Privacy Policy

Data controller
Ivo Kleňha, Company ID (IČO): 66375274 · Not VAT registered
Registered address: Za Zelenou liškou 1586/2a, 140 00 Prague 4
Premises (handover of media in person): Přímětická 10, 140 00 Prague 4 – Krč
Email: info@zaloha-vzpominek.cz
Phone: +420 607 828 970
This policy takes effect on 1 January 2026

Article 1 – Introduction

This Privacy Policy describes how the controller processes the personal data of natural persons (the „Data Subject“) in connection with providing audiovisual media digitising services and operating the website zalohavzpominek.cz.

Processing is governed by 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 (the „GDPR“) and by Act No. 110/2019 Coll., on Personal Data Processing.

Article 2 – Categories of data processed

• Identification data: first name, surname and, for business customers, company and tax identification numbers.
• Contact data: delivery address, email address, telephone number.
• Order data: description of the media, services selected, deadlines, price, payment details.
• Content of the digitised media: where a recording shows people, contains their voices or other information, this constitutes personal data of the Data Subject and of third parties under the GDPR (see Article 8).
• Website data: IP address, device identifiers, cookie data (see Article 7).

Article 3 – Purposes and legal bases for processing

Purpose of processing	Legal basis	Retention period
Performance of the contract (fulfilling the order)	Art. 6(1)(b) GDPR	duration of performance plus 3 years
Accounting and tax obligations	Art. 6(1)(c) GDPR	10 years as required by law
Backup copy of digitised content	legitimate interest of the controller, Art. 6(1)(f) GDPR	12 months
Marketing (newsletter, offers)	consent, Art. 6(1)(a) GDPR	until consent is withdrawn
Analytics and website traffic measurement	consent (cookies)	according to cookie settings
Defence of legal claims	legitimate interest of the controller	for the duration of the limitation periods

Article 4 – Recipients of personal data

Personal data may be passed, to the extent necessary, to the following categories of recipients (processors):

• Česká pošta, s.p. and its subsidiaries (Balíkovna) – for delivering parcels.
• Posílej.cz – for temporary cloud storage of transferred files.
• Google LLC – for analytics and measuring website effectiveness (Google Analytics, Google Ads), only with consent given through the cookie banner.
• Accountant and tax adviser – for compliance with statutory obligations.
• Public authorities, to the extent required by law.

Article 5 – Transfers to third countries

Where Google LLC services are used, certain technical data may be transferred to the USA. Such transfers take place under the Data Privacy Framework (DPF), in which Google LLC is certified. That framework constitutes an adequacy decision of the European Commission under Article 45 GDPR.

Article 6 – Retention period

We keep personal data only for as long as is necessary for the purposes for which they were collected, or for as long as the law requires.

A backup copy of the digitised content is kept for 12 months after the order is completed, in case the resulting medium is lost. After that period the backup is permanently deleted.

Article 7 – Cookies

Our website uses cookies (small text files) so that the site works properly, to measure traffic and to measure how well advertising campaigns perform.

• Necessary cookies – required for the site to operate. These cannot be declined.
• Analytics cookies (Google Analytics) – measure how visitors use the site. These require consent.
• Advertising cookies (Google Ads) – measure the effectiveness of advertising campaigns. These require consent.

Consent to optional cookies can be changed at any time using the „Cookie settings“ link in the site footer.

Article 8 – Content of the media and third-party data

Recordings supplied for digitising may contain personal data of third parties (for example images of family members). The controller processes such data solely for the purpose of performing the contract with the Customer, does not store them separately outside the order and does not pass them to third parties.

The Customer declares that they are entitled to deal with the content of the media supplied, or that they have obtained the necessary consents from the persons concerned.

Article 9 – Security

The controller has implemented appropriate technical and organisational measures to protect personal data, in particular:

• physical security of the premises,
• protection of data storage with passwords and encryption,
• a limited group of people with access to the data,
• regular updates of security systems.

Article 10 – Rights of the Data Subject

Under the GDPR, the Data Subject has the following rights:

• Right of access (Art. 15 GDPR) – to obtain confirmation as to whether their data are being processed and a copy of those data.
• Right to rectification (Art. 16 GDPR) – to request correction of inaccurate data.
• Right to erasure (Art. 17 GDPR) – to request erasure of personal data where there is no legal ground for continued processing.
• Right to restriction of processing (Art. 18 GDPR).
• Right to data portability (Art. 20 GDPR).
• Right to object to processing based on legitimate interest (Art. 21 GDPR).
• Right to withdraw consent at any time, where processing is based on consent (Art. 7(3) GDPR).
• Right not to be subject to automated decision-making (Art. 22 GDPR) – the controller does not carry out automated decision-making.
• Right to lodge a complaint with the supervisory authority: Office for Personal Data Protection, Pplk. Sochora 27, 170 00 Prague 7, www.uoou.cz.

Article 11 – Exercising your rights

The Data Subject may exercise these rights in writing by email at info@zaloha-vzpominek.cz or by post to the address of the premises. The controller will respond without undue delay and within 30 days at the latest.

Where there is doubt about the identity of the applicant, the controller may request additional verification.

Article 12 – Final provisions

This Privacy Policy is a translation of the Czech original. In the event of any discrepancy between the Czech and the English version, the Czech version prevails. The binding Czech wording is available at zalohavzpominek.cz/gdpr.html.

This Privacy Policy takes effect on 1 January 2026. The controller may amend the policy unilaterally; the current version is always published on the website.

Prague, 1 January 2026