Privacy Policy

I. Introduction

CSPI International, z.s. (CSPII) with its registered office at Lidická 700/19, Veveří, 602 00 Brno, Company-ID 03570894 (hereinafter referred to as "CSPII"), as the controller of your personal data, bears responsibility for your privacy. Your data shall be handled with due care and in line with legal obligations. These principles are processed in accordance with the Regulation of the European Parliament and EU Council 2016/679 as of 27th April 2016 on the protection of natural persons with regard to processing of personal data and the free movement of such data, and repealing the Directive 95/46/ES (GDPR).

By means of this document, CSPII intends to inform all data subjects on the manner of their personal data processing.

Based on the joint controllership agreement between the CSPI LLC and William B. French as one party, and CSPI International, z.s. as the other party, CSPI International, z.s. maintains the databases of the following personal data: the subscribers of the newsletter of the CSPI LLC and William B. French , people communicating and/or following social media accounts of the CSPI LLC and William B. French, buyers of books, audiobooks and eBooks of the CSPI LLC and William B. French.

II. General Principles

CSPII shall process your personal data always to the extent necessary for the given purpose. CSPII shall process personal data without your granted consent in the following cases:

a) CSPII is deemed to meet statutory obligations (e.g. the Accounting Act);
b) The data is needed for performance of our mutual agreement;
c) CSPII has a legitimate interest in its processing.

In other cases, CSPII shall process the data on the basis of your consent.

CSPII shall process personal data in order to properly secure it against any unauthorized access to the data, random loss, destruction, or damage. CSPII shall handle personal data only for the period that is strictly necessary.

III. Purpose of the Personal Data Processing

What is the purpose of personal data processing by CSPII?

1. Personal data of CSPII members shall be processed by CSPII particularly in order to enable performance of the rights related to the membership at CSPII as well as the possibility to review whether obligations resulting from the membership at CSPII are fulfilled or not. Thus, the legal ground for processing of personal data is the fulfilment of the provisions of the agreement (art. 6 (1)(b) GDPR).
2. CSPII shall process the personal data of its donors in order to keep internal records of donations or give confirmation of a donation (in case the donor requests it). Thus, legal grounds for the processing of personal data is fulfilment of the provisions of the agreement (art. 6 (1)(b)) and of legal obligations (art. 6 (1)(c) of GDPR).
3. CSPII shall process the personal data of the recipients of services and products (e.g. purchase of publications) as well as personal data of providers of services and products (e.g. translators) in order to conclude an agreement and consequently to provide subscription of the service/product. Thus, the legal grounds for the processing of personal data is fulfilment of the provisions of the agreement (art. 6 (1)(b) of the GDPR).
4. Personal data of the persons interested in receiving the newsletter, invitations, or other non-commercial notifications is processed in order to implement this activity. Thus, the legal grounds for the processing of personal data are in general the consent of the data subjects of (art. 6 (1)(b) of the GDPR) as well as the legitimate interested of CSPII (art. 6 (1)(f) of GDPR). In this case, the legitimate interest dwells in the possibility to make the interested persons acquainted with the relevant information regarding CSPII activities.
5. Personal data of the persons interested in the CSPII membership is processed in order to assess the possibility to accept such a member including assessment of the consistency of the values and the personal mindset of the applicant corresponding to the values and visions of CSPII. Thus, legal grounds for processing of the personal data are pre-contractual steps at the request of the data subject prior to entering into a contract and the legitimate interest of CSPII (art. 6 (1)(b) and (f) of the GDPR).
6. In line with implementation of the main activities of CSPII, personal data is gathered from publicly accessible resources (particularly the Internet) in some cases. This may concern, for instance, journalists or other publicly active persons. Such personal data is processed on the basis of legitimate interest of CSPII (art. 6 (1)(f) of the GDPR).
7. Personal data of the persons interested in participating in educational activities, incl. courses, webinars, trainings, etc. is processed in order to implement this activity. Thus, the legal grounds for the processing of personal data are in general the consent of the data subjects of (art. 6 (1)(b) of the GDPR) as well as the legitimate interest of CSPII (art. 6 (1)(f) of GDPR). In this case, the legitimate interest dwells in the possibility to make the interested persons acquainted with the relevant information regarding the CSPII activities.
8. Furthermore, CSPII shall process the personal data of the data subjects (members as well as contracted partners) in order to eventually justify its own interests in any juridical, administrative, or criminal proceedings. Thus, the legal grounds for the processing of personal data is the legitimate interest of CSPII (art. 6 (1)(f) GDPR). Legitimate interest dwells in the possibility to protect CSPII rights.
9. CSPII is obliged to process accounting documents and records containing the personal data of data subjects in order to meet the obligations abide by Act No. 563/1991 Coll., on Accounting. Thus, the legal grounds for the processing of personal data is the fulfilment of legal obligations (art. 6 (1)(c) of the GDPR).

IV. Scope of Processing of the Personal Data

What personal data shall CSPII process?

1. In order to enable performance of rights concerning membership at CSPII as well as the possibility to check performance of obligations resulting from membership, CSPII shall process the following personal data: first and last name, e-mail, phone number, permanent address. Some contact details of the member may be disclosed with his/her consent on the website, in invitations to various events, or other CSPII materials if it is a consequence of the particular activity or a function of the member within the CSPII organization.
2. In order to keep records of donations and donors, CSPII shall process the data the donor provided concerning the donation and the data on the amount of the provided monetary donation (or eventually other information identifying non-monetary donation). The donor is not obliged to provide data on its identity if the donor wishes to stay anonymous and in this case, the donor shall not require CSPII to issue confirmation of the provided donation.
3. In order to conclude the agreement and provide a service/product, CSPII shall process in general the following personal data: first and last name, e-mail, phone number, Company-ID, VAT-ID, delivery address, billing address, information on the payment made, information on the service/product ordered.
4. In order to send the newsletter or invitations or other non-commercial notifications, CSPII shall in general process the following personal data: first and last name, e-mail, phone number or correspondence address.
5. In order to assess the application of the person interested in the membership at CSPII, the following personal data is in general needed: the first and the last name, e-mail, phone number, permanent address, CV (including a photography), data from freely accessible resources (e.g. business social networks).
6. In order to implement the main activities of CSPII, the following personal data is in general processed and received from freely accessible resources: first and last name, e-mail, phone number.
7. In order to organize participation in educational activities, incl. courses, webinars, trainings, etc. the following personal data is in general needed: first and last name, e-mail, phone number or correspondence address.
8. In order to defend own interests in the juridical, administrative or criminal proceedings CSPII shall in general process the following personal data: first and last name, e-mail, phone number, Company-ID, VAT-ID, delivery address, billing address, information on the payment made, information on the service/product ordered, information on the delivery of the product/ provision of a service, information on possible complaints and the manner of their processing.
9. In order to meet the obligations pursuant to the Act No. 563/1991 Coll., on Accounting, CSPII shall process accounting documents and accounting records.

V. Period Needed for Personal Data Processing

How long shall CSPII process your personal data for?

1) Personal data processing is terminated and personal data will be disposed of without undue delay:

a) once the purpose of the personal data processing has ceased,

b) on the basis of the application of the data subject if

(A) it is not needed for the purposes it was gathered or otherwise processed;
(B) the data subject has withdrawn its consent for its processing;
(C) the data subject raised an objection against his/her personal data being processed;
(D) the processing of his/her personal data contradicts Legal Regulations regarding protection of the personal data due to other reasons.

c) after lapse of time for which the personal data was stored pursuant to the provisions indicated in the respective legal regulations and/or the following guidelines:

VI. Recipients of the Personal Data

Who may receive your personal data?

Categories of recipients of personal data include: members of CSPII who as part of meeting obligations resulting from the job role have access to personal data, service providers who on the basis of contractual relationship have the access to personal data granted by CSPII, and public institutions and authorities in connection to legal reporting obligations of the CSPII (such as, for example, tax authorities).

VII. Data Subject' Rights and the Manner of Their Application

What rights shall the data subject have with regard to personal data processing?

The data subject is entitled to withdraw his/her consent for personal data processing.

The data subject is entitled to require deletion of the personal data that CSPII processes.

As the personal data controller, CSPII is obliged to delete personal data without undue delay if:

a) the personal data is not needed anymore for the purpose it was gathered or processed;
b) the data subject has withdrawn its consent on the basis hereof the personal data was processed and there is not any other lawful reason for processing;
c) the data subject raised an objection against processing and there are not any prevailing lawful reasons for the controller to process the data;
d) the personal data was illegally processed;
e) the personal data has to be deleted in order to fulfill statutory obligations abide by the European Union law or a law of a membership country related to the controller.

CSPII cannot agree with personal data deletion if the data processing is necessary for meeting statutory obligations due to public interest in the area of public health or in order to determine, perform, or defend legal claims.

The data subject is entitled to access the personal data that CSPII processes. On the basis of a request also in the future, CSPII shall provide the data subject (for the period CSPII is deemed to process the personal data) with the information on the following:

a) the purpose for which the personal data is processed;
b) the category of the respective personal data;
c) any possible recipients or recipient categories that may access the personal data, in particular the recipients in the third countries or international organizations;
d) planned time frame during which CSPII stores the personal data or the criteria used for determination of such a time frame;
e) the existence of the right to require correction or deletion of the personal data or restriction of its processing or to raise an objection against such processing;
f) the right to raise an objection with the supervisory authority;
g) whether decision-making is automated, including profiling that has legal effects on the data subject or that significantly affects the data subject; in these cases, at least reasonable information regarding the method used as well as the significance and expected consequences of such processing on the data subject is needed.

The data subject is entitled to correction of the personal data that CSPII has processed. Upon request, CSPII shall correct inaccurate personal data that has been processed.

The data subject is entitled to raise an objection against personal data processing that is necessary for fulfillment of the task performed in the public interest or when exercising public power assigned to CSPII as well as the personal data processing affecting the data subject that is necessary in order to perform legitimate interests of CSPII. In this case, CSPII shall not process the personal data concerned if there are not any serious reasons proven that prevail over the interests or rights and freedoms of CSPII or in order to determine, perform, or defend legal claims of CSPII.

The data subject is entitled for restricting personal data processing by CSPII. CSPII shall restrict personal data processing if:

a) the data subject denies accuracy of the personal data for the time necessary for CSPII to verify accuracy of the personal data;
b) personal data processing is illegal and the data subject refuses deletion of the personal data and requests restriction of its use instead;
c) CSPII does not need the personal data any more for processing but the data subject requires it for determination, performance, or defense of legal claims;
d) the data subject raised an objection against the personal data processing concerned which is necessary for performing the task in public interest or exercising public power CSPII is appointed to as well as the personal data processing concerned and necessary for CSPII to perform its entitled interests, including profiling based on these regulations until it is verified whether the legitimate reasons of the controller prevail over the legitimate reasons of the data subjects.

If personal data processing is restricted, this personal data may be processed (with exception of their saving) only with the consent of the data subject or due to determination, performance, or defense of legal claims, due to protection of rights of another natural or legal person or due to essential public interest of the European Union or a membership country.

The data subject is entitled to portability of the personal data that CSPII processes. Upon request, CSPII shall submit the personal data of the data subject to another controller assigned by the data subject in a structured, regularly used, and machine-readable format. Nevertheless, performance of the right of portability cannot unfavorably affect the rights and freedoms of other persons.

The data subject may claim all aforementioned rights via an email to the e-mail [email protected] or via a letter to the aforementioned CSPII address. The application shall be handled without undue delay at least within one month from receipt. In exceptional cases, with regard to complexity and the amount of applications, CSPII may prolong the period by another two months (CSPII shall inform the data subject without undue delay about this matter).

What is the procedure if the data subject is not satisfied with the manner in which his/her personal data is processed by CSPII?

If the data subject is not satisfied with the manner in which personal data is processed by CSPII, meaning if he/she considers that CSPII proceeds in an illegal way or there was a breach of some rights, he/she may contact the supervisory authority with his/her complaint. In the Czech Republic, this ranks among the competence of the Office for Personal Data Protection (with its registered office at Pplk. Sochora 27, 170 00 Prague 7; www: https://www.uoou.cz).

VIII. Other Information

How does CSPII deal with your personal data?

Your data can be transferred to one or more countries within or outside the EU and processed there.

We only transfer your data to countries outside the EU where we operate if needed and if the European Commission is of the opinion that there is an adequate level of data protection inr these countries (a list of these countries can be found here: https://ec.europa.eu/info/law/law-topic/data-protection_en) or if the CSPII has established suitable security measures to protect the confidentiality of your information in the event of a data transfer.

Cookies and Google Analytics

The data subject that visits the CSPII website acknowledges that cookies may be saved by the company Google LLC, Nextcloud GmbH, or other companies at his/her device. Cookies are small text files without which CSPII is unable to ensure full functionality of the website. Apart from that, cookies are processed protocol log files saved at CSPII servers. The saved information includes, for instance, IP address, the webpage of the CSPII website being opened, http status code, and identification of the data subject's computer. This information shall be processed automatically as part of the operation of the Internet server with the purpose of its faultless run.

Most browsers are configured to automatically accept cookies. You may deactivate this setting so cookies are not stored by your browser and you may erase cookies at any time. Please note that without cookies, the use and experience of our services via this website may be impeded or impossible. Via your browser settings, you can also prevent certain cookies (such as third-party-cookies) from being stored, e.g. if you want to prevent web tracking. You will find further information in your browser’s help section.

Our website uses Google Analytics, a web analytics service by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (Google). Google Analytics uses cookies in order to analyze your use of this website. The information about your use of this website is collected via cookies. It is usually transferred to and stored on servers of Google Inc. in the US. Prior to the transfer to the US, Google masks and thereby anonymizes your IP address within the territory of the EU or of the European Economic Area. Only in exceptional cases, the full IP address is sent to and masked by Google servers in the US. On behalf of the website provider, Google will use this information to analyze your use of the website, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage to the website provider. Google will not combine your IP address with any other data held by Google.

Social Media Plugins und Video Streaming

CSPII uses sharing plug-ins of Facebook and Twitter social networks and YouTube plug-in to connect with YouTube. The plug-ins have been deactivated on the web pages of CSPII as the default setting so that, during the accessing of a web page, no personal data shall be initially passed on to the providers of the plug-ins. Only by clicking on one of the symbols of the respective social networks shall you activate the plug-in. After activation, the content from the plug-in shall be transmitted by the social network directly to your browser and integrated by your browser into the website. The plug-ins can be deactivated at any time again via your browser settings (through deleting respective third-party cookies). You will find further information in your browser’s help section.

By integrating a plug-in, data are transmitted to the respective provider in an automated fashion and can be saved by this respective provider. The provider receives the notification that you have visited our website. This is done regardless of whether you have set up a user account on the respective social network and are logged-in there or not. If you have logged in to the social network, the provider can classify these data directly to your user account. The possibility exists that the respective providers of the plug-ins will use the data for the creation of usage profiles. CSPII has no influence on the data collected by the provider and the continued processing thereof. The purpose and scope of the data collection as well as the continued processing and use of the data by the providers of the plug-ins as well as your related rights and setting options in order to protect your private sphere can be found in the respective provider’s Data Protection Declarations.

Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA – for their privacy policy see http://de-de.facebook.com/privacy/explanation.php

Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA – for their privacy policy see https://twitter.com/privacy

YouTube LLC, 901 Cherry Ave. San Bruno, CA 94066 USA – for their privacy policy see https://policies.google.com/privacy?hl=en-GB&gl=uk

Secure Document Sharing

CSPII uses DocSend, a secure document sharing platform. If you are a viewer who views documents via a DocSend link provided by CSPII, CSPII automatically collects information about your interaction with the document. The information we collect includes:

a) Whether or not you have viewed or are viewing document;
b) Date and time you viewed the document;
c) Number of times and length of time document was viewed;
d) Which portions of the document were viewed; and
e) Your location.

In order to access document(s) that CSPII wants to share with viewers, a viewer may be asked to provide his or her email address upon opening a DocSend link provided by CSPII or viewer’s email address may be provided directly by CSPII. In the event that you as a viewer provide CSPII with this information, you do so in accordance with this GDPR and Information on Personal Data Processing.

CSPII has no influence on any data collected by DocSend and the continued processing thereof. The purpose and scope of the data collection as well as the continued processing and use of the data by DocSend as well as your related rights and setting options in order to protect your private sphere can be found in the respective provider’s Data Protection Declarations.

If the viewer resides in North America (the United States, Canada, and Mexico), Dropbox, Inc. acts as the service provider (for more see the DocSend privacy policy in the link bellow)

DocSend Inc., 351 California St, San Francisco, CA 94104, USA – for their privacy policy see https://www.docsend.com/privacy-policy/

IX. Final Provisions

All legal relations arising in line with the processing of personal data are governed by the Legal Order of the Czech Republic. The respective Czech courts are authorized to resolve any possible disputes between the data subject and CSPII.

This version of the GDPR principles becomes effective as of 20th of June 2024.