Privacy policy

INFORMATION ON THE PROCESSING OF PERSONAL DATA

Company Global Tracking s.r.o., ID No.: 03807487, with its registered office at Pitterova 2855/7, Žižkov, 130 00 Prague 3, registered in the Commercial Register maintained by the Municipal Court in Prague, Section C, File 428433 (hereinafter only “Seller”), as the controller of personal data, hereby informs you about the processing of personal data that it carries out in connection with the operation of the online store available at https://www.kloki.cz (hereinafter only “E-shop”), the conclusion and performance of purchase contracts or service contracts with customers of the E-shop (hereinafter only “Buyer”) and the registration of Buyers in the E-shop, and further in connection with the operation of the Findee Kids application (hereinafter only “Application”) by the Seller as operator and used by Buyers and other users (hereinafter only “User”). This document also includes information about the rights to which data subjects are entitled in connection with the processing described above.

For any questions regarding privacy protection and the exercise of your rights, please use this contact:

• e-mail: support@kloki.cz 

Cookies, analytics and advertising

On our website, we use cookies and similar technologies for website functionality, analytics, ad measurement and ad personalization (ads personalization). More information about how Google processes data can be found here: How Google processes data.

1. For what purpose, on what legal basis and what personal data do we process? 

1.1. Purchase of goods or services on the E-shop

In order for the Seller to negotiate and conclude a purchase contract with the Buyer regarding goods or a contract for the provision of services offered in the E-shop (hereinafter only “Purchase Agreement”), the Seller needs the following personal data of the Buyer – a natural person:

• identification details of the Buyer (name, surname, and in the case of an entrepreneur also company ID No., VAT No., registered office address),
• contact details of the Buyer (e-mail, telephone number, delivery address and, where applicable, billing address),
• depending on the selected payment method, also the Buyer’s bank account number and other payment details,
• information from communication with you and information about the conclusion and performance of the Purchase Agreement.

Without the above data, it is not possible to conclude or perform the Purchase Agreement. The legal basis for processing this data is the conclusion and performance of the Purchase Agreement at the request of the Buyer.

The Seller allows Buyers to register and create a user account in the E-shop. If the Buyer registers and creates a user account, an agreement on registration and maintenance of the user account is concluded (hereinafter only “Agreement on Registration and Account in the E-shop”). For the purposes of performing this agreement, we process the data listed above and, in addition, also the access data of the Buyer – a natural person (username and password in encrypted form).

The above data is necessary for the registration of the Buyer and for the establishment and maintenance of their user account; without it, it is not possible to conclude or perform the Agreement on Registration and Account in the E-shop. The legal basis for processing this data is the conclusion and performance of the agreement at the request of the Buyer. 

1.2. Use of the Application and access to Paid Access

The Seller concludes an agreement with the User for the use of the Application (hereinafter only “Application Usage Agreement”).

Users are required to register in the Application. In order for the Seller to negotiate and conclude the Application Usage Agreement with the User, the Seller needs the following personal data of the User, which is necessary for their registration and for the establishment and maintenance of their user account in the Application:

• User ID (e-mail address and password in encrypted form),
• IP address, 
• information from communication with the User and other information about the course of the contractual relationship with the User.

Without the above data, it is not possible to conclude or perform the Application Usage Agreement. The legal basis for processing this data is the conclusion and performance of the agreement at the request of the User.

Paid Access is available in the Application, which the User may purchase through the Application. In order for the Seller to agree the conditions of the purchase of Paid Access with the User and provide Paid Access, the Seller needs the User’s personal data specified in section 1.2.2 of this document. Without this data, it is not possible to complete the purchase of Paid Access or provide Paid Access. The legal basis for processing this data is the purchase of Paid Access and the obligation to provide Paid Access at the request of the User.

For the purpose of enabling Paid Access and fulfilling the related obligations, the Seller processes the following personal data of the User: 

• contact details of the User (e-mail),
• data on the payment made for Paid Access (payment identifier, date of execution), 
• photographs and videos,
• telephone number,
• information about the device from which the User accesses the Application,
• geolocation data and pedometer data,
• records of voice messages and text messages,
• information about completed calls. 

1.3 Fulfilment of obligations arising from legal regulations 

The Seller must process personal data in cases where this is required by law. For this purpose, the Seller processes personal data primarily to the extent required by applicable legal regulations, in particular in connection with the Seller’s obligation to handle complaints from Buyers or Users, keep accounts and fulfil related tax obligations, or possibly for the fulfilment of obligations imposed by archival regulations.

1.4. Legitimate interests of the Seller

In justified cases, the Seller may process personal data on the legal basis of protecting its legitimate interests. However, the Seller always carefully assesses and ensures that the interest in processing your data for this purpose does not disproportionately interfere with your privacy.

Identification of persons acting on behalf of the Buyer – a legal entity: This typically concerns members of statutory bodies, employees or other authorised persons who are not themselves a party to the contract with the Seller, but who conclude the contract on behalf of the Buyer, communicate with the Seller and otherwise act towards the Seller on behalf of the Buyer. We need the personal data of these persons in order to communicate and act with the Buyer for the purpose of concluding the Purchase Agreement or the Agreement on Registration and Account in the E-shop, their further performance and, where applicable, the exercise of the Buyer’s rights. For these persons, we usually process name, surname, e-mail, telephone number, delivery address, information about job position or other relationship to the Buyer, and data from communication with them.

Proof of consent to the terms and conditions: In the case of concluding a contract with the Buyer or User online (by electronic means), we store data necessary to identify the Buyer or User as a contractual party, so that in the event of later doubts or disputes we have a timestamp available as proof of the conclusion of the contract and of consent to our terms and conditions in their specific wording.

Defence and enforcement of legal claims: We process personal data for the purposes of protecting our legitimate interest, which is to ensure the possibility of our defence in the event of potential legal disputes, proceedings before courts, or inspections by state authorities or other public administration bodies (typically the Czech Trade Inspection Authority, etc.). We process data in order to be able to demonstrate, where necessary, that we have acted in accordance with our contractual obligations and legal regulations. In this context, we typically process identification and contact data of the Buyer or User, or persons acting on behalf of the Buyer or User, data on concluded contracts, their performance and communication with the Buyer or User, or persons acting on behalf of the Buyer or User.

1.5. Sending commercial communications

In the case of Buyers with whom we have concluded a Purchase Agreement or who have registered in the E-shop and created a user account, and in connection with that we have obtained their e-mail and/or telephone number, or in the case of other persons who have actively and voluntarily subscribed to our newsletters, we process the personal data of these persons to the extent of their e-mail and telephone number for the purpose of sending information and updates about our services and products (commercial communications).

The legal basis for processing personal data for the purposes of sending commercial communications, in the case of Buyers with whom we have concluded a Purchase Agreement or who have a user account, is the legitimate interest of the Seller in informing them about the latest offers of the Seller.

The legal basis for processing personal data for the purposes of sending commercial communications, in the case of persons who have actively subscribed to the newsletter themselves, without us having concluded a contract with them, is their consent granted by subscribing to commercial communications.

1.6. Cookies, analytics and advertising technologies

When operating the E-shop, we use cookies and similar technologies that help us ensure the proper functioning of the website, security, analytics, traffic measurement, ad performance measurement, remarketing and ad personalization (ads personalization).

Depending on your choice in the cookie banner, we may process in particular the following data: IP address, device and browser information, cookies and advertising identifiers, information about website visits, pages viewed, clicks, traffic source and conversion data.

We use necessary cookies for the purpose of ensuring website functionality and security. Analytical and advertising cookies and related personal data are used only on the basis of your consent.

We use this data mainly for traffic evaluation, website improvement, campaign effectiveness measurement, displaying personalized and non-personalized advertising, and limiting repeated ad display.

More detailed information on how Google processes data obtained from websites and apps using its services can be found here: How Google processes data.

If you no longer wish to receive these messages from us, you may unsubscribe from them free of charge at any time, following the procedure stated in each commercial communication sent, within your user account, or by contacting us at the contact e-mail address provided above in this document.

2. From whom do we receive personal data and to whom do we transfer it?

We obtain personal data primarily from the data subjects themselves (Buyers or Users). Unless stated otherwise, we do not obtain any additional information about you other than the information you provide to us yourself, or which arises from your activity within the E-shop or the Application. Some personal data – in particular contact and payment data of data subjects – may be obtained from independent controllers – providers of payment methods available in the E-shop or in the Application (Apple Pay, Google Pay). Information on how these providers process your personal data can be found directly with those providers.

We may transfer personal data, under the conditions set by legal regulations, to public authorities if required by law, or if such an authority requests it within its powers.

We use the following processors for data processing:

• providers of accounting services,
• contractors – natural persons providing IT programming services,
• providers of hosting services.

If consent is given for analytical and advertising cookies, data obtained through cookies and similar technologies may also be made available to providers of analytics and advertising services, including Google. These recipients help us with analytics, traffic measurement, conversion measurement, remarketing and ad personalization.

More information on how Google processes data can be found here: How Google processes data.

Personal data may also be transferred to our business partners who act as independent personal data controllers in relation to your personal data. This mainly concerns:

• operators of payment gateways through which online payments are enabled in the online store, 
• cooperating carriers used for the delivery of goods.

Information on how these partners process your personal data can be found directly with these partners.

Personal data may be transferred to countries outside the EU (specifically to the USA). In such a case, personal data is transferred to the USA in accordance with the decision of the European Commission that the USA is a country ensuring an adequate level of protection within the meaning of Article 45(3) of Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation), under the EU-US Data Privacy Framework and in accordance with the Data Privacy Framework List.

3. How do we process personal data?

We process your personal data primarily in electronic form using automated means in our IT systems, or in the systems of our individual processors. Personal data may also be processed manually in accordance with the relevant purpose, where manual processing is necessary or appropriate.

When managing your data, our employees or other persons working for us may be involved, among other things, for the purpose of correcting errors, inaccuracies, etc. However, these persons may only process personal data under the conditions and to the extent stated above and are bound by the obligation of confidentiality regarding personal data and security measures, the disclosure of which would jeopardise the security of personal data.

We always process personal data in accordance with the relevant legal regulations and ensure proper care and protection. We take care to ensure that you do not suffer harm to your rights, especially the right to maintain human dignity and your privacy and personal life.

4. How long do we process personal data?
4.1. Purchase of goods or services on the E-shop or use of the Application and access to Paid Access

Personal data processed for the purposes of concluding and performing a contract with the Buyer or User is processed for the period of conclusion and performance of the given contract (i.e. for the time necessary to fulfil the obligations arising from the contract, or for the duration of your registration in the E-shop or for the duration of the use of the Application).

Even after that, we may process personal data for the following purposes:

4.2. Fulfilment of legal obligations

Personal data processed on the basis of our legal obligations is processed for the periods laid down by these laws.

Personal data required by legal regulations governing the Seller’s tax and accounting obligations (typically billing data and information about the provided performance) must be processed for accounting purposes and fulfilment of tax obligations. The processing period is 5 (five) years from the end of the accounting period; in the case of documents relevant for VAT payments, it is 10 (ten) years from the end of the tax period in which the performance took place. We archive relevant personal data in accordance with the requirements of archival legislation for the period specified therein. Data processed for the purpose of handling complaints is retained for the duration of the limitation period for asserting rights arising from defective performance, or for the duration of the warranty period, if applicable.

4.3. Legitimate interests

We process personal data even after the termination of the contract with the Buyer or User for the protection of our legitimate interests (i.e. defence against potential claims by the Buyer or User or third parties, including before courts) for the duration of the relevant limitation periods. If no relevant proceedings are initiated, we retain this data for a period of 5 (five) years from the termination of the contractual relationship with the Buyer or User.

4.4. Sending commercial communications

We send commercial communications as described above, and process personal data for these purposes, until you unsubscribe using the procedure specified in section 1.5 of this document.

4.5. Cookies, analytics and advertising technologies

Data obtained through cookies and similar technologies is processed for the duration of the relevant consent, but no longer than the lifetime of the specific cookies or similar identifiers.

You may change or withdraw your consent at any time through the cookie settings on our website. Once consent is withdrawn, we will no longer use non-essential cookies and related data for analytical and advertising purposes, unless their further limited retention is necessary to fulfil legal obligations or protect our legitimate interests.

4.6. Further processing

Personal data may be processed for a longer period than stated above if a relevant reason for further processing arises, typically if administrative or judicial proceedings are initiated for which the personal data is relevant.

5. What rights do you have?

First and foremost, you have the right to request access to your personal data, including obtaining a copy of all your personal data. You can exercise this right via the e-mail address provided in the header of this document.

Withdrawal of consent to processing: If we process your personal data on the basis of your consent, you may freely and free of charge withdraw your consent to such processing at any time, through the cookie settings on our website, your user account, the contact e-mail address provided above, or otherwise as stated elsewhere in this document. In such a case, we will no longer process your personal data processed on the basis of consent.

For personal data that is not processed on the basis of consent, it is not possible to withdraw consent to processing. However, based on your request, we will always assess whether it is still necessary to continue processing your personal data for any of the purposes stated above.

Your further rights:
We will always inform you about:

• the purpose of the processing of personal data,
• the personal data, or categories of personal data, that are the subject of processing, including all available information about their source,
• the nature of automated decision-making, including profiling, and information concerning the procedure used, as well as the significance and expected consequences of such decision-making for the data subject,
• the recipients, or categories of recipients, to whom personal data has been or will be disclosed, and in the case of transfer of personal data to a third country, also the appropriate safeguards relating to the transfer to ensure the security of personal data,
• the planned period for which personal data will be stored, or, if it cannot be determined, the criteria used to determine that period,
• all available information about the source of personal data, if it was not obtained from you.

Among your other rights are:

• to request an explanation from us,
• to require us to remedy the situation, in particular by blocking, correcting, supplementing, restricting processing or deleting personal data (the right to be forgotten),
• to request a copy of the processed personal data, or to request personal data concerning you in a structured, commonly used and machine-readable format, and to transfer this data to another controller without hindrance,
• to submit an inquiry or complaint to the Office for Personal Data Protection,
• to object to the processing of personal data concerning you.

6. How we protect your personal data

We protect your data. For this purpose, we use in particular the following security measures: implementation and enforcement of internal personal data protection rules, antivirus protection, firewalls, encryption, access management to personal data and authentication credentials, backups, physical means of protection and others.

This version of the Information on the processing of personal data is effective as of 2 April 2026.