Privacy policy
English translation
Provided for convenience. In case of any discrepancy the Czech version prevails.
Article 1 — Who the controller is and how to contact us
1.1. The controller of personal data is Tengo s.r.o., company ID 03339165, Dolní Valy 205, 262 72 Březnice, Czech Republic, operator of the killBottleneck service.
1.2. Contact for personal data matters: info@killbottleneck.com. Security incidents: security@killbottleneck.com. We have not appointed a data protection officer (DPO) — given the scope of processing it is not mandatory.
Article 2 — Two roles: when we are the controller and when the processor
2.1. We are the controller of data whose processing we decide on ourselves: customer data (accounts, orders, invoicing), operational logs of our infrastructure and communication with you. This policy describes those.
2.2. We are the processor of the content a customer puts into their hosted instance (maps, tasks, comments, time entries, e-mails of instance users). The customer, as controller, decides on the purposes of that processing; our obligations are set out in the Data processing agreement (DPA), an annex to the terms of service. If you are a user of some company's instance, direct questions about the content primarily to that company.
Article 3 — Which data we process, why and on what basis
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Customer account: name, e-mail, company name, company/VAT ID | setting up and managing the service, communication | performance of a contract (Art. 6(1)(b) GDPR) | for the term of the contract + 3 years for the defence of claims (legitimate interest) |
| Invoicing data: billing address, payment data and tax documents | invoicing, accounting, taxes | legal obligation (Art. 6(1)(c)) | according to the VAT and accounting acts — tax documents 10 years |
| Payment data (card number etc.) | making the payment | performance of a contract | processed directly by Stripe; we neither see nor store the full card number |
| Operational logs: IP address, access time, technical server and proxy records | security, operations, troubleshooting and incidents | legitimate interest (Art. 6(1)(f)) — securing the service | at most 90 days; in practice logs rotate much sooner (application logs when they reach a size limit, system logs after weeks) |
| Communication with support (e-mails to info@/support@/security@) | handling the request, support history | performance of a contract / legitimate interest | 3 years |
| Commercial communications — e-mails about new features and major service updates | marketing | legitimate interest for existing customers (with an unsubscribe option in every e-mail), otherwise consent | until consent is withdrawn / objection |
| Bug reports and ideas from the application: the text you send us, application version, the page you were on and browser information; a screenshot only when you attach it to the report yourself. E-mail address only when you ask for a reply yourself by ticking the box in the dialog. | fixing the bug, improving the program; when a reply is requested also communication with you | legitimate interest (Art. 6(1)(f)) — functionality of the service; for the screenshot and address your own initiative | 30 days — the bug gets fixed right away; we keep no file on the customer from it |
3.2. You send bug reports yourself, only when you want to, and anonymously by default. Before sending, the form lists what will go out with the message. Your address and company name are not sent — we fix the program for everyone, not individual accounts. If you want a reply, you tick the box and only then attach your address. Nothing is collected in the background and the content of your maps is not attached to the report; only what you write into it is sent — plus any screenshot you insert yourself (the dialog shows it before sending and it can be removed with one click). Inside your instance the report, including the screenshot, stays stored so you can see what you have already sent — only you see it, it is not shown to other users, and after 30 days it is deleted together with the screenshot.
3.3. The content of your maps is never stored in the AI service logs — this is a binding operating rule. AI computations run on the operator's hardware in the Czech Republic or at our supplier AKI.IO GmbH in Germany (EU) — without retaining content and without training.
3.4. We do not process data for automated decision-making with legal effects, nor do we carry out profiling.
Article 4 — Who we pass data to (recipients and processors)
4.1. The following suppliers (processors) process data on our behalf:
| Supplier | What for | Where the data are processed |
|---|---|---|
| Hetzner Online GmbH (Germany) | servers on which the service and backups run | EU (Nuremberg datacentre, Germany); off-site backups in the EU |
| Cloudflare, Inc. (USA) | DNS, network proxy and website protection | global network; transfers outside the EU are covered by the EU–US Data Privacy Framework adequacy decision (active certification verified in the dataprivacyframework.gov list, August 2026) and standard contractual clauses (SCC) in the Cloudflare DPA |
| Sendinblue SAS / Brevo (France) | sending transactional e-mails (confirmations, notifications) | EU |
| AKI.IO GmbH (Germany) | AI computations of the assistant (text replies, reading images) — the content of a request is processed and not retained, and is not used for training | Germany (datacentres in Germany); data processing agreement under Art. 28 GDPR |
| Stripe | payments and invoicing data | Stripe Payments Europe, Limited (Dublin, Ireland) as the contracting party for European customers; any transfers to the USA (Stripe, Inc.) are covered by the EU–US Data Privacy Framework (certification confirmed in the Stripe Data Privacy Framework Policy, August 2026) and SCC in the Stripe DPA |
4.2. We do not pass data to other recipients unless required by law (public authorities) or necessary for the defence of our legal claims (lawyer, court). We do not sell data.
4.3. Data are transferred outside the EU/EEA only to the extent described in the table above, always with safeguards under Chapter V GDPR (adequacy decision, standard contractual clauses).
Article 5 — Cookies and website analytics
5.1. We measure traffic on the killbottleneck.com / killbottleneck.cz websites with the Umami tool run on our own server in the EU. The measurement is anonymous: it stores no cookies or other identifiers on your device, does not profile visitors, and the measured data (pages viewed, clicks on the main links, plan chosen in the order, traffic source, browser type, country; we do not measure form contents) do not leave our infrastructure. The legal basis is our legitimate interest (Art. 6(1)(f) GDPR) in knowing the traffic of our own website. Because nothing is stored on the device, no cookie banner is needed.
5.2. The application (your instance) uses only strictly necessary cookies/storage for logging in and functioning — the service does not work without them; no consent is required for them.
5.3. Should we deploy analytics requiring consent in the future, we will update this policy in advance and ask for your consent.
Article 6 — How we protect data
6.1. We encrypt data in transit (TLS/HTTPS). Customer instances are isolated (separate container or VPS). Only the infrastructure administrator has access to the production servers. We back up data daily off the host server (in the EU). For details see the technical measures in the Data processing agreement.
Article 7 — Your rights
7.1. You have the right of access to your data, to rectification, erasure, restriction of processing, portability and the right to object to processing based on legitimate interest (including marketing — you can always easily unsubscribe from it). Where consent is the basis, it can be withdrawn at any time.
7.2. We handle requests at info@killbottleneck.com, usually within one month.
7.3. You have the right to lodge a complaint with the Office for Personal Data Protection (Úřad pro ochranu osobních údajů), Pplk. Sochora 27, 170 00 Praha 7, www.uoou.gov.cz.
7.4. If your request concerns the content of an instance of which you are a user (not the customer), we forward it to the respective customer as controller and provide them with assistance.
Article 8 — Changes to this policy
8.1. We may update this policy (change of suppliers, services, legislation). The current version is always on the website; we inform customers of material changes by e-mail.
8.2. Effective from: 8 August 2026.