Privacy Policy

PRIVACY POLICY

This Privacy Policy (hereinafter also referred to as the "Privacy Policy") explains how personal data is collected, used, and managed through the ActiveCow.com website (hereinafter referred to as the "Website").

This Privacy Policy is issued in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (the "GDPR").

Company:

Company name: CFI Group L.L.C.
Registration number: 6615443
Registered office: DE19801 Wilmington, Orange Street 1201, Suite 600, United States of America
Legal form: Limited Liability Company (LLC)
E-mail: [ceo@activecow.com](mailto:ceo@activecow.com)
Website: ActiveCow.com

acting as the data controller within the meaning of Article 4(7) of the GDPR (hereinafter referred to as the "Controller").

The protection of your personal data is our priority. We recommend that you carefully read this Privacy Policy, which provides essential information about how your personal data is processed, as well as your related rights and obligations.

I. PROCESSING OF PERSONAL DATA FOR THE PERFORMANCE OF THE SERVICE AGREEMENT

1.1. Personal data means any information relating to an identified or identifiable natural person. Personal data also includes individual pieces of information which, when combined, may lead to the identification of a specific individual.

1.2. An identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

1.3. In connection with the use of the ActiveCow.com Platform, the Controller processes the personal data that you provide through your activities on the Platform.

For natural persons, this includes:

- first name and surname, including academic title (if applicable),
- date of birth or personal identification number (where applicable),
- permanent residential address,
- correspondence address,
- telephone number,
- e-mail address,
- bank account details,
- any additional information necessary for the performance of the Service Agreement.

1.4. Pursuant to Article 6(1)(b) of the GDPR, the processing of personal data is necessary for the performance of the Service Agreement to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into such an agreement, including, in particular, registration for the Challenge.

1.5. The Controller also processes personal data for the purpose of maintaining records of the Service Agreement and, where necessary, for the future exercise or defence of the rights and obligations arising from that Agreement.

1.6. Personal data is stored and processed for the above purposes for a period of three (3) years from the date of execution of the Service Agreement or from the completion of the last part of the contractual performance. Where longer retention of contractual documentation, including personal data, is required, such processing may continue in accordance with Article 6(1)(c) and Article 6(1)(f) of the GDPR.

II. PROCESSING OF PERSONAL DATA FOR MARKETING COMMUNICATIONS

2.1. Personal data may also be processed and stored in accordance with Section 7(3) of Act No. 480/2004 Coll., on Certain Information Society Services, as amended, for the purpose of sending newsletters, commercial communications, and promotional materials from the Controller to your e-mail address or telephone number, provided that you did not opt out of receiving such communications when registering for the Challenge.

2.2. You may unsubscribe from receiving the above marketing communications at any time by using the unsubscribe link included in the communication or by contacting the Controller at [ceo@activecow.com](mailto:ceo@activecow.com).

2.3. If you have not unsubscribed from receiving marketing communications, the Controller may retain your personal data for this purpose for a maximum period of three (3) years from the date of your last Order.

III. RECIPIENTS OF PERSONAL DATA

3.1. In addition to the Controller, recipients of personal data include entities involved in:

- processing payments (Stripe),
- providing hosting, operation, and maintenance services for the ActiveCow.com Platform,
- providing other services related to the operation of the Platform,
- providing marketing services,
- providing e-mail communication services.

3.2. The Controller processes personal data within the territory of the European Union. The Controller may also transfer personal data to third countries or international organisations where this is necessary for the provision of the above services.

Recipients of personal data in third countries include, in particular, providers of marketing services.

3.3. The Controller has not appointed a Data Protection Officer (DPO).

3.4. If you have any questions regarding the processing of your personal data, please contact us at ceo@activecow.com.

IV. USE OF COOKIES

4.1. Cookies are small text files that are stored on your computer or mobile device when you visit and use the Website.

4.2. Cookies are used, for example, to remember your preferences, facilitate navigation between websites, personalize advertising content based on your interests, and collect anonymized statistics regarding the use of the Website.

4.3. In accordance with Article 6(1)(f) of the GDPR, based on the Controller's legitimate interest, the Controller uses the following categories of cookies on the ActiveCow.com Website:

- Necessary Cookies, which are essential for the operation of the Website;
- Analytical Cookies, which collect analytical information, such as Website traffic and visitor behaviour;
- Advertising Cookies, which record and store User preferences in order to display more relevant advertising content.

4.4. The following cookies may be collected and stored:

Necessary Cookies

- externalFontsLoaded – used for loading fonts.
- NOCHACHE – used to improve Website loading speed.
- PHPSESSID – used to identify the User's login session.
- previousURL – stores the previously visited page.
- referral – identifies the referring source of the visit.
- mccid / mceid – internal identifiers required for the proper operation of the Website.
- SRV_id – internal identifier used to ensure high Website availability.
- CookiesOK – stores the User's consent regarding the use of cookies.

Analytical Cookies

- Hotjar – monitors User behaviour on the Website and helps improve the Website.
- Leady – analyses User behaviour and Website performance.
- Google Analytics – measures Website traffic and evaluates Website performance.
- Google Optimize – used to improve Website functionality and user experience.
- Google Tag Manager – manages analytics and marketing scripts.
- Google reCAPTCHA – protects the Website against spam and automated abuse.
- Smartlook / Smartsupp – analyses Website usage and enables customer communication.
- SpeedCurve – monitors Website performance and loading speed.
- Luigi's Box – analyses User behaviour and improves Website functionality.

Advertising Cookies

- AdForm – banner advertising.
- Criteo – banner advertising.
- Google Ads – search, display and YouTube advertising.
- Google Ads (AdWords) – advertising targeting.
- Google Display & Video 360 – display advertising.
- Google Pay – payment gateway integration.
- TikTok Ads – advertising on TikTok.
- Allegro Ads – display advertising.
- DoubleClick – Google advertising services.
- LinkedIn Ads – advertising on LinkedIn.
- Facebook (Meta) – social sharing functionality.
- Facebook Ads (Meta) – Facebook advertising.
- Facebook Audience (Meta) – audience targeting.
- Seznam Sklik – advertising targeting.
- X (formerly Twitter) – social sharing functionality.
- X Ads (formerly Twitter Ads) – advertising on X.
- Zbozi.cz – shopping search advertising.
- Heureka.cz – shopping comparison advertising.
- RTB House – display advertising.

4.5. You may provide your consent to the use of cookies by selecting the appropriate option in the cookie consent banner displayed on the Website. You may also modify or withdraw your consent at any time through your browser settings.

4.6. Information about cookies, including the current list of cookies used, is available in your internet browser, usually under the Developer Tools section. Cookie settings can also be managed directly within your browser.

Guides for managing cookies are available at:

- Google Chrome
- Brave
- Microsoft Edge
- Mozilla Firefox
- Opera
- Safari

(Please refer to the official support pages of the respective browser providers.)

4.7. Third parties cooperating with the Controller, as listed in Section III of this Privacy Policy, may also use cookies or access information collected through cookies placed on the Controller's Website.

V. SECURITY OF PERSONAL DATA

5.1. The Controller declares that it has implemented all appropriate technical and organisational measures to ensure the security of personal data.

5.2. The Controller further declares that it has implemented all appropriate technical and organisational measures to protect data storage systems and physical records containing personal data.

5.3. The Controller declares that personal data is accessible only to authorised persons designated by the Controller and to authorised persons of the recipients of personal data referred to in Section III of this Privacy Policy.

VI. RIGHTS OF DATA SUBJECTS

6.1. You have the right to unsubscribe from newsletters and marketing communications at any time.

6.2. You have the right to contact the Controller to obtain information about which of your personal data is being processed, request access to such personal data, request its correction or updating, obtain a copy of your personal data, or request the restriction of its processing.

6.3. In certain cases, you also have the right to data portability and the right to erasure of your personal data, provided that exercising such rights does not conflict with applicable legal obligations or the Controller's legitimate interests.

6.4. You have the right to object to the processing of your personal data where such processing is based on the Controller's legitimate interests.

6.5. If you believe that the Controller is processing your personal data in violation of the GDPR or other applicable legislation, you have the right to lodge a complaint with the competent supervisory authority or seek judicial protection.

VII. FINAL PROVISIONS

7.1. By creating an account, the Customer confirms that they have read this Privacy Policy and express their full agreement with it through the online registration form.

7.2. The Controller reserves the right to amend this Privacy Policy at any time. Any updated version will be published on the ActiveCow.com Website.

This Privacy Policy shall become effective on 6 August 2026.