Your privacy. How information is used when you visit the website or contact us. 1. The controller The controller is Mgr. Lada Mladá, Czech business ID 21679517, Na Rubši 449, 257 21 Poříčí nad Sázavou, Czech Republic. For privacy questions and rights requests, contact hello@holdcloser.com. 2. Website visits and email Website requests involve technical data such as an IP address, time, requested URL, and browser information. These enable page delivery and protection against abuse. The legal basis is our legitimate interest in secure operation (GDPR Article 6(1)(f)). When you email us, we process your email address, any name you provide, and the message. Precontractual inquiries and contract support rely on Article 6(1)(b); other ordinary correspondence relies on our legitimate interest in responding. General inquiries without a subsequent business relationship are retained for no more than 1 year after the conversation ends, unless needed for a dispute. We use no advertising pixel or first-party visitor analytics. 3. Order processing To process your order, we use your email, edition and language, order ID, price and currency, payment reference, payment status, and a record of your delivery choice. Bank payments will be matched using their reference. We will also add the order number to your PDF as a personal-copy watermark, which can be matched to your order if the file is shared without permission. This relies on our legitimate interest in protecting copyright (GDPR Article 6(1)(f)). The bank may also provide the payer’s name and account number. The purposes are fulfilling the contract (Article 6(1)(b)), statutory recordkeeping (Article 6(1)(c)), and protecting legal claims (Article 6(1)(f)). An email address and necessary order information are required for electronic delivery. Marketing consent is not required for this processing. Order records are generally kept for 3 years after completion for fulfillment and legal claims, or as long as necessary to resolve a dispute. Tax and accounting documents are kept for the statutory period applicable to their type, including any applicable extension of tax assessment periods. Canceled unpaid orders will be deleted within 90 days unless needed to resolve a payment or dispute. We do not collect your answers to relationship questions, completed cards, or information about your intimate life. You use the PDF privately. Automated payment matching is not used for profiling; unclear payments are reviewed by a person. 4. Service providers Cloudflare hosts the website, stores order and payment records and private PDF files, sends order confirmations and products, and forwards incoming email. Cloudflare Turnstile protects the order form by processing technical request and device information to distinguish legitimate visitors from automated abuse. Messages sent to hello@holdcloser.com are forwarded to a Google Gmail inbox. Fonts are hosted on this website; your browser does not contact Google Fonts to load them. Air Bank processes payments. Public authorities may receive information where required by law. Cloudflare and Google may process data outside the European Economic Area. Their transfer information and safeguards are described in Cloudflare’s policy and Google’s policy. You can ask us for details about recipients and safeguards. 5. Cookies and language After you manually select CZ or EN, the website stores the hc_language cookie with the value cs or en for up to 1 year. Its only purpose is to remember your requested language. Otherwise, the language is selected using your browser preference. We currently use no first-party advertising or analytics cookies. You can remove or block cookies in your browser; you may then need to select your language again. Any future optional analytics or advertising will run only according to your choice. 6. Your rights Subject to GDPR conditions, you may request access, correction, deletion, restriction, and data portability. You may object to processing based on legitimate interests. Any consent can be withdrawn without affecting the lawfulness of prior processing. Data required by law or needed for legal claims may not be eligible for deletion. We normally respond within 1 month and will inform you if a lawful extension is needed. You may complain to the Czech Office for Personal Data Protection or the relevant supervisory authority where you live. 2026-11-15-v4