ComfiVelo / Privacy Policy
Privacy Policy
Effective from: 22 October 2026 · applies to the website comfivelo.com. The ComfiVelo app has its own policy inside the app.
Working draft of the text. Before publication I will fill in the details in the yellow brackets and have it checked by a lawyer.
This English text is a convenience translation of the Czech original. If the two differ, the Czech version prevails.
1. Who processes the data
The controller is Martin Budík, a natural person. Contact: info@comfivelo.com. Details are on the Operator page.
2. What data and why
| Purpose | Data | Legal basis | Retention |
|---|---|---|---|
| A message when the app is released (the “Notify me” form) | email, time and IP address of the consent confirmation | consent (Art. 6(1)(a) GDPR) | until consent is withdrawn. Addresses that do not react 12 months after the app is released will be deleted. I keep proof of consent for 3 years after withdrawal |
| Replying to your email | email address, content of the message | legitimate interest in replying (Art. 6(1)(f)) | 2 years from the last message (for contracts and documents, for the period set by law) |
| Operating and securing the website | IP address, time, page address, browser type (technical hosting logs) | legitimate interest in ensuring operation and security | short-term, only as long as needed to operate and secure the website; the exact period is set by the hosting provider (Cloudflare) |
The “Notify me” form is still being put into operation. Until then, no emails are stored through it. Once it is live, a confirmation email is sent first (double opt-in) and I add you to the list only after you click the link. I will send only the release announcement and possibly one or two important news items. You can unsubscribe using the link in every message. Statistics on opens and clicks are set to anonymous in the email service, so I cannot link them to your address. Links in the emails pass through Brevo, which rewrites them for security and abuse prevention.
3. Cookies, tracking and advertising
The website does not use cookies, does not track visits, does not use advertising or analytics tools and does not build a profile of you. Nothing is stored in your browser except what is necessary for the look of the page. That is why you do not see a cookie banner.
The website fonts (Sora and Source Sans 3) are stored on the same server as the website, so your IP address is not passed to any other company because of them.
4. Recipients and processors
I pass data only to providers I need for operation, and I have a processing agreement with them: website hosting and DNS (Cloudflare, Inc., USA), an email sending service (Brevo, France) and the mailbox with the domain registration (Forpsi, Czech Republic). I do not sell the data and I do not use it for advertising.
5. Transfers outside the EU
Some providers may process data outside the EU (for example in the United States). This happens only with safeguards under the GDPR. Cloudflare may process data in the United States and in the European Economic Area and bases transfers to the United States on its certification under the EU–U.S. Data Privacy Framework or, failing that, on the European Commission’s standard contractual clauses. Brevo stores data on servers in the European Union (France and Belgium); some of its sub-processors and Brevo group companies may be located outside the EEA (for example in the United States and India), and it bases such transfers on standard contractual clauses with supplementary measures or, where applicable, on the EU–U.S. Data Privacy Framework.
6. The app and your photos
A photo or video from a position analysis is processed directly on your phone and does not leave it. I do not collect any photos or videos on this website. Processing in the app is described by the policy inside the app.
7. Your rights
- to request access to your data and a copy of it,
- to request correction or erasure,
- to request restriction of processing and to object to processing based on legitimate interest,
- to request portability of data you gave me on the basis of consent,
- to withdraw consent at any time, without affecting the lawfulness of the processing carried out before.
Just write to info@comfivelo.com. I will reply within one month. You also have the right to lodge a complaint with a supervisory authority: the Czech Office for Personal Data Protection (Úřad pro ochranu osobních údajů), Pplk. Sochora 27, 170 00 Prague 7, uoou.gov.cz.
8. Children
The newsletter is intended for people aged 15 and over. If a younger child signs up, write to me and I will delete the data.
9. Changes
I may update this policy. The valid version is always on this page, with the date shown.