Privacy Policy
This document exists in Czech, Ukrainian, Russian, English, Romanian and Filipino. The Czech version is the legally binding one; the other language versions help with understanding the text.
1. What this policy is about
DOMLUV.TO is a tool in which two people write down a job agreement: one writes down the work, the date, the price and the payment and sends a link; the other opens it in a browser and confirms the agreement, declines it or proposes a change. The service does not send money, does not issue invoices and does not act as an intermediary for work.
This policy describes how we process personal data on the website domluv.to, in the app app.domluv.to and in the mini app and bot in Telegram, under Regulation (EU) 2016/679 (GDPR) and Czech Act No. 110/2019 Coll., on the processing of personal data.
2. Controller and contact
The controller of personal data is [name of the controller – to be filled in by the operator], [address of the controller – to be filled in by the operator].
For any matter concerning personal data, write to us at
. We have not appointed a data protection officer, because Art. 37 GDPR does not require us to.
3. What data we process and why
We process only what the service actually needs in order to work:
- Account: email, name, phone (optional), interface language and profile picture, if Google or Telegram provides one. Purpose: running the account and signing in. Legal basis: performance of a contract (Art. 6(1)(b) GDPR).
- Sign-in methods: the Google account identifier and the email Google has verified; the Telegram account identifier, username, name and photo from Telegram, and whether our bot may message you. Legal basis: performance of a contract.
- One-time codes and sign-ins on devices: the email we sent the code to, and the period of validity. We do not store the code or the sign-in token in readable form, only their hash. Legal basis: performance of a contract and our legitimate interest in keeping accounts secure (point (f)).
- Agreements: the name of the job, the date, the price, the payment terms, the place of work (address and, where given, coordinates), notes, ratings, photos and the full change history. Legal basis: performance of a contract; towards the other side, the legitimate interest of both sides in having the agreement documented.
- Contacts and saved places: names, emails and phone numbers of the people you make agreements with, for people picked from Telegram their Telegram identifier and username, and the addresses of places where work is done. You enter them and we keep them for you. Legal basis: performance of a contract; for the people entered, legitimate interest.
- Dictation: we send the audio recording to be converted into text and do not store it. We keep the transcript for 30 days. Legal basis: performance of a contract.
- Notifications: email, the subscription address and your browser keys for web push, the chat with the bot in Telegram. You turn on web push by allowing it in your browser, and the bot only messages you if you have allowed it to in Telegram; you can turn either off at any time. Legal basis: performance of a contract.
- Welcome from the bot: anyone who presses Start in our bot or allows it to message them gets a welcome message once. So that it does not arrive twice, we keep the Telegram account identifier and the time of the welcome; if someone does not create an account with us, we forget them after 30 days. Legal basis: legitimate interest.
- Machine processing of text: a sentence you type or dictate may be read by a language model to pre-fill the form; shared texts (the terms and shared notes) are translated into Czech, Ukrainian, Russian, English, Romanian and Filipino, so that the other side can read them in their own language. We send private notes nowhere. Legal basis: performance of a contract.
- Content checks: text that the other side will read may be checked automatically to make sure it is not offensive; we check photos for harmful files on our own server. Legal basis: legitimate interest in the safety of users.
- Address search: we send the address text or coordinates to the Nominatim service without any data about you. Your browser loads the map directly from the OpenStreetMap servers, and only when you open the map. Legal basis: performance of a contract.
- Emails you send us: the message (sender, recipients, subject, text and attachments) is received by the Resend service and we forward it to the people who run the service so that they can reply to you. We do not store the content of the message ourselves or write it into logs. Legal basis: legitimate interest in replying to you (point (f)); if the message concerns your account, performance of a contract.
- Technical logs: shortened IP address (without the last block), browser type, time and address of the request. Sign-in data, codes and links to agreements are not in the logs. Purpose: protection against abuse and fixing errors. Legal basis: legitimate interest.
We do not use the data for advertising, do not sell it and do not build profiles from it. The automatic text check may reject an offensive message – it tells you what is wrong and stores nothing; this is not decision-making with legal effects under Art. 22 GDPR.
4. The other side of the agreement
Whoever receives a link to an agreement and opens it in a browser does not have to create an account. If they open it in Telegram (in the mini app), Telegram signs them in – so the first time they open it, an account is created for them, just as when signing in with Telegram – and the agreement is saved to their history. Their name, email or phone number is entered by the author of the agreement into their contacts and into the agreement. What the recipient writes or uploads through the link – a reply, a proposed change, a note, a photo – we process as part of the agreement.
The legal basis is the legitimate interest of both sides in having the agreement documented (Art. 6(1)(f) GDPR). The recipient has the same rights as everyone else and can exercise them at
. If they later create an account, they can take the agreement over into their account.
5. Who we pass data to
The agreement can be seen by both of its sides and by whoever has the link. Apart from that, we use the following processors, who may handle the data only on our instructions. Some of them we switch on only when the feature in question is in operation.
| Recipient | What for | Where | Transfer safeguards |
|---|---|---|---|
| Hetzner Online GmbH | The servers that run the app and the database. | EU | Data processing agreement (Art. 28 GDPR). |
| Cloudflare, Inc. | Delivering the website and protecting it from attacks (sees the IP address and requests); photo storage (R2). | Global network, headquartered in the USA | EU–US Data Privacy Framework (DPF), standard contractual clauses. |
| Resend, Inc. | Sending emails: sign-in codes and notifications about agreements; receiving emails you send us. | USA | Standard contractual clauses, or the DPF where applicable. |
| Google LLC | Sign-in with Google (only if you choose it); the Gemini model for pre-filling the form from a typed or dictated sentence and for translating shared texts. | USA and other countries | EU–US Data Privacy Framework (DPF), standard contractual clauses. |
| Deepgram, Inc. | Turning dictated speech into text. We do not store the audio recording. | USA | Standard contractual clauses. |
| Typesafe (typesafe.ai) | Checking that text meant for the other side is not offensive; matching a spoken address to your saved places. | Outside the EU | Standard contractual clauses. |
| OpenStreetMap Foundation | Address search (Nominatim, with no data about you) and map tiles that your browser downloads directly (sees your IP address). | United Kingdom | European Commission adequacy decision. |
If you link your account to Telegram or Google, those services pass data about you to us as independent controllers under their own policies. Web push notifications are delivered by the service of your browser’s maker; the content of the notification is encrypted.
6. Transfers outside the European Union
Some processors are based in the USA or elsewhere outside the EU. We transfer data to them on the basis of a European Commission adequacy decision (the EU–US Data Privacy Framework for certified companies; the United Kingdom) or standard contractual clauses under Art. 46 GDPR. We will provide a copy of the safeguards on request.
7. How long we keep data
Data that is no longer needed is overwritten automatically during the daily clean-up:
| Data | How long |
|---|---|
| Account, sign-in methods, contacts, saved places, notification settings | For as long as the account exists. When the account is deleted, we overwrite them immediately. |
| Agreements (terms, change history, shared notes and photos) | For as long as the account exists. After the account is deleted, they remain with the other side in anonymised form, without your name and contact details. |
| Private notes and private photos | For as long as the account exists; we remove them when the account is deleted. |
| One-time sign-in code (the email address it was sent to) | 1 day after the code expires. |
| Sign-in on a device (session) | Valid for at most 30 days; we overwrite its record 30 days after it ends. |
| A removed web push device | 30 days after removal. |
| Transcript of dictated speech | 30 days. We do not store the audio recording at all. |
| Archive with a copy of your data (ZIP) | Available for download for 7 days after it is prepared; then we remove it from storage. We keep a record of when you requested the copy and how the request turned out. |
| A removed or unfinished photo | We remove it from storage during the next daily clean-up, within 24 hours at the latest; if storage is unavailable, we retry. |
| Stored address search results | 180 days. |
| An email you send us | We do not store it ourselves: we pass it on to the mailbox we reply from, and it stays there for as long as it is needed to deal with it. We keep a record of its receipt without the content of the message, and we remove the reference to the message at Resend from that record after 30 days. |
| Technical server logs (shortened IP address, browser, request address) | We keep them in a limited volume and overwrite them continuously. |
8. Deleting your account
You delete your account yourself in your profile, under “Danger zone”. We immediately end all sign-ins, cancel pending requests for a copy of your data, remove prepared archives and overwrite your email, name, phone, profile picture, Google and Telegram links, contacts, saved places, dictation transcripts, private notes, draft agreements and notification devices – including their change history. Photos that only you have seen are removed from storage.
Agreements you have already sent remain with the other side, because they are also that person’s record of what you agreed on (Art. 17(3)(e) GDPR and the legitimate interest of the other side). Instead of your name they will show “Deleted user”, and your contact details will disappear from them. You can then use the same email and the same Google and Telegram accounts to create a new account.
If the operator keeps database backups, the deleted data disappears from them as the backups are routinely replaced.
9. Your rights
You have the right:
- of access to your data – in your profile you can request a copy of all your data: we prepare a ZIP archive in the background (a data.json file, your photos and a short description), let you know, and it is available for download for 7 days; a list of your requests stays in your profile;
- to rectification – you change your name, phone and language in your profile;
- to erasure – you delete your account in your profile;
- to data portability – the data in the archive is in the machine-readable JSON format;
- to restriction of processing;
- to object to processing based on legitimate interest;
- to turn off notifications and stop the bot from messaging you at any time;
- to lodge a complaint with the Office for Personal Data Protection (Úřad pro ochranu osobních údajů), Pplk. Sochora 27, 170 00 Praha 7, www.uoou.gov.cz.
Send requests to
. We will reply without undue delay and within one month at the latest. So that we do not hand data over to anyone else, we may ask you to confirm that the account is yours.
11. Security
All communication is encrypted (HTTPS). Sign-in tokens are kept in cookies that scripts on the page cannot access. We store codes, tokens and links to agreements only as a hash. Photos are kept in non-public storage and are shown through short-lived links that only a party to the agreement receives. We check uploaded photos before anyone sees them.
12. Children
The service is not intended for people under 16. If we find out that a child has created an account, we delete it.
13. Changes to this policy
We may update this policy when the service or the law changes. The current version is always on this page with its effective date; we will tell you about significant changes in advance in the app or by email.
Other document: Terms of Use