Privacy Policy
Privacy Policy Information on Personal Data Processing
The company Dopravní podnik města Brna, a.s. (hereinafter referred to as "we" or "DPMB, a.s."), ID: 25508881, with its registered office at Hlinky 64/151, Pisárky 603 00 Brno, Postal code: 65646, registered in the Commercial Register kept by the Regional Court in Brno, Section B, Insert 2463, as the controller of personal data, hereby provides information on the manner and scope of processing of personal data by this company, including the scope of data subjects' rights related to the processing of their personal data by DPMB, a.s. DPMB, a.s. processes personal data in accordance with European Union law, in particular Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, effective as of May 25, 2018.
Why Do We Process Personal Data?
We process your personal data to the necessary extent and always exclusively for clearly defined purposes, by specified means, in a specified manner, and only for the time necessary for the purpose of the processing. We process your personal data to provide you with our products or services. Typically, this involves identifying you. We are required to process your personal data by a number of legal regulations. We are entitled by law to process your personal data without your consent in order to comply with legal obligations of DPMB, a.s., particularly in the following cases:
- Conclusion or performance of a contract with you
- Compliance with notification obligations towards public authorities
- Compliance with obligations related to enforcement proceedings
- Protection of the rights and legitimate interests of DPMB, a.s. and third parties
- Handling any contentious matters, particularly for the purposes of conducting legal or other disputes
- Processing for archival purposes
Processing on these grounds is limited, as the existence of legitimate interest is carefully assessed. In other cases, we process your data only with your consent.
The processing of personal data necessary to fulfill legal obligations that apply to us is based mainly on the following legal regulations:
- Act No. 500/2004 Coll., Administrative Procedure Code, as amended
- Act No. 499/2004 Coll., on Archiving and Records Service, as amended
- Act No. 361/2000 Coll., on Road Traffic, as amended
- Regulation (EU) No. 165/2014, on Tachographs in Road Transport
- Act No. 247/2000 Coll., on Acquiring and Enhancing Professional Competence to Drive Motor Vehicles, as amended
- Act No. 111/1994 Coll., on Road Transport, as amended
- Act No. 266/1994 Coll., on Railways, as amended
- Act No. 127/2005 Coll., on Electronic Communications, as amended
- Act No. 200/1990 Coll., on Misdemeanors, as amended
- Act No. 134/2016 Coll., on Public Procurement, as amended
- Act No. 218/2000 Coll., on Budgetary Rules, as amended
- Act No. 183/2006 Coll., on Construction, as amended
- Act No. 262/2006 Coll., Labor Code, as amended
- Act No. 435/2004 Coll., on Employment, as amended
- Act No. 589/1992 Coll., on Social Security Insurance and Contribution to the State Employment Policy, as amended
- Act No. 592/1992 Coll., on Public Health Insurance Contributions, as amended
- Act No. 586/1992 Coll., on Income Taxes, as amended
Are You Obligated to Provide Personal Data?
For the conclusion and fulfillment of a transport contract, purchase contract, or other obligations arising from legal duties, the provision of the required data is necessary. In such cases, your data will be processed in a lawful manner. In other cases, we process your personal data solely with your consent. It is entirely your decision whether to provide, limit, or withhold your consent in the scope proposed by DPMB, a.s.
Purpose of Personal Data Processing by DPMB, a.s.
DPMB, a.s. processes only accurate personal data obtained in compliance with the Data Protection Act, which is collected and processed for a specific purpose and for the time necessary to fulfill that purpose. DPMB, a.s. complies with technical and organizational measures to ensure a level of security appropriate to all potential risks, with all persons handling personal data obligated to maintain confidentiality regarding information obtained in connection with the processing of this data.
The main purposes of personal data processing at DPMB, a.s. include:
- Conclusion and fulfillment of transport contracts
- Conclusion of purchase contracts
- Sale of non-transferable time-based travel documents
- Electronic ticketing of passengers
- Operation of the Senior BUS service
- Provision of driving school services, driver competency training, and regular competency training
- Accounting and tax purposes
- Debt collection
- Marketing purposes
- Protection of the property and individuals of DPMB, a.s.
- Job offers for applicants for employment at DPMB, a.s.
- Fulfillment of obligations arising from labor relations
- Publishing activities
What Data Do We Process
We process only the data necessary to provide professional services and fulfill contractual obligations, comply with our legal duties, and protect our legitimate interests. We process your identification and contact details, data related to the services you use, and other data, ensuring that the scope of these data is proportionate, relevant, and limited to the necessary extent in relation to the purpose for which we collect and process it. Our primary goal is to provide you with professional services while complying with all legal obligations of DPMB, a.s., and the rights and legitimate interests of DPMB, a.s.
1. Identification Data
Identification data includes your name, surname, date of birth, delivery address, type and number of identification document, photograph, place of birth, email, phone number, and bank account number. Identification data is a necessary part of every transport contract you conclude with us. Additionally, data necessary for providing tariff benefits, such as for students or retirees, or for cases of ticket refunds or complaints, is also processed.
2. Contact Data
Contact data includes contact addresses, phone numbers, email addresses, and other similar contact information.
3. Data Generated by Fulfilling Contractual Obligations
Data generated by fulfilling contractual obligations involves data concerning the product or service being provided, depending on the nature of the product or service.
4. Data Obtained in Connection with Providing Products and Services
We process data obtained during our interactions with you, such as how you use our services, or data you provide or generate while using the services.
5. Data Generated Directly by DPMB, a.s.
This includes product or service numbers assigned by us, data created by evaluating your behavior or the data you provide (e.g., to determine eligibility for discounts), the evaluation of a request for a product or service, or assessments needed to decide whether to offer you a product or service.
6. Other Data
DPMB, a.s. monitors and records selected communications with you, particularly telephone calls. If recordings are made, you will always be informed in advance. The content of such communications is confidential and used solely to comply with legal obligations, conclude and fulfill contracts, protect rights and legitimate interests, and with your consent.
We also collect information about the devices you use to access our services electronically. This helps us optimize our platforms, further develop them, and enhance security. Additionally, cookies are stored on your device in this context. Cookies are small text files stored on your computer when you first load a website.
Thanks to your opinions and expressed preferences, we can improve our services. These data include information from your use of our websites and applications, as well as details of our interactions with you through any contact point (how long, on what topic, and through which channel we communicate), including the resolution of complaints and suggestions. We also process feedback, comments, suggestions, and results from non-anonymous surveys as personal data.
Furthermore, DPMB, a.s. monitors the premises where services are provided. Video recordings are made solely for the purpose of complying with legal obligations, concluding and fulfilling contracts, and protecting the rights and legitimate interests of DPMB, a.s., you, or third parties. If recordings are not deemed necessary for criminal, administrative, or other similar proceedings, DPMB, a.s. will delete them without undue delay.
Sources of Personal Data
DPMB, a.s. obtains your personal data primarily during negotiations to conclude transport, employment, or other contracts. DPMB, a.s. acquires your personal data directly from you or indirectly, for example, when using our products or services. Furthermore, DPMB, a.s. obtains your personal data from publicly available sources (public registers or records) and through its own activities by processing and evaluating these other personal data.
DPMB, a.s. will always inform you when providing personal data is necessary for a specific service and when it is voluntary. However, providing such personal data will facilitate communication between you and DPMB, a.s., and significantly enhance service provision.
To ensure the security of DPMB, a.s. and the services provided, camera systems are installed on buildings managed or owned by DPMB, a.s. and in vehicles. Data subjects are always informed about the location of camera systems through information signs and pictograms at the entrance to such premises. Recordings from camera systems are archived for the necessary time and are not further processed beyond the stated purpose.
Certain data of customers using transport services of DPMB, a.s. within the IDS JMK framework is obtained from Kordis JMK, a.s., limited to data necessary for fulfilling transport contracts or conducting transport inspections in accordance with relevant legislation. Additionally, data is obtained from publicly available sources and registers, such as the business register.
How Long Do We Retain Your Data?
When handling your data, we adhere to the principles of data minimization. This means we have strict internal archiving rules to ensure that your personal data is processed only for the necessary duration relative to the purposes of its processing. We retain your personal data only for the time necessary to achieve the purpose. Afterward, your personal data is archived for 10 years to protect the rights and legitimate interests of DPMB, a.s. and third parties, and to address any potential disputes, particularly for conducting legal or other proceedings.
Data that we process with your consent is retained for as long as your consent remains valid. For clarity, we retain the consent itself, any changes, or revocations of the consent based on our legitimate interests for the entire period the consent is valid and for 10 years after it expires.
Recipients of Personal Data
We primarily process your personal data within DPMB, a.s. Data is transferred outside DPMB, a.s. only when required by legal regulations, when it stems from a contractual relationship, or when you permit it through consent. Data related to fulfilling a transport contract that is necessary for fulfilling the transport contract within the entire IDS JMK system, or for conducting transport inspections in accordance with relevant legislation, is transferred to Kordis JMK, a.s.
Rights of Data Subjects
We process your data transparently, fairly, and in accordance with the law. You have the right to access your data, request explanations, and exercise other rights if you believe the processing is not appropriate. You may also file a complaint with the Office for Personal Data Protection.
Scope of Processed Personal Data
DPMB, a.s. processes your personal data to the extent necessary to fulfill the aforementioned purposes. We primarily process contact and identification data, descriptive data, and other data in the necessary and legitimate scope. You have the right to information regarding the processing of your personal data. We will promptly provide you with all the information about what data we process about you. However, the rights of third parties must not be affected by this. We are entitled to request a reasonable fee not exceeding the necessary costs for providing such information.
Interested in Correcting Your Data?
If you find or believe that your data is incorrect or inaccurate, we will correct it upon your request or notification of an error, provided that we consider your request to be justified. Considering the purposes for which the data is processed, you also have the right to have incomplete data completed.
Do You Not Want or Are Unable to Provide Your Data?
You may refuse to provide the personal data we request from you. However, if the requested data is essential for fulfilling the contract or required by legal regulations, we cannot provide you with the associated service.
Do You Want to Revoke Your Consent?
You are not obligated to grant DPMB, a.s. consent to process your personal data, and you are also entitled to revoke this consent. In some cases, we are authorized to process certain personal data for specific purposes without your consent. If you revoke your consent, we will stop processing the relevant personal data for the purposes that require your consent, although we may still be authorized or even obligated to continue processing the same personal data for other purposes.
If you do not grant or revoke your consent, we may:
- Adjust the availability, scope, or conditions of our products or services accordingly, or
- Refuse to provide you with our products or services if we determine that such consent is necessary to provide the product or service under the given conditions.
Do You Want Us to Delete Your Data?
You have the right to request the deletion of personal data if our processing is unlawful.
Camera Systems
More information about camera systems and how data is stored can be found on a separate page.
Events Organized by DPMB, a.s.
During the course of our activities, there are times when we showcase our work, our progress, our products and services, or our employees at events organized by us. Please note that during such events, photographs and video recordings may be taken. These recordings will primarily capture the event itself. Individual participants will only be recorded if they consent to it. Additionally, we would like to inform you that we currently use social media platforms such as Facebook, LinkedIn, Instagram, and Twitter, so photos and video recordings from these events may be posted on these platforms. Recordings will always be made by a clearly identified person, so if you have any concerns about being recorded, feel free to approach them to ensure no further personal recordings are made. This person will also be able to provide you with all the necessary information about where the photos or videos may be posted.
You Can Exercise Your Rights with the Data Protection Officer at DPMB, a.s.
Data Protection Officer is R. Tomek: 543 171 252, email: rtomek@dpmb.cz. To submit a request, please use this form.