Privacy and Personal Data Protection Policy

1. Who processes your personal data?

The company PLANET STORE a.s., IČO 04132416, with its registered office at Štefánikova 25/18, , 150 00 Prague 5 (hereinafter referred to as "PLANET STORE"), is the administrator of the personal data of Users processed within the framework of these Personal Data Protection and Privacy Policy (hereinafter referred to as the "Policy" ). The company PLANET STORE processes personal data of Users in accordance with Act No. 101/2000 Coll., on the protection of personal data, as amended (hereinafter referred to as the "Act on the Protection of Personal Data"). Starting on 25 May 2023, personal data of Users will be processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and on the repeal of Directive 95 /46/EC (general regulation on the protection of personal data) (hereinafter referred to as the "Regulation"), and in accordance with all legal regulations that will replace the Personal Data Protection Act in the future. All capitalized terms have the meaning defined in the Terms of Use of the PLANET STORE - winTwins Services (hereinafter referred to as the "Terms"), unless otherwise defined in these Policies.

2. What personal data does PLANET STORE process?

PLANET STORE only processes personal data that Users provide to it in connection with the use of the PLANET STORE Services of the winTwins application, especially in connection with the Registration of the PLANET STORE of the winTwins application. This is in particular the following personal data that Users provide to us during Registration:

email address,

name and surname,

Year of birth,

face photo,

and further personal data that we obtain from Users by using the PLANET STORE Services of the winTwins application:

IP address of the User's Device,

basic geographical location (for reasons of maintaining territoriality and fulfilling license agreements)

3. For what purposes does PLANET STORE process your personal data?

The main reason why PLANET STORE processes the personal data of its Users is to be able to manage their User Accounts, to be able to provide them with the PLANET STORE Services of the winTwins application, and to ensure and constantly improve the security of its services and thus the protection of the personal data of its Users.

Personal data of Users is further processed by PLANET STORE for the purpose of:

improving the quality and further development of the PLANET STORE Services of the winTwins application,

performing analyzes and measurements in order to find out how the PLANET STORE Services of the winTwins application are used,

basic analysis of User preferences in order to display content that corresponds to the individual needs of Users,

sending commercial messages, including the offer of products and services of third parties (unsubscribing from receiving commercial messages can be done in the settings of the service for which the User has registered to receive such messages, or by e-mail to the e-mail address info@planet-store.com) and content newsletters,

to a reasonable extent also for the purpose of remarketing (i.e. for more targeted display of content and advertising on the PLANET STORE Website), in cooperation with third parties from social media providers, such as Facebook or Google.

4. Who has access to your personal data?

PLANET STORE protects and ensures the security of your personal data. It carefully selects its partners to whom it entrusts this data and who are able to ensure such technical and organizational security of your personal data that unauthorized or accidental access to personal data or their other misuse cannot occur. None of PLANET STORE's partners may use the provided personal data for any purposes other than those for which it was made available to them.

Third parties that may have access to your personal data are:

persons who ensure the technical operation of certain services for PLANET STORE or operators of technologies used by PLANET STORE, especially infrastructure and IT technologies and services,

service providers who provide PLANET STORE services related to marketing activities, including direct marketing, processing market research and/or performing statistical analysis and remarketing via social media such as Facebook and Google,

delivery service providers,

persons who ensure sufficient security and integrity of their services and websites for PLANET STORE,

payment gateway providers,

providers of accounting and legal services and other similar services based on a contractual or other legal relationship.

Under certain conditions, PLANET STORE is also obliged to hand over some of your personal data on the basis of valid legal regulations, e.g. to law enforcement authorities and other public administration authorities.

5.Collection and storage of data provided from the facial photo.

PLANET STORE in winTwins uses an advanced facial recognition process to secure the user's profile as unique and prevent duplicate or fraudulent profiles. At the same time, the face recognition function allows each user to have control over the sharing of photos in the application by other users and will always notify the user who recognizes them on the shared photo.

PLANET STORE has partnered with SkyBiometry for facial recognition. SkyBiometry is a biometric technology provider that delivers cloud-based facial detection and recognition software as a service (SaaS) and is a spin-off from Neurotechnology, a trusted provider of high-precision biometric identification, object recognition and computer vision technologies for over 30 years. SkyBiometry collects and stores all data from winTwins users' photos anonymously. That is that there is no email, name or ID associated with the photo. The winTwins application collects and stores only the TID value, which is unique for each user. Read more at

PLANET STORE does not collect or store any facial data in the winTwins app.

PLANET STORE does not share facial data with third parties.

PLANET STORE stores all data in the winTwins application only until the user deletes his account in the application. After deleting a user, all data including all data with SkyBiometry is deleted.

6. What are cookies and what types of cookies does PLANET STORE use?

Cookies are small text files that the websites you visit save on your computer. These files are normally used to run or make more efficient use of websites and to provide internet services and features to users. Cookies are stored on individual computers using a web browser. Cookies do not pose a danger, they do not serve to obtain any sensitive personal data or to identify your specific person, but they are important for privacy protection.

Cookies can be either permanent (persistent cookies) or temporary (session cookies). Permanent cookies are text files sent by an Internet server to an Internet browser, which after the browser saves them, remain active until the set deletion date (if the user does not delete them before this date). Conversely, temporary cookies are deleted at the end of each session after the Internet browser is closed.

PLANET STORE's cookie files, for example, enable the User to be recognized as an existing User (e.g. when logging into their User account, etc.) or to adapt the given PLANET STORE Service of the winTwins application to user preferences. PLANET STORE may also use cookies for statistical purposes or to measure the number of visitors to the PLANET STORE website, etc. Cookies are not used to obtain any sensitive personal data. PLANET STORE also uses cookies to display so-called behaviorally targeted online advertising on the PLANET STORE website, i.e. to display only such advertising that is relevant to the User in question, without being bothered by advertising that does not interest him.

PLANET STORE stores two variables in cookies. The first variable is the authentication token, with which it is possible to identify the User and recognize that he is logged in. However, this variable does not contain any user data and the User is identified only on the server side. The second variable is the language of the interface, thanks to which it is possible to recognize which language version the User last used.

Another group is represented by third-party cookies (e.g. Google Analytics for the analysis of PLANET STORE website traffic). These cookies are controlled by third parties and PLANET STORE does not have access to read or write this data.

Some cookies are also created by advertising systems. Through our web server, cookies can also be stored on your computer from other entities, namely operators of advertising systems that are operated on the PLANET STORE website. PLANET STORE uses the advertising systems of several entities on PLANET STORE's Website, e.g. Google's system (AdSense, AdExchange), Facebook, etc. These systems usually use remarketing techniques.

As users, you have the option to refuse the use of cookies. If your browser allows the use of cookies, PLANET STORE will assume that you agree to the use of standard cookies by PLANET STORE.

In most Internet browsers, the above-mentioned cookies can be managed in the browser settings. More information about cookies and how to find out what cookies have been set and how to manage and delete them can be found on the websites www.aboutcookies.org and www.allaboutcookies.org.

If you want to change the cookie settings installed by Google Analytics, visit http://tools.google.com/dlpage/gaoptout.

Please note that any changes to the cookie settings in your internet browser may affect the correct functioning of the PLANET STORE Website and/or the PLANET STORE Services of the winTwins application.

7. How long does PLANET STORE process your personal data?

The company PLANET STORE processes your personal data for the entire period of use of the PLANET STORE Services of the winTwins application (i.e. for the duration of the contractual relationship established by the Registration Agreement) and subsequently based on your consent for a further 5 years, unless you consent to the processing personal data revoked by you.

Here, however, we would like to point out that the personal data that are necessary for the proper provision of the PLANET STORE Services of the winTwins application, or in order to fulfill all our obligations, whether these obligations result from the Registration Agreement or from generally binding legal regulations, we must process regardless of your consent for the period determined by the relevant legal regulations or in accordance with them and after any withdrawal of your consent.

Data obtained as part of the Registration, if it is possible to process these personal data even without your consent, then we process them for the duration of the use of the PLANET STORE Services of the winTwins application, for the period until the Registration is canceled by you, and also for a maximum period of 2 years, if your User account inactive for this entire period (after this period, your Registration will be canceled by PLANET STORE). Subsequently, only basic identification data and information on the reason for which the Registration was terminated or data forming part of operational backups are usually stored for a reasonable period of time.

8. Can PLANET STORE process your personal data even without your consent?

Yes, PLANET STORE may process your personal data even without your consent, but only for the purpose of:

provision of the PLANET STORE Services of the winTwins application (in particular, the fulfillment of the Registration Agreement concluded between you and PLANET STORE),

fulfillment of legal obligations arising for us from generally binding legal regulations (e.g. tax or accounting obligations), or

the legitimate interests of PLANET STORE, provided that these legitimate interests do not conflict with the legitimate interests and basic rights and freedoms of the User (e.g. for direct marketing, ensuring the security of our websites, etc.).

The possibility and legality of such processing of personal data follows directly from applicable legal regulations (especially the Regulation), and your consent to this processing is therefore not required.

9. On what basis can PLANET STORE process your personal data?

PLANET STORE may process your personal data on the basis of your consent, but also, for example, on the basis of its legitimate interest (in particular, the processing of personal data for the purpose of direct marketing) or for the fulfillment of the Agreement concluded between us on the registration and provision of PLANET STORE Services of the winTwins application , to the extent of personal data necessary for such performance. Last but not least, the reason enabling PLANET STORE to process your personal data even without your consent is the fulfillment of obligations arising for our company by law. Individual processing purposes are described in more detail in point 3 of these Principles.

If required by the relevant legal regulations, PLANET STORE may ask you to give your express consent to the processing of your personal data for direct marketing purposes (sending newsletters and other business communications). Such consent may be revoked by the User at any time by sending an e-mail to PLANET STORE at info@planet-store.com or by using the unsubscribe link provided in each e-mail from PLANET STORE containing marketing communications . Withdrawal of consent by the User will not adversely affect the performance of the Registration Agreement by PLANET STORE and/or the provision of the PLANET STORE Services of the winTwins application to the User.

10. How is your personal data secured?

The company PLANET STORE protects the personal data provided by you to the maximum extent possible using modern technologies that correspond to the level of technical development. PLANET STORE regularly checks that the system does not contain weak points and has not been exposed to attacks. The company PLANET STORE uses such security measures that, taking into account the current state of technology, provide sufficient security so that, if possible, there is no unauthorized access to your personal data. The security measures taken are then regularly updated. Only persons authorized to handle personal data have access to your personal data.

In order to better secure your personal data, access to this data is password protected. Therefore, we recommend that you keep your unique passwords and other access information to the winTwins PLANET STORE Services secret and follow basic security principles.

11. How and when can you withdraw your consent to the processing of personal data?

Your voluntarily granted consent to the processing of your personal datayou can revoke at any time free of charge by sending an e-mail message to the address: info@planet-store.com. Withdrawal of consent does not affect the processing of personal data that we process on a different legal basis than consent (i.e. especially if the processing is necessary for the fulfillment of the Registration Agreement, legal obligations or for other reasons specified in applicable legal regulations).

12. Are you obliged to provide PLANET STORE with your personal data? What if you do not provide personal data?

You provide your personal data to PLANET STORE voluntarily. Some of your personal data are necessary for the conclusion and fulfillment of the Registration Agreement and the proper provision of the PLANET STORE Services of the winTwins application. If such necessary personal data is not provided to PLANET STORE by you, PLANET STORE will not be able to properly fulfill the Registration Agreement and provide the PLANET STORE Services of the winTwins application.

13. What rights do you have in connection with the protection of your personal data?

In relation to your personal data, you have the following rights in particular:

the right to withdraw your consent at any time,

the right to correct or supplement personal data,

the right to request restriction of processing,

the right to raise an objection or complaint against processing in certain cases,

the right to request the transfer of personal data (including the right to obtain your processed personal data free of charge in a structured, commonly used and machine-readable format),

the right to access personal data,

the right to be informed of a breach of personal data security in certain cases,

the right to erasure of personal data in certain cases (including the right to be "forgotten"), and possibly also

other rights set forth in the Personal Data Protection Act and the Regulation (after its entry into force).

The aforementioned request and/or notification must contain information about the User's name and e-mail address in order to verify that such request and/or notification actually originates from the User in question. If the User submits a request by e-mail and does not specify another form of communication, PLANET STORE will comply with the User's request and will communicate with the User through his/her e-mail address. If PLANET STORE receives your request in the sense of the previous paragraph, it will inform you of the measures taken without undue delay and in any case no later than one month after receiving the request. If necessary, this deadline can be extended by another two months, taking into account the complexity and number of applications. If PLANET STORE does not take the relevant measures you request, it is obliged to inform you immediately and no later than one month after receiving the request about the reasons for not taking the measures. In this context, we would like to point out that in certain cases stipulated by the Regulation, PLANET STORE is not obliged to comply with your request in whole or in part. This will be the case especially if your request is clearly unfounded or unreasonable, especially because it is repeated. In such cases, PLANET STORE may (i) impose a reasonable fee taking into account the administrative costs associated with providing the requested information or communication or performing the requested actions or (ii) refuse to comply with the request.

14. How can you contact PLANET STORE?

In case of any question about the protection of personal data or withdrawal of consent to the further processing of your personal data, please contact us at our e-mail address info@planet-store.com or in writing at the address Štefánikova 18/25, Smíchov, 150 00 Prague 5. In in this context, we would like to inform you that we may require you to prove your identity in an appropriate way so that we can verify your identity. This is a preventive security measure to prevent unauthorized persons from accessing your personal data. Similarly, we may require you to prove your identity to us in an appropriate manner in the event that this is necessary for the fulfillment of obligations for the company PLANET STORE resulting from binding legal regulations of the Czech Republic and/or directly binding and applicable regulations of the European Union.

15. What are the remedies in case of violation of your rights?

In the event of a violation of your rights associated with the processing of your personal data, you can file a complaint with the Office for the Protection of Personal Data (www.uoou.cz). In order to resolve all privacy matters as quickly and easily as possible, we recommend that you first send any complaints or questions to PLANET STORE before contacting the authorities.