Privacy Policy

What personal data we process about you, why, on what legal basis, who we share it with, how long we keep it and what your rights are. This is a translation for convenience; the Czech wording prevails.

Effective from 14 September 2026

1. Who processes your data

The controller of personal data is Be OFF.line s.r.o., Company ID 236 16 661, with its registered office at Mladoboleslavská 3321, 276 01 Mělník, Czech Republic, registered in the Commercial Register kept by the Municipal Court in Prague, file no. C 430208/MSPH.

Contact for personal data matters: veronika@off-line.cz.

We have not appointed a data protection officer — the law does not require us to. Ing. Veronika Mrázová is responsible.

Processing is governed by Regulation (EU) 2016/679 (GDPR) and by Act No. 110/2019 Coll.

2. What data we process

CategoryWhat exactly
Identification and contactfirst name, surname, e-mail, phone number
Billingthe details needed to issue an invoice; for businesses, the company ID and registered office
Paymentdetails from the bank statement relating to your payment — payer name, account number, amount, date, variable symbol and any message for the recipient. You pay by transfer in your own banking app, typically via a QR code. You never enter a payment card with us and we do not process card numbers at all.
Starting Map answersanswers to 25 statements, the options you ticked and free-text answers
Communicationthe content of e-mails and messages you send us
Attendance at offline eventsregistration for the hike or the Closing Day, and possibly photographs
Technical datadata from the website and e-mail tools — see section 10

3. Why we process it and on what basis

PurposeLegal basisHow long
Entering into and performing the contract — registration, access to the content, the members’ area, evaluating the Starting Map, communication about the programmeperformance of a contract, Article 6(1)(b)for the duration of the programme and 6 months after it ends
Bookkeeping and tax obligationslegal obligation, Article 6(1)(c)5 years from the end of the accounting period; where a specific regulation sets a longer period, that period
Improving the programme — aggregated and anonymised evaluation of answerslegitimate interest, Article 6(1)(f)until anonymisation, at the latest 12 months after the programme ends
Sending news about our other events to people who have bought something from uslegitimate interest, Article 6(1)(f), in conjunction with Section 7(3) of Act No. 480/2004 Coll.until you unsubscribe, at most 3 years from the last order
Sending news to everyone else who is interestedconsent, Article 6(1)(a)until consent is withdrawn
Defending legal claims and keeping records of withdrawals from contractslegitimate interest, Article 6(1)(f)4 years from the end of the contractual relationship
Security of the website and the members’ arealegitimate interest, Article 6(1)(f)6 months
Photographs from offline eventssee section 93 years

You can unsubscribe from the news at any time using the link in every e-mail or by writing to our contact address. You can object to processing based on legitimate interest — see section 11.

4. The Starting Map

The Starting Map is a questionnaire for your own self-reflection. It is not a diagnostic tool, it does not assess your health and its output is not an expert opinion.

The questionnaire is deliberately designed so that it does not collect health data or other special categories of personal data under Article 9 GDPR. It asks how often ordinary everyday situations happen, not about diagnoses, treatment, mental state or their causes.

Your answers are seen by you and by us. We do not publish them, we do not share them with other participants and we do not use them to compare you with anyone.

We do not collect any data from your device — not screen time, not a list of apps, nothing of the sort. If you track such data yourself during the programme, it stays with you alone.

5. Automated evaluation

The Starting Map output is produced automatically: based on how often you gave each answer, it identifies which situation recurs most for you and shows you the text belonging to it.

This is not automated decision-making with legal or similarly significant effects within the meaning of Article 22 GDPR. The result has no bearing on the price, on admission to the programme or on anything else — it is just your own answers put in order and shown back to you. If the output does not fit you, nothing happens; the programme works the same.

6. Free-text answers

The questionnaire gives you space to write in your own words what you have been putting off and what you want to remember.

We do not publish these texts. We may use them as inspiration when creating content, but only in a form from which you cannot be identified, and only if you do not tell us not to — a message is enough.

7. Who we share the data with

We share data only with those without whom we could not run the programme:

WhoWhy
Vercel Inc.running the website and the members’ area
Supabase, Inc.the database and its backups
n8n GmbHautomation through which the programme e-mails are sent
Google Ireland Limitedmailbox, sending messages and traffic measurement
Microsoft Ireland Operations Limitedmeasuring behaviour on the site
Fakturoid s.r.o.issuing invoices
Slack Technologies Limitedinternal notifications about new registrations
Our accountantbookkeeping

We have a data processing agreement in place with each of them. We do not share data with anyone else and we do not sell it.

Some of the processors listed process data outside the European Union. Such transfers take place on the basis of an adequacy decision (the EU-US Data Privacy Framework) or on the basis of standard contractual clauses under Article 46 GDPR.

You pay by transfer in your own banking app, so there is no payment gateway between us and you. Payment details reach us from the bank statement.

Joining the OFF.line community is voluntary and it runs on WhatsApp. Once you enter the group, its operator also processes your data under its own terms, and in that respect we are no longer the controller.

We may also share data with public authorities where the law requires it.

8. The members’ area and access

You have access to the members’ area until 30 November 2026. Once it closes we will delete or anonymise your account and the data associated with it, except for data we have to keep under section 3.

9. Photographs from offline events

We may take photographs on the hike and at the Closing Day. We use reportage photographs from an event to promote OFF.line on the basis of legitimate interest — they document the event as a whole.

If we wanted to use a photograph in which you are the main subject, we would ask for your consent.

At any time — on the spot, in advance or afterwards — you can tell us that you do not want to be photographed or that you do not want a particular photo used. We will respect that and take the photo down.

10. Cookies and the website

Necessary cookies are required for the site to work — they remember your choice in the cookie bar and keep you signed in to the administration. We set them without consent, because without them the site would not function.

Analytics cookies (Google Analytics 4 and Microsoft Clarity) are only stored once you give consent in the cookie bar. We do not use marketing or advertising cookies. The full list with lifetimes is in the Cookie policy, where consent can be changed or withdrawn at any time; if you refuse, we also delete the ones already stored.

When you sign in to the members’ area we process your e-mail address, a hash of the one-time code, the IP address the request came from and your browser identification. This serves to sign you in and to stop anyone getting into someone else’s mailbox by guessing. Neither the code nor the sign-in secret is stored in readable form, only as a hash — anyone who got hold of the database could not sign in with it.

We do not track opens or clicks in the programme e-mails.

11. Your rights

You have the right:

  • of access — to know what data we hold about you and to receive a copy of it,
  • to rectification when something is wrong,
  • to erasure, where we no longer need the data and are not obliged to keep it,
  • to restriction of processing,
  • to portability of data you gave us and that we process automatically on the basis of a contract or consent,
  • to object to processing based on legitimate interest — for the news, just say so and we stop immediately,
  • to withdraw consent if you gave it; withdrawal does not affect the lawfulness of processing before it,
  • to lodge a complaint with the Office for Personal Data Protection, Pplk. Sochora 27, 170 00 Prague 7, Czech Republic, www.uoou.gov.cz.

Write to us at veronika@off-line.cz. We will get back to you within one month; in complex cases the deadline may be extended, but we will let you know.

12. Security and changes

We protect data with appropriate technical and organisational measures — access is limited to the people who need it for their work and accounts are protected by strong passwords and two-factor authentication.

We may update this policy. The latest version is always at off-line.cz/ochrana-osobnich-udaju. We will let you know by e-mail about material changes.

This policy is effective from 14 September 2026.

Be OFF.line s.r.o. · Company ID: 23616661

Registered in the Commercial Register kept by the Municipal Court in Prague, file no. C 430208

Registered office: Mladoboleslavská 3321, 276 01 Mělník, Czech Republic

E-mail: veronika@off-line.cz