Reframia

Legal

Privacy Policy

Effective from 10 September 2026.

This policy explains how I process personal data when you use reframia.com, send an application, subscribe to the newsletter or work with me.

1. Controller

Valerie Baráková
Business ID (IČO): 06367364
Registered office: Cínová hora A 6370, 669 02 Znojmo, Czech Republic
Email: valerie@ccnrmethod.com

You can contact me at this email address with any question about your personal data.

2. What I process, why, on what legal basis and for how long

Applications through the website form

Data: name, email, the offer you are applying for, and what you write in the form.

Purpose: to read your application and reply to you.

Legal basis: steps taken at your request before concluding a contract (Art. 6(1)(b) GDPR).

Retention: if no contract follows, 12 months from our last contact.

Providing the services (Pattern Audit, 1:1)

Data: contact details, what you share in the preparation and during calls, the written analysis, our email correspondence.

Purpose: to provide the service.

Legal basis: performance of a contract (Art. 6(1)(b) GDPR).

Retention: for the duration of the contract and then 3 years for the possible defence of legal claims (legitimate interest, Art. 6(1)(f) GDPR).

Payments, invoicing and accounting

Data: name, address, business ID if you have one, payment and invoice details.

Purpose: to receive payment and meet my tax and accounting obligations.

Legal basis: legal obligation (Art. 6(1)(c) GDPR).

Retention: for the period required by tax and accounting laws, up to 10 years.

Newsletter

Data: email and name.

Purpose: sending the newsletter.

Legal basis: your consent (Art. 6(1)(a) GDPR). If you are already my client, I may send you the newsletter about similar services on the basis of legitimate interest (Art. 6(1)(f) GDPR) under the conditions of Czech Act No. 480/2004 Coll.

Retention: until you unsubscribe or withdraw your consent. Every email contains a link to unsubscribe.

Website operation and security

Data: technical data such as IP address and browser information, processed by the hosting provider.

Purpose: to run the website securely.

Legal basis: legitimate interest (Art. 6(1)(f) GDPR).

Retention: for the short period needed for operation and security.

3. Information about your health or mental wellbeing

My services are not healthcare. Still, in the preparation or during calls you may choose to share information about your health or mental wellbeing. I only process such information if you give me your explicit consent (Art. 9(2)(a) GDPR), which I ask for when you book a service. You can withdraw this consent at any time.

Please do not include information about your health in the application form.

4. Who has access to your data

I do not sell your data. I share it only with providers who help me run the website and provide the services, and only to the extent they need:

  • website hosting and the application form: my web hosting provider
  • invoicing and payment administration: FAPI
  • card payments: Stripe (Stripe Payments Europe, Limited), which also processes some data as an independent controller under its own privacy policy
  • email: Google (Gmail)
  • video calls: Zoom
  • my bank, for bank transfers

I may also disclose data to public authorities if the law requires it.

5. Transfers outside the EU

Some of these providers, in particular Google, Zoom and Stripe, may process data outside the European Economic Area, mainly in the United States. In that case the transfer is based on the EU-US Data Privacy Framework or on the European Commission's standard contractual clauses.

6. Cookies

The website uses only technically necessary storage that it needs to work. It does not use analytics or marketing cookies, so it does not ask for your consent. If this changes, I will ask for your consent before any such cookies are used and update this policy.

7. Your rights

You have the right to:

  • access your personal data
  • have inaccurate data corrected
  • have your data erased
  • restrict processing
  • data portability
  • object to processing based on legitimate interest, including direct marketing
  • withdraw your consent at any time, without affecting processing carried out before the withdrawal

To use any of these rights, write to me at the email address in section 1. I will reply within one month.

You also have the right to lodge a complaint with the supervisory authority: Úřad pro ochranu osobních údajů, Pplk. Sochora 27, 170 00 Praha 7, Czech Republic, www.uoou.gov.cz, or with the data protection authority in the EU country where you live.

8. Other information

Providing your data is necessary if you want me to reply to your application or provide a service. Subscribing to the newsletter is voluntary.

I do not use automated decision-making or profiling.

I protect your data with appropriate technical and organisational measures.

I may update this policy. The current version is always available on reframia.com.