Privacy Policy
This is a translation for convenience. The Czech version is binding.
1. Data controller
Desire Agency is a brand of two independent sole traders: Alena Kamalova, Company ID 19536259, registered office Žitomírská 640/3, Vršovice, 101 00 Praha 10 and Daria Loshchakova, Company ID 08692181, registered office Nad Turbovou 1194/21, Košíře, 150 00 Praha 5. They process personal data as joint controllers (Art. 26 GDPR). You can exercise your rights with either of them, and the email below is the shared contact point.
For anything about personal data, contact us at desire.smm.prague@gmail.com. We have not appointed a Data Protection Officer.
2. What data we process
- From the application form: name, company or brand, website or social link (optional), the service you need, one contact of your choice (Telegram, email or phone), message (optional).
- From the quick inquiry: name, one contact, message.
- From a data request: name, email, and optionally a contact used earlier and details.
- Technical data: IP address and request logs created when the site runs.
- Correspondence, plus contract and billing details if you become our client.
We have no user accounts and do not use Google, Apple or Meta login. We make no automated decisions or profiling with legal effects.
3. Purposes and legal bases
| Purpose | Legal basis (GDPR) | Retention |
|---|---|---|
| Replying to you and preparing a proposal | Art. 6(1)(b): steps before entering a contract | 12 months from the last contact if no contract follows |
| Performing the contract | Art. 6(1)(b) | For the contract and the limitation period |
| Accounting and tax duties | Art. 6(1)(c) | Statutory periods, usually 10 years for tax documents |
| Website security and preventing form abuse | Art. 6(1)(f): legitimate interest | IP address in the rate limiter for up to 10 minutes; operational logs per the hosting provider's settings |
| Handling data subject requests | Art. 6(1)(c) | 3 years from handling |
Ticking the box in a form confirms that you have read this policy; it is not consent to processing. We cannot reply without the form details, but giving them is voluntary.
4. Marketing messages
We do not send newsletters or marketing emails. If we ever start, we will send them only with separate consent or as Czech Act No. 480/2004 Coll. allows, and each message will have a working unsubscribe link.
5. Recipients and transfers outside the EU
| Recipient | Purpose | Location and safeguards |
|---|---|---|
| Cloudflare, Inc. | Website hosting and form handling | USA and global network; EU-U.S. Data Privacy Framework and Standard Contractual Clauses |
| Google (Gmail) | Our email inbox | EU and USA; EU-U.S. Data Privacy Framework |
| Telegram | Delivering enquiries to our internal chat | Outside the EEA. Under Telegram's policy, data of accounts registered from the EEA is stored in the Netherlands and may be shared with group companies in the British Virgin Islands and Dubai under standard contractual clauses. Telegram acts as an independent controller. |
| Accountants and tax advisers | Bookkeeping and tax, if you are our client | As set out in the adviser's contract |
| Targeted advertising partners | Running ad campaigns, if you are our client and ordered this service | As set out in the client contract |
If you choose to talk over Telegram or phone, that happens through the provider under its own terms. We do not sell data.
7. People in our portfolio
Our portfolio shows photos and videos from client projects, which may include people. We publish them on the basis of permission or contract. If you appear in one and do not want to, write to us and we will sort it out promptly.
8. Your rights
- Access (Art. 15) and rectification (Art. 16).
- Erasure (Art. 17) and restriction (Art. 18).
- Portability (Art. 20) and objection (Art. 21).
- Withdrawing consent at any time, without affecting earlier processing.
- Complaining to the Czech Office for Personal Data Protection, Pplk. Sochora 27, 170 00 Prague 7, www.uoou.gov.cz.
We answer without undue delay and within one month at the latest. We cannot erase data the law requires us to keep, such as accounting records; if that applies, we will tell you.
9. Changes
We may update this policy. The current version and its date are always on this page.