Privacy and Cookies Policy
This policy applies to visitors to the smartmailer.cz website. The processing of personal data of contacts (recipients) uploaded to the application by customers is governed by the Data Processing Agreement (Annex No. 1 to the Terms and Conditions).
1. Personal Data Controller
The controller is Dominik Ulrich (operator of the SmartMailer service), Company ID No. 74729381, VAT ID No. CZ9005173595, with registered office at K Blahobytu 1699, 530 02 Pardubice, e-mail info@smartmailer.cz.
2. What Data We Process
- Contact form / enquiry: name, e-mail, phone number and message content that you send to us yourself.
- Registration and user account: login and billing data necessary for creating an account and providing the service (governed by the Terms and Conditions).
- Technical operational data: IP address, browser and device type, request time and visited pages — from server operational logs for security and stability.
- Traffic measurement (Trackless): pseudonymous visit data without storing cookies — see Article 4.
3. Purposes and Legal Basis of Processing
| Purpose | Legal basis |
|---|---|
| Provision of the service and user account administration | performance of a contract (Article 6(1)(b) GDPR) |
| Handling a question / enquiry from the contact form | steps prior to entering into a contract, or legitimate interest (Article 6(1)(b/f) GDPR) |
| Securing the website and forms against misuse (reCAPTCHA) | legitimate interest (Article 6(1)(f) GDPR) |
| Website traffic measurement (Trackless, without cookies) | legitimate interest (Article 6(1)(f) GDPR) |
| Compliance with legal obligations (for example accounting and tax obligations) | legal obligation (Article 6(1)(c) GDPR) |
4. Cookies and Third-party Tools
For our own traffic measurement we do not use analytics cookies — we measure traffic using the server-side analytics tool Trackless, which does not store cookies or other identifiers in the browser. Therefore we do not display a separate banner for analytics cookies; technical and security features are described below. Trackless works with pseudonymous identifiers (created from a salt, IP address, User-Agent header and time window) and with common data such as referrer, UTM parameters, device type, browser, operating system and language — not with your identity.
| Category | Purpose and provider | Consent |
|---|---|---|
| Necessary | Ensures basic website operation and login (sessions, protection of forms against misuse — CSRF). | not required |
| reCAPTCHA | Protection of forms against spam and misuse by robots. Provider: Google Ireland Ltd. It may use cookies and similar identifiers. | necessary for security (legitimate interest) |
5. Cookies and Consent
Because we do not use cookies for our own analytics and Trackless measures on the server side, we do not require consent to analytics cookies. We therefore do not display a separate cookie banner for analytics. We use Google's reCAPTCHA service, which may set its own identifiers for protection against misuse, on the basis of a legitimate interest in securing the website. You can restrict necessary cookies and the behaviour of reCAPTCHA in your browser settings (this may affect website functionality).
6. Data Recipients and Transfers Outside the EU
Only authorised persons, the hosting provider and the suppliers listed below have access to the data. Hosting and Trackless measurement take place in the EU. When using reCAPTCHA, processing is carried out by Google; any transfer outside the EU/EEA takes place on the basis of standard contractual clauses under Article 46 GDPR.
7. Retention Period
We usually keep operational logs for no more than 30 days (unless we are dealing with an incident). Trackless analytics session tags are cleaned after approximately 24 hours. We keep contact form messages for the time necessary to handle and document the communication. Account data and billing data are kept for the duration of the contract and subsequently for the period required by legal regulations.
8. Your Rights
You have the right of access to personal data, the right to rectification or erasure, restriction of processing, objection and data portability. You can send a request to info@smartmailer.cz. You also have the right to lodge a complaint with the Office for Personal Data Protection: uoou.gov.cz.
9. Contact
Please send questions regarding personal data protection and cookies to info@smartmailer.cz.