Effective date: January 07, 2019

D3S a.s. (“us”, “we”, or “our”) operates the website (the “Service”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from

Your Rights Under GDPR

Under GDPR, data controllers must identify how personal data is being processed and must provide a means for data subjects to apply their rights under GDPR.

Our “Information Memorandum” describes the scope of personal data collected and how personal data is processed. The “Request” form allows you, as a data subject, to submit requests according to your rights under GDPR Article 13(2)(b), or lodge a complaint according to your rights under GDPR Article 13(2)(d).

Click here to learn more about how we protect your rights under GDPR.

Information Collection And Use for Website Visitors

We collect several different types of information for various purposes to provide and improve our Service to you.

Types Of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • First Name
  • Last Name
  • Phone Number
  • Email address
  • Cookies and Usage Data

Usage Data

We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

Use Of Data

D3S a.s. uses the collected data for various purposes:

  • To provide and maintain the Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer care and support
  • To provide analysis or valuable information so that we can improve the Service
  • To monitor the usage of the Service
  • To detect, prevent and address technical issues

Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside Czech Republic and choose to provide information to us, please note that we transfer the data, including Personal Data, to Czech Republic and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

D3S a.s. will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure Of Data

Legal Requirements

D3S a.s. may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of D3S a.s.
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security Of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.


We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

On this website, the controller has integrated components of Google Analytics. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:

Hubspot Analytics

On this website, the controller has integrated components of Hubspot. The Hubspot components include two necessary cookies: (1) a cookie used to distinguish between humans and bots; and (2) a cookie used to implement forms on the website. The Hubspot components also include a marketing cookie that sends data to the Hubspot marketing platform, used by the controller, to learn about the website visitor’s device and behaviour. This cookie tracks the visitor across devices and marketing channels, if consent is provided. For more information on the privacy practices of Hubspot, please visit the Hubspot privacy page:

LeadBoxer Analytics

On this website, the controller has integrated components of LeadBoxer. The LeadBoxer components automatically recognize and qualify companies who visit a website. The LeadBoxer component allows the operator of a website that uses the component to generate leads, thus qualifying potential new customers for our Service.

The operating company of LeadBoxer is LeadBoxer BV, Herengracht 182, 1016 BR, Amsterdam, The Netherlands.

We use a LeadBoxer tracking pixel.

A tracking pixel is a miniature graphic embedded in a web page to enable log file recording and log file analysis to subsequently perform a statistical analysis. LeadBoxer also sets a cookie on the information technology system of the data subject. The setting of the cookie enables us to analyze the usage of our Service.

Using the data obtained, usage profiles are created. The usage profiles are used for the purpose of analyzing visitor behavior and enabling an improvement of our Internet offer. Data collected through the LeadBoxer component are not used to identify the data subject without first obtaining a separate and explicit consent from the data subject. These data will not be merged with personal data or with other data which contains the same usage profile. By default, LeadBoxer identifies the companies, not the individuals, who are accessing the website, and presents firmographic information.

With each call-up to one of the individual pages of this website, the Internet browser on the information technology system of the data subject is programmatically requested to submit data for the purpose of online analysis to the LeadBoxer component. During the course of this technical procedure, LeadBoxer gains knowledge of visitor information, such as the requesting IP address, which inter alia, serves to understand the origin of visitors and clicks.

The cookie is used to store anonymized information, such as the access time, and the frequency of visits to our website. With each visit of our Internet pages, these visitor data, including the IP address of the Internet access used by the data subject, are logged and stored by the LeadBoxer server. Further information and the applicable data protection provisions of LeadBoxer may be retrieved under

Blocking Analytics Cookies

The data subject may prevent the setting of cookies through our Service at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Inception CRM, Google Analytics, Hubspot and LeadBoxer from setting cookies on the information technology system of the data subject. In addition, cookies already in use by Inception CRM, Google Analytics Hubspot, and LeadBoxer may be deleted at any time via a web browser or other software programs.

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Inception CRM App Users

D3S  processes necessary personal information of the end users of our business products and applications (“Inception CRM”). D3S will process personal data only if and to the extent that at least one of the following applies:

  • The user has given consent to the processing of their personal data for one or more specific purposes;
  • processing is necessary for the performance of a contract to which the user is a party or in order to take steps at the user’s request prior to entering into a contract;
  • processing is necessary for compliance with a legal obligation to which D3S is subject; or
  • processing is necessary for the purposes of the legitimate interests pursued by D3S or by a third party, except where such interests are overridden by your interests or your fundamental rights and freedoms.
D3S makes sure that each user (as data subject) is aware of the intended purposes of the processing of their personal data as well as the legal basis for the processing, as well as any legitimate interests pursued by D3S or by a third party whose services are used for the performance of the services provided by D3S to the end user. 
This information may communicated to the end user directly, or communicated to their sponsor (typically, their employer, or the company who has contracted the D3S business services they are using), with the understanding that their sponsor will provide this information to them. 
D3S also makes sure each user is informed, either directly or their sponsor, about the recipients or categories of recipients of the personal data, if any, as well as the safeguards that have been implemented to protect their personal data. We also inform users of the retention period of their personal data, where possible, or else inform them of the criteria used to determine that period. 
Each user maintains an individual right, under GDPR, to request access to and rectification or erasure of their personal data, or to restrict of its processing, or to object to its processing, as well as the right to data portability. Where processing is based on consent, the user has the right to withdraw their consent at any time; such withdrawal does not the lawfulness of processing based on consent prior to its withdrawal. 
Where processing is based on a contract, data subjects who use D3S business services under the auspices of an employment or work contract with, or permission from a sponsor whose contract with D3S makes those services available to them, must withdraw their consent from the sponsor, who is the controller of their personal data. D3S is obligated to process personal data, including the personal data of end users, only under the express instructions of the data controller.
End users have the right to lodge a complaint with a supervisory authority, regardless of whether the personal data has been provided on the basis of a contractual agreement with the user’s sponsor, was provided by the user’s sponsor directly under such contract, or the user was required by their sponsor to provide it to us directly. 
Except for what is required for account creation and access to the services, the exact scope of end user personal data collected and processed by D3S, as well as its processing, is determined by the Data Processing Agreement between the contractual parties: D3S and its named customer, who may be the end user’s sponsor. The personal data required by D3S for account enablement is limited to the following:
  • First Name
  • Last Name
  • Business Email Address
In addition, the application may request permission from end users to share their device’s location, access their various device features, such as the camera, in order to provide requested services. Where such permission is granted, the application collects and stores data related to those permissions. Additionally, as a business application, Inception CRM and other D3S business products include standard logging and auditing features that are used to measure performance and enable required functions of the application. By using the application, the end user consents to such logging and auditing, and accepts the legitimate interest of D3S in maintaining those features for the performance and utility of its business products.
If D3S further processes a user’s personal data for a purpose other than that for which the personal data were collected, such as to provide access to online resources, or keep users informed of relevant information related to our business products and services, including by email, D3S will provide the user, prior to that further processing, with information on that other purpose and with any relevant further information, including the means to withdraw consent. D3S undertakes to maintain easily accessible options for withdrawing consent to such processing (including communications), which can be exercised at any time without adverse impact on the contractual relationship with the user or their sponsor.
You may exercise your data subject rights under GDPR Articles 15 to 22 by contacting [email protected]. D3S will provide information on action taken on a request under Articles 15 to 22 to you without undue delay and in any event within one month of receipt of the request.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

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