Privacy policy.

The operator and data controller of upnext.cz (operated under the Upnext brand) is:

The address above is the registered seat recorded in the Commercial Register. Send post and GDPR requests to our correspondence address, Michelská 403/13, Michle, 140 00 Praha 4, or straight to [email protected]. We use that address for data-protection matters across all our documents, the cookie policy included.

The site presents our services and also hosts a public sandbox of small browser-side tools, engineering notes, and prototypes.

• IP address - used solely for rate-limiting (capping how many requests hit our server so nobody can overload our proxy services for ARES, VIES, ČNB, etc.). We keep the IP in memory for at most 5 minutes and store it nowhere.
• Cloudflare Turnstile cookie - when Turnstile is enabled (bot protection), Cloudflare sets a short-lived cookie. It is managed by Cloudflare, not us. Cloudflare privacy policy.
• Traffic measurement data - we collect it only after you allow the analytics category in the cookie banner. Via Google Tag Manager we deploy Google Analytics 4 (measurement G-PQDM00986F) and self-hosted Rybbit, which runs on our own domain pulse.upvote.cz. Google Analytics 4 does load without consent, but until you give it, it neither stores nor reads cookies and sends only the anonymous ping described below; Rybbit does not start at all without consent. Rybbit stores a visitor identifier in localStorage and can record a session replay (mouse movement, scrolling, clicks). Input fields are masked in it, passwords and e-mail addresses included - that is a setting on the Rybbit side which we keep switched on. The rest of the page is recorded as displayed, including the results our tools render from the data you typed into them. The recordings stay on pulse.upvote.cz only and reach no one else.
• Advertising measurement data - only after you allow the marketing category in the cookie banner. We use the Meta Pixel (Facebook and Instagram), Google Ads and Sklik (Seznam.cz). The individual cookies, their retention and their recipients are listed in our cookie policy.
• Meta Conversions API - with the same consent, our server sends selected events (page view, form submission, tool usage) directly to Meta. Each event carries the IP address, user agent, and the _fbp/_fbc cookies. The email and phone number from the lead form are sent exclusively as a SHA-256 hash, never in readable form.
• Proof of consent - the moment you decide in the cookie banner, a record carrying the pseudonymous upnext_pseudo_id identifier, your decision, the allowed categories, the derived Google Consent Mode signals and a timestamp is sent to cookies.upnext.cz (our own server, operated by Fronde s.r.o.). It carries neither your IP address nor any browser identification; the IP address is used there in memory only, to rate-limit requests. The record is immutable and serves the single purpose of demonstrating that consent was given.
• Google Consent Mode anonymous ping - before you decide, and also when you refuse measurement, Google Analytics 4 loads and sends Google a so-called anonymous ping. It neither stores nor reads cookies and carries no identifier linking you across visits; it does carry the page address and title, screen resolution, language, basic browser information and your IP address at the connection level. This is the only traffic measurement that runs without consent, and we do it on the basis of legitimate interest.

What we do not process: no user accounts, no visitor logins. Files you load into the tools (videos, images, XML feeds) are processed in your browser - the server never sees them.

More about cookies in our cookie policy.

For rate-limiting, our legal basis is legitimate interest under Art. 6(1)(f) GDPR - the interest in preventing abuse of publicly accessible tools. Without rate-limiting, a single person could send thousands of requests per second to ARES or ČNB through our proxies and harm both their service and ours.

For traffic measurement and marketing (Google Analytics 4, Rybbit, Meta Pixel, Meta Conversions API, Google Ads, Sklik), the legal basis is your consent under Art. 6(1)(a) GDPR, given in the cookie banner and revocable at any time.

For the Google Consent Mode anonymous ping, which runs without consent, the legal basis is legitimate interest under Art. 6(1)(f) GDPR in a basic, non-identifying view of how the site performs. You can object to this processing at our e-mail address.

We keep the proof of consent because Art. 7(1) GDPR requires us to be able to demonstrate that consent was given. The legal basis is compliance with a legal obligation under Art. 6(1)(c) GDPR, so this part cannot be refused on its own - it comes into being only because you made a choice in the banner.

For the enquiry form and the intro-call booking, the legal basis is steps prior to entering into a contract under Art. 6(1)(b) GDPR - without your contact details we can neither reply nor meet you.

IP addresses live in our server’s memory only for a sliding 5-minute window (rate-limiter), then are deleted automatically. Server logs, which may temporarily contain IPs, are kept for up to 30 days.

Measurement data (Google Analytics 4, Rybbit, Meta, Google Ads, Sklik) follows the retention rules of the respective tool. Consent lasts 13 months and you can withdraw it at any time via the floating cookie icon or the “Cookie settings” link in the footer. On withdrawal we stop the measurement tools, delete the _ga, _ga_*, _fbp and _fbc cookies and clear the Rybbit localStorage entries; the _gcl_au cookie from Google Ads and the sid cookie from Seznam are not deleted by our banner and stay in your browser until they expire or you clear them yourself. From then on only the Google Consent Mode anonymous ping described above still runs. Enquiry and booking data is kept for the duration of the discussion and then for up to 3 years so we can pick up where we left off.

The proof of consent is kept for as long as the consent is valid and then for as long as we must remain able to demonstrate it to the supervisory authority. It holds only the pseudonymous identifier, the decision, the categories and a timestamp - no IP address and no browser identification.

Some tools forward your input to public services to avoid the browser’s CORS restrictions:

• A company ID (IČO) is sent to ARES (Czech Ministry of Finance).
• A VAT ID is sent to VIES (European Commission).
• A date is sent to the ČNB API (Czech National Bank).
• A feed/page URL is sent only to our server, which fetches it and returns the results (Heureka feed validator, SEO validator). It goes no further.
• Intro-call bookings are handled by Cal.com, Inc. (USA). The “Let's meet” button is a plain link - nothing reaches Cal.com until you click it. On their page you enter a name, e-mail and time slot, which Cal.com processes as our processor under standard contractual clauses.

When you write to us through the form on the site or book an intro call, we process your name, e-mail, phone number (if you fill it in), your website address and whatever you tell us. The purpose is to reply and agree on working together; the legal basis is steps prior to entering into a contract under Art. 6(1)(b) GDPR.

• CRM - enquiries live in a self-hosted Twenty CRM on our own infrastructure (Fronde s.r.o.).
• Ecomail.cz s.r.o. (Czech Republic) - if you asked for an analysis result or follow-up e-mails, we deliver them through Ecomail.
• Cal.com, Inc. (USA) - intro-call bookings.
• Meta Conversions API - if you allowed the marketing category, a form-submission event goes to Meta; the e-mail and phone number only as a SHA-256 hash.

We never sell enquiry data and never use it for profiling. We keep it for the duration of the discussion and then for up to 3 years.

If you have given consent in the cookie banner:

• Google Ireland Limited and Google LLC - Google Analytics 4 (measurement G-PQDM00986F) and Google Ads. Data may be processed in the USA.
• Meta Platforms Ireland Limited - Meta Pixel and Meta Conversions API. Data may be processed in the USA.
• Seznam.cz, a.s. - Sklik. The data stays in the EU.
• Rybbit is self-hosted on pulse.upvote.cz, a domain operated by Fronde s.r.o., so its traffic statistics reach no third party. It is not storage-free, though: it writes a visitor identifier to localStorage and can record a session replay with input fields masked.
• cookies.upnext.cz - the server running our cookie banner and holding the proof of consent. It is operated by Fronde s.r.o., the same company that runs this site, so that data reaches no third party either.

Transfers to the USA by both Google and Meta rely on their certification under the EU-US Data Privacy Framework.

The measurement scripts are managed through Google Tag Manager (Google Ireland Limited). That container also holds the Google Analytics 4 property, so Google is not merely a script manager but a recipient of measurement data too - see the first bullet above. The cookie banner itself is loaded straight from the page from cookies.upnext.cz, so consent stays withdrawable even when Tag Manager is blocked.

We have no user accounts, and apart from measurement data, enquiry data and the proof of consent we hold no identifiable data for longer than 5 minutes. For measurement and enquiry data you can exercise your GDPR rights: access, rectification, erasure, restriction, portability and objection. You can withdraw consent to measurement at any time via the floating cookie icon or the “Cookie settings” link in the footer. With any question or objection, reach us at [email protected]. You may also lodge a complaint with the Czech Data Protection Authority (ÚOOÚ), Pplk. Sochora 27, 170 00 Prague 7.

We may update this policy from time to time. The current version is always on this page.