Privacy Policy

Effective: 16 October 2026

1. Who the controller is and how to contact us

1.1 The controller of the personal data described in this policy is HypeDigitaly s.r.o., company ID (IČO) 17665655, registered office Velká Hradební 2800/54, 400 01 Ústí nad Labem, Czech Republic (“we”, “us”). We run the HypeLead service (the “Service”) and the HypeLead website.

1.2 For data protection matters, including requests to exercise your rights, write to us at info@hypedigitaly.ai (see section 17). We have not appointed a data protection officer.

1.3 This policy explains what personal data we process, why, on what legal basis, to whom we pass it, how long we keep it and what rights you have under Regulation (EU) 2016/679 (GDPR).

2. Our roles

2.1 We are the controller of data about our customers and users, billing data, data about website and waitlist visitors, data for the security and operation of the Service, and data we find and enrich about companies and contacts (“lead data”).

2.2 We are a processor of the data that our customers put into the Service and use to contact their recipients, for example their contacts, campaigns, messages and replies. The customer is the controller of that data. We process it on the customer’s instructions and under the Data Processing Agreement.

2.3 If one of our customers contacted you by email through the Service, you will find that customer’s own privacy notice through the link in its email. It describes how the customer handles your data. This policy covers only our part, meaning how we, as controller, found and enriched your data.

2.4 We are also the provider of an AI system within the meaning of Regulation (EU) 2024/1689 (the AI Act).

3. Customers and users of the Service

3.1 What data: name, email, password (stored only as a secure hash), language, role in the workspace, company details, settings, details of connected accounts (for example the mailbox address; we store access credentials encrypted), records of use of the Service, security records (for example IP address and browser at login), support communication, and records of your acceptance of our documents (version, time, IP address and browser).

3.2 Why and on what basis:

• providing the Service and managing the account: performance of a contract (Art. 6(1)(b) GDPR),
• security, preventing misuse and improving the Service: our legitimate interest (Art. 6(1)(f) GDPR),
• proof of acceptance of documents and defence of legal claims: our legitimate interest,
• service emails (for example a verification code, invitations, a reminder that the trial is ending): performance of a contract.

3.3 If you sign in with Google, we receive from Google only your name, email and profile picture. This does not give us access to your Gmail.

4. Billing and payments

4.1 Subscriptions are sold by Stripe as merchant of record under Stripe Managed Payments. At payment the purchase appears as “Sold through Link”.

4.2 For the payment, taxes and the invoice, Stripe is an independent controller. Stripe handles the payment and purchase data it processes and keeps under its own privacy policy. For that data, contact Stripe (stripe.com/privacy). Stripe keeps transaction data while it provides its services and then for as long as its legal, tax and accounting duties and fraud prevention require.

4.3 Data we hold: billing name and address, company ID and VAT ID, billing email, Stripe customer, subscription and payment identifiers, and the last four digits and type of the payment card. We never receive the full card number or security code. The card form is hosted by Stripe.

4.4 Why and on what basis: performance of a contract, compliance with accounting and tax obligations (Art. 6(1)(c) GDPR), and our legitimate interest in handling payment disputes and claims.

4.5 We check company IDs and VAT IDs in public registers (ARES, VIES, HMRC for UK companies, SEC EDGAR for US companies) so that we can prefill billing details.

4.6 If you ask for erasure, we do not delete the Stripe payment identifiers immediately. We restrict their processing to accounting and the defence of claims and keep them for the period required by law.

5. Trial protection

5.1 To make sure each person gets a trial only once, we store a hash (made with a secret key) of the verified email address and a card fingerprint from Stripe processed the same way. Neither the address nor the card number can be recovered from the hash.

5.2 The basis is our legitimate interest in preventing misuse. We keep the hash for as long as we offer trials, and it stays after the account is deleted. It is erased by replacing the secret key.

6. People we find (lead data)

6.1 The Service helps our customers find companies and work contacts for the people who work there. We are the controller of this search and enrichment.

6.2 What data: name, job title, company, work email, work phone (if available), a link to a public profile (for example LinkedIn), country and city, and public information about the company.

6.3 Where the data comes from:

• from the company and contact database supplier Prospeo,
• from public company registers, for example ARES,
• from public websites that our system reads, including searches through Serper,
• in Research mode, at a customer’s request, our AI agent reads public websites (an organisation’s own pages, public directories and search results) and finds the people who hold the roles the customer asked for. For each person we record the address of the page and the date it was read,
• from our own derivation: our system can guess the pattern of a work email address from the company domain and check with the mail server whether the address exists.

6.4 Why and on what basis: so that our customers can find and contact companies that fit their offer. The basis is the legitimate interest (Art. 6(1)(f) GDPR) of us and our customers. We have a written legitimate-interest assessment. We review it at least once a year and whenever we change how we find or enrich data. On request we will send you a summary of it (section 1.2).

6.5 How we protect you:

• the Service is built for work contacts: our system never guesses addresses at free email providers (for example gmail.com or seznam.cz). If such an address reaches the Service from our data supplier or from a customer, the Service does not block revealing or using it; whether the customer may use it is the customer’s responsibility,
• we do not collect special categories of data (for example health, religion, political opinions), and if our filter catches any, we delete it,
• anyone who contacts you by email through the Service must include in the first email a link to their privacy notice and an unsubscribe link. Messages sent through the Service on LinkedIn or WhatsApp do not contain these links; if you do not want such messages, tell the sender or contact us (section 17),
• if you unsubscribe from or object to the sender who contacted you, we add the email address or other identifier you used to that sender’s unsubscribe list, and the sender can no longer contact you through the Service at that identifier. If the sender’s contact record links that identifier to other identifiers of yours (for example another email address, a LinkedIn profile or a phone number), we block those too; otherwise the block covers only the identifier you used. You can object to our own search and enrichment directly with us (section 17).

6.6 Automated scoring: the Service can give a company a score for how well it matches the ideal customer our customer described. The score is only an input. A person decides whom to contact. This is not automated decision-making with legal effects under Art. 22 GDPR.

6.7 We keep lead data while the legitimate interest lasts, or until a customer or we delete it. Search results that a customer has not saved to its contacts are kept in full for 90 days from when the Service found them. After that the Service deletes the person’s name, job title, company and contact details from the result. Of the identifiers (email address, phone number, profile link and the data supplier’s record number) it keeps only a hash made with a secret key, from which they cannot be read, so that the customer does not fetch and pay for the same person twice. The same happens at once when a customer rejects a search result. The hash stays in that customer’s workspace until the workspace is deleted. If your data is erased, these records are deleted in full, and the Service keeps only what the next sentences describe. When your data is erased from a customer’s workspace, the Service keeps two things in that workspace on purpose, so that the customer who held your data cannot upload you and contact you again: a hash of your identifiers made with a secret key, from which the identifiers cannot be read, and an entry on that workspace’s unsubscribe list. The unsubscribe entry contains the identifier itself (for example your email address) in plain text, in a standardised form, because the Service needs it to keep your unsubscribe working. The entry stays even if the customer later deletes its workspace. This block applies only to that customer. If you want no customer to be able to email you through the Service, ask us to block you for every customer (section 17).

6.8 Research mode. In Research mode, at a customer’s request, our AI agent looks on public websites for the people who hold the roles the customer is interested in. As for all lead data in this section 6, we are the controller of finding your data and of passing it to that customer (section 6.1). The customer is the controller of its own outreach to you: it decides whether to save you to its contacts and whether to contact you, and you can also exercise your rights about that outreach with the customer. In addition:

• the first email that the customer sends you through the Service says that HypeDigitaly found your data and where, links this policy and gives our address for objections;
• to object to our processing, or to exercise your other rights (section 17), write to info@hypedigitaly.ai. A member of our staff handles your request within the period in section 17.4;
• if you object to us, we block your email address across the whole Service: no sender using HypeLead can email you at that address, and Research mode no longer stores that address for any customer. To keep this working, we keep your email address on our blocking list. The block works by email address, so if you use other addresses, tell us all of them;
• we read only pages that anyone can open without logging in, and we respect robots.txt;
• we delete results the customer did not save no later than 90 days after the search ends. Results the customer saved are kept by the customer as its contacts, and the customer is then responsible for them;
• we do not search for private individuals or minors, or for people by their health, religion, political opinions, trade-union membership, sexual orientation or criminal record.

7. Onboarding guide before sign-up

7.1 On the entry screen you can enter your website address or a description of your company and the Service shows you what finding customers would look like. This works before an account is created.

7.2 We process what you enter, the public pages of your website and the results of company and contact searches. Contacts are hidden before sign-up: you see only the first name and the initial of the last name, with no email or profile link. Nothing is revealed or sent.

7.3 The basis is our legitimate interest in showing the Service to a prospective customer. If you do not sign up, we delete everything after 7 days.

7.4 During the guide we use only a necessary session cookie (see the Cookie Notice).

8. Website visitors

8.1 Server logs. When you visit our website, the server records your IP address, the time, the page requested, browser details and the address of the website you came from. Of that address we keep only the website itself (for example google.com), never the specific page or the link parameters (such as the fbclid click identifier). From older logs we removed the link parameters (such as fbclid) from that address once. We use the logs for security and troubleshooting on the basis of our legitimate interest. We keep them for 14 days. We do not pass them to Google Analytics, Meta or the visit script.

8.2 Google Analytics 4. On the main website we load Google Analytics 4 only if you allow the Analytics category in the cookie banner. The waitlist page (waitlist.hypelead.ai) has no cookie banner: there we load it as soon as the page opens, unless you switched Analytics off there before. You can switch it off at any time through “Cookie settings” in the footer. It tells us how many people visit the website, which pages they read and what they click. The data is pseudonymous: a random identifier, pages, events, approximate location at city level and device details (for example device type, operating system, browser and language). Google Analytics 4 does not store IP addresses. We do not send names, emails or text you type into forms to Google. Google signals and ad personalisation are off. Google Analytics keeps event and user data for 2 months. The service is provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland); it may transfer the data to Google LLC in the USA under the EU-US Data Privacy Framework and standard contractual clauses. Once we link Google Analytics 4 to our Google Ads account, Google Ads will import only one event from Google Analytics as a conversion: that you saved your details in the second step of the waitlist sign-up. From it Google Ads learns how many sign-ups our Google ads brought; we will not share any audiences for Google ads. On the main website, with your consent to the Marketing category, Google Analytics may then also store Google advertising cookies (gcl*) and use the data to measure our Google ads; without that consent, Google advertising signals stay off. On the waitlist page we do not store Google advertising cookies. On the main website the basis is your consent (Art. 6(1)(a) GDPR and § 89(3) of Czech Act No. 127/2005 Coll.). On the waitlist page the basis is our legitimate interest in measuring the effectiveness of our advertising (Art. 6(1)(f) GDPR); you can switch measurement off at any time in Cookie settings. The cookies last 14 months.

8.3 Company-level visits. We are preparing our own script which, after your consent in the Company-level visits category, would only find out which company a visit came from. It does not identify people, stores nothing in the browser and keeps the IP address for at most 24 hours. The script is not active yet and the category does not appear in the banner. We will update this policy before we switch it on.

8.4 Website address box on the home page. When you type into it, we send the text to our app so that we can suggest company names. For company name suggestions we use the Clearbit service. After you submit, we redirect you into the app, where section 7 applies.

8.5 Language and appearance. We remember your choice of language and light or dark appearance in your browser (see the Cookie Notice).

8.6 Meta Pixel. On the main website (hypelead.ai) we load the Meta Pixel only if you allow the Marketing category in the cookie banner; there the basis is your consent (Art. 6(1)(a) GDPR and § 89(3) of Czech Act No. 127/2005 Coll.), and you can withdraw it at any time through “Cookie settings” in the footer. The waitlist page has no cookie banner: we load the Meta Pixel as soon as the page opens, unless you switched the Marketing category off there before. It measures how many people came from our ads on Facebook and Instagram and how many of them joined. Meta receives the page, the time, browser and device details, the IP address, the identifier from the _fbp cookie (and _fbc if you came from an ad) and the fact that a waitlist sign-up happened. Automatic advanced matching is switched on for the pixel in Meta’s settings. The pixel can therefore turn contact details you type into a form on a page with the pixel (for example your email or phone number) into a hash in your browser and send that hash to Meta, so that Meta can match the visit to a Facebook or Instagram account. Meta does not receive these details in readable form, and we do not send it other text from the form, such as your answers to the questions. Section 9.7 describes how we report sign-ups directly from our server. We are jointly responsible with Meta Platforms Ireland Limited (Merrion Road, Dublin 4, Ireland) for collecting and passing on this data; further processing, for example for advertising, is done by Meta as a separate controller under its own policies. Meta may transfer the data to Meta Platforms, Inc. in the USA under the EU-US Data Privacy Framework. On the waitlist page the basis is our legitimate interest in measuring the effectiveness of our advertising and in matching visits to Meta accounts for that measurement (Art. 6(1)(f) GDPR); you can switch measurement off at any time in Cookie settings. The cookies last 90 days and are set for the whole hypelead.ai domain, so the browser also sends them to our other addresses ending in hypelead.ai; the app does not read them. The previous version of HypeLead at legacy.hypelead.ai uses the Meta Pixel on its own public pages too, only after your consent there. You can switch the Meta Pixel off at any time through “Cookie settings” in the footer; it then no longer loads.

8.7 On the main website the Meta Pixel is the only advertising pixel, and it loads only after your consent (section 8.6). We use no separate tag for Google Ads; we measure Google ads through Google Analytics 4 (section 8.2). We ourselves use no session recording, heatmaps or identification of individual visitors anywhere; matching with Meta accounts is described in section 8.6.

8.8 Page-load counter. For each page load on our website in a browser, the server writes to a separate log only the day, the website address (hypelead.ai or waitlist.hypelead.ai), the page, the request result, a flag for whether it is an automated program (a bot), the campaign tags in the link and the address of the website the visit came from (without the specific page). We do not write IP addresses, browser details or cookies to it. We use the log only to count how many times pages were loaded, by day, website and campaign tags, and which websites visits came from. The log itself is deleted after 14 days at the latest. Every day we turn it into aggregate counts, which identify no one, and we keep only those counts, for 25 months. This tells us which ads and posts bring visitors, even if you reject Google Analytics measurement. The basis is our legitimate interest in measuring and improving our marketing (Art. 6(1)(f) GDPR).

9. Waitlist

You can join the waitlist on the waitlist page (waitlist.hypelead.ai) or through the form on the main website (hypelead.ai). Both forms collect the same data and this section applies to both.

9.1 What data: email address, optionally your phone number (asked after you join, only to arrange the free setup), optionally your website address, optionally your answer to what you want to use the AI sales agent for, for sign-ups before 30 September 2026 optionally whether you want to use it on LinkedIn too and a link to your LinkedIn profile or company page, the campaign tags in the link you came through (utm_source, utm_medium, utm_campaign, utm_content, utm_term, for example which ad or post it was; we do not store the Facebook click identifier fbclid in the sign-up record), once this feature is switched on also the address of the website you came from (the website only, without the specific page), optionally your answers to four short questions after you join (your role, who you sell to, how many people sell in your team and where you heard about us), an internal fit rating A, B or C, the page language, and a consent record (time, IP address, browser, version of the consent text and of the policies you saw, and whether you ticked product news).

9.2 Why and on what basis:

• adding you to the waitlist, telling you when the Service launches, early access, and arranging and preparing the free setup: steps taken at your request before entering into a contract (Art. 6(1)(b) GDPR),
• your answer on whether you want to use the AI sales agent on LinkedIn too, and the link to your LinkedIn profile or company page (asked only before 30 September 2026): we use them only to prepare the setup and to know whether you want the LinkedIn channel. The basis is steps taken at your request before entering into a contract (Art. 6(1)(b) GDPR),
• the campaign tags from the link and, once this feature is switched on, the address of the website you came from: we use them to know which ads, posts and websites bring sign-ups, and to help decide whom to invite first. The basis is our legitimate interest in measuring and improving our marketing and in inviting first the people the Service fits best (Art. 6(1)(f) GDPR),
• your answers to the four questions after you join: they are voluntary and you can skip them. We use them to prepare the free setup; the basis is steps taken at your request before entering into a contract (Art. 6(1)(b) GDPR). Together with the campaign tags we also use them to decide whom to invite first, and your answer on who you sell to feeds the fit rating; the basis for that is our legitimate interest in inviting first the people the Service fits best (Art. 6(1)(f) GDPR),
• the fit rating A, B or C: we work it out from whether your email is a company or a personal address, whether you gave a website and who you sell to. It only helps us decide whom to invite first; a person on our team makes that decision, and the rating has no other effect on you. The basis is our legitimate interest in inviting first the people the Service fits best (Art. 6(1)(f) GDPR). You can object to it at any time (section 17): write to info@hypedigitaly.ai and we delete your rating and do not rate you again,
• product news by email: only if you tick the separate optional box, on the basis of consent (Art. 6(1)(a) GDPR). You can withdraw consent at any time through the link in every email.

9.3 We use the phone number only to arrange the free setup. We do not make sales calls to you, send SMS or WhatsApp messages, look up or enrich the number anywhere. We do not copy it into any contact list, campaign or the Service.

If you signed up before 30 September 2026, we use the LinkedIn link only to prepare the setup. We do not enrich, look up, scrape or import the profile or company page, we do not copy it into the Service, and we do not use it for any other purpose.

9.4 There is nothing to confirm: entering your email puts you on the waitlist. We send the welcome email through our email supplier Resend. Through Resend we also send the HypeDigitaly team an internal notice of your sign-up with these details: email, the form language, the time of sign-up, the campaign tags from the link and the fit rating. The notice does not contain your phone number.

9.5 How long: we keep your waitlist data (email, phone, website, your use-case answer, your LinkedIn answer and link if you signed up before 30 September 2026, the campaign tags, the address of the website you came from (once recorded), your answers to the questions and the fit rating) until 12 months after the product launches, and then we delete it. If you have become our customer by then, we keep it on as customer data (section 3). We delete it earlier if you ask or if you leave the list. If you sign up for the Service, we move your consent to product news to your account; otherwise we delete it together with the sign-up. We shorten the IP address after 30 days. The internal team notice (section 9.4) stays in the team mailbox, and we delete it together with the record: 12 months after the product launches, or earlier if you ask.

9.6 Deletion: write to info@hypedigitaly.ai. We delete the sign-up within the period in section 17. You do not need an account for this.

9.7 Reporting sign-ups to Meta from our server. Once we switch this feature on, our server will report two events directly to Meta (through the Meta Conversions API): that you joined the waitlist (the Lead event) and that you saved your details in the second step for the first time (the CompleteRegistration event). We send only the event identifier and time, the page address, the IP address and browser details stored with your sign-up, and the identifiers from the _fbp and _fbc cookies (_fbc only if you came from a Meta ad). We never send your email or phone number this way. We send an event only if the Marketing category is on for you: on the main website only after your consent to it, on the waitlist page unless you switched it off. We do not store the _fbp and _fbc identifiers in the sign-up record. Until they are sent they stay only in the job that sends the event, and after a successful send we delete them from it. If sending still fails after 7 days, we stop trying and delete the identifiers from the job. If you delete your sign-up, we also cancel jobs that have not been sent yet. We are jointly responsible with Meta for collecting and passing on this data, and the same legal basis applies as for the Meta Pixel (section 8.6).

10. Booking a call

10.1 You book the setup call in the Cal.com service. Our website only links to it and does not embed it, so it loads no cookies on our website.

10.2 We receive the details you enter in Cal.com (name, email, time, answers to questions) and use them to hold the call. The basis is steps taken at your request before entering into a contract. Cal.com’s privacy policy also applies to the booking itself. We keep booking data for no longer than 3.5 years after the call.

11. Affiliate programme

11.1 If you join the affiliate programme, we process your contact details, commission payout details and tax details, and information about customers who came through your link, to the extent needed to calculate the commission.

11.2 The basis is performance of a contract and compliance with accounting and tax obligations. We keep the data for the duration of the partnership and then for the period required by accounting and tax law.

12. Our own business outreach

12.1 We also use HypeLead ourselves to contact companies that may find it useful. In that case we are the controller and section 6 applies to you. Every email we send contains a link to this policy and an unsubscribe link.

13. Artificial intelligence

13.1 The Service uses artificial intelligence to find companies from a description, to research public information about companies, to score fit with the ideal customer, to write message drafts, to sort replies and in the in-app assistant.

13.2 We send tasks that may contain personal data through OpenRouter, Inc. (USA). Its data processing agreement, which forms part of its terms of service, contains the standard contractual clauses approved by the European Commission. Every request allows OpenRouter to pass the task only to the model providers OpenAI, Anthropic and Google. We do not promise that a provider stores no data at all. What it may do with the data is set by its contract with OpenRouter. The providers are listed in the Sub-processor List.

13.3 Speech-to-text runs on our own servers. We delete the audio right after transcription.

13.4 We mark emails with content created by artificial intelligence in a machine-readable way in the message header.

13.5 More information is on “How we use artificial intelligence”.

14. Open and click tracking in campaigns

14.1 Email open and click tracking is off by default in the Service. A customer can turn it on for a specific campaign, and only on its own verified domain. This is the customer’s decision and responsibility as controller.

14.2 If tracking is on, the customer states this in its privacy notice, which every one of its campaign emails links to. The recipient can unsubscribe at any time with one click.

15. Who we pass data to

15.1 We pass data only where needed:

• to our sub-processors and suppliers, for example for hosting, backup storage, email, search and artificial intelligence; the current list is on “Sub-processor List”,
• to Meta Platforms Ireland Limited to measure ads on the waitlist page, unless you switch it off, and on the main website after your consent (see sections 8.6 and 9.7),
• to Stripe as seller and independent controller for payments,
• to public registers in which we check company details,
• to authorities and courts where the law requires it.

15.2 Selling and sharing. We do not supply our data about people as a standalone list or data feed to data brokers or advertisers. We make the lead data described in section 6 available to our customers, who pay for the Service, including credits for revealing contact details; customers can also export the contacts they save. When we look up a contact in the Prospeo database, we send Prospeo the details needed for the lookup (for example the name, company, web address, email address or profile link), and Prospeo keeps them as its own data, as an independent controller, to maintain its database. Data about visits to our websites goes to Google and Meta only as described in sections 8.2, 8.6 and 9.7, apart from the encrypted backup copy described in section 15.3, which Google cannot read. You can object to our processing of lead data about you at any time (section 17).

15.3 Where the data is. We store Service data on Hetzner servers in the European Union. We also keep a copy of our backups with Google (Google Workspace). We encrypt it on our server before it leaves, and only we hold the key, so Google cannot read its content. Google may store this copy in any country where it has data centres, including the USA. Some suppliers are based outside the European Economic Area. For each of them, the Sub-processor List states which safeguard applies:

• for suppliers certified under the EU-US Data Privacy Framework (today Google, Meta, Resend, HubSpot and Cal.com), the European Commission’s adequacy decision for that framework,
• for OpenRouter (USA), the standard contractual clauses approved by the European Commission, which are part of its data processing agreement,
• for Prospeo (Canada), the European Commission’s adequacy decision for Canada; for its servers in the USA, Prospeo adds standard contractual clauses in its data processing addendum.

Where standard contractual clauses are the only safeguard, we have assessed in writing whether the law of the destination country allows the supplier to comply with them (a transfer impact assessment). We will give you a copy of the safeguards on request.

Web search (Serper.dev). Our system sends search queries to the web search supplier Serper.dev. Most queries are about companies (company name, web address, place). When the Service looks for contacts at a company, including finding email addresses for contacts a customer has imported or saved, and in some deeper company research, artificial intelligence writes the queries itself. Such a query may contain the name of a person: a name the artificial intelligence read on a web page, or the name of a contact that we or the customer already hold for that company. Serper.dev does not publish where it is established or where it processes data, so we cannot tell you whether an adequacy decision of the European Commission covers that country. It is not certified under the EU-US Data Privacy Framework and has given us no data processing agreement and no standard contractual clauses, so no other safeguard under Chapter V GDPR applies to this transfer. You can object to this processing (section 17).

16. How long we keep data

17. Your rights

17.1 You have the right:

• of access to your data, including where we got it,
• to have inaccurate data corrected,
• to erasure,
• to restriction of processing,
• to data portability for data you gave us,
• to object to processing based on legitimate interest; an objection to direct marketing always succeeds,
• to withdraw consent at any time, without affecting processing before the withdrawal.

17.2 How to exercise your rights: write to info@hypedigitaly.ai; you do not need an account. If we cannot tell from your message that the request comes from the person it concerns, we may ask you to confirm it from the email address the request is about. If you do not want to receive emails from a specific sender, just click the unsubscribe link in their email.

17.3 If the request concerns data controlled by one of our customers, we pass it to that customer and help them handle it.

17.4 We reply within one month. For complex or numerous requests we may extend this by two further months; we will tell you within the first month, with the reason. Handling is free of charge, except for manifestly unfounded or excessive requests.

18. Complaint to the supervisory authority

18.1 If you believe we process your data unlawfully, you have the right to lodge a complaint with the Czech Office for Personal Data Protection (Úřad pro ochranu osobních údajů, https://uoou.gov.cz) or with the supervisory authority in the country where you live or work.

19. Security

19.1 We protect data with encrypted transfer, encrypted storage of access credentials, separation of each customer’s data at database level, secure password storage, encrypted backups and access control. The one-off copy taken just before a database update is not encrypted; it stays on our own server, only administrators can access it, and we delete it within 30 days. Details are on /security.

20. Age

20.1 The Service is intended for people aged 18 or over. We do not knowingly process children’s data.

21. EU representative

21.1 We are established in the European Union, so we do not need to appoint a representative under Art. 27 GDPR.

22. Cookies

22.1 The cookies and similar technologies we use are described in the Cookie Notice.

23. Changes to this policy

23.1 We may update this policy. Each version has an effective date and stays available at a permanent link. We will tell you about material changes in the app or by email.