Privacy and Cookie Policy

Effective from 11 September 2026

Version: 2026-09-11

1. Who processes the data

The operator of the Sentioo system and the controller of personal data for the purposes described below is Mentioo s.r.o., Company ID 23605740, with its registered office at Újezdská 272/1, Újezd, 312 00 Pilsen, registered in the Commercial Register maintained by the Regional Court in Pilsen under file no. C 47133 (“Mentioo”).

General contact: info@sentioo.cz
Privacy and exercise of rights: gdpr@sentioo.cz
Complaints about the technical service: reklamace@sentioo.cz

This Policy applies to the central website, administration interface, customer accounts and the sales websites of individual projects technically operated within Sentioo.

2. When Mentioo is the controller and when the Seller is the controller

Mentioo acts as an independent controller in particular when managing its own user and Seller accounts, securing the Service, managing Plans and fees, complying with legal obligations, providing technical support, defending legal rights and measuring its own website traffic.

The Seller identified for a particular project or offer is the independent controller of the data of its customers and prospects where the Seller determines the purposes of processing—for example in connection with sales, teaching, educational records, marketing, communications or a custom assignment. Mentioo processes such data on the Seller’s behalf as a processor under Schedule 1 to the Terms of Service.

A request relating exclusively to a purchase, teaching or marketing by a particular Seller should also be addressed to that Seller. Mentioo will forward the request where appropriate and provide technical assistance. Information about the Seller and its own privacy policy is available on its sales website or in the order.

3. What data we process

• Account and identity: name, email address, securely hashed password, photograph, language, account status, roles, team memberships, notification settings, two-factor authentication and an identifier for a connected account.
• Seller data: company name or personal name, date of birth, registered office or address, company ID, VAT ID, tax residence and status, bank and billing details, contact details, Project, domain, Plan and connected payment-account data.
• Orders and payments: items, prices, currency, discounts, taxes, billing details, payment status, Stripe identifiers, refunds, complaints, disputes, documents and records of accepting terms and immediate access. Sentioo does not store the complete payment-card number or CVC.
• Education and performance: course enrolment, learning progress, test answers, results, notes, certificates, participation, attendance, bookings, waiting lists, subscriptions, downloads and access to content.
• Communications and community: messages, attachments, discussions, live-stream chat, reviews, ratings, content reports, forms, support requests and related metadata.
• User Content: courses, lessons, products, files, photographs, audio and video, websites, blogs, email templates and other content created by a User.
• Custom assignments: questionnaire responses, source materials, attachments, revisions, deliverables, deadlines and an audit trail. We process special-category data only in a field expressly designated as sensitive by the Seller and subject to separate explicit consent or another valid legal basis.
• Technical and security data: IP address, user agent, device, request time and path, session and security identifiers, login records, change audits, use of APIs and webhooks, errors and security events.
• Integrations: connected-account designation, email address or account name, permission scope, encrypted access and refresh tokens and their validity, synchronisation metadata and identifiers of objects created or selected by the User.
• Marketing and analytics: consent, opt-out, traffic source, a pseudonymous visitor identifier and website events; optional marketing data only with consent or under the statutory regime for existing customers.

4. Where we obtain data

We obtain data directly from the User, the Seller and members of its team; automatically when the Service is used; from connected services at the User’s direction; from Stripe during payment and account verification; and from other persons, for example where a Seller enrols a participant or a User sends an invitation. We may verify business and tax details against public registers, ARES or VIES.

5. Purposes and legal bases

• Contract and steps before entering into a contract: registration, login, Plan, sales website, order, payment, access, teaching, communications, support, exports and selected integrations; Article 6(1)(b) GDPR.
• Legal obligation: accounting and tax records, cooperation with authorities, records of consents, consumer protection, the DSA, P2B Regulation, DAC7 where applicable and other legal obligations; Article 6(1)(c) GDPR.
• Legitimate interests: security, prevention of fraud and misuse, auditing, limited operational statistics, defence of legal rights, improvement and stability of the Service and reasonable customer communications; Article 6(1)(f) GDPR. You may object to such processing.
• Consent: optional analytics and marketing technologies, certain commercial communications, display of external-calendar details and specified processing of special categories of data; Article 6(1)(a) and, where applicable, Article 9(2)(a) GDPR. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.
• Protection of rights and safety: exceptionally, protection of vital interests or the establishment, exercise or defence of legal claims under the relevant provisions of the GDPR.

Where Mentioo acts as a processor, it follows the Seller’s documented instructions; the Seller, as controller, is responsible for the legal basis in relation to the customer.

6. Retention periods

• We retain an account and ordinary operational data for the duration of the account. When a Seller terminates the Service, a 30-day export period follows, after which we delete or anonymise the data unless another legal basis requires retention.
• When a Customer asks us to close an account, we remove connected identities, the current billing profile, cart and authentication data, and anonymise the account. Accounting records, orders, documents, consents and necessary transaction snapshots remain subject to restricted retention.
• We retain accounting and tax documents for the period required by applicable legislation, typically 5 or 10 years depending on the type of document and tax status.
• We retain records required for contractual claims for the ordinary limitation period, generally 3 years after the relationship ends, and longer while a dispute is pending.
• We retain security, access and audit records for a period proportionate to the risk and the need to investigate an event; ordinary records should be deleted no later than 12 months afterwards unless the law or a specific incident requires longer retention.
• We delete responses and input files for a custom assignment 12 months after its completion or closure. The completed deliverable remains in the Seller’s storage according to the Seller’s instructions and Plan; the audit trail may be retained to protect legal rights.
• We retain records of marketing consent and opt-out for the period of their validity and subsequently for as long as necessary to demonstrate lawfulness and honour the opt-out.
• We delete or invalidate OAuth tokens when an integration is disconnected. Operational metadata for created meetings, events or imports may remain with the related content or order.
• Backups are separated from ordinary operations, used only for restoration and deleted by overwriting in the configured rotation cycle. Recorded deletion requests are reapplied following restoration.

7. Recipients and other processors

We disclose data only to the extent necessary:

• the Seller and its authorised team for the order, teaching, support and other purposes determined by the Seller;
• Hetzner Online GmbH, Germany – production server and storage infrastructure at an EU location selected by Mentioo;
• Stripe Payments Europe, Ltd., Stripe Technology Europe, Ltd. and related Stripe companies – payment services, Stripe Connect, verification, fraud prevention, refunds and disputes; depending on the operation, Stripe may act as a processor or independent controller;
• a contracted email-infrastructure provider – delivery of operational and transactional messages;
• Google Ireland Limited / Google LLC – optional login and integrations, Google Analytics, Google Tag Manager, Google reCAPTCHA, Google Drive, Calendar, Meet and YouTube;
• Microsoft Ireland Operations Limited / Microsoft Corporation – optional login and the Microsoft 365 calendar;
• LinkedIn Ireland Unlimited Company and Meta Platforms Ireland Limited – optional login and, where applicable, LinkedIn or Facebook features and Facebook Live;
• Dropbox International Unlimited Company – optional import from Dropbox;
• Zoom Video Communications, Inc., Vimeo.com, Inc., Twitch Interactive, Inc. and the operator of the selected CalDAV server – only where the relevant meeting, stream, video, storage or calendar is used;
• SmartEmailing or another marketing service connected by the Seller – only according to the Seller’s settings and recorded marketing authorisation;
• content-delivery-network and web-library providers, including Cloudflare/CDNJS, jsDelivr, unpkg, Google Fonts and jQuery CDN – technical delivery of web resources; they may receive the IP address and technical data when a request is made;
• accounting, legal and security advisers bound by confidentiality, and public authorities where required by law.

The involvement of other processors may change as features become available. We notify the Seller in advance of a material change concerning data processed for that Seller in accordance with the data-processing agreement.

8. Transfers outside the European Economic Area

Core production data is intended to be stored with Hetzner at the selected EU location. Some integration providers are global and may also process data outside the EEA, particularly in the United States. Transfers rely on a European Commission adequacy decision, including the EU–US Data Privacy Framework for a certified recipient, Standard Contractual Clauses or another valid mechanism under Articles 44 to 49 GDPR. Supplementary contractual and technical measures are applied according to the risk.

Where a Seller connects its own account with an external service, the Seller also decides to use that provider and must assess its terms, processing location and the lawfulness of the transfer for the Seller’s purposes.

9. Login using social and work accounts

External login is optional. It is used only to verify access, create or connect an account and protect against duplicates. Sentioo stores an internal link to the provider and its identifier; when creating a new account, it may download and store the profile photograph locally.

• Google: email and profile permissions; we receive the Google account identifier, name, email address, email-verification status and available profile photograph.
• LinkedIn: openid, profile and email; we receive the OIDC sub identifier, name, email address, its verification status and an available photograph. LinkedIn login is not official identity verification.
• Facebook: email and public_profile; we receive the Facebook ID, name, available email address and profile photograph.
• Microsoft: openid, profile, email and User.Read; we receive the account ID, display name, email address or user principal name and available profile photograph.

During login, the provider receives technical request data and information that you are using its login. You may ask Sentioo support to remove the internal link and revoke the permission in the provider’s settings at the same time. Removing the link or the permission at the provider does not itself delete the Sentioo account.

Use of an external account is also governed by the provider’s terms and policies: Google Terms and Google Privacy Policy, the LinkedIn User Agreement and LinkedIn Privacy Policy, the Meta/Facebook Terms and Meta Privacy Policy, and the Microsoft Services Agreement and Microsoft Privacy Statement.

10. Google API and the Limited Use policy

A Google account can be connected separately for each purpose. Login authorisation is not used as authorisation for Google Drive, Calendar, Meet or YouTube. Sentioo uses information received from Google APIs only for the feature requested by the User, does not sell it, does not use it for targeted advertising and does not allow human access except as necessary for security, support with the User’s consent or a legal obligation.

Sentioo’s use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including its Limited Use requirements.

11. Cloud storage

Cloud storage is connected only at the Seller’s request. For Google Drive, Sentioo gains access only to files that the Seller expressly makes available through Google Picker. For Dropbox, it may load metadata across the connected account in order to display and search for files; content is downloaded only for files selected by the Seller for import. A separate copy is then stored in Sentioo’s media library and is not automatically deleted when the integration is disconnected.

• Google Drive: openid, email, profile and drive.file. The Seller selects a file in the official Google Picker. The drive.file permission applies only to files expressly made available to the application; Sentioo uses them solely to read metadata and content during the import process. It does not browse the entire Google Drive and does not create, modify or delete files there.
• Dropbox: the application uses Scoped access with Full Dropbox access and the account_info.read, files.metadata.read and files.content.read permissions. Sentioo loads the basic account designation, may recursively display and search file and folder metadata throughout the connected Dropbox and downloads content only for files selected by the Seller for import. It does not request write permission and does not create, modify or delete files in Dropbox.

Access and refresh tokens are encrypted in the database. The User may disconnect an integration at any time; Sentioo deletes the tokens stored in its database. Permissions may also be revoked directly with the provider. Disconnecting does not delete copies of files already imported into Sentioo.

External storage is also governed by the provider’s rules, including the Google and Microsoft terms linked above and the Dropbox Terms, Dropbox Privacy Policy and Dropbox Developer Terms.

12. Calendars, meetings and live streaming

• Google Calendar: calendar.calendarlist.readonly for the list of calendars and calendar.events to read availability and create, modify or delete events according to the User’s settings.
• Microsoft Calendar: openid, profile, email, offline_access, User.Read and Calendars.ReadWrite.
• CalDAV/iCloud: server URL, username and app-specific password. The password is encrypted. By default, synchronisation stores times and availability; titles and descriptions are stored only when details are enabled. When details are disabled, previously stored titles and descriptions are removed during subsequent synchronisation processing.
• Google Meet: openid, email, profile and meetings.space.created; creation, modification and reading of metadata only for Meet spaces created by Sentioo. The permission does not include general access to the calendar, recordings or Drive.
• Zoom: user:read:user, meeting:write:meeting, meeting:update:meeting and meeting:delete:meeting; account designation and creation, modification or cancellation of a meeting created by Sentioo. Sentioo does not read other meetings or recordings.
• YouTube: openid, email, profile and youtube.force-ssl; identification of the connected channel and creation, modification, connection or deletion of live broadcasts and streams at the User’s express direction. Sentioo does not use this permission to manage ratings, comments, captions or other videos.
• Twitch: user:read:email; account and email designation for connecting a streaming account.
• Facebook Live: pages_show_list, business_management, pages_read_engagement and pages_manage_posts; list of managed Pages, their designation, and creation or management of live video on the selected Page. We use business_management only to locate Pages that the User expressly assigned through a business portfolio and to obtain access to the selected Page; we do not manage ad accounts or other business assets. We use pages_read_engagement only for Page identification and basic metadata required by the Pages API; we do not read Page posts or comments. The integration uses a separate Meta application with the Live Video API feature and does not request permission to publish to a personal timeline.
• Vimeo: private, upload, edit, create and stats; connection of the account, import or upload of a video and its technical management at the Seller’s direction.

We store OAuth tokens and app-specific passwords in encrypted form. We make meeting or broadcast links and identifiers available to the Seller and authorised participants. When disconnected, we delete credentials and the synchronisation cache; objects previously created with the provider may remain and are managed by the User directly with that provider.

13. Artificial intelligence

The Senti assistant uses OpenAI's API. In the public area, the provider receives the question, Sentioo's public knowledge base and a limited conversation context. In a lecturer account, at the User's request, it may also receive only the data necessary for the answer and available to that User's role, especially aggregate order counts and amounts, mentoring times and setup or connection status. We do not send passwords, OAuth tokens, secret keys, complete payment-card data or content obtained from Google APIs.

API requests disable provider storage of the response object; the provider's API rules may nevertheless apply to technical and security logs. Sentioo stores conversation text locally for continuity for no more than 30 days in the public area and 180 days in a lecturer account. A public answer may be cached for no more than 24 hours. Separate usage and tool-audit records do not contain the question text, credentials or tool output.

Senti is used to provide a feature expressly requested by the User, for security, limit enforcement and troubleshooting. Sentioo does not use conversations for advertising or to train its own models. The User must not enter sensitive or confidential data that is unnecessary for the question and must verify an answer before relying on it.

Sentioo does not carry out automated individual decision-making with legal or similarly significant effects, or profiling for such decision-making.

14. Cookies and similar storage

We use essential cookies and local storage for login, security, the cart and features expressly requested by the User. Consent is not required for these because the requested Service cannot be provided securely without them. Analytics and marketing technologies are enabled only after freely given consent. Refusal does not affect core features.

Name / technology	Purpose	Duration	Category
PHPSESSID	Login and session state	Until the session/browser is closed	Essential
_nss	Form protection and session verification	Session	Essential
mentioo_cart_guest_*	Assigning a guest cart to a specific Project	30 days or until emptied/login	Essential
sentioo_cookie_consent_v1 and Project variants (localStorage)	Storing privacy choices	180 days	Essential
sentioo_view_visitor_token (localStorage)	Pseudonymous first-party view statistics	180 days	Analytics
_ga, _ga_* and, where applicable, _gid	Google Analytics – traffic measurement	According to Google settings, usually up to 2 years; _gid usually 24 hours	Analytics
Google Tag Manager and tags enabled through it	Campaign evaluation and marketing integrations	According to the specific tag identified in the consent settings	Marketing
Temporary sessionStorage	Draft notes and the state of certain interfaces	Until the tab is closed	Functional / essential

In a testing or development environment, an authorised developer mode may use the diagnostic tracy-session cookie; it should not be active on the public production service.

A Seller’s own sales website may use the Seller’s GA4 identifier. In that case, the Seller determines the purpose of its analytics and must describe them in its own policy. The central website may use Google Tag Manager after marketing consent; individual tags must not be triggered contrary to the stored choice.

You can change your choice at any time using the “Cookie settings” link in the footer. When consent is withdrawn, we stop further optional measurement, delete our own analytics identifier and attempt to remove known first-party cookies. Third-party cookies can also be removed in the browser. We request your choice again after 180 days.

15. reCAPTCHA and external content

Google reCAPTCHA protects the registration form against automated abuse. It is loaded only when a protected form is submitted, as an essential security measure. Google may receive the IP address, device data, interaction behaviour and its own cookies. If you do not wish to use reCAPTCHA or it does not load, contact us for a reasonable alternative procedure.

Embedded players, maps, video conferences or other Seller content may, when loaded, transfer technical data to the relevant provider and be governed by its cookies and terms. Where the nature of the feature permits, we activate external content only following an action by the User; the Seller is responsible for lawful embedding and information relating to its own content.

16. Commercial communications

Operational messages necessary for an account, order, security or contractual changes are not marketing and cannot be disabled if the Service is to function. We send Mentioo’s own marketing with consent or under the statutory regime for similar services to existing customers, with a simple means of opting out.

Marketing by a particular Seller is controlled by that Seller as controller. Sentioo transfers a name, email address and selected order or event data to a connected marketing service only according to the Seller’s settings and where an authorisation has been recorded. Consent may be withdrawn using the link in the message or by contacting the Seller.

17. Security

We use measures appropriate to the risk, including HTTPS, secure password hashing, encryption of OAuth tokens, app-specific passwords and designated sensitive responses, multi-factor authentication, segregation of Project data, roles and access restrictions, protection against CSRF and automated abuse, audit records, updates, backups and incident management. Not all ordinary database data is individually encrypted; it is protected by the infrastructure, access controls and other layers.

No service is absolutely secure. Users must protect their password, device, API keys and connected accounts and report an incident to info@sentioo.cz.

18. Your rights

Depending on the circumstances, you have the right to access your data and obtain a copy, rectification, erasure, restriction of processing, data portability, objection to processing based on legitimate interests, withdrawal of consent and the right not to be subject to solely automated decision-making with significant effects. You also have the right to know the source and recipients of the data.

Send your request to gdpr@sentioo.cz. We may reasonably verify your identity. We respond without undue delay, normally within one month; for a complex case, the period may be extended under the GDPR. The right to erasure is not absolute, particularly for statutory records, the protection of legal rights and data required to complete a contract.

You may lodge a complaint with the Czech Office for Personal Data Protection, Pplk. Sochora 27, 170 00 Prague 7, uoou.gov.cz. We would appreciate the opportunity to address your concern first, but this is not a condition.

19. Children

A Seller account is intended for persons aged 18 and over. A Customer under 15 may use Sentioo only through or with the consent of a parent or guardian. A User aged 15 to 18 may use the Service independently only to the extent appropriate to their age and legal capacity. We do not carry out marketing profiling of persons whom we know to be minors.

20. Changes to this Policy

We may update this Policy when the law, Service, processing or providers change. We will announce a material change in an appropriate manner before it takes effect and request fresh consent where processing relies on consent and the change goes beyond its original scope.

This Policy is effective from 7 September 2026.