General principles

1. The controller of the personal data you provide is James Cook Languages s.r.o., Company ID No.: 26753456, with its registered office at Národní 416/37, 110 00 Prague 1, Czech Republic (hereinafter referred to as “JCL”), with whom you have concluded a contract or to whom you have granted consent to process personal data.

2. The Data Protection Officer is Milan Kinský, e-mail: poverenec@eduagroup.cz

3. At JCL, we process your personal data:

• for a clearly and comprehensibly defined purpose, by specified means, in a specified manner, and only for the period necessary in relation to the purposes of processing;
• we process only accurate personal data and ensure that the processing corresponds to the stated purposes and is necessary to fulfil them;
• we always clearly inform you about the processing of your personal data and about your rights to accurate and complete information regarding the circumstances of such processing, as well as your other related rights;
• we have implemented appropriate technical and organisational measures to ensure a level of security corresponding to all possible risks;
• all persons who come into contact with personal data are obliged to maintain confidentiality regarding information obtained in connection with the processing of such data.

All personal data processing is carried out 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, repealing Directive 95/46/EC (General Data Protection Regulation; hereinafter referred to as the “Regulation”).

Legal Basis, Purpose and Scope of Processing

Without Your Consent

We may process your personal data without your consent:

• on the basis of a concluded contract for the purpose of entering into and/or performing the contract;
• for the purpose of fulfilling legal obligations of the supplier or customer (especially accounting obligations);
• for the purposes of our legitimate interests, e.g. sending commercial communications to our customers.

In this case, we process in particular identification and contact data, i.e. first name, surname, address (or business address), Company ID No. (if cooperation is based on a trade licence), date of birth, e-mail address, and telephone number.

With Your Consent

Based on your consent, we process in particular identification data, i.e. first name, surname and e-mail address. Consent is granted for the purposes specified in the consent, e.g. for sending commercial communications. You are not obliged to grant consent and may withdraw it at any time.

Method of Processing

We process your personal data manually, in particular by storing it in IT systems, on data carriers, through administration and retention (archiving), backups, blocking, and making it accessible to persons designated by the Controller.

Recipients of Personal Data

Your personal data is processed by our duly trained employees who work with your personal data in finance and customer care. To the necessary extent, your personal data is also processed by third parties acting as processors within the EDUA Group group, to which JCL belongs, namely:

• EDUA Group, s.r.o., Company ID No.: 03148441, Národní 416/37, 110 00 Prague 1, as a service company within EDUA Group providing accounting and IT services;
• School of languages s.r.o., Company ID No.: 27641074, Národní 416/37, 110 00 Prague 1;
• Jipka moje jazykovka, s.r.o., Company ID No.: 27385906, Národní 416/37, 110 00 Prague 1;

and other external service providers based in the Czech Republic, such as freelance language teachers.

Before any transfer of your personal data to a third party (processor), we always conclude a written agreement with such party containing the same guarantees for personal data processing as required by law.

Your personal data is processed within the Czech Republic and other member states of the European Union.

It is also processed in the cloud services of Google LLC, and such processing is safeguarded on the basis of the European Commission Adequacy Decision without the need to use transfer tools under Article 46 GDPR, namely the EU-U.S. Data Privacy Framework. Google LLC is listed in the Data Privacy Framework List maintained and published by the U.S. Department of Commerce and therefore ensures an adequate level of protection for personal data transferred from the EU to organisations in the United States.

Apart from the processing described above, your personal data is not transferred to any third country or international organisation.

Retention Period

We process personal data only for the period necessary in relation to the purposes of processing, in particular for the duration of the contractual relationship for the purpose of fulfilling the contract or agreement, and for the period required to fulfil legal obligations; in the case of granted consent, for 5 years and/or until it is withdrawn.

We continuously assess whether there is still a need to process certain personal data for a given purpose. If we determine that such data is no longer necessary for any of the purposes for which it was processed, we will delete or anonymise it.

Your Rights

In the area of personal data processing, you have the following rights:

• the right of access to personal data;
• the right to rectification;
• the right to erasure;
• the right to restriction of processing;
• the right to data portability;
• in the case of data processed without your consent, the right to object;
• the right to lodge a complaint with the Office for Personal Data Protection;
• the right to withdraw granted consent.

You are not obliged to grant consent to the processing of your personal data, and you are entitled to withdraw such consent at any time.

Please note that some personal data may also be processed for certain purposes without your consent. If you withdraw your consent in such a case, we will cease processing the relevant personal data for purposes requiring consent, but we may remain entitled, or even obliged, to continue processing the same personal data for other purposes.

If you wish to withdraw your consent to the processing of personal data (if granted), please contact us in writing at: James Cook Languages, s.r.o.
Karlínské náměstí 8, 186 00 Prague 8, Czech Republic or by e-mail: jazyky@jcl.cz or using the above-mentioned contact details of the Data Protection Officer.

Final Provisions

These Personal Data Processing Principles are valid from 1 June 2025.