Draft — to be completed and reviewed before public launch.
Privacy Policy
Last updated: [date of last update]
Who is responsible
The controller of your personal data is [Operator full name], [Contact address, Slovakia]. Contact: [privacy@your-domain].
What we collect and why
| Data | Purpose | Legal basis (GDPR Art. 6) | Kept for |
|---|---|---|---|
| Email, username, password (stored only as a hash) | Your account and signing in | Contract (1)(b) | Until you delete the account; inactive accounts are deleted after 24 months, with a warning email 2 months before |
| Learning progress, answers, assessment results | The service itself: scheduling reviews, scores, history | Contract (1)(b) | Same as the account |
| Sign-in sessions: IP address, browser type | Keeping your account secure, preventing abuse | Legitimate interest (1)(f) | 30 days |
| Aggregated usage statistics (e.g. how many assessments are taken per day) | Running and improving the app | Legitimate interest (1)(f) | Derived from the data above; no separate tracking |
We do not use advertising, tracking cookies or third-party analytics. If you use Cartola without an account, your progress is stored only in your browser and never sent to us.
Who processes data for us
- Hetzner Online GmbH, Germany — hosting and database (servers in Germany).
- Sendinblue SAS (Brevo), France — sending account emails (confirmation, password reset).
Both act under data processing agreements. Your data is not transferred outside the European Union.
Your rights
You can access, correct, export and delete your data at any time from your account page (Download my data / Delete account). You also have the right to restrict or object to processing. For anything else, write to [privacy@your-domain]; we reply within 30 days.
You may lodge a complaint with the supervisory authority: Úrad na ochranu osobných údajov Slovenskej republiky (dataprotection.gov.sk).
Children
Accounts are for people aged 16 or older.
Security
All traffic is encrypted (HTTPS). Passwords are hashed, never stored in plain text. Administrator access requires two-factor authentication and is logged.