Draft for legal review. Not yet in force. Bracketed items are placeholders until the operating company is incorporated.
Privacy policy
Last updated: [date]
[Company name] s.r.o., [registered office], company ID [IČO], is the controller of the personal data described here. Contact: [privacy email].
What we collect
| Data | Why | Legal basis |
|---|---|---|
| Name, email, password hash | Run your account | Contract |
| Country and date of birth | Serve your market and enforce the 18+ rule | Contract, legal obligation |
| Offer credits, reversals and cash-outs | Pay you and keep financial records | Contract, legal obligation |
| PayPal email, Revtag or other payout details | Send your cash-outs | Contract |
| IP address, browser and sign-in times | Prevent fraud and multiple accounts | Legitimate interest |
| How you found us (referral or campaign code) | Measure which channels work | Consent |
Who receives it
- Offer networks such as BitLabs and AdGate Media receive your member ID and technical data when you open their walls. They act as independent controllers for their own attribution and fraud checks.
- The payout provider you choose (PayPal, Revolut or our bank) receives the details needed to send a cash-out. For gift cards, our gift-card provider [name] receives your email address to deliver the code.
- Our email, hosting and database providers process data on our behalf.
Some of these providers are in the United States. Transfers rely on the EU-US Data Privacy Framework or on Standard Contractual Clauses.
How long we keep it
Account data is kept while your account is open. Financial records are kept as long as accounting and tax law require, currently up to 10 years. Fraud signals are kept for up to 2 years after your last activity.
Cookies
We use cookies that are strictly necessary to sign you in and remember your language. The acquisition-source cookie is set only for visitors who arrive from a referral or campaign link. [Consent mechanism to be added before launch.]
Your rights
You can ask for access to, correction, deletion or a copy of your data, and object to processing based on legitimate interest. Write to [privacy email]. You can also complain to the Czech Office for Personal Data Protection (ÚOOÚ) or the authority in your country.