Information-Supplier

Information for SUPPLIERS according to Articles 13 and 14 of the GDPR

In accordance with Articles 13 and 14 of the GDPR and on the basis of the relevant provisions of the Principles for the Processing and Protection of Personal Data (https://www.aspena.com/Privacy-policy-en/), Aspena, s.r.o., ID: 607 51 185, with its registered office at Brno, Veveří, Gorkého 64/15, Postal Code 602 00, registered in the Commercial Register under File Number: C 19243 maintained in the Regional Court in Brno, as the Personal Data Provider (hereinafter referred to as  „the Company“), informs the suppliers who offer or provide goods and services to the company (hereinafter referred to as the „Supplier“), on the processing of personal data:


1.   Name and Contact Information of the Company

Aspena, s.r.o., ID 607 51 185, with its registered office at Brno, Veveří, Gorkého 64/15, Postal Code 602 00, e-mail: gdpr@aspena.cz


2.   Personal Data Protection Officer

The company is not required to have a Data Protection Officer.


3.   Purpose and Legal Basis for Processing Personal Data

  • The Company obtains personal data from the Supplier through e-mail or the form on the website of the Company.
  • The Company processes the obtained personal data from the Supplier in an automatic and manual manner.
  • For a Supplier whose personal data is processed by the Company in accordance with the GDPR, a natural person may be considered the following:

     a.       as the one offering or providing the Company with translation and interpreting services (hereinafter referred to as „the Contractor“),

     b.       another natural person doing business (hereinafter referred to as the „Other Supplier“), or

     c.       a natural person authorised to act on behalf of the legal entity of the Supplier and ad a) or ad b)(hereinafter referred to as the „Other Contractor“).


3.1   Contractor – Purpose and Legal Basis of Processing

The Company processes the personal data of the Contractor in accordance with the GDPR for the following purposes, proceeding on the basis and within the mentioned legal titles below for the processing of personal data:

  • The fulfilment of a contract , to which the Contractor is a party – mainly the identification and contacting of the Contractor, the conditions of the contract fulfilment performance, information necessary to change the content of the contract, and the rights and obligations of liability for defects (legal title according to Article 6, Paragraph 1, Letter b) of the GDPR);,
  • Compliance with the legal obligations applicable to the Company, being an accounting entity and a tax subject and, for this reason, retaining documents and accounting documents that may contain the Contractor’s personal data, as well as compliance with the Company’s legal obligations within the liability for defects (Article 6, Letter c) of the GDPR);
  • The fulfilment of the legitimate interests of the Company – mainly the judicial or extra-judicial recovery of receivables from the Contractor, sending the newsletter to the Contractor, evaluation of the Contractor’s provided services, and the subsequent demand for the Contractor’s services (Article 6, Letter f) of the GDPR).


3.2   Other Supplier – Purpose and Legal Basis of Processing

The Company processes the personal data of the Other Supplier in accordance with the GDPR for the following purposes, proceeding on the basis and within the mentioned legal titles below for the processing of personal data:

  • The fulfilment, of a contract to which the Other Supplier is a party – mainly the identification and contacting of the Contractor, the conditions of the contract fulfilment performance, information necessary to change the content of the contract, and the rights and obligations of liability for defects (legal title according to Article 6, Paragraph 1, Letter b) of the GDPR);
  • Compliance with the legal obligations applicable to the Company, being an accounting entity and a tax subject and, for this reason, retaining documents and accounting documents that may contain the Other Supplier’s personal data (Article 6, Letter c) of the GDPR);
  • The fulfilment of the legitimate interests of the Company – mainly the judicial or extra-judicial recovery of receivables from the Other Supplier, sending the newsletter to the Other Supplier, evaluation of the Other Supplier’s provided services, and the subsequent demand for the Other Supplier's services (Article 6, Letter f) of the GDPR).


4.   Legitimate Interests of the Company

The Company mainly applies the following legitimate interests in the processing of personal data:

  • Education – sending a newsletter to the Contractor for purposes of information and an increase in qualifications,
  • The recovery of receivables – the judicial or extra-judicial recovery of possible receivables from the Supplier,
  • Evaluation of the Supplier’s provided service – a suitable setting of the Contractor’s priority, the Supplier’s evaluation to protect the Company’s assets,
  • The subsequent demand of the Supplier’s services.


5.   Recipient of Personal Data

The Company reserves the right to disclose the personal data of the Supplier to the employees of the Company if necessary for the performance of their work duties, and to further processors with whom the Company has a personal data processing agreement (e.g. for accounting, IT and marketing services) as well as institutions in accordance with the law, mainly state authorities and other public administration authorities, on the basis of the legal obligation to provide personal data.


6.   Transfer of Personal Data to Third Countries or International Organisations

The Company does not have the intention of transferring personal data to third countries outside the EU or to international organisations.


7.   Period for Retaining Personal Data

The Supplier’s personal data will be retained by the Company for the duration of the contract with the Supplier or for 10 years from entering the personal data of the Supplier into the IS of the Company. Upon termination of the contract with the Supplier, the personal data of the Supplier will be retained to fulfil legal obligations according to the applicable laws (especially in the field of accounting and taxation) and at the same time for 10 years after the termination of the contract in order to execute the above-mentioned legitimate interests of the Company.


8.   The Rights of the Supplier in the Processing of Personal Data

The Supplier may exercise the following rights with the Company in relation to his/her personal data, by e-mail to the address gdpr@aspena.cz:

  • Right to Access Personal Data,
  • Right to Modification,
  • Right to Deletion,
  • Right to Restriction of Processing after a Certain Period,
  • Right to Portability,
  • Right to Object Against Processing due to Legitimate Interest.


9.   Right to Revoke Consent

If the processing of personal data is based on consent, the Supplier may at any time revoke this consent by e-mail through gdpr@aspena.cz.


10.   Right to File a Grievance

The Supplier has the right to file a grievance with the Personal Data Protection Office if he/she considers the processing of his/her personal data to have violated the GDPR.


11.   Legal/Contractual Requirement to Provide Personal Data

The provision of the Supplier’s personal data is primarily a contractual requirement. The result of unprovided personal data by the Supplier is an unconcluded contract.


12.   Automated Decision-Making, including Profiling

The personal data of the Supplier are not the subject of automated decision-making nor profiling.