Privacy Policy
1. Introduction
This Privacy Policy is issued by StartupJobs.com s.r.o., company ID 291 53 786, registered office at Šostakovičovo náměstí 1515/5, Stodůlky, 155 00 Praha 5, Czech Republic, entered in the Commercial Register under file no. C 204709 kept by the Municipal Court in Prague (“we”, “us”), which operates UpWolf at upwolf.com.
It explains how we process personal data of people who use UpWolf on behalf of our customers, who are interested in UpWolf, and who visit our website. We process personal data in accordance with Regulation (EU) 2016/679 (GDPR), Act No. 110/2019 Coll., on personal data processing, Act No. 480/2004 Coll., on certain information society services, and other applicable legislation.
UpWolf is a tool for businesses. We act in two roles:
- Controller of the data of customers' Users, prospective customers and website visitors (this Policy).
- Processor of personal data that may be contained in the data customers upload to UpWolf, such as listings, images and videos. Here the customer is the controller and the Data Processing Agreement applies.
Our Data Protection Officer is Hana Mikschiková, [email protected].
2. What personal data we process
Users of the customer's account
A User is a person whom the customer has given access to its UpWolf account. The legal basis is the performance of the contract with the customer and our legitimate interest in the security of the Service.
| Category | Data | Purpose |
|---|---|---|
| Identification and contact data | Email, name (optional), role in the account, language | Creating and managing the account, signing in, service notifications |
| Sign-in data | Session records including IP address and browser type, time of last sign-in | Account security, preventing misuse |
| Account activity | Record of actions (e.g. who approved a creative, launched or paused a campaign), including actions performed through the API or a connected AI assistant | Traceability of actions, account security, support |
| Connections | API keys and OAuth authorisations (stored only as a hash), name of the connected tool, time of last use | Connecting customer systems and AI assistants |
| Communication | Messages sent to support or via the feedback form | Answering questions and support |
Prospective customers
A prospective customer is someone who requests access to UpWolf or sends us an enquiry through a form on our website. The legal basis is steps taken prior to entering into a contract and our legitimate interest in responding to the enquiry.
| Category | Data | Purpose |
|---|---|---|
| Identification and contact data | Email, name, phone, company, website | Contacting the person who is interested in the Service |
| Information about the business | Answers in the questionnaire (e.g. advertising volume, budget, who manages ads, timing, note), message text, links | Assessing whether and how UpWolf can help |
| Technical data | Hash (fingerprint) of the IP address | Spam protection |
Customers
Customers are businesses; data about a legal entity is not personal data. For sole traders and contact persons, we process the following. The legal basis is the performance of the contract and compliance with legal obligations (accounting and tax).
| Category | Data | Purpose |
|---|---|---|
| Billing data | Company name, company ID, VAT ID, address, billing email | Invoicing and payments |
| Contact persons | Name, email, phone | Communication with the responsible persons |
| Transaction history | Credit purchases and usage | Billing the Service, accounting |
Website visitors
When you visit upwolf.com, the server records technical data (IP address, time, requested page, browser type) for operation and security. Analytics cookies are used only with your consent. Details are in the Cookie Policy.
On preview pages we prepare for a specific job board (for example upwolf.com/reed), we also measure visits without cookies so that we know whether the board has seen the offer: time, page language, how long the page was visible, how far it was scrolled and the referring website. We do not store the IP address, only a keyed hash of it combined with the browser type, which lets us recognise a repeat visit. The legal basis is our legitimate interest in following up on an offer we sent.
3. Recipients and processors
We share personal data only with providers we need to operate UpWolf, and only to the extent necessary:
| Recipient | Purpose | Location |
|---|---|---|
| Webglobe, s.r.o. | Hosting, database, sending emails | Czech Republic (EU) |
| Anthropic, PBC | AI models used to prepare creatives and targeting suggestions from listing content | USA |
| Meta Platforms Ireland Ltd. | Running campaigns on the customer's ad account | Ireland (EU), group also USA |
| Google Ireland Ltd. | Google Analytics 4: website traffic statistics (only with consent) | Ireland (EU), group also USA |
| Slack Technologies, LLC | Internal operational notifications for our team (may contain the account name and the identification of the User who performed an action) | USA |
In addition, data may be provided to our accountants and legal advisers bound by confidentiality, and to public authorities where required by law.
Transfers outside the European Economic Area take place only with appropriate safeguards under the GDPR, in particular based on an adequacy decision (EU-US Data Privacy Framework) or the European Commission's standard contractual clauses. We use AI models only through commercial API interfaces whose providers do not use the transmitted data to train their models.
UpWolf does not perform automated individual decision-making within the meaning of Article 22 GDPR.
4. How long we keep personal data
We keep personal data only as long as necessary for the purposes described here, to fulfil our legal obligations and to protect our rights:
- User account data for the duration of the contract with the customer, or until the customer removes the User. After the contract ends, for no more than 3 years to protect legal claims.
- Sign-in sessions are valid for 30 days from the last activity; session records are kept for no more than 12 months.
- Account activity records for the duration of the contract with the customer.
- Prospective customer data for no more than 2 years from the last contact, unless a contract is concluded.
- Visits to job board preview pages for no more than 2 years.
- Invoices and accounting records for 10 years as required by tax legislation.
- Records of communication with the ad platform: full content for 14 days, the record itself for 90 days.
- Database backups are continuously overwritten; deleted data disappears from them within 30 days.
- Cookies for the period stated in the Cookie Policy.
5. Security
Access tokens to ad accounts and other secrets are stored encrypted; API keys and sign-in links only as a hash. Each customer's data is isolated from other customers. Communication runs over HTTPS. Only people who need personal data for their work have access to it, and only to the necessary extent. We host data in the Czech Republic and back it up daily.
6. Your rights
Under the conditions set out in the GDPR, you have the following rights in relation to your personal data:
- Right of access: to obtain confirmation of whether we process your data, and information about the processing.
- Right to rectification: to have inaccurate or incomplete data corrected.
- Right to erasure: to have your data deleted if the conditions of the GDPR are met. Erasure may mean that we can no longer provide you with the Service.
- Right to restriction of processing.
- Right to data portability: to receive the data you have provided to us in a structured, machine-readable format.
- Right to object to processing based on legitimate interest.
- Right to withdraw consent where processing is based on consent; withdrawal does not affect the lawfulness of processing before it.
You can exercise your rights at [email protected]. How to request deletion of data we received from Meta (Facebook, Instagram) is described in the Data Deletion Instructions. If your request is manifestly unfounded or excessive, we may charge a reasonable fee or refuse it. If you are a User of a customer's account and your request concerns data that we process for the customer, we will forward it to the customer.
If you believe your personal data has been processed unlawfully, you can also contact the CEO of StartupJobs.com directly at [email protected]. You also have the right to lodge a complaint with the supervisory authority, which in the Czech Republic is the Office for Personal Data Protection (uoou.gov.cz).
7. Final provisions
UpWolf is not intended for persons under 18. We may change this Policy; the new version replaces the previous one from its effective date. We will inform registered Users of material changes by email.
This Policy takes effect on 6 October 2026.