Privacy Policy

This document describes how Bc. Nikola Bělochová, Company ID: 04940105, based in the Czech Republic (hereinafter referred to as the "Controller"), processes personal data of users of the web application https://elisgrid.com (hereinafter referred to as the "web application") in compliance with applicable data protection laws, including the European Union's General Data Protection Regulation (GDPR), the CAN-SPAM Act, and the California Consumer Privacy Act (CCPA).

1. Categories of Processed Personal Data

When subscribing to the newsletter:
- email address
  → used solely for sending newsletters via Mailchimp.

When purchasing a digital product (PDF crossword):
- email address
- personalized crossword content (solution, questions, answers), which may include personal data
- IP address, purchase date and time, technical data about product downloads
  → these data are necessary for contract performance and handling potential complaints.

Data stored in the user's browser (localStorage):
- unfinished crossword temporarily saved only on the user's device
  → these data are not transmitted to the Controller or third parties.

2. Use of Cookies and Analytical Tools

The web application uses essential technical cookies necessary for its basic functionality (e.g., remembering cookie consent).

With granted consent, the following tools may be used:

  • Google Analytics (gtag.js): anonymized tracking of visits and user behavior to optimize the website
  • CookieYes: tool for managing and recording cookie consents

The Controller does not use cookies for marketing purposes nor shares data with third parties for targeted advertising.

3. Legal Bases for Processing Personal Data

The processing of personal data is based on the following legal grounds (in accordance with GDPR and other applicable laws):

  • Consent of the data subject – e.g., for newsletter subscription and optional cookies
  • Performance of a contract – e.g., during purchase and delivery of the digital product
  • Legitimate interests of the Controller – e.g., ensuring security, technical operation of the application, complaint handling

4. Data Retention Period

  • Data provided for sending commercial communications are retained for 10 years or until consent withdrawal.
  • Data related to the purchase of the digital product are retained as long as necessary to fulfill legal obligations, but no longer than 10 years.

5. Withdrawal of Consent

The data subject has the right to withdraw consent to personal data processing at any time.
Withdrawal can be done by:

  • using the link in the received email (e.g., for newsletters),
  • or by sending a request to the Controller's email address: elisgridapp@gmail.com

Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

6. Data Subject Rights

Data subjects have rights under applicable data protection laws, which may vary depending on jurisdiction. Common rights include:

  • right of access to personal data,
  • right to rectification of inaccurate or incomplete data,
  • right to erasure ("right to be forgotten"),
  • right to restriction of processing,
  • right to data portability,
  • right to object to processing,
  • right to lodge a complaint with a competent supervisory authority.

Specific procedures and supervisory authorities depend on the applicable laws of the respective country.

7. Controller Contact Information

All requests, inquiries, or comments related to personal data processing can be sent to:
elisgridapp@gmail.com