Privacy Policy

naboso, s.r.o., Company ID: 039 03 796, registered office: Jaselská 464/38, Bubeneč, 160 00 Prague 6, Czech Republic (hereinafter referred to as “we”) protects all personal data you provide during registration, ordering, and/or purchase (name, surname, address, telephone number, email) against misuse and processes them in accordance with applicable legislation. We would like to inform you about some new rules and information related to the European General Data Protection Regulation (GDPR), which is effective in the European Union, including the Czech Republic, from 25 May 2018. Your data security is our priority, and we want you to continue using all our services without restrictions.

This document provides a clear overview of what personal data we process about our customers when they register or place orders on our e-shop, the legal basis for processing, specific purposes, potential recipients of the data, and your rights. More detailed information, especially about other processing purposes, methods, processing periods, and your rights, is available at www.naboso.cz in the “Privacy Policy” section.

What personal data do we process?

We process the following personal data:

a) Identification data: name, surname, username, password;

b) Contact data: email address, telephone number, postal address, your social media profile;

c) Your settings: saved addresses, profiles, product/service reviews;

d) Order details: purchased products/services, delivery and payment methods including payment account number, claims data;

e) Behavioural data on our website: viewed items/services, clicked links, navigation and scrolling behaviour, device info (IP address and location, device ID, OS, screen resolution, browser and version), cookies and similar technologies;

f) Inferred data: derived from your behaviour and preferences, including shopping patterns and product/service preferences.

When you visit our website

We store and read small files (cookies) from your device. Cookies are small text files stored in your browser or on your device’s hard drive. Some cookies connect your activity during one browser session; these are deleted when you close your browser. Others remain stored and activate when you revisit a website. We also use pixel tags (web beacons), which function similarly but are embedded directly in web content. For simplicity, we refer to all such technologies as cookies hereafter.

Some cookies are set directly by our website and help us to:

• identify you across pages and visits (e.g. preserve your cart or login);
• record your consent to this policy or participation in surveys;
• ensure security (e.g. prevent misuse of your session);
• monitor, detect, and fix website malfunctions.

These cookies are essential. If you block them, the website may not function properly, and we may be unable to deliver our services.

We also store cookies to:

• track website traffic and performance, create statistics, and measure ad effectiveness;
• test new features on the website;
• personalize the content you see, e.g. previously viewed products and targeted offers;

Third-party cookies may be used to:

• track your behaviour across our site and others;
• show tailored offers and targeted advertising on other websites;
• integrate social media (e.g. Facebook “Like” buttons or social login).

You can reject these cookies via the “Cookie Settings” link in the footer at www.naboso.cz.

Behavioural data is also gathered via:

• IP address;
• MAC address;
• OS version and language settings;
• browser version and language settings;
• referring URL (previous page).

We process these data based on our legitimate interest in order to:

• improve the website and user experience;
• measure website traffic and advertising effectiveness;
• test new features before launch;
• prevent attacks and maintain data security.

This processing is limited in duration. You have the right to object.

If you consent, we may also use behavioural data for site personalization and targeted ads, and share them with advertising or social media networks (see sections Tailored Offers and Sharing with Social Networks).

A.1.1 Tailored Offers and Targeted Ads

If you consent during your visit without registering or placing an order, we use only behavioural data. If logged into your account, we combine this with other personal data.

A.1.2 Sharing Data with Social Media for Personalized Ads

Same rules apply: behavioural data may be used alone or in combination with other data if logged in.

A.1.3 Who We Share Data With

With your consent, we may share behavioural or personal data with:

• Seznam.cz, a.s., Radlická 3294/10, 150 00 Prague 5, Czech Republic
• Google LLC, 1600 Amphitheatre Parkway, CA 94043 Mountain View, USA
• Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland
• PRIA SYSTEM s.r.o., Nad Stráněmi 5656, 760 05 Zlín, Czech Republic
• Simplia s.r.o., Drtinova 557/10, 150 00 Prague 5, Czech Republic
• Heureka Shopping s.r.o., Karolinská 650/1, 186 00 Prague 8
• ABRA Flexi s.r.o., Jeremiášova 1422/7b, 155 00 Prague
• General Logistics Systems Czech Republic s.r.o., Průmyslová 5619/1, 586 01 Jihlava
• Zásilkovna s.r.o., Lihovarská 1060/12, 190 00 Prague 9
• Smartsupp.com, s.r.o., Šumavská 31, 602 00 Brno, Company ID: 03668681
• Twisto payments a.s., Újezd 450/40, 118 00 Prague 1, Company ID: 01615165

This consent is granted for a period of one year.

You acknowledge that:

• Your data is only processed with your voluntary consent, which you may withdraw anytime by emailing gdpr@twisto.cz or contacting Twisto’s Data Protection Officer.
• Withdrawal of consent does not affect previous lawful processing.
• Twisto can be reached at dotaz@twisto.cz, tel. +420 222 70 33 33, or in person at Sokolovská 47, 186 00 Prague 8.
• You have the right to access, rectify, erase, restrict, transfer, and object to the processing of your personal data under Regulation (EU) 2016/679 (GDPR).

1. Why do we process personal data and what authorizes us to do so?
2. If you register, order, or purchase from us

1) If you register or place an order, we process your identification, contact, and order data to perform a contract (no consent needed).

2) We also process your data based on our legitimate interest to display personalized offers and ads, even before a purchase. This includes data from previous sessions and segmentation based on your behaviour.

Sending Offers

If you do not opt out, we may send offers via email, SMS, phone, or post. These offers relate to our own products and services. We may combine contact data with behavioural and transactional data to ensure relevance.

Who Processes and Receives Your Data?

We act as the data controller. We also use processors acting under our instructions for:

a) cloud and technology services;

b) marketing tools for site optimization and personalization;

c) SMS/chat providers;

d) mailing and delivery providers.

Where Do We Get Your Data?

Most data is provided directly by you during your use of the site or communication with us. We also collect behavioural data through your activity.

Data Transfers Outside the EU

We may transfer your data outside the EEA only if the recipient commits to EU Standard Contractual Clauses, available at: http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087.

Your Rights

• Access: Learn what data we process and obtain a copy.
• Rectification: Request correction of inaccurate or incomplete data.
• Erasure: Request deletion if data is no longer needed or processing is unlawful.
• Restriction: Temporarily halt processing in certain cases.
• Objection: Object to processing based on legitimate interest, especially marketing.
• Complaint: Lodge a complaint with the Czech Data Protection Authority at Pplk. Sochora 27, 170 00 Prague 7.

Contact us for any personal data matters:

a) by email: info@naboso.cz

b) by phone: +420 223 013 609

We will respond without undue delay and no later than within one month. In exceptional cases, we may extend the deadline by up to two more months and will inform you accordingly.

These terms are effective from 22 May 2018.