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Privacy Policy

1. Introduction

This Privacy Policy (“Policy”) describes the different ways Mirrana corp.s.r.o. (“we”, “us”, “our”, “Company”) may collect, use, and share information obtained when you interact with the website (the “Website”) and use Website services (the “Services”), or provide us with information about yourself via email, video call, voice call, or in any other way. Such treatment may include, but is not limited to, the following:

●     collection

●     recording

●     organization

●     storage

●     structuring

●     adaptation

●     alteration

●     retrieval

●     consultation

●     use

●     disclosure by transmission

●     dissemination or otherwise making available

●     alignment or combination

●     restriction

●     erasure or destruction

You can be our unregistered user (“visitor”) or registered user (“user”) (collectively “users”):

●     You are a visitor when you merely browse this Website and/or submit your personal data via email at;

●     You become a user when you submit your personal data through a registration form on the Site to obtain Services from us through an account on our Website.​​

When you submit your personal data to us, you may be asked to consent to our processing of the personal data you provide, as explained in this Policy, to enable us to provide you with the information or Services requested, if no other legal ground can be used.

2. Definitions

We use the following definitions in this Policy:

“data controller” means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data is processed.

“data processor” means the natural or legal person who processes personal data on behalf of the data controller.

“data subject” is any living individual who is using our Website and/or Services.

“personal data” means any information relating to you and helping identify you (directly or indirectly) such as your name, last name, email, location data, etc.

“processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

The definitions of terms used within this Policy are taken from the GDPR considering the definitions established in the CCPA. The pair of definitions “personal data” and “personal information”; “controller” and “business”; “processor” and “service provider”; “data subject” and “consumer” may be used interchangeably unless another meaning is mentioned.

3. Data Collection

We act as a controller in relation to the different categories of personal data.

We collect the information through our Website and email and process it as a data controller. In particular, we collect the following:

Visitor data:

(a) Contact Information. We can collect some personal data when you submit your personal data via email to contact and/or provide feedback on our website or Services. Such data may include name, email, phone number, and other information you may provide us via available contact options.

(b) Cookies Information. On our Site, we may use cookies and other tracking technologies for various purposes: for analytics, marketing activities, remembering your preferences, and other purposes. Such use may involve transmitting information from us to you and from you to a third-party website or us. To learn more regarding our use of cookies, please see our Cookie Policy.

User data:

(c) Registration Information. When you create an account, we collect certain information about you that allows us to provide you with the services requested: first name, last name, date of birth, country, city, and email address. You must enter this information yourself to create an account.

We also collect additional information you share with us when you complete your profile. This information includes: eyes color, hair color, marital status, children number, information about your habits, like smoking and drinking, your physique, weight, zip information, your phone number, address information, your messenger account information, and other information you provide us when you complete your profile.

During the registration process and while updating your profile, you may provide us with personal information that is considered “sensitive” in your jurisdiction. You may change, update or delete your information by accessing your profile anytime. We can collect that information only in case of your consent

(d) Automatically Collected Information. When you use our Website, we collect certain information about you and your device automatically, including device IP, current time, your location, and time zone.

(e) Service Usage Information. We may collect some information about your activities related to the usage of our Services, such as customer lifecycle costs, average order value, information that you upload to the site, like your photos, your description in the "About Me" section, video broadcasts and other information you uploaded.

Furtherly, we store information about the settings of your profile, for example, the interface language, your notification settings, the visibility settings of your photos and, finally, we store your contact list, chat history, a list of selected and ignored users, ratings, messages you send and receive, and other information about the actions you take on the site in order to provide you with the best experience of using our service.

We DO NOT sell your data. We DO NOT use automated decision-making and profiling.

We DO NOT intentionally collect and process any sensitive personal data. Please, refrain from sharing your or third-party sensitive personal data with us.

4. Grounds for processing

We collect and process your personal data in accordance with the provisions of the GDPR.

GDPR provides an exclusive list of lawful bases allowing us to process your personal data. During personal data processing, we rely only on four of them, namely:

Article 6.1(a): consent

We collect the information you choose to give us, and we process it under your consent. You may withdraw your consent to the processing of your personal data at any time.

Please remember that the withdrawal of consent does NOT automatically mean that the processing before the withdrawal is considered unlawful. You may withdraw the consent to the processing of your personal data by sending us an email at or by contacting us in any other way convenient for you.

Article 6.1(f): legitimate interests

We process your personal data to prevent any fraudulent actions and to provide you with the desired services. Also, we need some of your data to enable our Site to run smoothly and give you a pleasant user experience. We use only strictly necessary data under this legal ground.

Article 6.1(b): performance of a contract

When you provide a third-party payment processor with the personal data with requested banking information to purchase services, this can be deemed as your request to form a contract or to perform a contract between you and us. However, we may ask you to give us clear consent in case of doubt.

Article 6.1(c): legal obligation

We process your personal data to fulfill the applicable legal obligations arising mainly from the GDPR. In the event of you sending us the request to fulfill the rights granted by the GDPR, we may ask you for some personal data we already have to identify you and achieve compliance with the applicable law.

5. Use of Your Personal Data

As a data controller, we use your personal data for the purposes listed in the table below, where we also detail the type of personal data processed, legal bases we rely on to do so, third parties with whom we may share your personal data:


Purposes Type of personal data Legal grounds Third Parties recipients
Creating an account in the Website Registration information

Performance of a contract (Article 6(1)(b))

Your consent (Article 6(1)(a))

Maintenance of the account in the Website

Service usage information

Automatically Collected Information.

Performance of a contract (Article 6(1)(b))

Our legitimate interest (Article 6(1)(f))

Ensuring the security of the Users and the Platform

Service usage information

Automatically Collected Information.

Our legitimate interest (Article 6(1)(f)) None
Communication with visitors and customers Contact Information Your consent (Article 6(1)(a)) None
Marketing (to suggest and notify you about news of our Website)

Contact Information

Cookies Information

Your consent (Article 6(1)(a)) None
Analytics and developing (for optimising and improving our Website)

Contact Information

Cookies Information

Automatically Collected Information

Your consent (Article 6(1)(a))

Our legitimate interest (Article 6(1)(f))

Google Analytics
Complying with the law or legal process

Contact Information

Cookies Information

Automatically Collected Information

Legal obligation (Article 6(1)(c))

Our legitimate interest (Article 6(1)(f))

Delivering relevant interest-based advertising to you on third-party websites Cookies Information Your consent (Article 6(1)(a)) Our legitimate interest (Article 6(1)(f)) Google Tag Manager Cookie Providers

6. Use of cookies

We use cookies and other tracking technologies on our Website for a number of purposes, including enabling the functionality of the Website, enhancing user experience, understanding the online behavior of people who interact with our Site and delivering relevant interest-based advertising to you on third-party websites.

We do not use cookies to identify you directly. We only use cookies for the following purposes:

Necessary: these cookies and other tracking technologies are essential for your use of the Website and our compliance with applicable data protection laws. We can use them to provide the basic functions of the website.

Preferential: these cookies enable our Website to remember choices that you make, i.e., to optimise the chatbot functionality or language choices.

Analytics: these cookies help us to understand how users interact with our Website (e.g., page visits and page load speed) by collecting information anonymously to avoid your identification. Their sole purpose is to improve website functions.

Marketing: these cookies and other tracking technologies are used to deliver relevant online advertising to you on other websites. These cookies are placed by us and selected third parties and enable adverts to be presented to you on third-party websites.

To learn more about cookies, please read our Cookies Policy.

7. Data Security, Integrity, and Retention

As a data controller, we store and process your personal data until we do not need it for any of the purposes defined in this Policy unless longer storage is required or expressly permitted by law. Usually, we retain your data while your account is actively used, but we will delete your personal data if we notice that you have not used your account for a long time or if you ask us to delete your personal data. Some categories of data can be stored for a shorter time: for example, cookies expire in a few days, weeks, or months as they are programmed to (or earlier if you clean your browser’s cache).

Please notice that we may retain your personal data for a longer time if there is a legal obligation to do so or if we need it to defend a legal claim or otherwise participate in a legal proceeding. We will apply suitable safeguards to ensure that your data is secure and delete your data once we do not need it anymore.

Despite any of the aforementioned periods of data storage, you may request to delete your personal data or send any other data subject request by sending us an email at or contacting us via another way convenient for you.

We have implemented appropriate organisational, technical, administrative, and physical security measures that are designed to protect your personal data from unauthorised access, disclosure, use, and modification. We regularly review our security procedures and policies to consider appropriate new technology and methods.

8. Data Sharing and Disclosure

We may share your personal data as a data controller to joint controllers and data processors in accordance with the provisions specified hereafter.

Sharing data with data processors

There are many features necessary to provide you with access to our Website that we cannot complete ourselves, thus, we seek help from third parties. We may grant some service providers access to your personal data, in whole or in part, to provide the necessary services.

Therefore, we may receive your data from or share and disclose your personal data to our data processors:

● Google Analytics (Google LLC, USA): to analyse statistical data on how the visitor uses the Website in order to improve our Website’s functionality, to improve advertisement campaigns. You may read Google LLC’s Privacy Policy here.

● During our business activities, we may engage different specialists which may receive your personal data, including technical, sales, and marketing specialists, to provide you with better customer service. Also, we may disclose some of your personal data to our outsource legal and accounting professionals to make our business accurate and transparent. The abovementioned specialists are collectively referred to as Contractors.

We also work with Traforce to promote the services of our Company and enhance our website visiting rate. However, we do not receive your IP addresses or other personal data from them: we can only see the statistical information in the aggregated form in our account with Traforce.

We may transfer your personal data to countries outside the EU and EEA (for example, the USA) that are not determined to offer an adequate level of data protection on the basis of article 45 of GDPR (adequacy decision) with appropriate safeguards as determined under the GDPR.

We only transfer your personal data to third parties within the requirements under the GDPR. Where possible and necessary, we always enter into Data Processing Agreements (DPAs) and Non-Disclosure Agreements (NDAs) with them and treat personal data transfer seriously. Where the Contractor has an appropriate data processing agreement in place, Company may adjoin such data processing agreement. If so, Company and the Contractor may regulate the transfer of the personal data to such Contractor by means of this data processing agreement.

9. Your Rights under the GDPR

You may exercise the following rights by submitting your request at

Your rights under the GDPR include:

● right of access means that you may ask us to send you a copy of your personal data collected together with information regarding the nature, processing, and disclosure of that personal data;

● right to rectification means that you may ask us to update and correct the false data, missing or incomplete personal data.

● right to erasure (to be “forgotten”) means that you may ask us to delete your personal data collected, except insofar it is prohibited by appropriate laws.

● right to restriction of processing means that you may ask us to restrict processing where:

      1.     your personal data is not correct or outdated;

      2.     the processing is unlawful.

● right to object to the processing means that you may raise objections on grounds relating to your particular situation;

● right to data portability means that you may ask us to transfer a copy of your personal data to another organisation or you;

● right to withdraw the consent when your personal data processed on the basis of your consent;

● right to lodge a complaint with the supervisory data protection authority pertaining to the processing of your personal data.

You may submit the complaint to the supervisory authority of your place of residence within the EU or to the data protection authority stated in this Policy.

Please, note that we may need to confirm your identity to process your requests to exercise your rights under the GDPR. Thus, we may not be able to satisfy your request if you do not provide us with sufficient detail to allow us to verify your identity and respond to your request.

10. Data Protection Authority under the GDPR

We kindly invite you to share concerns with us in the first place regarding any issue related to your personal data processing. You may contact us to address your inquiries at

11. Supervisory Authorities under GDPR:

In case of any questions regarding data protection, you can apply to the supervisory authority authorities to resolve any privacy-related complaints that cannot be amicably resolved between you and us. You can find the full list of EU supervisory authorities through the link.

Our supervisory authority is Office for Personal Data Protection ('UOOU') (Czech Republic). Find below the details:


Pplk. Sochora 27

170 00 Praha 7

Czech Republic

Phone information: +420 234 665 800

Phone switchboard: +420 234 665 111

12. Children’s Privacy

Our services are restricted to individuals who are 18 years of age or older. The user is obliged to confirm that the age of majority has been reached. We do not permit individuals under the age of 18 on our platform. If you suspect that a user is under the age of 18, please use the reporting mechanism available on the service.

13. Changes to Privacy Policy

This Policy may be changed from time to time due to the implementation of new updates, technologies, laws’ requirements, or for other purposes. We will send notice to you if these changes are dramatic, and where required by applicable laws, we will obtain your consent for the subsequent processing. In any case, we encourage you to review this Policy to check for any changes regularly.

Such notification may be provided via email, announcement published on our Website and by other means consistent with applicable law.