Personal Data Processing Instructions for Good Angels – Donors
The GOOD ANGEL foundation always processes personal data in compliance with the laws in force, i.e. Act No. 110/2019 Coll. (Personal Data Protection Act), and with effect as of May 25, 2018, also 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), which will replace the personal data protection act in certain respects (the “Regulation”).
Below, please find a summary of major information about the processing of your personal data that you provide to us in connection with your participation in the GOOD ANGEL system.
Personal Data Processing Instructions
Personal Data Administrator
DOBRÝ ANDĚL, nadace, with its registered office at Holečkova 3331/37, 150 00 Praha 5 – Smíchov, Business ID No. 24161501 (“GOOD ANGEL”), telephone: 733-119-119, e-mail: [email protected], website: https://www.dobryandel.cz.
Personal Data Representative
Pursuant to the Regulation, starting as of May 25, 2018, GOOD ANGEL will be required to appoint a personal data representative. The personal data representative’s contact details will be published here as of May 1, 2018 at the latest.
Scope of Personal Data Processing
GOOD ANGEL processes personal data received from each Donor via the registration form or otherwise, e.g. via telephone, in writing. The personal data subject to processing thus may include, in particular:
- Regular Personal Data: Name and surname, e-mail address, and if provided by the Donor, academic title, place of residence, telephone number, date and place of birth, personal and marital status, sex, size of municipality in which the Donor lives, bank account number, individual contribution payments, profile photograph, and also in connection with electronic access to the website and the GOOD ANGEL mobile application, IP address, cookies and the Donor’s device identifier (e.g. mobile telephone using the GOOD ANGEL application).
- Sensitive Personal Data or Special Category (Article 9 of the Regulation): None.
Purpose of Personal Data Processing and Legal Basis for Processing
The personal data of Donors is processed to secure the proper participation of Donors in the GOOD ANGEL System, i.e. particularly their registration, and the processing and allocation of their donations, and communication with the Donors, including issuing a receipt for income tax deduction purposes.
As part of this purpose of processing, the data will be processed in particular:
1) For identification of the Donor and their donation as per and to the extent of the data they provided so as to allow the Donor monitor to whom (Beneficiary/Beneficiaries) their donation was provided, and also in respect of any donations provided by the Donor in a period preceding registration,
2) For internal communication with the Donor (e.g. the distribution of news, automatically generated notices, acknowledgements and other messages, and the issuance of receipts for income tax deduction purposes),
3) For GOOD ANGEL’s external communication (e.g. for display on the list of Donors, for processing of statistical summaries about Donors and provided donations, or for other information to the extent approved by the Donor),
all by virtue of the personal data processing consent granted to GOOD ANGEL by the Donor or their statutory representative, and further
4) In connection with the statutory compliance of GOOD ANGEL, as required, currently or in the future, by Czech laws and/or EU law, or
5) Where necessary to protect the rights and legal titles of GOOD ANGEL (pursuant to the Act), or for the sake of the justified interests of GOOD ANGEL or other persons (pursuant to the Regulation); justified interests, as envisaged in the Regulation, may again include, in particular, cases of the protection of the rights and legal titles of GOOD ANGEL.
In some cases, certain personal data may be used for public presentation and marketing activities of GOOD ANGEL in respect of current or potential donors or the public with the aim of boosting the participation of donors and obtaining donations and allocating them to the beneficiaries through the GOOD ANGEL System. However, the personal data will only be so used upon your special prior consent granted to GOOD ANGEL in the specific case.
GOOD ANGEL meets its obligations set out in Sections 358 and 359 of the Civil Code (Act No. 89/2012 Coll.), requiring them to specify in their annual report the name and surname and the total annual amount of donation of each Donor who donated in total more than CZK 10,000 per year. The Donor may send a request to GOOD ANGEL, in writing or via e-mail, asking GOOD ANGEL not to give such details in their annual report. Such request is best delivered to GOOD ANGEL by March 31 of the subsequent year, but by no later than the time the respective annual report is approved.
Personal Data Sources
The personal data intended for processing is obtained from Donors, particularly in connection with their registration with GOOD ANGEL or as part of further communication with Donors, whether personal, telephone, written or other, and from other underlying documents and materials provided by the Donor to GOOD ANGEL.
Recall of Consent to Personal Data Processing
The consent to the processing of personal data is always voluntary and the Donor is free to recall it at any time, whether in part or in full. The consent may be recalled via the Angel Account at www.dobryandel.cz (i.e. in the manner it was originally granted), or by means of a written notice sent to the address of GOOD ANGEL’s registered office or to their e-mail address, as given above.
As of the day GOOD ANGEL is notified of the recall of consent, GOOD ANGEL may only process the personal data to the extent required on other legal grounds, i.e. particularly in complying with GOOD ANGEL’s legal obligations or for the sake of the protection of rights and legal titles, as described above.
Subjects Processing Personal Data
Personal data is processed directly by GOOD ANGEL, in written and electronic form. Personal data may also be so processed for GOOD ANGEL by other entities in the position of “processors”, with whom the Administrator enters into a personal data processing agreement.
Providing Other Person with Access to Data
Personal data may be further made accessible to entities authorized under special law (e.g. law enforcement, judicial and penal authorities, etc.) and to persons in the position of personal data processors acting for GOOD ANGEL with whom GOOD ANGEL will cooperate in the provision of support. The current list of processors cooperating with GOOD ANGEL is available at www.dobryandel.cz/oou, or it may be sent by GOOD ANGEL to the Donor, at their request, to the Donor’s e-mail address.
Upon the special prior consent of the data subject, personal data may also be made accessible to other persons, or to the public, in connection with the public presentation and marketing activities of the Administrator.
Period Covered by Consent of Data Subject to Process Personal Data, and Period of Keeping Personal Data
The Donor gives their consent to processing for the entire duration of their participation in the GOOD ANGEL System. The period for which the consent is granted also ends upon the recall of the consent (see also above).
Personal data will be processed and kept for the entire duration of the Donor’s participation in the GOOD ANGEL System. After the Donor’s participation in the GOOD ANGEL System is terminated, GOOD ANGEL will keep the personal data for 5 years following termination of such participation.
Other Information about Rights in Personal Data Processing Context
In addition to the rights described above, the persons - data subjects - whose personal data is processed by GOOD ANGEL are granted, by the Act and the Regulation, also the particular rights summarized below. In exercising such rights, GOOD ANGEL strives to accommodate the data subjects to the maximum extent possible.
Right to Personal Data Access pursuant to Section 12 of Act: If the data subject asks to be informed of the processing of their personal data, GOOD ANGEL is obligated to provide them with such information (always containing a notice pursuant to Section 12(2) of the Act) without undue delay.
Right to Protection pursuant to Section 21 of Act: Every subject who finds out or suspects that the Administrator is processing their personal data in a manner disrupting the protection of the private life of the subject or at variance with the law, particularly if the personal data is inaccurate within the context of the processing purpose, the subject may ask the Administrator or processor for an explanation or demand that the Administrator or processor remedy such situation (particularly by blocking, correcting, adding or deleting the personal data).
Pursuant to the Regulation, the data subject enjoys the following rights, in particular:
Right to Access Personal Data: The data subject is entitled to demand confirmation from GOOD ANGEL whether GOOD ANGEL processes their personal data, and if so, the data subject is authorized to seek access to such data.
Right to Correction or Deletion, or Limitation of Processing: The data subject is authorized (in those cases set out by the Regulation) to ask GOOD ANGEL to correct or supplement any incorrect or incomplete personal data, respectively, ask for deletion of the personal data, where the reason for processing has ceased to exist or does not exist at all, or ask for only limited processing of the personal data in the context of dealing with circumstances around the process of personal data processing at GOOD ANGEL.
Right to Raise Objection: For reasons related to their specific situation, the data subject may at any time raise an objection with GOOD ANGEL to the processing of their personal data processed for the sake of the justified interests of GOOD ANGEL or other persons (under the Regulation); justified interests, as envisaged by the Regulation, may include, in particular, the cases of the protection of the rights and legal titles of GOOD ANGEL.
Right to Data Transferability: The data subject (subject to terms set out in the Regulation) may request that GOOD ANGEL provide them with their personal data, and hand the same over to a different personal data administrator.
Right to Complain to Supervisory Authority: If the data subject suspects that the processing of their personal data results in a violation of the Regulation, they may complain to the supervisory authority. The supervisory authority for data subjects residing in the Czech Republic is the Office for Personal Data Protection.
The current Personal Data Protection Instructions (last update on January 12, 2018) are always available at www.dobryandel.cz.
If you have any questions or find any of the above information unclear, please do not hesitate to contact us. We are happy to assist you.
Personal Data Representative:
Algotech a. s.
Sokolovská 668/136d, Praha 8
List of Personal Data Processing Entities Cooperating with GOOD ANGEL is available here (bottom of the page).