Findee Guardian

Privacy Policy

Effective from September 1, 2024

Global Tracking s.r.o., ID: 03807487, with registered office at Pitterova 2855/7, Žižkov, 130 00 Prague 3, registered in the Commercial Register maintained by the Municipal Court in Prague, File No.: C 428433 (hereinafter referred to as "Seller"), as the controller of personal data, hereby informs about the processing of personal data carried out in connection with the operation of the online store available at https://www.findeeguardian.com (hereinafter referred to as "E-shop"), the conclusion and performance of purchase contracts or service contracts with E-shop customers (hereinafter referred to as "Buyer") and the registration of Buyers in the E-shop, as well as in connection with the operation of the Findee Guardian application (hereinafter referred to as "Application") by the Seller as the operator and used by Buyers and other users (hereinafter referred to as "User"). This document also includes information about the rights that data subjects have in connection with the above-mentioned processing.

For any questions regarding privacy protection and the exercise of your rights, please use this contact:

1. For what purpose, on what legal basis, and what personal data do we process?

1.1. Purchase of goods or services in the E-shop

In order for the Seller to negotiate and conclude a purchase contract regarding goods or a service contract offered in the E-shop (hereinafter referred to as "Purchase Contract") with the Buyer, the Seller needs the following personal data of the Buyer - natural person:

  • identification data of the Buyer (name, surname, in the case of an entrepreneur also ID number, VAT number, registered office address),
  • contact details of the Buyer (e-mail, phone number, delivery and possibly billing address),
  • depending on the chosen payment method for the ordered goods, also the Buyer's bank account number and other payment data,
  • information from communication with you, information about the conclusion and performance of the Purchase Contract.

Without the above data, it is not possible to conclude or perform the Purchase Contract. The legal basis for processing this data is the conclusion and performance of the Purchase Contract at the Buyer's request.

The Seller allows Buyers to register and create a user account in the E-shop. If the Buyer registers and creates a user account, a contract for registration and management of a user account is concluded (hereinafter referred to as "E-shop Registration and Account Agreement"). For the purpose of fulfilling this contract, we process the data mentioned above and, in addition, the Buyer's access data - natural person (username and password in encrypted form).

The above data is necessary for the Buyer's registration and the creation and management of their user account; without it, it is not possible to conclude or perform the E-shop Registration and Account Agreement. The legal basis for processing this data is the conclusion and performance of the contract at the Buyer's request.

1.2. Use of the Application and access to Paid Access

The Seller concludes an agreement on the use of the Application with the User (hereinafter referred to as "Application Usage Agreement").

Users are required to register in the Application. In order for the Seller to negotiate and conclude the Application Usage Agreement with the User, the Seller needs the following personal data of the User necessary for registration and creation and management of their user account in the Application:

  • User ID (email address and password in encrypted form)
  • IP address,
  • information from communication with the User and other information about the course of the contractual relationship with the User.

Without the above data, it is not possible to conclude or perform the Application Usage Agreement. The legal basis for processing this data is the conclusion and performance of the contract at the User's request.

Paid Access is available in the Application, which the User can purchase through the Application. In order for the Seller to negotiate the terms of purchase of Paid Access and provide Paid Access with the User, the Seller needs the User's personal data specified in paragraph 1.2.2 of this document. Without this data, it is not possible to make a purchase of Paid Access or provide Paid Access. The legal basis for processing this data is the purchase of Paid Access and the obligation to provide Paid Access at the User's request.

For the provision of Paid Access and the fulfillment of related obligations, the Seller processes the following personal data of the User:

  • User's contact details (email),
  • data on the Paid Access payment made (payment identifier, date of execution),
  • photos and videos,
  • phone number,
  • information about the device from which the User accesses the Application,
  • geolocation data and pedometer data,
  • voice message recordings and text messages,
  • information about calls made.

1.3. Fulfillment of obligations arising from legal regulations

The Seller must process personal data in cases where required by law. For this purpose, the Seller processes personal data in particular in the scope required by the relevant legal regulations in connection with the Seller's obligation to handle complaints from Buyers or Users, keep accounts and fulfill related tax obligations, or to fulfill obligations imposed by archiving law.

1.4. Legitimate interests of the Seller

In justified cases, the Seller may also process personal data on the legal basis of protecting its legitimate interests. However, the Seller always carefully assesses and ensures that the interest in processing your data for this purpose does not disproportionately interfere with your privacy.

Identification of persons acting on behalf of the Buyer - legal entity: These are typically members of statutory bodies, employees or other authorized persons who are not a party to the contract with the Seller, but conclude the contract on behalf of the Buyer, communicate with the Seller and otherwise act on behalf of the Buyer. We need the personal data of these persons so that we can communicate and deal with the Buyer for the purpose of concluding a Purchase Contract or an E-shop Registration and Account Agreement, its further performance, or exercising the Buyer's rights. For these persons, we usually process name, surname, email, phone number, delivery address, job position or other relationship to the Buyer and data from communication with them.

Proof of consent to terms and conditions: When concluding a contract with a Buyer or User online (by electronic means), we store data necessary to identify the Buyer or User as a contracting party, so that in case of later doubts or disputes, we have a timestamp available as proof of the conclusion of the contract and consent to our terms and conditions in a specific version.

Defense and enforcement of legal claims: We process personal data for the purpose of protecting our legitimate interest, which is to ensure the possibility of our defense in any legal disputes, court proceedings or during inspections by state authorities or other public administration bodies (typically the Czech Trade Inspection, etc.). We process data so that we are able to prove, if necessary, that we have acted in accordance with our contractual obligations and legal regulations. In this context, we typically process identification and contact data of the Buyer or User, or persons acting with us on behalf of the Buyer or User, data on concluded contracts, their performance and communication with the Buyer or User, or persons acting on behalf of the Buyer or User.

1.5. Sending commercial communications

In the case of Buyers with whom we have concluded a Purchase Contract or who have registered in the E-shop and created a user account and in connection with which we have obtained their email and/or phone number, or in the case of other persons who have actively and voluntarily subscribed to our newsletters, we process personal data of these persons in the scope of email and phone number for the purpose of sending information and news about our services and products (commercial communications).

The legal basis for processing personal data for the purpose of sending commercial communications in the case of Buyers with whom we have concluded a Purchase Contract or who have a user account is the Seller's legitimate interest in informing about the Seller's latest offers.

The legal basis for processing personal data for the purpose of sending commercial communications in the case of persons who have actively subscribed to the newsletter without having concluded a contract with us is their consent, which was given by subscribing to commercial communications.

If you no longer wish to receive these messages from us, you can unsubscribe from them at any time free of charge, following the procedure stated in each commercial communication sent, or within your user account, or you can contact us at any time at the contact email listed above in this document.

2. From whom do we receive personal data and to whom do we pass it on?

We primarily obtain personal data from data subjects (Buyers or Users). Unless otherwise stated, we do not find out any other data about you, other than what you provide us yourself or what arises from your activity within the E-shop or the Application. Some personal data - especially contact and payment data of data subjects - we may obtain from independent controllers - providers of payment methods available in the E-shop or the Application (Apple Pay, Google Pay). Information on how these providers process your personal data can be found directly with these providers.

We may transfer personal data under the conditions laid down by legal regulations to public administration bodies where required by law, or if requested by the given body within its competence.

For data processing, we use the following processors:

  • accounting service providers,
  • contractors - natural persons providing IT programming services,
  • hosting service providers.

Personal data may also be passed on to our business partners who act as independent controllers of personal data. These include in particular:

  • payment gateway operators through which online payments are enabled in the online store,
  • cooperating carriers used for delivering goods.

Information on how these partners process your personal data can be found directly with these partners.

Personal data may be transferred to countries outside the EU (specifically to the USA). In such a case, personal data is transferred to the USA in accordance with the European Commission's decision that the USA is a country that ensures an adequate level of protection within the meaning of Art. 45(3) of EU Regulation No. 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) according to the EU-US Data Privacy Framework and in accordance with the Data Privacy Framework List.

3. How do we process personal data?

We process your personal data primarily in electronic form by automated means in our IT systems, or in the systems of our individual processors. Personal data may also be processed manually in accordance with the relevant purpose where manual processing is necessary or appropriate.

Our employees or other persons working for us may be involved in the management of your data, including for the purpose of correcting errors, inaccuracies, etc. However, these persons may only process personal data under the conditions and to the extent stated above and are bound by the obligation to maintain confidentiality about personal data and security measures, the disclosure of which would jeopardize the security of personal data.

We always process personal data in accordance with the relevant legal regulations and ensure their proper care and protection. We take care that you do not suffer harm to your rights, especially the right to preserve human dignity and your private and personal life.

4. How long do we process personal data?

4.1. Purchase of goods or services in the E-shop or use of the Application and provision of Paid Access

Personal data processed for the purpose of concluding and performing a contract with the Buyer or User are processed for the duration of concluding and performing the given contract (i.e. for the time necessary to fulfill the obligations arising from the contract, or for the duration of your registration in the E-shop or for the duration of using the Application).

Even after that, we may process personal data for the following purposes:

4.2. Fulfillment of legal obligations

Personal data processed under our legal obligations are processed within the deadlines set by these laws.

Personal data required by legal regulations governing the Seller's tax and accounting obligations (typically billing data and information about the services provided) must be processed for the purpose of accounting and fulfillment of tax obligations. The processing period is 5 (five) years from the end of the accounting period, in the case of documents relevant for VAT payments it is 10 (ten) years from the end of the tax period in which the performance took place. We archive relevant personal data in accordance with the requirements of the archiving law for the periods set therein. We keep data processed for the purpose of handling complaints for the duration of the period for exercising rights from defective performance, or for the duration of the warranty period.

4.3. Legitimate interests

We process personal data even after termination of the contract with the Buyer or User for the protection of our legitimate interests (i.e. defense against any claims of the Buyer or User or third parties, including before a court) for the duration of the relevant limitation periods. If no relevant proceedings are initiated, we keep this data for 5 (five) years from the termination of the contractual relationship with the Buyer or User.

4.4. Sending commercial communications

Commercial communications, as stated above, are sent, and personal data for these purposes are processed until you unsubscribe from receiving them following the procedure stated in paragraph 1.5 of this document.

4.5. Longer processing

Personal data may be processed for longer than stated above in the event that a relevant reason for further processing arises, typically administrative or court proceedings are initiated for which personal data is relevant.

5. What rights do you have?

First of all, you have the right to ask us for access to your personal data, including obtaining a copy of all your personal data. You can do this using the email listed at the top of this document.

Withdrawal of consent to processing: If we process your personal data based on your consent, you can freely withdraw your consent to their processing at any time, free of charge, through your user account, the contact email listed above, or otherwise as stated elsewhere in this document. In such a case, we will no longer process your personal data processed on the basis of consent.

For personal data that is not processed on the basis of consent, it is not possible to withdraw consent to processing. However, based on your request, we will always assess whether it is still necessary to process your personal data for any of the above purposes.

Your other rights:

We will always inform you about:

  • the purpose of personal data processing,
  • personal data, or categories of personal data, that are the subject of processing, including all available information about their source,
  • the nature of automated decision-making including profiling and information concerning the procedure used, as well as the significance and expected consequences of such decision-making for the data subject,
  • the recipient, or categories of recipients, to whom personal data have been or will be disclosed, and in the case of transfer of personal data to a third country, also appropriate safeguards relating to the transfer to ensure the security of personal data,
  • the planned period for which personal data will be stored, or if it cannot be determined, the criteria used to determine this period,
  • all available information about the source of personal data, if they are not obtained from you.

Your other rights include:

  • asking us for an explanation,
  • requesting that we remedy the situation, in particular this may include blocking, correction, supplementation, restriction of processing or destruction of personal data (the right to be forgotten),
  • requesting a copy of processed personal data, or requesting personal data concerning you in a structured, commonly used and machine-readable format, and transferring this data to another controller without us hindering it in any way,
  • submitting a query or complaint to the Office for Personal Data Protection,
  • raising objections to the processing of personal data concerning you.

6. How do we protect your personal data

We protect your data. The following security measures serve this purpose: implementation and enforcement of internal regulations on personal data protection, antivirus protection, firewalls, encryption, access control to personal data and authorization data, backup, physical means of protection and others.