Privacy Policy of the ECLI Application

Last updated: 10 August 2026 · Effective from: 10 August 2026 · Version: 1.0

Operator: Leseta s.r.o., Kukučínová 98/14, 040 01 Košice – mestská časť Juh, Slovakia
Company ID (IČO): 52764524 · Tax ID (DIČ): 2121132068 · VAT ID: SK2121132068
E-mail: info@ecli.cloud · Website: https://ecli.cloud

1. Operator

The operator of the ECLI mobile application (hereinafter referred to as the “Application”) is:

Business name: Leseta s.r.o.
Registered office: Kukučínová 98/14, 040 01 Košice – mestská časť Juh, Slovakia
Company ID No.: 52764524
Tax ID No.: 2121132068 · VAT ID: SK2121132068
E-mail: info@ecli.cloud
Website: https://ecli.cloud

(hereinafter referred to as the “Operator”).

This Privacy Policy explains what personal data the Operator processes, for what purposes, on what legal basis, how long it retains such data, to whom it may disclose such data, and what rights the user has under Regulation (EU) 2016/679 of the European Parliament and of the Council (“GDPR”) and the applicable laws of the Slovak Republic.

2. What Personal Data We Process

Depending on how the Application is used, we may process in particular:

2.1 User Account Data

first and last name, if provided by the user,
username or nickname,
e-mail address,
user account identifier,
data required for login,
data obtained through Google or Apple when using their login services,
profile photograph, if provided by the user.

2.2 Reservation Data

date and time of the reservation,
data about the reserved place or service,
reservation status,
data required for the execution and recording of the reservation.

2.3 Catch Data

In connection with a catch, we may process in particular:

photographs of the catch,
date and time of the catch,
weight,
length,
fish species,
data about the fishing lake or location,
data about repeated catches,
other data provided by the user.

2.4 Photographs

The Application allows the user to:

take a photograph using the device’s camera,
upload a photograph from the gallery,
upload a photograph from supported storage.

A photograph may contain a fish, the user, the user’s face, or other persons. If a natural person is identifiable in the photograph, the photograph may constitute personal data under the GDPR.

2.5 Technical Data

We may process:

IP address,
device type and model,
operating system,
Application version,
technical identifiers,
date and time of use,
system and error messages,
data required to secure the Application.

2.6 Payment Data

If payments are made through Stripe, the payment data required to complete the transaction are processed by Stripe. The Operator does not normally store complete payment card details.

3. Purposes of Processing

We process personal data in particular for:

creation and management of the user account,
authentication,
provision of Application features,
execution of reservations,
recording catches,
displaying photographs,
creating statistics,
creating rankings,
providing information about fish and fishing lakes,
processing payments,
communication with the user,
customer and technical support,
securing the Application,
prevention of fraud and misuse,
protection of the Operator’s rights,
development and improvement of the Application,
development and improvement of the system for recognizing individual fish.

4. Database of Individual Fish

One of the main purposes of the Application is to create and develop a database of individual fish. Based on photographs and catch data, the Application may create a historical record of a specific fish.

Such a record may contain, for example:

photographs,
catch dates,
weight,
length,
location,
historical records,
results of automated recognition,
technical data required for comparing photographs.

The purpose is to enable identification of the same individual fish at different points in time and to track its development. This may include, for example, tracking:

growth,
changes in weight,
changes in length,
stagnation in growth,
repeated catches,
historical development of a specific fish.

5. Development of the Fish Recognition System

Photographs and catch data may be used for the development, testing, validation, and improvement of technologies enabling automatic or semi-automatic recognition of specific fish.

This may include in particular:

comparison of photographs,
identification of similarities between photographs,
creation of a database of individual fish,
testing algorithms,
evaluation of identification accuracy,
improvement of algorithms,
creation of statistical models.

The purpose of the system is to identify a specific fish, not to identify a natural person depicted in the photograph. If the Operator uses technologies for automated image processing, the result of such processing may be used to create or update the record of a specific fish.

6. Photograph of the Angler

A photograph of a catch may contain the user’s face. The Operator generally does not process facial image data for the purpose of uniquely identifying the user. The user’s face may form part of a photograph of a catch as a natural visual component of the photograph.

If the Operator introduces technology intended to identify persons by their faces in the future, the user will be specifically informed about such processing and the Operator will ensure an appropriate legal basis.

7. Public Profiles and Rankings

If permitted by the features of the Application, the following information about the user may be publicly displayed:

nickname,
profile photograph,
photographs of catches,
catch data,
statistics,
results,
ranking position.

The scope of publicly displayed data will depend on the settings of the Application.

8. Sharing on Social Media

The user may voluntarily share a photograph of a catch directly from the Application to social media or other external services. When shared, the photograph may automatically be supplemented with the name, logo, or other designation of the Application. Sharing is initiated by the user. After the photograph is sent to a social media platform, further processing of the photograph is subject to the terms and privacy policies of the respective social media platform.

9. Legal Bases for Processing

The Operator processes personal data according to the specific purpose, in particular on the basis of:

a) Performance of a Contract
Article 6(1)(b) GDPR.

b) Compliance with a Legal Obligation
Article 6(1)(c) GDPR.

c) Legitimate Interest
Article 6(1)(f) GDPR.
This may include in particular:

securing the Application,
fraud prevention,
protection against misuse,
protection of legal claims,
security purposes,
development of technical solutions to the extent that such a legal basis is appropriate and lawful.

d) Consent
Article 6(1)(a) GDPR, where consent is required for the specific processing.

10. Long-Term Retention of Photographs and Catch Data

Given the purpose of the Application, it may be necessary to retain photographs and catch data on a long-term basis. The reason is that the system for recognizing individual fish uses historical photographs and data to identify the same individual fish in the future. Individual photographs may therefore remain valuable even many years after they were created.

The Operator may retain photographs and catch data even after cancellation of the user account if there is a legal basis for their further processing. Where technically possible and appropriate, data that are no longer required to identify the user may be separated, pseudonymized, or anonymized.

11. Account Cancellation

Cancellation of the user account may not automatically result in the deletion of all photographs and historical catch data. The data may be retained to the extent necessary for:

preserving the historical record of a specific fish,
development and improvement of the recognition system,
preservation of historical statistics,
protection of legal claims,
compliance with legal obligations.

If further retention of specific personal data is no longer legally justified, the Operator will take appropriate measures to delete, anonymize, or pseudonymize such data.

12. Retention Period

User account data: for the duration of the account.
Reservation data: for the period necessary for their recording, handling of complaints, and protection of legal claims.
Accounting data: for the period prescribed by law.
Technical and security data: for the period necessary for the secure operation of the Application.
Photographs and catch data: on a long-term basis, including the period after cancellation of the account, if their further retention and processing have a legal basis and are necessary for the purposes set out in this Policy.

13. Recipients of Data

Personal data may be disclosed in particular to:

hosting providers,
cloud providers,
IT providers,
database providers,
security service providers,
analytics service providers,
Stripe,
Google,
Apple,
e-mail service providers,
legal and accounting advisers,
public authorities, where required by law.

Where a recipient acts as a processor, the Operator will ensure that an appropriate agreement is in place pursuant to Article 28 GDPR.

14. Transfers Outside the EU/EEA

Where personal data are transferred outside the European Economic Area, the Operator will ensure appropriate safeguards under the GDPR, such as an adequacy decision or standard contractual clauses.

15. User Rights

Under the GDPR, the user has in particular the right:

of access,
to rectification,
to erasure,
to restriction of processing,
to data portability,
to object to processing,
to withdraw consent,
to lodge a complaint with a supervisory authority.

These rights may be restricted in cases provided for by applicable law.

16. Security

The Operator takes appropriate technical and organizational measures to protect data against unauthorized access, loss, destruction, damage, or misuse.

17. Permissions

The Application may request:

camera access,
access to photographs,
access to storage,
internet connection,
notifications.

Each permission is used to the extent necessary for the relevant feature.

18. Minors

The Application is not intended for persons under the age of 16 without the appropriate consent of a parent or legal guardian to the extent required by applicable law.

19. Changes to the Policy

The Operator may amend or update this Policy. The current version will be available in the Application and/or on the Operator’s website.

20. Contact

Leseta s.r.o.
Address: Kukučínová 98/14, 040 01 Košice – mestská časť Juh, Slovakia
E-mail: info@ecli.cloud

21. Supervisory Authority

The user has the right to lodge a complaint with the Office for Personal Data Protection of the Slovak Republic.

22. Effective Date

This Policy shall enter into effect on 10 August 2026.