PRIVACY & SECURITY POLICY

Effective date/ Last review date: 13 May 2025

This Privacy & Security Policy (“Policy”) explains how TMDS CZ s.r.o. ("TMDS", "we", "our", or "us") handles your personal data when you interact with our website www.tm-ds.cz (“Site”) or contact us directly. We are committed to protecting your privacy and ensuring compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR) and relevant trade and financial sanctions regulations.

This Policy applies to all users of the Site and to any personal data obtained through direct communication with TMDS (e.g. email correspondence). It does not apply to third-party websites linked from our Site. TMDS does not control or endorse the privacy practices of such websites, and we encourage users to review their privacy policies independently.

TMDS does not actively collect or process personal data from visitors to its Site, nor do we employ analytics or tracking tools for profiling or marketing purposes.

We may, however, collect limited personal data if you:

• Contact us by email or contact form;
• Provide information in the course of business negotiations or due diligence.

This data is collected directly and voluntarily from you and may include your name, contact details, and business information necessary for communication and compliance.

Any personal data we receive is processed solely for legitimate purposes, including:

• Responding to your inquiries;
• Carrying out business communications or contractual obligations;
• Ensuring compliance with legal obligations (e.g. AML, sanctions screening, export control checks).

Legal bases under GDPR include:

• Article 6(1)(b): Performance of a contract or pre-contractual steps;
• Article 6(1)(c): Compliance with a legal obligation;
• Article 6(1)(f): Legitimate interests, such as maintaining contact with counterparties or ensuring regulatory compliance.

We do not use your data for direct marketing, nor do we sell or share your personal information with third parties for commercial purposes.

Personal data is retained only for as long as necessary to fulfill the purpose for which it was collected or to comply with legal, regulatory, or contractual obligations. When no longer needed, data is securely deleted or anonymized.

We implement appropriate technical and organizational security measures to protect personal data against unauthorized access, alteration, or disclosure. These measures include access controls, encryption protocols, and secure communication channels for business correspondence.

TMDS may engage in business communications with entities based outside the EU. Any such engagement is subject to screening against applicable EU, UN, and US sanctions lists. We ensure that no personal or business data is transferred to or processed by entities or individuals on restricted or prohibited lists.

We do not conduct business or store data in jurisdictions subject to comprehensive sanctions, embargoes, or data protection inadequacies without lawful exemption.

You have the right to:

• Access your personal data (Art. 15 GDPR)
• Rectify inaccurate or incomplete data (Art. 16)
• Request erasure (“right to be forgotten”) (Art. 17)
• Restrict processing under certain conditions (Art. 18)
• Object to processing (Art. 21)
• Receive your data in a portable format (Art. 20)
• Withdraw consent (Art. 7(3)) where consent is the legal basis

To exercise your rights, please contact us at info@tm-ds.cz.

This Site does not use cookies for behavioral tracking, analytics, or advertising. Only functional cookies essential for navigation and basic performance may be used. You will not be prompted to accept or reject cookie tracking because no non-essential cookies are present.

TMDS does not engage in unsolicited promotional outreach (e.g. cold calling, mass emailing). All communications are initiated based on existing business relationships or lawful interest.

We reserve the right to decline or ignore communication that lacks a clear lawful basis, especially if it originates from or is linked to jurisdictions under sanction or trade restrictions.

We may revise this Policy periodically to reflect changes in law, technology, or our business practices. The most current version will always be available on our Site. We encourage you to review it regularly.

For any questions, concerns, or data-related requests, please contact: info@tm-ds.cz