Resources · Legal · Document 06

Privacy Notice

Annex 06 to the Master Services Agreement · Version 1.0 · Effective from December 2026

Version 1.0 · Effective from December 2026

1. Controller and contact

1.1 Controller. DCXPS SE, a European company with its registered seat at Karla Engliše 3208/5, Smíchov, 150 00 Praha 5, Czech Republic, ID No. (IČO) 24546810, registered in the Commercial Register maintained by the Municipal Court in Prague, file No. H 2803 ("DCXPS", "we" or "us"), is the controller of the personal data described in this notice. This notice gives you the information required by Articles 13 and 14 of Regulation (EU) 2016/679 (the "GDPR") when you represent a customer or a prospective customer of DCXPS, use the Chapek.io Platform (the "Platform"), pay for our services (the "Services"), visit the facility in the Czech Republic from which we provide the Services (the "DCXPS Facility"), use our website or send us a notice under Regulation (EU) 2022/2065 (the "Digital Services Act").

1.2 Contact. You can contact us about your personal data at privacy@chapek.io or by post at our registered seat. We have not appointed a data protection officer.

1.3 Data of our customers. This notice does not cover the personal data that our customers store or process on the servers we provide to them ("Customer Data"). We process Customer Data as a processor on behalf of the customer under the Data Processing Agreement; the customer is the controller of those data, and its own privacy notice applies to them.

2. Personal data we process

We process the personal data listed below. The personal data of the representatives of our customers and of the persons whom our customers authorize to use the Services ("Users") that we process to manage our contracts with them form the "Account Data".

Persons concernedPersonal dataSource
Representatives, signatories and contact persons of customers and prospective customersName, role, employer, business contact details, communications with us, contract and order historyYou or the organization you represent
Users of the PlatformName, business e-mail address, credentials (stored as hashes), role and permissions, identifiers of multi-factor authentication devices, login and activity logs, IP addresses, support ticketsYou or the customer; generated by your use of the Platform
Billing contacts and cardholdersName, billing address, the name on the card, the last four digits, the expiry date and the token of the payment card, payment and prepayment records, pro-forma documents, tax documents and receipts. You enter the full card data on the page of the Payment Processor (section 6); full card numbers never reach our systems.You; the Payment Processor
Directors, owners of ten percent (10%) or more and Users of customers subject to sanctions screeningName, date of birth, nationality, the type, number and validity of the identity document presented, screening resultYou or the customer; sanctions lists and public registers (public sources)
Visitors, contractors and auditors at the DCXPS FacilityIdentity document data for access, access records, video recordings of common areasYou; our access-control systems
Website visitorsTechnical data (IP address, device and browser data, pages visited) and cookie data as described in the cookie notice (section 12)Your device
Persons who send us notices of illegal content or review requests under the Digital Services ActName, e-mail address, content of the notice or request, our decisionYou

4. Your right to object

4.1 You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data based on Article 6(1)(f) of the GDPR. We then stop the processing unless we demonstrate compelling legitimate grounds for it which override your interests, rights and freedoms, or the processing is needed for the establishment, exercise or defense of legal claims. You may also object at any time to the use of your personal data for direct marketing, and we then stop using them for that purpose (Article 21 of the GDPR). Send your objection to privacy@chapek.io or use the link in any marketing e-mail.

5. Whether you must provide personal data

5.1 Account Data are required to conclude and perform a contract with us: without them we cannot open an account, accept an order or provide the Services. The data needed for tax documents and for sanctions screening are required by law. Providing any other personal data is voluntary.

6. Recipients

6.1 We disclose personal data only to:

(a) our personnel who need them for the purposes in section 3;

(b) service providers that process personal data on our behalf as processors, all established in the Union and processing personal data only in the Union (facility services, e-mail and ticketing, accounting, identity and access management, sanctions screening, electronic signature, invoicing and billing, customer relationship management, and website hosting and forms), listed at chapek.io/legal;

(c) our payment service provider, Adyen N.V., a credit institution authorized in the Netherlands, established in the Union (the "Payment Processor"), which processes card payment data as an independent controller under its own privacy notice, and our bank, which processes the data of bank transfers as an independent controller;

(d) the card schemes and the card issuer through which a card payment is settled, which receive card payment data from the Payment Processor as independent controllers;

(e) our statutory auditor and our tax and legal advisers, who are bound by confidentiality; and

(f) courts and public authorities, including the tax authorities, where Union or Czech law requires it; we handle every such request under our Government Access Protocol (Annex 08, Part C, to the Master Services Agreement).

6.2 We do not sell personal data. DCXPS Inc., a separate legal entity in the United States, receives none of the personal data described in this notice and has no access to our systems.

7. Location of processing

7.1 We and our processors store and process the personal data described in this notice only in the Union. We do not transfer personal data to a country outside the Union or to an international organization. If Union or Czech law requires such a transfer, we make it only under Chapter V of the GDPR and inform you, unless the law prohibits it. The Payment Processor, the card schemes and the card issuer process card payment data under their own privacy notices.

8. Retention

We keep personal data only for as long as the purpose requires and within the periods below. At the end of the period we delete or anonymize them.

Personal dataRetention period
Tax documentsTen (10) years from the end of the tax period in which the supply took place (Section 35(2) of Act No. 235/2004 Coll.)
Other accounting records, payment and prepayment records, pro-forma documents and receiptsThe periods required by Czech tax and accounting law
Contract and order data and correspondence with customer representativesThe term of the contract and thereafter four (4) years, covering the general three-year limitation period for claims arising from the contract
Card tokensUntil the card is removed from the account or the account is closed
Platform accountsThe duration of the account
Security and activity logs of the PlatformTwelve (12) months from the date of the record or, for the logs of management and maintenance sessions concerning a customer's servers, until twelve (12) months after the end of the last prepaid service period of the order under which those servers are provided, whichever is later (Annex 08, Part B, section B.2.4, to the Master Services Agreement)
Access records of the DCXPS FacilityTwelve (12) months from the date of the record or, for the records of access to the hall in which a customer's servers are installed, until twelve (12) months after the end of the last prepaid service period of the order under which those servers are provided, whichever is later (Annex 08, Part B, section B.2.3, to the Master Services Agreement)
Video recordings of common areas of the DCXPS FacilityTwenty-one (21) days or, where a recording concerns an incident, until the incident has been resolved
Screening recordsThe term of the contract and five (5) years after its end
Notices and review requests under the Digital Services ActSix (6) months after our decision or, where a dispute is pending, until it has been finally resolved
Data of prospective customersTwenty-four (24) months after the last contact
Objections to marketing e-mailsFor as long as we send marketing e-mails, so that we respect the objection

9. Your rights and complaints

9.1 Your rights. Under Articles 15 to 22 of the GDPR you have the right:

(a) of access to your personal data (Article 15);

(b) to rectification (Article 16);

(c) to erasure (Article 17);

(d) to restriction of processing (Article 18);

(e) to data portability, for personal data you have provided to us and that we process by automated means on the basis of a contract or of your consent (Article 20);

(f) to object (Article 21; section 4); and

(g) not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you (Article 22).

We notify each recipient of a rectification, erasure or restriction as Article 19 of the GDPR requires, and we inform you about those recipients on request.

9.2 Exercising your rights. You can exercise your rights by writing to privacy@chapek.io. We respond without undue delay and in any event within one (1) month of receipt of your request. Where necessary, taking into account the complexity and number of requests, we may extend that period by two (2) further months; we then inform you of the extension, with the reasons, within the first month (Article 12(3) of the GDPR). We may ask you to confirm your identity.

9.3 Automated decisions. We take no decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you.

9.4 Complaints. You have the right to lodge a complaint with the Office for Personal Data Protection (Úřad pro ochranu osobních údajů) in the Czech Republic or with the supervisory authority of the Member State of your habitual residence, of your place of work or of the place of the alleged infringement (Article 77 of the GDPR).

10. Security

10.1 We protect the personal data described in this notice with the technical and organizational measures that we apply to the Services and that are described in Annex B of the Data Processing Agreement and in Annex 08 to the Master Services Agreement, including access control, encryption, logging, processing in the Union by personnel located in the Union, and incident response.

11. Marketing e-mails

11.1 We send marketing e-mails about our own similar services to the e-mail address that you or your organization gave us in connection with an order of the Services, as permitted by Section 7(3) of Act No. 480/2004 Coll., on Certain Information Society Services, as amended. You can refuse such e-mails free of charge when you give us the address and at any time afterwards, including by the link in each e-mail.

12. Cookies

12.1 Our website and the Platform use cookies and similar technologies as described in the cookie notice at chapek.io/legal, which states their purposes and legal bases, the consent you can give or refuse, and how you can withdraw it.

13. Changes to this notice

13.1 We update this notice when our processing changes. The current version and its effective date are published at chapek.io/legal, and we notify account holders of material changes through the Platform.

Online version of document 06 of the DCXPS EU Customer Standard Pack, Version 1.0, effective from December 2026. Questions and signed copies: sales@chapek.io.