Legal

Privacy Policy

Version 1.0

# Privacy Policy

## 1. Controller

The controller of personal data collected through the Service is the operator

identified in the footer of the Service ("Operator"). You can reach us at the

support email shown in the Service.

## 2. What we collect

- **Account data:** name, email, password hash, preferred locale, role.

- **Organisation data:** company name, address, tax identifiers, bank details,

invoicing settings, SMTP credentials you configure.

- **Application data:** everything you enter about properties, leases, tenants,

invoices, expenses, attachments, and audit log entries.

- **Billing data:** subscription plan, billing period, and payment status. Card

details are collected and stored solely by our payment processor and never

reach the Operator's servers.

- **Technical data:** IP address, User-Agent, timestamps of logins and audit events.

## 3. Purposes and legal bases

- **Providing the Service** — Art. 6(1)(b) GDPR, performance of the contract.

- **Security, abuse prevention, audit logs** — Art. 6(1)(f), legitimate interest.

- **Billing and tax records** — Art. 6(1)(c), legal obligation.

- **Service communications** — Art. 6(1)(b) and (f).

- **Product analytics** (PostHog: events, pageviews and the signed-in user's

email address) — Art. 6(1)(a), your consent to analytics cookies.

- **Measuring our ad campaigns** — Art. 6(1)(a), your consent to marketing

cookies. When you sign up or start a paid plan, the Service reports that event

to Meta and Seznam (Sklik) with a hashed email address (for Meta also a hashed

user ID, your IP address and User-Agent), the ad cookies listed in section 4

and the value of the plan. Without marketing consent nothing is sent.

You can withdraw either consent at any time under "Cookie settings" at the

bottom of the page; withdrawal does not affect processing that took place before.

## 4. Cookies

Cookies that are **strictly necessary** for the Service are always set. Under

ePrivacy rules they need no consent.

| Cookie | Purpose | Duration |

| --- | --- | --- |

| `sid` | Signed-in session | 7 days, renewed on use |

| `lz_app` | Marks a browser that has signed in, so the installed app opens straight away | 7 days |

| `tpsid` | Tenant portal session | 7 days |

| `oauth_state_*`, `oauth_invite_*`, `oauth_register_context` | Sign-in and registration with Google | 10 minutes |

| `lumezzo_consent` | Your cookie choices | 180 days |

| `lumezzo_ref` | Code from a referral link, so the referral discount applies when you register | 60 days |

Analytics and marketing cookies are set **only with your consent**, which you

give, change or withdraw at any time under "Cookie settings" at the bottom of

the page.

| Cookie | Purpose | Duration |

| --- | --- | --- |

| `ph_*_posthog` (PostHog) | Product analytics (analytics consent) | 1 year |

| `lumezzo_gclid`, `lumezzo_gbraid`, `lumezzo_wbraid` and Google's own cookies, e.g. `_gcl_au` | Measuring Google Ads conversions (marketing consent) | 30 days; Google's cookies under Google's policy |

| `_fbp`, `_fbc` (Meta) | Measuring Meta ad conversions (marketing consent) | 90 days |

| `lumezzo_sznaiid`, `lumezzo_sem` and Seznam's own cookies, e.g. `sid` and `udid` | Measuring Sklik ad conversions (marketing consent) | 30 days; Seznam's cookies under Seznam's policy |

You can also delete or block cookies in your browser settings; blocking the

strictly necessary cookies will prevent the Service from working.

## 5. Retention

Application data is retained for as long as your organisation exists. After you

request deletion, data is hard-deleted following the grace period configured in

the Service. Audit logs and billing records may be retained longer where required

by law.

## 6. Recipients

We share personal data only with the categories of processors strictly necessary

to run the Service; the up-to-date list of named providers is maintained on the

**Subprocessors** page of the Service. The categories are:

- a **transactional email delivery provider** (verification, notifications,

billing emails sent by the Service);

- a **payment processor** for paid plans, which acts as an independent controller

for card data;

- a **DNS and network security provider** in front of the Service;

- an **identity provider**, only if you choose to sign in with a third-party

account (for example Google OAuth).

Only with your marketing consent, the conversion data described in section 3

goes to **Meta Platforms Ireland Ltd.** and **Seznam.cz, a.s.**, which use it to

measure our ads as independent controllers under their own privacy policies.

Google receives data only through its own tag in your browser, also only with

marketing consent.

The application and its database are hosted on infrastructure operated directly

by the Operator in the European Union. Emails you send through your own configured

SMTP server (for example invoices to your tenants) are transmitted by your

provider and remain under your control. We do **not** sell personal data.

## 7. International transfers

Where these processors transfer data outside the EEA we rely on Standard

Contractual Clauses or other safeguards required by the GDPR. Meta may

transfer conversion data to the USA under the EU–US Data Privacy Framework.

## 8. Your rights

You have the right to access, rectify, erase, restrict, object to, and port your

personal data, and to lodge a complaint with your supervisory authority.

## 9. Contact

Requests should be sent to the support email shown in the Service. We will respond

without undue delay and in any case within one month.