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Solureach

Privacy Policy

Last updated:

Note for the site owner — complete before publishing:

  1. The company number and place of business of both controllers (marked [TO ADD] in section 1).
  2. The hosting provider and the country its servers are in (section 5).
  3. Once those are filled in, change draft: true to draft: false — the page then enters the sitemap and becomes available to search engines.

Important: this document describes Google Analytics and the Meta Pixel, neither of which is deployed on the site yet. Under § 109(8) of Act No. 452/2021 Coll. and under the GDPR, both may load only after consent has been given. Do not deploy them until the consent bar is working on the site — otherwise this document would describe a state of affairs that is not true.

The document reflects what the site actually does. Have a lawyer review it before publishing — this is not legal advice.

This English version is a translation provided for convenience. In case of any discrepancy, the Slovak version is the binding one.

1. Who processes your data

The website https://solureach.com, under the Solureach name, is operated jointly by two self-employed individuals:

Adam Hupka — self-employed

  • Company number: [TO ADD]
  • Place of business: [TO ADD]

Leo Rehúš — self-employed

  • Company number: [TO ADD]
  • Place of business: [TO ADD]

We decide on the purposes and means of processing together, and are therefore joint controllers within the meaning of Article 26 GDPR. You may exercise your rights with either of us and against either of us — most easily at [email protected].

We have not appointed a data protection officer (DPO); the law does not require us to.

2. What data we process, and why

2.1 Visiting the website

The site is static — it has no login and no database. Our hosting provider does, however, automatically record the technical data needed to deliver the page and to protect against attacks on each visit: IP address, date and time of the request, browser and operating system type, referring page.

  • Purpose: delivering the content, security and stability of the service.
  • Legal basis: legitimate interest in operating the site securely (Article 6(1)(f) GDPR).

We serve our fonts from our own server, so loading a page sends no request to Google Fonts or anywhere else.

2.2 When you contact us by email

There is no contact form on the site — you write to us directly at [email protected]. We process the content of your message and the data you include in it (usually your name, email address and information about your business or project).

  • Purpose: replying to you, preparing a proposal and agreeing on working together.
  • Legal basis: pre-contractual steps and performance of a contract (Article 6(1)(b) GDPR).

2.3 Booking a consultation through Calendly

The “Book a consultation” buttons lead to Calendly, an external service. The booking form is already on the calendly.com domain — the data you enter there (name, email, time slot and any answers to follow-up questions) is processed there and then made available to us.

  • Purpose: arranging and organising the intro call.
  • Legal basis: pre-contractual steps (Article 6(1)(b) GDPR).

2.4 The quick funnel audit

The tool on /funnel-audit/ runs entirely in your browser. Your answers are not sent anywhere, are not stored, and we have no access to them — they are gone when you close or reload the page.

If you choose “I want the detailed video breakdown” at the end, a pre-filled email opens in your own mail program. The data reaches us only when you send it yourself, at which point section 2.2 applies.

2.5 Playing videos (YouTube)

Videos load only once you click on them. Until then, no connection to YouTube’s servers is made. Once a video starts, it loads from the youtube-nocookie.com domain, which limits tracking to the necessary minimum; Google processes your IP address and playback data in the process.

  • Legal basis: your consent, expressed by clicking play (Article 6(1)(a) GDPR).

2.6 Traffic statistics — Google Analytics 4

We use Google Analytics 4 to measure traffic. The tool stores cookies on your device (for example _ga, _ga_<ID>) and processes a truncated IP address, the pages visited, time spent on the page, the source of the visit, the device and browser type, and an approximate location at city level.

We have IP anonymisation switched on, and we do not use Google Signals or any link to advertising identifiers for the purpose of building advertising profiles.

  • Purpose: finding out which content is useful and where visitors leave.
  • Legal basis: your consent (Article 6(1)(a) GDPR). Without consent, the tool does not load.
  • Retention: 14 months from the last visit.

2.7 Advertising measurement — Meta Pixel

We use the Meta Pixel to evaluate advertising on Facebook and Instagram. It stores the _fbp cookie and processes your IP address, browser identifier, the pages visited and the actions taken (for example clicking through to book a consultation). If you are logged in to Facebook or Instagram, Meta is able to attribute these events to your account.

We use the data to:

  • measure how our ads perform,
  • remarket — reach people again who have already visited our site,
  • build lookalike audiences based on visitor behaviour.

This is profiling for advertising purposes within the meaning of Article 4(4) GDPR. It has no legal effect on you and no similarly significant impact — it affects only which ads you see. We do not carry out any automated decision-making under Article 22 GDPR.

In collecting the data and sending it to Meta, we act as joint controllers with Meta Platforms Ireland Limited; Meta is separately responsible for any further processing after it is sent, under its privacy policy.

  • Legal basis: your consent (Article 6(1)(a) GDPR). Without consent, the pixel does not load.
  • Retention: as set by Meta, generally no more than 180 days for event data.

The analytics and marketing tools in sections 2.6 and 2.7 load only after you have given us your consent in the information bar shown on your first visit. Consent is voluntary; you may decline it and the site will work exactly the same.

You can withdraw your consent at any time — open the cookie settings in the site footer or write to us at [email protected]. Withdrawal does not affect the lawfulness of processing carried out before it.

A detailed list of the individual cookies is in the cookie policy.

4. How to avoid tracking beyond our site

5. Who we share data with

We do not sell data, and we do not give it to anyone for their own marketing purposes. We share it only with the providers we need in order to operate:

Recipient For what Based in
[TO ADD — hosting provider] running the site, server logs [TO ADD]
Google Ireland Limited Google Analytics, YouTube playback Ireland / USA
Meta Platforms Ireland Limited Meta Pixel, advertising Ireland / USA
Calendly LLC consultation bookings USA
Email provider delivering our mail EU

We may also disclose data to public authorities where the law requires it.

6. Transfers outside the European Union

Google, Meta and Calendly process some data in the United States. Those transfers are covered by the European Commission’s adequacy decision under the EU–U.S. Data Privacy Framework, or by standard contractual clauses under Article 46 GDPR.

7. How long we keep data

Data Period
Email correspondence 3 years from the last message
Client records and invoicing 10 years (statutory period)
Calendly bookings for the booking, and 12 months afterwards
Google Analytics 14 months
Meta Pixel generally up to 180 days
Server logs as configured by the host, generally 30 days

Once these periods pass, we erase or anonymise the data.

8. Your rights

Under the GDPR you have the right:

  • of access — to know whether and what data we process about you, and to receive a copy (Article 15),
  • to rectification of inaccurate or incomplete data (Article 16),
  • to erasure (the “right to be forgotten”) (Article 17),
  • to restriction of processing (Article 18),
  • to data portability to another controller (Article 20),
  • to object to processing based on legitimate interest and to direct marketing — you may object to direct marketing at any time and without giving a reason (Article 21),
  • to withdraw consent at any time, without affecting the lawfulness of prior processing (Article 7(3)).

Exercise your rights at [email protected]. We will reply within one month. Exercising your rights is free of charge.

If you are not satisfied with how we handle it, you have the right to lodge a complaint with the supervisory authority:

Office for Personal Data Protection of the Slovak Republic

9. Is providing data mandatory?

Providing data is voluntary. Without an email address, however, we cannot reply to you or arrange a consultation. Consent to the analytics and marketing tools is entirely voluntary, and declining it has no effect on your use of the site.

10. Changes to this policy

We may update this policy when we change tools or the way we process data. The current version is always on this page; the date of the last change is in its header.

11. Contact

Solureach — Adam Hupka and Leo Rehúš