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Privacy Policy

Draft structure — to be reviewed by a lawyer before launch.

1. Controller

Disrupt Collective s.r.o., Kmochova 135/40, 614 00 Brno, Czech Republic, IČ 23420693, hello@sotto.zone.

2. Two roles

On this website and for your Sotto account we are the controller of your data. For the files, comments and personal data that you and your clients put into a Sotto library, we act as a processor on your behalf; a data processing agreement is part of the terms of service.

3. What we process

Beta and contact requests (name, email, company, the answers you give); account data (name, email, profile picture, sign-in provider); usage data in the service (views, downloads, ratings, comments — needed to run the features you use); technical data (IP address, browser, pages visited) via necessary and — with consent — analytics cookies.

Answering requests and preparing offers (Art. 6(1)(b) GDPR); providing the service under contract (Art. 6(1)(b)); security, abuse prevention and service operation (Art. 6(1)(f)); billing and statutory accounting (Art. 6(1)(c)); analytics cookies (Art. 6(1)(a), consent).

5. Processors and recipients

Hosting and database (Vercel, Supabase), file delivery and video (Cloudflare R2 and Stream), transactional email (Resend), payment provider [to be decided], and — only for features you switch on — an AI provider for image suggestions, which receives thumbnails, never originals [list and regions — confirm]. Transfers outside the EU only with appropriate safeguards.

6. Retention

Beta requests that do not lead to an account: [12 months — confirm]. Account data: for the duration of the contract, then deleted or anonymised, except where accounting law requires longer retention.

7. Your rights

Access, rectification, erasure, restriction, portability, objection, withdrawal of consent. Complaints: Úřad pro ochranu osobních údajů, Pplk. Sochora 27, 170 00 Praha 7, www.uoou.cz.

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