cooperating third parties. The T.E Group processes all of this data jointly and can also be shared among the controllers. This means, for example, that the information that you provide about yourself to an advisor from T.E Development Group is available for marketing purposes to other companies in the T.E Group. It also means that we also share the publicly-available information about you.


For what purposes do you grant this approval?

The purpose for the processing of the personal data is understood to be the offer of products and services provided by the T.E Group or the cooperating third parties specified below, also through electronic channels as well as marketing processing, analyses and profiling with the goal of adapting our offer to your needs and to arrange and improve the quality of the services we offer.

With the approval of the client we process his/her personal information primarily with the goal of ensuring the smooth realisation of the product you selected, or the product pursuant to a contract regarding a product we offer, and/or for use for the purpose of offers of products and services and the creation of suitable offers of products and services provided by the T.E Group. We do not want to burden our clients with needless and unsuitable communications, thus we use the gathered personal data to come to better know their needs and so that we are able to offer suitable products. It can be an offer of products, service communications, satisfaction surveys or birthday wishes.

We use a wide spectrum of channels for communication with you – classic mail, e-mail communication (individual e-mail messages and mass newsletters), telephone, SMS messages, communication on social networks or also “pop-up” windows in Internet applications.

Information on the use of our products and services help us to monitor and constantly improve their quality and to maintain the good favour of our clients. We also process the personal data of our clients to support business decisions and to identify commercial potential, to assess the suitability of an offer for a specific client, to submit offers, and to verify the proper functioning of products and services offered to clients in internal systems.

The actual utilisation of information precedes its processing. This is the marketing processing of the data. This can mean statistical or mathematical analyses with the goal of getting insight into the client’s behaviour and to estimate his/her future behaviour or commercial potential, as well as for profiling the client, various segmentation, reporting, etc. The processing can be either manual or automated.

In the event that you have also formerly granted or shall, in the future, grant marketing approval directly to the individual companies from the T.E Group (see above), the given specific company from the T.E Group will process the aforementioned data together with other data that it has about you for marketing purposes in connection with the products and services they offer.


To whom are you granting the approval?

You grant your approval to T.E Development Group, and other companies in the T.E Group, specified right in the introduction to this Information on the Processing of Personal Data, which are: T.E Bleriot s.r.o., Company ID No. (IČ): 04549678, with its registered office at Strakonická 1199/2 d, Hlubočepy, 150 00 Prague 5, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. C 249562, Top.Estates Sakura s.r.o., Company ID No. (IČ): 24202401, with its registered office at Strakonická 1199/2 d, Hlubočepy, 150 00 Prague 5, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. C 188214, Top.Estates Carpentry s.r.o., Company ID No. (IČ): 035 14 706, with its registered office at Strakonická 1199/2 d, Hlubočepy, 150 00 Prague 5, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. C 232549, Top.Estates Zahrada s.r.o., Company ID No. (IČ): 041 86 231, with its registered office at Strakonická 1199/2 d, Hlubočepy, 150 00 Prague 5, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. C 243848, Top.Estates Barrandov a.s., Company ID No. (IČ): 277 51 091, with its registered office at Strakonická 1199/2 d, Hlubočepy, 150 00 Prague 5, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. B 5080, Top.Estates Projekt 05 s.r.o., Company ID No. (IČ): 04553217, with its registered office at Strakonická 1199/2 d, Hlubočepy, 150 00 Prague 5, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. C 249609, T.E Construction Management s.r.o., Company ID No. (IČ): 041 86 389, with its registered office at Strakonická 1199/2 d, Hlubočepy, 150 00 Prague 5, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. C 243850, HomeSKR s.r.o., Company ID No. (IČ): 04992784, with its registered office at Strakonická 1199/2 d, Hlubočepy, 150 00 Prague 5, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. C 256726) and also third parties, i.e. commercial entities and individuals cooperating with T.E Development and/or with companies of the T.E Group or with some or all of them, as the processors (see Article 5 below).

In accordance with the legal definition, the controller is the controller of the personal data of each subject, who specifies the purpose and means for processing the personal data and performs the collection, processing and storage of it for its specified purpose.

All of the aforementioned companies act as the “joint” controllers of your personal data. For the purposes specified in the approval, they can therefore share and process the data given in the approval.

It is not possible to choose to which companies the approval will be granted and which not when granting the approval or later. Thus we will consider your disapproval with the inclusion of only some of the specified “joint” controllers to be the refusal to grant or the withdrawal of this marketing approval.


Who can process your data?

The regulation of the protection of personal data makes it possible for the controller to entrust the processing of the personal data to processors. A processor of personal data is any subject that processes the personal data on the basis of a special law or authorisation or power of attorney from the controller. Companies of the T.E Group also use this procedure in some cases when processing the personal data for marketing and/or commercial purposes. In these cases the same protection of your personal data as that on the part of the controller is guaranteed contractually and by regulations. The most important processers that the companies of the T.E Group use for the processing of the personal data for marketing or commercial purposes include the following companies: Design&Co, s.r.o., Company ID No. (IČ): 29021235, with its registered office at Klimentská 1207/10, 110 00 Prague 1 - Nové Město, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. C 160497, EASYCORE MEDIA LTD, with its registered office at Kemp house 152-160, City Road, London EC 1V 2NX, United Kingdom of Great Britain and Northern Ireland, registration number: 7992430, acting on the territory of the Czech Republic through the branch EASYCORE MEDIA LTD, organizační složka, Company ID No. (IČ): 02511371, with its registered office at Svatoslavova 849/24, 140 00 Prague 4 - Nusle, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. A 76420, KOFEIN s.r.o., Company ID No. (IČ): 03055540, with its registered office at Chrudimská 2526/2a, 130 00 Prague 3 - Vinohrady, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. C 226903, Breezy s.r.o., Company ID No. (IČ): 27733823, with its registered office at Plzeňská 157/98, 150 00 Prague 5 - Košíře, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. C 163153.


How long do we store the personal data?

You grant approval to T.E Development Group and to other companies in the T.E Group and it remains valid and in effect for the period our offer is open and the approval is granted and/or until the termination of the implementation from the contract regarding the product you selected from the offer and the following three (3) years or until you withdraw your approval.

If you do not become our client (i.e. a contractual relation will not be concluded with T.E Development Group or another company of the T.E Group), your approval will be valid for three (3) years from the date it is granted. After the expiration of the validity and effect of the approval, your personal data will be deleted or only processed in the extent and for the purposes for which approval is not required pursuant to legal regulations.


How can you withdraw your approval?

Approval is voluntary. You can refuse to grant it or withdraw your granted approval at any time, specifically at T.E Development Group or at any company of the T.E Group. Not granting or withdrawing approval has no consequences on your contractual relations with any of these companies or on the use of their products and services for which this approval is not required. If you withdraw the approval from one of these companies, this withdrawal will apply to the other companies, which means that after this date, none of them will be able to continue to process your personal data for the purposes specified in the approval. If you withdraw your approval we will work from the assumption that you no longer wish for use to continue to process your personal data for marketing and/or commercial purposes, not even on the basis of any earlier granted approvals or any specific approvals. We will consider these other marketing and/or commercial approvals to be also withdrawn.


What are your legal rights during the processing of your personal data?

You have the right to ask us to provide information on the personal data about you that is processed, the purpose and the nature of the processing of the personal data and on the recipients of the personal data. If you determine and/or feel that we are performing the processing of your personal data contrary to the protection of your private and/or personal life and/or contrary to the legal regulations, you are entitled to ask for an explanation or to ask for this defective state to be rectified. In the event of a breach of our obligations, you also have the right to turn to the Office for Personal Data Protection with a request to ensure remedial measures.






T.E Development Group s.r.o., Company ID No. (IČ): 03496147, with its registered office at Strakonická 1199/2d, 150 00 Prague 5 - Hlubočepy, entered in the Commercial Register maintained by the Municipal Court in Prague, ref. no. C 231831 and the T.E Group