DATA PROCESSING NOTICE

Please find below the privacy notice regarding the protection and processing of personal data processed by LTA in relation to the consulting services provided to its clients. To the extent necessary for the given purpose, we process personal data of our clients, suppliers, job applicants and employees. We may also process personal data of other persons for marketing purposes (such as sending of newsletters and invitations to educational events).

LTA consists of the following companies:

LTA Legal s.r.o.

Reg. no.: 24796166

Registered in the Commercial Register of the Municipal Court in Prague Section C, File 174994

Registered office: Praha – Vinohrady, Lazarská 13/8, 120 00

LTA Tax s.r.o.

Reg. no.: 24792730

Registered in the Commercial Register of the Municipal Court in Prague Section C, File 174679

Registered office: Praha – Vinohrady, Lazarská 13/8, 120 00

LTA Audit s.r.o.

Reg. no.: 24129275

Registered in the Commercial Register of the Municipal Court in Prague Section C, File 181252

Registered office: Praha – Vinohrady, Lazarská 13/8, 120 00

Each of the above companies is a separate data controller in relation to personal data (or the data of your employees, debtors, etc.) except when you provide us, as your accounting services provider, with personal data of third parties, in which case LTA Tax s.r.o. will be in the position of a personal data processor. In such a situation, LTA Tax s.r.o. will, as a general rule, provide you with a data processing agreement.

1. Legal bases for processing and purposes of processing

We process personal data in compliance with applicable legislation, in particular in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 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) („GDPR“) and Czech data protection legislation which supplements the GDPR.

The legal basis for the processing of your personal data is

  1. Article 6(1) a) GDPR – you have given your consent to personal data processing
  2. Article 6(1) b) GDPR – processing is necessary for the performance of a contract or for entering into a contract
  3. Article 6(1) c) GDPR – processing is necessary for compliance with a legal obligation
  4. Article 6(1) f) GDPR – processing is necessary for the purposes of legitimate interests of the controller

The scope and the purpose of the processing of your personal data depends on the legal basis on which you have provided your personal data to us:

  1. On the basis of the consent granted, we process your contact details, usually for the purpose of answering questions, sending of legal or tax newsletters for registered subscribers, and for the purpose of organizing and holding educational seminars or other training sessions for which you have registered.
  2. For our clients, we process contact and other personal details for the purpose of providing our services under a consultancy agreement. If you apply for a job at LTA, your personal data will be processed in relation to the recruitment process to allow us to contact you and possibly select you as a suitable candidate. Personal data of non-clients may also be processed if such processing immediately precedes conclusion of a contract and relates to steps taken prior to entering into the contract at the data subject’s request.
  3. If the legal basis for processing is an obligation imposed on us by applicable legislation, we may also process some of your personal data for tax and accounting purposes, but only in the scope which is strictly necessary under the law.
  4. On the basis of legitimate interest, we usually keep all documents received from you or form another source which contain personal data for 5 years after the end of processing based on another legal basis. We shall only keep your personal data for this purpose if it is necessary for the establishment, exercise or defence of our legal claims.

Direct marketing is considered a legitimate interest. If you are our client or have used our services in the past, we can inform you about our news or invite you to educational or other events that could be beneficial to you by using your contact details. You have the right to decline this form of contact at any time via any of the contact channels listed below.

Please note that all the legal bases for personal data processing listed above are without prejudice to our statutory duty of confidentiality, which remains unaffected. Any information which you may disclose to us will be shared with third parties only with your consent or, in exceptional events, to public authorities exercising their statutory powers if such a disclosure is required by law.

2. Sources and categories of personal data

Personal data may also be obtained from sources other than data subjects, e.g. from documents obtained from public registers or from other publicly available sources. However, personal data must always be processed in accordance with GDPR and other applicable legislation.

We process, in particular, the following categories of personal data: identification and contact data, employment-related data, billing and payment data and records of mutual communication. This information, and possibly other information, if necessary, is processed primarily for the purpose of performing audits or providing tax or legal advice.

3. Method of processing personal data

We process personal data both manually and by automated means.  Processing does not involve automated decision-making or profiling within the meaning of Article 22 of the GDPR.

4. Recipients of personal data

Personal data can be accessed by authorised employees of the LTA group and in some cases also by members of LTA’s statutory bodies, attorneys or tax advisors who are LTA’s permanent collaborators, cooperating law firms, public notaries, IT service providers and external translators. In justified cases, your personal data may also be transferred to carriers or may be shared internally within the LTA group for accounting purposes as the companies in the LTA group keep joint accounts. For pre-defined purposes, public authorities and providers of banking, insurance or other financial services may also become recipients of your personal data (for example when arranging for escrow account services and similar).

We have taken adequate organisational, technical and security measures to protect your personal data from loss, unauthorised access or misuse. Your personal data will not be transferred outside the Czech Republic, unless individually agreed otherwise.

5. Retention period of personal data

We keep your personal data for as long as necessary to meet the purpose for which you have provided us with that data. This retention period usually lasts for the duration of our cooperation. In case of certain personal data, the retention period may be extended for a longer period of time, usually between 5 and 10 years, if tax laws, accounting rules or other applicable legislation so require.

Personal data which are processed on the basis of a data subject’s consent will only be processed for as long as the consent is valid.

If applicable legislation does not require personal data to be processed for a certain additional period of time, we keep your personal data on the basis of our legitimate interest in the scope strictly necessary for that purpose for up to another 5 years after the termination of our contractual relationship.

6. Consequences of failure to provide personal data

If a data subject refuses to provide personal data required by law or necessary to provide the services requested, those services cannot be provided. Provision of personal data is voluntary, but in some cases necessary for the services to be provided. If we are not able to provide you with the service requested because you have refused to share your personal data with us, we will notify you, so that you can consider all the circumstances. Providing your consent to the processing of personal data is also completely voluntary.

7. Rights of data subjects

Under the terms defined in the GDPR you have the following rights relating to the processing of your personal data.

In case of any questions, please contact us via any of the contact channels listed below.

  1. Right to access personal data under Article 15 of the GDPR including the right to confirm whether your personal data has been processed by the controller. If we process your personal data, you have the right to access the personal data processed and to receive information listed in Article 15(1) of the GDPR and the right to obtain one free copy of the personal data that is being processed about you (additional copies may be subject to a fee).
  2. Right to rectification of personal data under Article 16 of the GDPR, i.e., the right to promptly have any personal data being processed by the controller rectified or completed if they are inaccurate or incomplete.
  3. Right to erasure of personal data under Article 17 of the GDPR; controller must erase your personal data without undue delay if any of the grounds for erasure of personal data listed in Article 17 of the GDPR are present. Personal data are erased mainly if they are no longer needed for the purposes for which they were collected or otherwise processed or if the personal data were processed unlawfully; exceptions listed in Article 17(3) of the GDPR apply.
  4. Right to restriction of processing of personal data in cases listed in Article 18 of the GDPR. This right applies in particular where you contest the accuracy of the personal data processed. It applies for the time necessary to verify the data‘s accuracy, where the processing of personal data is unlawful and you refuse to have the personal data erased or where the controller does not need the personal data for its own purposes of processing but you require the data for the establishment, exercise or defence of your own legal claims.
  5. Right to withdraw consent to the processing of your personal data under Article 7(3) of the GDPR at any time, preferably by email sent to the email address below. However, the withdrawal of your consent to personal data processing will not affect the lawfulness of processing based on consent given before the withdrawal.
  6. Right to personal data portability within the meaning under the terms of Article 20 of the GDPR, i.e. the right to obtain personal data which are processed by automated means in a structured, commonly used and machine-readable format and the right to have personal data transferred directly by the controller to another controller, provided that such a transfer is technically feasible.
  7. Right to object to personal data processing applies in situations when personal data are processed on the basis of the controller‘s legitimate interests or for purposes of direct marketing. The controller will be entitled to continue processing the data subject’s personal data after an objection has been raised only if it demonstrates that the processing is necessary for the establishment, exercise or defence of the controller’s legal claims or if it demonstrates compelling legitimate grounds for continued processing which override the interests or rights and freedoms of the data subject.
  8. Right to lodge a complaint with the supervisory authority under Article 77 of the GDPR; the supervisory authority in the Czech Republic is Úřad pro ochranu osobních údajů, address: Pplk. Sochora 727/27, 170 00 Praha 7, email address: posta@uoou.cz.

You can exercise all of the above rights by contacting us via any of the contact channels listed in Section 8 below.

8. Contact details

If you have any questions, requests or comments regarding the processing of your personal data or if you wish to exercise your rights as a data subject, please contact us through any of the following channels:

Email:                             LTA@LTApartners.com

Telephone:                  +420 246 089 010

Registered office:     LTA, Lazarská 13/8, 120 00 Praha 2, Czech Republic

If you are already one of our clients, you can also contact your LTA contact person at any time.