Privacy policy

Who processes your data

The controller of your personal data is FRAGMENTO SE, company ID 21956839, registered office Okružní 433/1, Lesná, 638 00 Brno, zapsaná v obchodním rejstříku vedeném Krajským soudem v Brně, oddíl H, vložka 737 (“we”).

For anything concerning your personal data, write to info@fragmento.cz or call +420 604 827 601.

What data we process

Inquiries and questions: name, e-mail, phone, your message and your answers in the form (for example the property or country you are interested in and when we may call you), the page you sent it from and when, and the campaign name if you came to the website through a link that carries one (utm_ parameters in the address).
Newsletter: your e-mail address, the language and page you signed up on, when and to which consent text, when you confirmed with the link in our e-mail, and the campaign name as for inquiries.
Shareholders: identification and contact details, details of the share and its transfers, details needed for invoicing and, in the client zone, stay bookings.
Browsing the website: technical data your browser sends with every request (IP address, browser type, page address and time). We need it to run and secure the website.
Our own visitor measurement: which pages and links are used, where visitors come from and how fast pages load. It stores no cookies or other identifier on your device; it tells visits apart by an encrypted fingerprint of the IP address and browser that changes every week. It never records what you type into forms.
Analytics and marketing cookies (only with consent): browser identifiers stored in cookies, the pages viewed, clicks on calls to action, forms sent (never what you type into them), where you came from and technical details of your browser and device. They are collected by Google Analytics, Google Ads, the Meta Pixel and Sklik, as described on the Cookies page.

Why we process data and on what basis

Answering your inquiry and discussing a purchase: steps before a contract that you asked for, and the consent you give when you send the form.
Concluding and performing a contract, the share register and stay bookings: performance of the contract and our legal obligations, such as accounting and tax.
Newsletter: your consent, which you can withdraw at any time through the link in every e-mail or by writing to info@fragmento.cz.
Running, securing and measuring the website: our legitimate interest in a secure, working website and in knowing which pages help people.
Analytics and advertising (Google Analytics, Google Ads, Meta Pixel, Sklik): your consent in the cookie banner, which you can withdraw at any time in the cookie settings. Without consent, Google Analytics and Google Ads measure only in cookieless mode, based on our legitimate interest in knowing how many people our ads brought to the website.

We do not sell your data and do not use it for automated decision-making. Only if you agree to marketing cookies do the ad systems of Google, Meta and Seznam choose which ads to show you based on your visit to the website (remarketing).

Who receives your data

We pass data only to processors who help us run our business, and only as far as they need it:

the provider of the servers that run the website and its database;
Google (Google Workspace), through which we send and receive e-mail;
RAYNET s.r.o., operator of the Raynet system, where we keep inquiries, newsletter subscribers and our correspondence with prospective buyers, and from which we send the newsletter;
Cloudflare, Inc., whose Turnstile service checks that a person is sending our forms: when you start filling in a form, your browser passes it your IP address and technical details of your browser and device, which Cloudflare uses to recognise bots;
Esri, which provides map data: when you open a map, your browser downloads map tiles from it and so passes it your IP address;
Google (YouTube), whose player loads from youtube-nocookie.com only when you start a video on the website: your browser then passes it your IP address, and Google decides on the playback data as an independent controller under its own policies;
Google Ireland Limited, which runs Google Analytics and Google Ads for us: it evaluates visits to the website and the results of our ads; with your consent to marketing cookies it also processes the data for its own advertising purposes under its own policies;
Meta Platforms Ireland Limited, only with your consent to marketing cookies: its Meta Pixel measures who came to the website from an ad on Facebook or Instagram and lets us show ads to the website's visitors; we are jointly responsible with it for collecting this data on the website;
Seznam.cz, a.s., only with your consent to marketing cookies: it measures the results of Sklik ads in the Seznam network and lets us show ads to the website's visitors;
our accountants and legal advisers, and public authorities where the law requires it.

Some of them may process data outside the European Economic Area, for example in the USA. Such transfers rely on a European Commission adequacy decision or on standard contractual clauses.

How long we keep data

Inquiries and correspondence with prospective buyers for at most 3 years after our last contact, unless they lead to a contract.
Shareholders' data for as long as they hold a share and then for as long as the law requires (accounting records 10 years) or as we need to protect our rights.
Your newsletter e-mail address until you unsubscribe.
Data from analytics and marketing cookies for the period set in each service.
The record of your choice in the cookie banner (a random consent ID, the choice, the banner's wording, the language, the page and the time) for 3 years from the choice, so that we can show what you agreed to.
Server logs only as long as needed to run and secure the website.

We may keep aggregate statistics that identify no one without limit.

Your rights

You have the right:

to access your data and receive a copy;
to have inaccurate data corrected;
to have data erased that we no longer need or that we process only on the basis of consent you have withdrawn;
to restrict processing;
to data portability for data you provided to us;
to object to processing based on our legitimate interest;
to withdraw your consent at any time; this does not affect processing before the withdrawal.

Just write to info@fragmento.cz. We will reply without undue delay and within one month at the latest.

If you believe we are not handling your data properly, you can lodge a complaint with the Czech Office for Personal Data Protection (uoou.gov.cz (opens in a new tab)) or the supervisory authority in your country.

Cookies

The website uses essential cookies for signing in, for confirming a newsletter subscription and for storing your choice in the cookie banner, and remembers the price currency you chose and the campaign you came with. We use analytics and marketing cookies only with your consent, which you can change at any time in the cookie settings. When you play a video, YouTube may store its own data in your browser. See Cookies for details.

Security

The website runs only over an encrypted connection (HTTPS), only authorised people can access personal data, and database backups are stored encrypted.

Changes to this policy

We may update this policy, for example when we start using a new tool. The current version is always on this page; we inform shareholders of significant changes by e-mail.