Privacy Policy

Effective from: 25 October 2026Version: 1.0

This Privacy Policy explains how the operator of the GrauTech Cleaner platform processes users’ personal data in connection with use of the web application available at https://vw40crashclear.com.

1. Data controller

Operator identification details are available on request at the contact email.

Contact email: [email protected]

2. Personal data we process

We process registration and account data, in particular first and last name, company name, email address, password in hashed form, country, billing details, company ID (IČO), VAT ID or VAT number, if provided by the User.

We process data about use of the Platform, in particular registration date, login date, login history, IP address, user agent, website language, actions performed in the account and audit logs.

We process job-related data, in particular the name of the uploaded file, file size, file hash, upload date, job status, job metadata, error logs, support notes and the output file.

We process payment data, in particular the selected credit package, payment amount, payment status, payment identifier from the payment gateway, payment date and billing details.

The Controller does not store full payment card data. Such data is processed by the payment gateway.

We process communications, in particular messages in the internal chat, email correspondence and information needed to resolve support or complaints.

We also process technical data, for example cookies, IP address, device type, browser, operating system, security logs and error information.

3. Data contained in uploaded files

The User acknowledges that uploaded files may contain technical data that in some cases may directly or indirectly relate to a specific vehicle, control unit, service job or the User’s customer.

The User is responsible for having the right to upload such a file to the Platform and for not infringing third-party rights or legal regulations.

Before uploading a file, the User must consider whether the file contains personal data or confidential third-party data.

4. Sign-in with Google

If the User signs in or registers using a Google account, we process data provided by Google to the extent necessary to create and manage the user account, in particular email address, name, profile identifier if applicable, and other data that Google passes during sign-in.

We use this data only to verify the User’s identity, create the account, sign in and secure the Platform.

Use of Google sign-in is also governed by Google’s privacy policy.

5. Purposes of processing

We process personal data to create and manage the user account, provide the digital service, process jobs and make results available.

We further process data to operate the credit system and payments, issue tax documents, fulfil accounting and tax obligations, customer support, internal chat and complaint handling.

We also use data for Platform security, protection against misuse, fraud, unauthorised access and technical incidents, maintaining audit logs, protecting legal claims, improving the Platform, error analysis, technical maintenance and marketing communications where there is a lawful basis.

6. Legal bases for processing

We process personal data on the basis of performance of a contract, in particular for registration, account operation, service provision, job processing, credit management and customer support.

Other legal bases include compliance with legal obligations, the Controller’s legitimate interests in Platform security, fraud prevention, log records, protection of legal claims, dispute resolution, service improvement and basic communication with customers, and consent where required.

7. Retention period

We retain user account data for the lifetime of the Account and thereafter for as long as necessary to protect legal claims or comply with legal obligations.

We retain payment, invoice and tax document data for the period required by law.

We retain job, file, result, log and support communication data for as long as necessary to provide the service, handle complaints, ensure security and protect legal claims.

We retain technical and security logs for a reasonable period according to their purpose.

When data is no longer needed, we delete or anonymise it.

8. Recipients of personal data

Personal data may be disclosed to the following categories of suppliers:

hosting and server infrastructure providers,

database providers,

cloud file storage providers,

payment gateway providers,

email service providers,

third-party authentication providers, for example Google,

security, logging and error-tracking tool providers,

accounting, tax and legal advisers,

public authorities where required by law.

Specific suppliers will be listed according to the Platform’s production configuration before launch of public paid operations.

9. Transfers outside the EU

Some suppliers may process personal data outside the European Union or the European Economic Area.

Where such transfers occur, they are carried out only with appropriate safeguards under the GDPR, for example standard contractual clauses or another lawful mechanism.

10. Cookies

The Platform uses essential cookies for sign-in, security, session management and core functionality. These cookies do not require consent.

With your consent, we use Google Analytics 4 (analytics) to measure traffic and the purchase journey, and Google Ads (advertising) to measure ad results and personalise ads. You give consent separately for analytics and for advertising in the cookie banner. The legal basis is your consent.

We use Google Consent Mode in advanced mode. The Google tag loads on every page, but until you give consent, analytics_storage, ad_storage, ad_user_data and ad_personalization are set to denied: no analytics or advertising cookies are stored, and Google receives only signals without cookie identifiers (for example event type, time, device and browser type and page address). Google uses them to estimate aggregate statistics.

If you arrive from a Google ad, the page address may contain an ad click identifier (gclid). Without advertising consent this identifier is not stored in cookies; it is only passed along in the URL when you move between pages.

On the first visit we store our own cookie vw40_acquisition (90 days) with the visit source: landing page, referring domain and campaign parameters (utm_*). It tells us which channel a registration or order came from. The ad click identifier (gclid) is stored in it only with your advertising consent. This data is not shared with third parties.

After you register we also store the cookie vw40_signup for up to 10 minutes with the sign-up method (email or Google). Your browser deletes it on the next page and sends only a general registration event to Google Analytics.

We do not send email addresses, file names, VINs or uploaded file contents to analytics or advertising systems. We measure only general events such as registration, completed upload, checkout start and purchase, including the order value.

The recipient of this data is Google Ireland Limited. Data may be transferred to the USA under the EU-US Data Privacy Framework or standard contractual clauses. Analytics data is kept in Google Analytics for no longer than 14 months.

Consent can be changed or withdrawn at any time using the cookie settings link in the footer.

11. User rights

Under the GDPR, the User has in particular the following rights:

right of access to personal data,

right to rectification of inaccurate data,

right to erasure where legal conditions are met,

right to restriction of processing,

right to data portability,

right to object to processing based on legitimate interests,

right to withdraw consent where processing is based on consent,

right to lodge a complaint with the Office for Personal Data Protection, Pplk. Sochora 27, 170 00 Prague 7, Czech Republic.

12. How to exercise your rights

You may exercise your rights by email at [email protected].

The Controller may request verification of the applicant’s identity to prevent unauthorised disclosure of data.

We respond to requests within the statutory time limit.

13. Data security

The Controller implements technical and organisational measures to protect personal data, in particular:

encrypted connection via HTTPS,

password hashing,

restricted access to administration,

logging of security events,

storing files outside the public web area,

user permission controls,

regular system maintenance.

Nevertheless, absolute security of transmission or storage of data on the internet cannot be guaranteed.

14. Automated decision-making

The Platform may automatically evaluate technical parameters of uploaded files for validation, security and job processing.

This evaluation is not used for decision-making that would produce legal effects concerning the User within the meaning of the GDPR, unless expressly stated otherwise.

15. Changes to this policy

The Controller may change this policy.

The current version will always be published on the Platform.

If a material change occurs, the User may be informed by email or notice in the Account.

16. Contact

For questions about personal data processing, contact us at:

[email protected]