Privacy policy

Effective from 28 April 2026 (updated 15 May 2026)

This is an English translation of our privacy policy for convenience. The legally binding version is the Czech original, as Frumo s.r.o. is a company registered in the Czech Republic.

1. Data controller

Frumo s.r.o., Company ID 08230731, registered office at Stará 101/21, Zábrdovice, 602 00 Brno, Czech Republic, registered in the Commercial Register kept by the Regional Court in Brno. Contact: info@refresos.cz.

2. What data we process

On refresos.cz we process only the data you send us via the contact form:

• Full name
• Company name
• Email and phone number
• Information about company size and the plan you are interested in (optional)
• Text of your message

When you submit the form, we also automatically record your IP address and browser identifier (User-Agent) to protect against abuse of the form (legitimate interest of the controller, Art. 6(1)(f) GDPR). These data are part of the enquiry email and of a short-lived audit log file (see section 8).

The website does not use analytics cookies, marketing trackers or social network pixels. The site loads the Inter font from Google Fonts (Google LLC, USA) - see section 5.

3. Purpose and legal basis of processing

• Handling your enquiry - legal basis: pre-contractual measures (Art. 6(1)(b) GDPR).
• Sending offers and further business communication - legal basis: legitimate interest of the controller (Art. 6(1)(f) GDPR).

4. Retention period

• Enquiries leading to a business relationship - for the duration of the cooperation and 3 years from the last communication.
• Enquiries without a follow-up relationship - no longer than 12 months from the last communication, then we delete the data.
• Accounting documents - for the period required by law (10 years).
• Contact form audit log (see section 8) - 90 days.

5. Recipients of the data

We pass your data only to the following recipients, strictly to the extent necessary to run the service:

• WebSupport s.r.o. (web and email hosting) - processor based in the EU, under a data processing agreement.
• Google LLC, USA (Google Fonts) - loading the Inter font from fonts.googleapis.com and fonts.gstatic.com causes your IP address and browser data to be transferred to the USA. The transfer is covered by Google's certification under the EU-US Data Privacy Framework (Commission Decision C(2023) 4745). Google does not build advertising profiles or set advertising cookies via this service. If you do not wish the transfer to take place, block the domain fonts.gstatic.com in your browser - the site will remain fully functional, just with a system fallback font.
• Accounting and tax advisors - to the extent required by law for invoicing and tax records.

6. Your rights

In accordance with GDPR you have the right to:

• Access your personal data
• Have inaccurate data corrected
• Erasure ("right to be forgotten")
• Restriction of processing
• Data portability
• Object to processing based on legitimate interest
• Lodge a complaint with the Office for Personal Data Protection (www.uoou.cz)

To exercise any of these rights, send an email to info@refresos.cz. We will respond within 30 days.

7. Cookies and local storage

The refresos.cz website does not set any third-party cookies. The server only sets technical cookies necessary for site functionality (e.g. spam protection on the contact form) - these cookies do not require consent under Section 89(3) of Czech Act No. 127/2005 Coll.

To remember your acknowledgement of the cookie information banner we use the browser's localStorage (key refresos_cookie_ack_v1). This data never leaves your browser and is not transmitted anywhere.

Loading the font through Google Fonts may cause your IP address to be logged on Google's side (see section 5).

8. Security and audit

The site runs over an encrypted HTTPS connection with HSTS enforced for 1 year. The contact form:

• is protected against spam (honeypot, timing check, rate limiting of max 5 submissions per IP per hour),
• does not store data in a database - the message is sent by email to our working inbox,
• writes a short audit record (timestamp, company name, email, send result) to a server-side log file used solely for diagnostics and abuse protection. The log is kept for at most 90 days and then deleted.

For rate limiting we temporarily (max 1 hour) store a one-way hash of your IP address in the server's temporary storage. The original IP address cannot be recovered from the hash.

9. Changes to the policy

We may update this policy. The current version is always available on this page. The effective date is shown in the header of the document.

Frumo s.r.o. · Company ID 08230731 · Stará 101/21, 602 00 Brno-Zábrdovice, Czech Republic · info@refresos.cz