Privacy Policy

I.

General Provisions

1. The controller of personal data pursuant to Article 4(7) of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the “GDPR”) is CircuitNinja, Company ID No. 23151200, with its registered office at Kurzova 2222/16, Stodůlky, 155 00 Prague 5, Czech Republic (hereinafter the “Controller”).

2. The Controller’s contact details are as follows:

   • Address: Podkovářská 800/6, 190 00, Praha 9-Vysočany

   • E-mail: info@circuitninja.cz

   • Telephone: +420 702 687 546

3. Personal data means any information relating to an identified or identifiable natural person; an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

4. The Controller has not appointed a Data Protection Officer.

II.

Sources and Categories of Processed Personal Data

1. The Controller processes personal data that you have provided to the Controller or personal data that the Controller has obtained in connection with the performance of your order.

2. The Controller processes your identification and contact details, as well as data necessary for the performance of a contract.

III.

Legal Basis and Purpose of the Processing of Personal Data

1. The legal basis for the processing of personal data is:

   • the performance of a contract between you and the Controller pursuant to Article 6(1)(b) GDPR;

   • the legitimate interest of the Controller in providing direct marketing (in particular the sending of commercial communications and newsletters) pursuant to Article 6(1)(f) GDPR;

   • your consent to the processing of personal data for the purposes of direct marketing (in particular the sending of commercial communications and newsletters) pursuant to Article 6(1)(a) GDPR in conjunction with Section 7(2) of Act No. 480/2004 Coll., on Certain Information Society Services, where no goods or services have been ordered.

2. The purposes of the processing of personal data are:

   • the processing of your order and the exercise of rights and obligations arising from the contractual relationship between you and the Controller; personal data required for the successful processing of an order (name, address, contact details) are necessary for the conclusion and performance of the contract; without the provision of such personal data, it is not possible to conclude or perform the contract on the part of the Controller;

   • the sending of commercial communications and the carrying out of other marketing activities.

3. The Controller does not carry out automated individual decision-making within the meaning of Article 22 GDPR. You have given your explicit consent to such processing.

IV.

Data Retention Period

1. The Controller retains personal data:

   • for the period necessary to exercise rights and obligations arising from the contractual relationship between you and the Controller and to assert claims arising from such contractual relationships (for a period of 10 years from the termination of the contractual relationship);

   • for the period until consent to the processing of personal data for marketing purposes is withdrawn, but no longer than 3 years, where personal data are processed on the basis of consent.

2. Upon expiry of the retention period, the Controller shall delete the personal data.

V.

Recipients of Personal Data (Controller’s Processors)

1. Recipients of personal data are persons:

   • involved in the delivery of goods or services or the processing of payments under a contract;

   • involved in ensuring the operation of services;

   • providing marketing services.

2. The Controller intends to transfer personal data to a third country (a country outside the EU) or to an international organisation. Recipients of personal data in third countries are providers of mailing services.

VI.

Your Rights

1. Under the conditions set out in the GDPR, you have:

   • the right of access to your personal data pursuant to Article 15 GDPR;

   • the right to rectification of personal data pursuant to Article 16 GDPR, or restriction of processing pursuant to Article 18 GDPR;

   • the right to erasure of personal data pursuant to Article 17 GDPR;

   • the right to object to processing pursuant to Article 21 GDPR;

   • the right to data portability pursuant to Article 20 GDPR;

   • the right to withdraw your consent to the processing of personal data in writing or electronically at the address or e-mail address of the Controller specified in Article III of these terms.

2. You also have the right to lodge a complaint with the Office for Personal Data Protection if you believe that your right to the protection of personal data has been infringed.

VII.

Conditions for Securing Personal Data

1. The Controller declares that it has adopted all appropriate technical and organisational measures to secure personal data.

2. The Controller has adopted technical measures to secure data storage and storage of personal data in paper form, in particular antivirus software, secure storage of backups, secure access passwords, etc.

3. The Controller declares that only authorised persons designated by the Controller have access to personal data.

VIII.

Final Provisions

1. By submitting an order via the online order form, you confirm that you have read these Personal Data Protection Terms and that you accept them in their entirety.

2. You agree to these terms by ticking the consent box via the online form. By doing so, you confirm that you have read these Personal Data Protection Terms and that you accept them in their entirety.

3. The Controller is entitled to amend these terms. The new version of the Personal Data Protection Terms will be published on the Controller’s website or, where appropriate, sent to you by e-mail to the address you have provided to the Controller.

These Personal Data Protection Terms shall enter into force on 13 October 2025.