Privacy Policy
1. Data Controller
Tomáš Brabec
Business identification number (IČO): 73778915
Registered address: Štefánikova 7235, 760 01 Zlín, Czech Republic
Email: info@tomasbrabec.com
Website: https://www.tomasbrabec.com
This policy explains how personal data are processed in connection with enquiries, the Structured Email Program, and the Ongoing Guidance Program.
2. Personal Data and Purposes
Depending on your interaction with me, I process:
- Your name, email address, country of residence, and enquiry, to answer your questions and arrange a program.
- Necessary billing details, the program ordered, payment status, and transaction references, to administer payment and meet accounting and legal obligations.
- Your questionnaire responses and email correspondence, to provide individual written guidance.
- Information about your health and personal circumstances that you choose to share, where necessary for the agreed program and subject to the appropriate consent. Please avoid sending unnecessary identifying information about other people. PayPal processes the payment details submitted through its service under its own privacy notice. I do not need your card details or PayPal password. Please do not send them by email.
3. Legal Bases
Enquiries and program administration are processed to take steps at your request before entering into a contract and to perform that contract, under Article 6(1)(b) GDPR. Records required by law are processed under Article 6(1)(c) GDPR. Where necessary, limited records may also be retained to establish, exercise, or defend legal claims under Article 6(1)(f) GDPR. Health information is a special category of personal data. For this advisory program, I request your separate, explicit consent before collecting or using such information, under Article 9(2)(a), together with Article 6(1)(a) GDPR. Other special-category information is handled on the same basis where relevant.
You may withdraw this consent at any time by emailing me. Withdrawal does not affect the lawfulness of earlier processing. If the agreed guidance cannot continue without this information, we will discuss stopping or adjusting the program. Basic contact information is needed to arrange the program. Providing sensitive information is voluntary; without information necessary for individual guidance, it may not be possible to provide the program as agreed.
4. Recipients and International Transfers
Data may be accessible to providers of email, website hosting, and necessary technical support, and to accounting advisers where needed. Access must be limited to the relevant purpose. PayPal receives information necessary for payment processing and operates under its own terms and privacy notice. Your questionnaire and personal story are not supplied to PayPal as part of payment processing.
I do not sell your personal data or use your program correspondence for advertising, publication, or research without a separate appropriate permission or legal basis. If a provider processes personal data outside the European Economic Area, the applicable transfer mechanism must be established, such as a relevant adequacy decision or appropriate contractual safeguards. You can contact me for details of the providers and safeguards used for your data.
5. Retention and Security
Enquiries are kept for the time needed to respond and resolve the enquiry. Program correspondence is retained for the duration of the program and for any necessary agreed follow-up. Any further retention must be justified by a legal obligation or the need to establish, exercise, or defend legal claims. The criteria are the purpose of the record, applicable legal retention requirements and limitation periods, and any unresolved dispute. Unnecessary sensitive information is deleted rather than retained with routine accounting records. Access to program correspondence is restricted. Appropriate technical and organisational safeguards are required for accounts, devices, and stored messages. Email is not a completely secure communication channel; please share only information relevant to the program.
6. Your Rights
Subject to the applicable conditions, you may request access, correction, deletion, restriction of processing, and data portability. You may object to processing based on legitimate interests and withdraw consent where processing relies on consent. You may complain to the Czech Office for Personal Data Protection (Úřad pro ochranu osobních údajů), https://uoou.gov.cz, or the competent supervisory authority in your country.
To exercise your rights, contact info@tomasbrabec.com. Requests are normally answered within one month, subject to the extensions permitted by GDPR. Identity verification may be required. Program data are not used for automated decision-making or profiling producing legal or similarly significant effects. Marketing emails require a separate applicable legal basis; ordering a program does not automatically subscribe you to a newsletter.
7. Updates
This policy may be updated to reflect changes in the service or data-processing arrangements. The current version is published on the website. Material changes affecting existing clients will be communicated where required.