Privacy Policy – Summary
I. Basic Provisions
The data controller under EU Regulation 2016/679 (GDPR) is Smartgenio, s.r.o., ID 17794960, Nové sady 988/2, 602 00 Brno. Contact: info@smartgenio.eu.
Personal data includes any information relating to an identified or identifiable natural person. The controller has not appointed a data protection officer.
II. Sources and Categories of Data
Data is collected directly from you or obtained to fulfill your order. It includes identification and contact information necessary to perform contracts.
III. Legal Basis and Purpose of Processing
Legal grounds:
- Contract performance (Art. 6(1)(b) GDPR)
- Legitimate interest for direct marketing (Art. 6(1)(f) GDPR)
- Consent for direct marketing where no contract exists (Art. 6(1)(a) GDPR)
Purpose:
- Fulfilling inquiries or orders and related contractual obligations
- Sending commercial communications and newsletters
No automated decision-making is performed.
IV. Data Retention
- Data is stored as long as necessary for contractual purposes (up to 15 years).
- Marketing data is kept until consent is withdrawn, maximum 15 years.
- After retention periods, data will be deleted.
V. Recipients (Subcontractors)
Recipients may include:
- Providers of goods, services, or payment processing
- Service operators and marketing service providers
Data may be transferred to countries outside the EU for cloud or mailing services.
VI. Your Rights under GDPR
You may:
- Access, correct, or request deletion of your data
- Restrict processing or object to processing
- Request data portability
- Withdraw consent at any time
- File a complaint with the Data Protection Authority
VII. Data Security
Appropriate technical and organizational measures are in place, including secure storage, antivirus protection, backups, and controlled access.
VIII. Final Provisions
Submitting an inquiry or order confirms that you accept these privacy terms. The controller may update this policy; updates will be published online or sent via email.
IX. Cookies
Cookies are used according to the specified table.
| Processor | Cookies designation | Personal data | Purpose of processing | Legal Reason | Processing time |
|---|---|---|---|---|---|
| Technical cookies / similar technologies | |||||
| Smartgenio, s.r.o. | dcb_dsv | no | Version of consent to the processing of cookies. | legitimate reason | local storage / 365 dní |
| Smartgenio, s.r.o. | dcb_config | no | Configuration of consent to the processing of cookies. | legitimate reason | local storage / 365 dní |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | cookiePreferences | no | Registers the user's cookie preferences. | user consent | 2 years |
| Analytical cookies / similar technologies | |||||
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | _ga | no | ID used to identify users | user consent | 2 years |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | _ga_ | no | ID used to identify users | user consent | 2 years |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | _gid | no | ID used to identify users for 24 hours after the last activity | user consent | 24 hours |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | _gat | no | Used to track the number of Google Analytics server requests when using Google Tag Manager | user consent | 1 minute |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | _dc_gtm_ | no | Used to track the number of requests from the Google Analytics server | user consent | 1 minute |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | AMP_TOKEN | no | It contains the token code that is used to retrieve the client ID from the AMP Client ID service. | user consent | 30 seconds to 1 year |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | _gat_gtag_ | no | It is used to set up and get tracking data. | user consent | 1 hour |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | _gac_ | no | It contains information related to the user's marketing campaigns. These are shared with Google AdWords/Google Ads when Google Ads and Google Analytics accounts are linked. | user consent | 90 days |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | __utma | no | An ID used to identify users and sessions. | user consent | 2 years after last activity |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | __utmt | no | It is used to track the number of requests from the Google Analytics server. | user consent | 10 minutes |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | __utmb | no | It is used to differentiate between new sessions and sessions. This cookie is set when the GA.js javascript library is loaded and there is no existing __utmb cookie. The cookie is updated each time data is sent to the Google Analytics server. | user consent | 30 minutes after the last activity |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | __utmc | no | It is only used with old versions of Urchin Google Analytics, not with GA.js. It is used to differentiate between new sessions and sessions at the end of the session. | user consent | End of session (browser) |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | __utmz | no | It contains information about the traffic source or campaign that directed users to the website. The cookie is set when the GA.js javascript is loaded and is updated when data is sent to the Google Analytics server. | user consent | 6 months after last activity |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | __utmv | no | Custom information for web developers is received through the _setCustomVar method in Google Analytics. The cookie contains new updates as well as new reports on the Google Analytics server. | user consent | 2 years after last activity |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | __utmx | no | It is used to determine whether a user is included in an A/B test or a multivariate test. | user consent | 18 months |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | __utmxx | no | It is used to determine when an A/B or multivariate test in which the user participates ends. | user consent | 18 months |
| Hotjar Ltd - Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian\'s STJ 3141, Malta | _hjid | no | This cookie is set when a customer first lands on a page with a Hotjar script. It is used to keep a random user ID, unique to a given website in the browser. This ensures that the behavior on subsequent visits to the same website is attributed to the same user ID. | user consent | 365 days |
| Hotjar Ltd - Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian\'s STJ 3141, Malta | _hjIncludedInSample | no | This session cookie is set so that Hotjar knows if a given visitor is included in the sample that is used to create funnels. | user consent | 365 days |
| Hotjar Ltd - Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian\'s STJ 3141, Malta | _hjClosedSurveyInvites | no | This cookie is set as soon as a visitor interacts with the survey invitation modal pop-up. It is used to ensure that the same invitation does not appear again if it has already been displayed. | user consent | 365 days |
| Hotjar Ltd - Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian\'s STJ 3141, Malta | _hjDonePolls | no | This cookie is set once a visitor completes a survey using the Feedback Survey widget. It is used to ensure that the same poll does not appear again if it has already been completed. | user consent | 365 days |
| Hotjar Ltd - Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian\'s STJ 3141, Malta | _hjMinimizedPolls | no | This cookie is set as soon as a visitor minimizes the feedback survey widget. It is used to ensure that the widget remains minimized as the visitor navigates through your website. | user consent | 365 days |
| Hotjar Ltd - Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian\'s STJ 3141, Malta | _hjDoneTestersWidgets | no | This cookie is set once a visitor submits their information to the Recruit User Testers widget. It is used to ensure that the same form does not appear again if it has already been filled out. | user consent | 365 days |
| Hotjar Ltd - Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian\'s STJ 3141, Malta | _hjMinimizedTestersWidgets | no | This cookie is set as soon as a visitor minimizes the Recruit User Testers widget. It is used to ensure that the widget remains minimized as the visitor navigates through your website. | user consent | 365 days |
| Hotjar Ltd - Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian\'s STJ 3141, Malta | _hjShownFeedbackMessage | no | This cookie is set when a visitor minimizes or completes an incoming feedback. This is done so that incoming feedback is loaded as minimized immediately if they go to another page where it is set to be displayed. | user consent | 365 days |
| Hotjar Ltd - Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian\'s STJ 3141, Malta | _hjTLDTest | no | When the Hotjar script runs, we try to determine the most general cookie path we should use, instead of the hostname of the page. This is done so that cookies can be shared across subdomains (where applicable). To find out, we try to store the cookie _hjTLDTest for various URL substring alternatives until it fails. After this check, the cookie is deleted. | user consent | end of session (browser) |
| Hotjar Ltd - Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian\'s STJ 3141, Malta | _hjUserAttributesHash | no | User attributes sent through the Hotjar Identify API are cached for the duration of the session to detect when an attribute has changed and needs to be updated. | user consent | end of session (browser) |
| Hotjar Ltd - Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian\'s STJ 3141, Malta | _hjCachedUserAttributes | no | This cookie stores user attributes that are sent through the Hotjar Identify API whenever a user is not in a sample. These attributes will only be stored when the user interacts with Hotjar Feedback. | user consent | end of session (browser) |
| Hotjar Ltd - Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian\'s STJ 3141, Malta | _hjLocalStorageTest | no | This cookie is used to check if the Hotjar tracking script can use local storage. Where possible, this cookie is set to 1. Data stored v_hjLocalStorageTest has no validity period, but is deleted immediately after it is created, so the expected storage time is below 100 ms. | user consent | local storage |
| Hotjar Ltd - Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian\'s STJ 3141, Malta | _hjptid | no | This cookie is set for logged-in Hotjar users who have admin team member permissions. It's used during pricing experiments to show consistent pricing for admins across the site. | user consent | end of session (browser) |
| Hotjar Ltd - Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian\'s STJ 3141, Malta | _hjAbsoluteSessionInProgress | no | The cookie is set so that Hotjar can track the start of the user's journey for the total number of sessions. It does not contain any identifiable information. | user consent | 30 minutes |
| Hotjar Ltd - Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian\'s STJ 3141, Malta | _hjFirstSeen | no | The cookie is set so that Hotjar can track the start of the user's journey for the total number of sessions. It does not contain any identifiable information. | user consent | 30 minutes |
| Hotjar Ltd - Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian\'s STJ 3141, Malta | _hjIncludedInPageviewSample | no | This cookie is set so that Hotjar knows if a given visitor is included in the data sampling defined by your website's pageview limit. | user consent | 30 minutes |
| Hotjar Ltd - Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian\'s STJ 3141, Malta | _hjIncludedInSessionSample | no | This cookie is set to tell Hotjar if a given visitor is included in the data sampling defined by your website's daily visit limit. | user consent | 30 minutes |
| Advertising cookies / similar technologies | |||||
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | _gac_UA-* | no | The function is to store and count page views. | user consent | 90 days |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | goog_pem_mod | no | The function is to provide ad serving or redirects. | user consent | permanently |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | ads/ga-audiences | no | The function is to store information for remarketing purposes. | user consent | immediately |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | session_depth | no | The function consists of saving the frequency of display of advertisements. | user consent | 30 minutes |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | _gac_* | no | The function is to store and count page views. | user consent | 90 days |
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | google_pem_mod | no | The function is to provide ad serving or redirects. | user consent | permanently |
| Other cookies / similar technologies | |||||
| Google LLC - 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States | _GRECAPTCHA | no | Google reCAPTCHA sets a necessary cookie (_GRECAPTCHA) at startup in order to provide a risk analysis. | legitimate reason | 179 days |
Effective Date: 1 February 2022
