Joint processing of project data

1. Companies and purposes

The proposed joint controllers for jointly determined campaigns and sales records are AI Web s.r.o., company number 21012288, registered office Rohožnická 2908, Újezd nad Lesy, 190 16 Praha 9, Czech Republic, registered with the Municipal Court in Prague, section C, file 395519 and Neonmedia s.r.o., company number 23825944, Požárníků 162/2, Slavonín, 783 01 Olomouc, Czech Republic, Regional Court in Ostrava, section C, file 101103. Each company’s accounting, personnel and unrelated projects have separate purposes.

Data include business contact details, company and role, enquiry source and subject, relevant correspondence, agency attribution, licence status and necessary settlement records. Customer workflow content and special-category personal data are not automatically included. Depending on the purpose, the basis may be pre-contractual steps or a contract with the individual, assessed legitimate interests for company contacts, legal obligations or required consent.

2. Access by both companies and changing responsibilities

Either company may authorise its staff or contractors to handle project communications and relevant data. Access follows the actual task, necessity and confidentiality obligations; it is not reserved to one company or a named individual. Task handovers are recorded without rewriting the entire contract.

Sharing project correspondence does not mean opening entire private mailboxes or unrelated databases. Work carried out solely on another party’s instructions requires an Article 28 processing arrangement. Actual decisions determine roles regardless of contract labels.

3. Third-party tools

Either company may use assessed CRM, hosting, file storage, communications, billing, marketing-automation and AI services for the agreed purpose. No particular brand is mandatory. Before personal data are entered, the legal provider, role, purpose, required contract, security, retention and any transfer outside the EEA must be assessed.

Actual suppliers and data flows are maintained in current records and disclosed as required by law. Changes to subprocessors under general authorisation require active notification and an opportunity for the relevant controller to object under the adopted agreement. New processing cannot start before these requirements are satisfied.

Processing a contact in a business AI service and uploading an entire CRM into a personal account have different contractual and security requirements. A general mention of AI does not authorise both.

4. Individual rights and responsibilities

The proposed common contact is privacy@ptbk.io; individuals may exercise rights against either company. AI Web coordinates notices and request records. Neonmedia provides information when collecting contacts and forwards requests within two working days. Each company remains responsible for the systems and suppliers it engages; task transfers are recorded.

Retention follows the necessary purposes and applicable legal claims. On termination, access is adjusted and legally retained records are separated. Permission to send marketing emails is assessed independently: sharing a contact does not itself transfer consent or another company’s customer exemption.