PRINCIPLES OF PERSONAL DATA PROCESSING

Solkind s.r.o., law firm, with its registered office at Jugoslávská 620/29, Vinohrady, 120 00 Prague 2, Czech Republic, ID No.: 283 05 043, registered in the Commercial Register maintained by the Municipal Court in Prague, File No. C 60014 (hereinafter referred to as “Solkind“) processes personal data in the course of its business activities.

Solkind processes personal data only on the basis and to the extent permitted by 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, and repealing Directive 95/46/EC.

(General Data Protection Regulation) (hereinafter referred to as “GDPR”) and related legislation, as well as other regulations to which Solkind is bound.

The protection and security of processed personal data is a priority for Solkind. Solkind therefore pays due attention to personal data and its protection and always proceeds in accordance with the basic principles set out below, which are derived from Article 5 of the GDPR:

  • Principle of lawfulness, fairness, and transparency of processing – Solkind always processes the personal data of data subjects on the basis of a valid legal title, in a fair and transparent manner
  • Principle of purpose limitation of processing – personal data of data subjects are collected and processed by Solkind exclusively for specific, legitimate purposes expressly stated in the information documents; personal data are not processed by Solkind in a manner incompatible with these purposes.
  • Principle of minimizing processed personal data – Solkind processes personal data only to the extent that is appropriate, relevant, and necessary in relation to the purpose for which it is processed.
  • Principle of accuracy and timeliness of processed personal data – Solkind processes personal data in an accurate and, where necessary, updated form. Solkind takes reasonable measures to ensure that personal data that is inaccurate, taking into account the purposes for which it is processed, is deleted or corrected without delay;
  • Principle of limiting the storage and processing of personal data – Solkind stores and processes personal data in a form that allows the identification of data subjects for no longer than is necessary to achieve the purposes for which they are processed;
  • Principle of integrity and confidentiality of processed personal data – Solkind processes personal data in a manner that ensures the proper security of personal data, including its protection by appropriate technical or organizational measures against unauthorized or unlawful processing and against accidental loss, destruction, or damage.

Solkind is the personal data controller for most purposes of personal data processing. Only in exceptional cases is Solkind the personal data processor.

Solkind, as the controller, is responsible for the processing of personal data, and you may exercise most of your rights listed below against Solkind.

Solkind has not appointed a data protection officer, but has designated a person who is responsible for this area and who supervises the proper processing and protection of personal data.

Solkind employees, cooperating lawyers, and Solkind executives follow the rules and procedures set out in the internal personal data protection policy, including security measures implemented to protect personal data, when processing personal data.

Compliance with the information obligation

Solkind complies with its information obligation towards data subjects pursuant to Articles 13 or 14 of the GDPR by means of separate information documents, which are provided to data subjects in an appropriate manner (e.g. as part of a contract concluded with Solkind, sent by email, published on websites, etc.).

In the information document, the data subject is always informed, among other things, about:

  • the purpose of personal data processing;
  • the legal basis for processing;
  • the recipients or categories of recipients of personal data;
  • the period for which personal data will be stored;
  • the specific rights of the data subject;
  • the categories of personal data concerned (if Solkind has not obtained the personal data directly from the data subject);
  • the source from which the personal data originate, or the fact that the personal data originate from publicly available sources (if Solkind has not obtained the personal data directly from the data subject).

Data subjects’ rights and their exercise

Data subjects may exercise the following rights in relation to their processed personal data with Solkind under the conditions set out in Articles 15 to 22 of the GDPR:

  • Right of access to processed personal data

 

The right of access is the right of the data subject to obtain the following information from Solkind: (a) whether their personal data is being processed, (b) for what purpose, (c) what personal data is being processed, (d) whether their personal data is being transferred to other recipients, (e) for how long their personal data is being processed, (f) information about their rights in relation to the personal data being processed. At the same time, the data subject has the option of obtaining copies of the personal data being processed.

  • Right to rectification of processed personal data

The right to rectification includes the right of the data subject to request Solkind to rectify incorrectly processed personal data or to complete incomplete processed personal data.

  • Right to erasure of processed personal data

The right to erasure includes the right of the data subject to request Solkind to erase processed personal data in the absence of a valid legal basis for their processing.

The data subject therefore has the right to request the erasure of personal data in the following cases:

  • the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
  • the data subject has withdrawn the consent on which the processing of personal data was based, and there is no other legal reason for their processing;
  • the data subject has objected to Solkind on the basis of legitimate interests and believes that Solkind has no overriding legitimate reasons for processing it;
  • the data subject has objected to Solkind processing personal data for direct marketing purposes;
  • the personal data has been processed unlawfully;
  • the personal data must be erased to comply with a legal obligation under European Union law or the law of a Member State of the European Union.

The data subject does not have the right to request Solkind to erase the personal data being processed if Solkind has a valid legal basis for processing them (i.e., in particular

for as long as Solkind is entitled to process the data for the purpose of performing a contract or fulfilling obligations stipulated by law).

  • Right to restrict the processing of personal data

The right to restrict processing includes the right of the data subject to request Solkind to restrict the scope of personal data processing in the following cases: (a) the data subject disputes the accuracy of the personal data being processed – processing may be restricted until a decision is made; (b) the processing is unlawful, but the data subject only requests the restriction of processing; (c) Solkind no longer needs the personal data for the establishment, exercise, or defense of legal claims; (d) the data subject has objected to the processing – processing is restricted until the objection is resolved.

  • Right to data portability

The right to data portability includes the right of the data subject to obtain from Solkind the personal data processed in a structured, commonly used, and machine-readable format for the purpose of transferring it to another controller (another law firm), or the right to request, in technically feasible cases, that it be transferred directly to another controller. This right may only be exercised if the processing is necessary for the performance of a contract or is based on the consent of the data subject and is carried out by Solkind through an information system (automatically).

  • Right to withdraw consent

The data subject has the right to withdraw consent to the processing of personal data at any time. However, withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

  • Right to object to the processing of personal data

The data subject has the right to object in cases where the processing of their personal data is necessary for the purposes of Solkind’s legitimate interests or where personal data is processed for direct marketing purposes. After an objection has been raised, Solkind is not entitled to further process the personal data of the data subject unless it demonstrates compelling legitimate grounds for further processing that override the interests or rights and freedoms of the data subject, or demonstrates the necessity of processing for the establishment, exercise, or defense of its legal claims. If an objection is raised against the processing of personal data for direct marketing purposes, Solkind may no longer process personal data for this purpose.

The above rights must always be exercised with the personal data controller; therefore, it is not possible to exercise these rights against Solkind in cases where the personal data is only processed for a specific purpose

in the position of processor (e.g., for personal data processed in the administration of public contracts for clients).

The data subject is entitled to exercise the above rights at Solkind:

  • in person at Solkind’s registered office at Jugoslávská 620/29, Vinohrady, 120 00 Prague 2, Czech Republic;
  • by letter delivered to Solkind’s registered office at Jugoslávská 620/29, Vinohrady, 120 00 Prague 2, Czech Republic;
  • by email sent to info@solkind.cz;
  • by telephone to Solkind’s telephone number +420 222 866 555;
  • by message delivered to Solkind’s data box with the data box identifier mrzn3bp.

In order for Solkind to process the data subject’s request quickly and properly, the request must clearly state the following:

  • who is submitting the request (the applicant’s first and last name, date of birth, and address);
  • what right is being exercised by the request (a description in words or a reference to the relevant article of the GDPR is sufficient);
  • what the data subject is requesting and, if applicable, why;
  • how the data subject wishes to receive a response (by letter, email, telephone, data box);
  • the data subject’s contact details (telephone, email) for any additional questions.

Solkind is obliged to process requests free of charge, however, if requests are manifestly unfounded or excessive, in particular because they are repetitive, Solkind is entitled to charge a reasonable fee taking into account the administrative costs of providing the requested information or communication or taking the requested action, or has the right to refuse to comply with the request.

Solkind will always respond to requests within one month of receipt.

If the data subject believes that the processing of personal data violates the GDPR, they have the right to lodge a complaint with a supervisory authority, in particular in the state

his usual place of residence, place of work, or place where the alleged infringement occurred. The supervisory authority for the Czech Republic is the Office for Personal Data Protection, with its registered office at Pplk. Sochora 27, 170 00 Prague 7, Czechia, ID No.: 708 37 627, www.uoou.gov.cz.

In Prague on January 1, 2026