Personal Data Processing Policy These Personal Data Processing Policies are issued by BELO ENERGY s.r.o. in accordance with Regulation (EU) 2016/679 on the protection of natural persons in connection with the processing of personal data (“the Regulation” or “GDPR”) for the purpose of fulfilling the information obligation of BELO ENERGY s.r.o. as the data controller under Article 13 of the GDPR towards data subjects whose personal data BELO ENERGY s.r.o. processes in accordance with these policies and the GDPR.
  1. Personal Data Controller
Personal data is processed by BELO ENERGY s.r.o., registered office: U Trezorky 921/2, Jinonice, 158 00 Prague 5, Company ID: 17352975, registered in the Commercial Register maintained by the Municipal Court in Prague, Section C, File 370454, as the data controller, for the purposes, in the manner, on the legal basis and for the duration specified further in this policy.
  1. Controller’s Contact Details
When exercising their rights listed below, the data subject may contact the data controller in writing at the address BELO ENERGY s.r.o., U Trezorky 921/2, Jinonice, 158 00 Prague 5, or via e-mail at info@beloenergy.cz, or by calling the customer support line at +420 771 141 418.
  1. Categories of Data Subjects
Data subjects whose personal data BELO ENERGY s.r.o. processes include in particular:
  • customers of BELO ENERGY s.r.o.
  • employees and members of BELO ENERGY s.r.o.
  • transport and logistics partners
  • suppliers
  • business representatives of BELO ENERGY s.r.o.
  • other persons who are in contractual relationships with BELO ENERGY s.r.o.
  • persons with whom BELO ENERGY s.r.o. negotiates the conclusion of a contract or another legal relationship
  • job applicants
  1. Categories of Personal Data
A personal data item is any information relating to a natural person who can be identified by BELO ENERGY s.r.o. In connection with the provision of services and sale of products, BELO ENERGY s.r.o. may process in particular the following categories of personal data:
  • address and identification data necessary to uniquely identify the data subject (e.g. first name, last name, academic title, personal identification number, date of birth, permanent residence address, business address, mailing address, billing address, Company ID, VAT ID, bank details, identification data of a customer representative or contact person designated by the customer, contracts and signatures), data enabling contact with the data subject (contact details such as address, phone number, fax number, e-mail address and similar information), and other data necessary for contractual performance
  • data provided beyond statutory requirements and processed on the basis of consent from the data subject (processing of photographs, use of personal data for HR development purposes, signature patterns, photocopies of ID documents for the purpose of identifying a participant in a transaction, guarantee declarations with personal data)
  1. Purposes, Legal Grounds, and Retention Periods for Personal Data Processing
The scope of processed data depends on the purpose of the processing. For certain purposes, personal data may be processed directly on the basis of a contract, the legitimate interest of BELO ENERGY s.r.o., or a legal obligation (without requiring consent), while for other purposes processing is only possible on the basis of consent. Consent is not required for the processing of personal data necessary for the performance of a contract, compliance with legal obligations of BELO ENERGY s.r.o., or for the protection of the legitimate interests of BELO ENERGY s.r.o. A data subject may object to processing carried out for legitimate interests. Processing based on the performance of a contract or compliance with legal obligations cannot be refused. The main partial purposes include in particular:
  • employment and payroll administration (legal obligation);
  • accounting (legal obligation);
  • fulfilment of tax obligations (legal obligation);
  • contract negotiations (legitimate interest of BELO ENERGY s.r.o.);
  • provision of services and sale of goods, warranty fulfilment, complaint handling, service improvement (contract performance, legitimate interest, legal obligation);
  • billing purposes (contract performance, legal obligation);
  • debt collection and other customer disputes (legitimate interest of BELO ENERGY s.r.o.);
  • marketing and commercial communication, loyalty programmes (legitimate interest, consent).
Commercial communications sent by BELO ENERGY s.r.o. are always clearly marked as such in accordance with applicable legislation, and BELO ENERGY s.r.o. is always identified as the sender. Commercial communications may be sent to customer contacts based on BELO ENERGY’s legitimate interest until the customer objects to processing, or based on explicit consent to processing for marketing purposes or consent to electronic marketing communication. Each commercial communication also contains an option to unsubscribe. For data subjects who have granted consent to marketing communication via an electronic contact, BELO ENERGY s.r.o. processes the provided contact details for the period specified in the consent for the purpose of sending marketing offers and information about BELO ENERGY s.r.o. services and products. Processing of cookies on websites operated by BELO ENERGY s.r.o.

If a data subject has cookies enabled in their browser and visits the website www.beloenergy.eu, BELO ENERGY s.r.o. may record their IP address, the duration of the visit, and the website from which the visitor arrived. The use of cookies to measure website traffic and adapt website display is considered the legitimate interest of BELO ENERGY s.r.o., as it enables the company to improve services provided to its customers and website visitors. The website can also be viewed in a mode that prevents the collection of personal data. Data processing via cookies can be prevented by adjusting browser settings. A data subject may disable or customize the use of cookies on www.beloenergy.eu. Detailed cookie rules are provided in a separate document available on the website. Personal data for the above purposes are processed only to the extent necessary for fulfilling those purposes and for the period necessary to achieve them, or for the period directly stipulated by legal regulations, a contract, or BELO ENERGY s.r.o.’s retention schedule. After this period, personal data is deleted or anonymized. The basic retention periods are listed below. Personal data will be processed as follows (the stated retention periods may be extended by statutory limitation periods, especially when there is a risk of litigation):
Purpose of Processing Categories of Personal Data Legal Grounds Retention Period
Contract negotiation and performance Personal data entered in an inquiry or included in a contract Contract performance, legitimate interest 3 years after fulfilment/termination of the contract
Employment administration Employee personal data Legal obligation According to statutory retention periods for each document type
Issuing invoices, order fulfilment, accounting, tax obligations Personal data necessary for invoicing, accounting and tax compliance Legal obligation Up to 10 years
Warranty and defect liability Data relating to warranty claims and defect liability Contract performance, legal obligation Until the expiry of statutory claim periods
Customer inquiries and support Personal data submitted in inquiries Legitimate interest Until the inquiry is resolved
Website monitoring, ensuring user-friendly environment Data related to website use, form submissions, clicks (incl. cookies) Consent Until consent is withdrawn
Communication with job applicants Contact data and CV details submitted with online job applications Consent Until consent is withdrawn
Sending electronic newsletters and individual offers Contact data required for such purposes (email) Legitimate interest (for existing customers)
Consent (for subscribers who opted in) 		Until objection is raised
Until consent is withdrawn
Sending printed newsletters and individual offers Contact data required for such purposes (postal address) Legitimate interest (for existing customers)
Consent (for subscribers who opted in) 		Until objection is raised
Until consent is withdrawn
Analysis of past orders and service usage for marketing optimisation Identity data, purchase history, service usage Legitimate interest Until objection is raised
Participation in surveys and market research Contact details submitted for this purpose Consent Until consent is withdrawn
  1. Categories of Recipients to Whom Personal Data Has Been or Will Be Disclosed, Including Recipients in Third Countries or International Organisations
BELO ENERGY s.r.o., in fulfilling its legal obligations, provides personal data to administrative authorities and public bodies as required by applicable legislation. Furthermore, in fulfilling contractual obligations, BELO ENERGY s.r.o. uses specialised services provided by other entities. If such suppliers process personal data received from BELO ENERGY s.r.o., they act as data processors and may process personal data only in accordance with the instructions of BELO ENERGY s.r.o. and may not use them for any other purpose. These may include debt collection agencies, experts, accountants, translators, lawyers, auditors, IT service providers, online advertising providers, or business representatives. BELO ENERGY s.r.o. carefully selects each supplier and enters into a personal data processing agreement with them, ensuring strict obligations regarding personal data protection and security. All processors used have their registered office within the Czech Republic. Currently, no data is transferred to third countries. If, in the future, personal data is transferred or processed in countries outside the European Union, such transfers will always comply with applicable legislation, particularly through the use of Standard Contractual Clauses under Commission Implementing Decision (EU) 2021/914 of 9 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679. Categories of personal data recipients include:
  • financial institutions
  • public authorities
  • data processors
  • contractual partners
  • state and other public bodies in connection with legal obligations under applicable regulations
  • other recipients — e.g. based on the consent of the data subject (e.g. transfers of data abroad — EU countries)
A current list of recipients/categories of recipients cooperating with BELO ENERGY s.r.o.:
Data Processors Processing Activity
Other Recipients Processing Activity
  1. Updating of Personal Data
BELO ENERGY s.r.o. updates processed personal data using information provided by data subjects, third parties, or publicly available sources (online databases, public registers).
  1. Method of Personal Data Processing
Personal data is processed by BELO ENERGY s.r.o. at its registered office or branch offices by authorised employees of BELO ENERGY s.r.o. or by processors. Processing is carried out using computer systems or manually in the case of physical documents, always in compliance with all security and organisational measures for data protection. BELO ENERGY s.r.o. has implemented technical and organisational measures to ensure the protection of personal data, preventing unauthorised or accidental access, alteration, destruction, loss, unauthorised transfers, or other misuse. All entities that may have access to personal data must respect the right to privacy and comply with applicable data protection regulations.
  1. Information About Data Subject Rights in Connection with Personal Data Processing
A data subject, once properly identified as an identifiable natural person, has the rights listed below. These rights may be exercised only in relation to personal data that, beyond doubt, belong to the requesting data subject. Right to Information (Articles 13 and 14 GDPR)

Under Articles 13 and 14 GDPR, a data subject has the right to information, particularly regarding the scope and purpose of processing, the method of data processing, and the recipients to whom personal data may be disclosed. BELO ENERGY s.r.o. fulfils this obligation through these policies published on www.beloenergy.eu, through information included in contracts with customers and partners, and through responses to individual data subject requests. Right of Access to Personal Data (Article 15 GDPR)

Under Article 15 GDPR, a data subject has the right of access to personal data, which includes the following:
  • confirmation whether personal data is being processed,
  • information on processing purposes,
  • categories of processed personal data,
  • recipients to whom personal data has been or will be disclosed,
  • planned retention period,
  • information on the right to request correction or erasure of personal data, restriction of processing, or to object to processing,
  • information on the right to lodge a complaint with a supervisory authority,
  • information on the source of personal data if not collected from the data subject,
  • information on automated decision-making, including profiling, appropriate safeguards when data is transferred outside the EU,
  • the right to obtain a copy of the personal data, provided this does not adversely affect the rights and freedoms of others.
In case of repeated requests, BELO ENERGY s.r.o. may charge a reasonable administrative fee. Right to Rectification (Article 16 GDPR)

Under Article 16 GDPR, a data subject has the right to request the correction of inaccurate personal data or the completion of incomplete personal data processed by BELO ENERGY s.r.o. The correction will be made without undue delay, within the limits of technical capabilities. Right to Erasure (“Right to be Forgotten”) (Article 17 GDPR)

Under Article 17 GDPR, a data subject has the right to request the erasure of personal data if BELO ENERGY s.r.o. cannot demonstrate legitimate grounds for processing. BELO ENERGY s.r.o. has mechanisms in place to ensure automatic anonymisation or deletion of personal data once they are no longer needed for the purpose for which they were processed. Personal data will be erased in particular if:
  • the controller no longer needs the personal data for the stated purpose,
  • processing is based on consent which has been withdrawn and no other lawful basis exists,
  • processing is based on legitimate interest and the data subject objects, and no overriding legitimate grounds exist,
  • personal data has been processed unlawfully,
  • erasure is necessary to fulfil legal obligations,
  • the data was collected in connection with information society services.
Right to Restrict Processing (Article 18 GDPR)

Under Article 18 GDPR, a data subject has the right to restrict processing while the accuracy, legality, or justification of processing is being verified, or while an objection is being assessed. Right to Notification of Rectification, Erasure, or Restriction (Article 19 GDPR)

Under Article 19 GDPR, a data subject has the right to be notified by BELO ENERGY s.r.o. when their personal data has been corrected, erased, or when processing has been restricted. Right to Data Portability (Article 20 GDPR)

Under Article 20 GDPR, a data subject has the right to request from BELO ENERGY s.r.o. the personal data concerning them that they have provided to BELO ENERGY s.r.o. in connection with a contract or consent, or data that is processed automatically. The data must be provided in a structured, commonly used, and machine-readable format. The data subject also has the right to request the transfer of this data to another controller, provided that the authorised representative of the receiving controller can be properly identified and authorised. This right cannot be exercised if it would adversely affect the rights and freedoms of others. Right to Object (Article 21 GDPR)

Under Article 21 GDPR, a data subject has the right to object to the processing of their personal data based on the legitimate interest of BELO ENERGY s.r.o. If BELO ENERGY s.r.o. does not demonstrate compelling legitimate grounds for the processing that override the interests, rights, or freedoms of the data subject, processing will be stopped without undue delay. Right to Withdraw Consent

Consent to personal data processing may be withdrawn at any time after it has been granted. Withdrawal must be made as a clear and unambiguous expression of will. Consent to marketing communication provided for a specific electronic contact may be withdrawn at any time using the method described in the commercial communication. Withdrawal does not affect the legality of processing based on consent before its withdrawal. Automated Decision-Making, Including Profiling (Article 22 GDPR)

Under Article 22 GDPR, a data subject has the right not to be subject to any decision based solely on automated processing, including profiling, which would produce legal effects concerning them or similarly significantly affect them. BELO ENERGY s.r.o. confirms that it does not carry out automated decision-making. Profiling — i.e., automated processing and evaluation of personal data — may be carried out by BELO ENERGY s.r.o. for the purpose of sending marketing communications and offers, based on the data subject’s consent. This process affects the data subject only to the extent described above (i.e., receiving personalised offers or newsletters). Consent for profiling can be withdrawn at any time. Right to Lodge a Complaint with a Supervisory Authority (Article 77 GDPR)

Under Article 77 GDPR, a data subject has the right to lodge a complaint with the supervisory authority — the Office for Personal Data Protection (www.uoou.cz) — if they believe that the processing of their personal data violates their rights or the GDPR.