Privacy Policy

1. Who we are (data controller)

The controller of personal data within the meaning of Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”) and Act No. 18/2018 Coll. on the Protection of Personal Data of the Slovak Republic is:

We have not appointed a Data Protection Officer, as we are not required to do so under Article 37 GDPR. For any privacy-related question you can contact us at the e-mail address above.

2. Scope

This Privacy Policy applies to:

• the website ml-code.eu and its sub-pages (the “Website”), and
• mobile applications published by ml-code s.r.o. on the Apple App Store, Google Play or other distribution platforms (the “Apps”), unless a specific App provides its own privacy policy that says otherwise.

3. Website: what data we process

3.1 No cookies, no analytics, no tracking

The Website is a static informational site. It does not set cookies or use similar technologies (local storage, pixels, fingerprinting), does not embed third-party analytics, advertising or social-media scripts, and does not contain contact forms. Fonts and all other assets are served from our own domain, so visiting the Website does not cause your browser to contact third-party services. For this reason no cookie consent banner is displayed — there is nothing to consent to.

3.2 Server log files

Like every website, the Website is delivered by a web server, operated for us by our hosting provider WebSupport, s.r.o. (Slovakia, EU). The server automatically records technical access data in log files: IP address, date and time of the request, requested URL, HTTP status, amount of data transferred, referrer and browser/operating-system identification (user agent).

• Purpose: technical delivery of the Website, ensuring security and stability, detecting and investigating abuse or attacks.
• Legal basis: Article 6(1)(f) GDPR — our legitimate interest in operating a secure and functioning website.
• Retention: log files are kept only for the period configured by the hosting provider for security purposes (typically a few weeks) and are then deleted or anonymised. We do not use them to identify or profile visitors.

3.3 When you contact us

If you contact us by e-mail or phone, we process the personal data you provide (name, e-mail address, phone number, company, and the content of your message) in order to respond to your enquiry and, where relevant, to prepare an offer or conclude and perform a contract.

• Legal basis: Article 6(1)(b) GDPR (steps prior to entering into a contract / performance of a contract) and Article 6(1)(f) GDPR (our legitimate interest in handling business communication).
• Retention: for as long as necessary to handle your enquiry and any subsequent business relationship, and thereafter for the period required by statutory retention obligations (e.g. accounting and tax law, up to 10 years for accounting documents) or the limitation periods for legal claims.
• Providing data is voluntary; without it we simply cannot respond to you.

4. Mobile applications

Unless stated otherwise in the App Store / Google Play listing or inside a specific App, our Apps are designed according to the principle of data minimisation:

• Our Apps do not require registration and do not collect, transmit or store personal data on our servers. Any data you enter into an App stays on your device (and, if enabled by you, in your personal iCloud / Google backup, which is governed by Apple’s or Google’s privacy policy).
• Our Apps do not contain third-party advertising SDKs and do not sell or share personal data.
• Apple and Google may provide us with aggregated, anonymised statistics (e.g. number of downloads, crash reports) that we cannot link to individual users. Their processing is described in Apple’s and Google’s own privacy policies. Crash reports are used solely to fix defects (legitimate interest, Article 6(1)(f) GDPR).
• If a particular App needs additional data (for example an optional account, notifications, purchases or location), the App will inform you before such processing starts and, where required, ask for your consent which you can withdraw at any time. The specific details will be listed in that App’s store listing and in an App-specific privacy notice referenced from this page.
• Requests to delete data associated with an App can be sent to info@ml-code.eu; where no data is stored by us, deleting the App from your device removes all data.

5. Recipients of personal data

We do not sell personal data and do not transfer it to third parties for their own purposes. Data may be processed on our behalf by carefully selected processors bound by data-processing agreements under Article 28 GDPR: our web-hosting and e-mail provider (WebSupport, s.r.o., Slovakia) and, where applicable, our accounting provider. Personal data may be disclosed to public authorities only where required by law.

6. International transfers

Personal data is stored within the European Union / European Economic Area. If an App is distributed via the Apple App Store or Google Play, Apple Inc. or Google LLC act as independent controllers for the purchase and distribution process; any transfer they perform is covered by their own safeguards.

7. Your rights

Under the GDPR you have the following rights, subject to the conditions set out in the Regulation:

• the right of access to your personal data (Article 15);
• the right to rectification (Article 16) and erasure (“right to be forgotten”, Article 17);
• the right to restriction of processing (Article 18);
• the right to data portability (Article 20);
• the right to object at any time to processing based on our legitimate interests (Article 21), including direct marketing (which we do not carry out);
• the right to withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing before withdrawal (Article 7(3));
• the right not to be subject to automated decision-making, including profiling (Article 22) — we do not carry out any.

To exercise your rights, write to info@ml-code.eu. We will respond without undue delay and at the latest within one month; this period may be extended by two further months where necessary, taking into account the complexity and number of requests.

You also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or place of the alleged infringement. The supervisory authority in Slovakia is: Office for Personal Data Protection of the Slovak Republic (Úrad na ochranu osobných údajov SR), Hraničná 12, 820 07 Bratislava 27, Slovakia, dataprotection.gov.sk.

8. Security

We apply appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access — including transport encryption (HTTPS/TLS) on the Website, access controls and the principle of data minimisation.

9. Children

The Website and our Apps are not directed at children under 16 and we do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.

10. Changes to this policy

We may update this Privacy Policy from time to time, for example when we publish a new App or when the law changes. The current version is always available at https://ml-code.eu/privacy/ together with the date of the last update.