Privacy policy
This policy describes how the Kotlo service (the web app at app.kotlo.app, the Android app and the kotlo.app website) processes personal data.
1. Controller and contact
The controller of personal data is Stanislav Rohel, a natural person operating the Kotlo service. For any question about personal data, contact us at privacy@kotlo.app. No data protection officer is appointed, as this is not required for processing of this scope.
2. What data we process
- Account: e-mail, name (optional), password stored only as a hash, language and time zone; for sign-in with Google or Microsoft, your account identifier at that provider.
- Households: memberships and roles, invitations (e-mail of the invited person).
- Household data you enter: heat sources, purchases, suppliers, stock, refills, inventory corrections and imported files. This data is indirectly personal because it is linked to your account.
- Acceptance of documents: the versions of the terms and this policy you accepted, the time and IP address.
- Technical and security records: IP address, account identifier, time, device or browser type, application errors.
- Device: a push notification token, if you turn notifications on in the app.
3. Purposes and legal bases
- Providing the service (account, households, records, calculations, forecast, e-mails about your account and invitations): performance of a contract, Art. 6(1)(b) GDPR.
- Security and account protection (sign-in records, abuse protection, backups): legitimate interest, Art. 6(1)(f) GDPR.
- Inviting a person without an account: legitimate interest of the inviting user; the e-mail is used only to deliver the invitation.
- Optional features (such as tips in push notifications or anonymous usage statistics, if we introduce them): consent, Art. 6(1)(a) GDPR. They are off by default and you can withdraw consent at any time.
We do not use third-party advertising or tracking tools and we do not sell data.
4. How long we keep data
- Account and household data while you use the service. A deleted account or household can be restored for 30 days; then the data is deleted permanently.
- Inactive account: after 2 years without sign-in we warn you by e-mail, after 3 years we delete the account.
- Invitation not accepted: until it expires (7 days) or is declined.
- Security records: 12 months; IP addresses are shortened after 90 days.
- Application operation logs: 30 days.
- Imported workbooks: the file is not stored; rows read for an import that was not confirmed are deleted within 7 days.
- Database backups: up to 35 days; deletions reach the backups only when they expire.
5. Processors and transfers
We process data in data centres in the European Union. Under data processing agreements the following work for us:
- Microsoft Ireland Operations Ltd. – hosting (Microsoft Azure), database, monitoring and sending e-mails (Azure Communication Services), EU region.
- Google Ireland Ltd. – delivering push notifications (Firebase Cloud Messaging, only the device token and the notification text) and app distribution (Google Play). Any transfer outside the EU is covered by standard contractual clauses.
We pass data to other recipients only where the law requires it.
6. Cookies and local storage
We use only necessary cookies and local storage: sign-in, form protection and your choice of language and appearance. We do not use analytics or marketing cookies, so we show no cookie banner.
7. Your rights
You have the right to access your data, to rectification, erasure, restriction of processing, data portability and to object to processing based on legitimate interest. You can withdraw consent at any time. You can change your name, e-mail, language and time zone yourself in your profile, and the owner of a household can delete it in the settings. Send other requests to privacy@kotlo.app; we handle them without undue delay and within one month at the latest.
If you believe we process data unlawfully, you can lodge a complaint with the Czech Office for Personal Data Protection (www.uoou.cz) or the supervisory authority of your country.
8. Security
Communication is encrypted (HTTPS), the database is encrypted at rest, the data of each household is kept apart from the others and passwords are stored only as hashes. Only the operator has access to production data, and access is logged.
9. Children
The service is not intended for persons under 15.
10. Changes to this policy
When the policy changes we publish a new version with its effective date. We inform you of material changes in advance and ask you to confirm the new version at your next sign-in.
The Czech version of this document prevails.