Privacy Policy for TOP 09

This Privacy Policy describes what personal data the TOP 09 mobile app processes, for what purposes and on what legal basis, who can access it, how long it is kept and what rights you have, including the right to request deletion of your account and data. The Czech version is available at implayo.cz/app-privacy .

1. Who operates the app

Publisher and technical operator of the app:
Implayo s.r.o.
Pražská 135, 530 06 Pardubice, Czechia
Company ID (IČO): 288 13 171
Privacy and data-deletion contact: support@implayo.cz

The app is developed in cooperation with the political party TOP 09 (Company ID 71339728, Opletalova 1603/57, Nové Město, 110 00 Praha 1, Czechia) and is intended for its members and supporters. The app content (news, articles, events, answers from guarantors) comes from TOP 09. Party contact: info@top09.cz .

We process personal data only for the purposes of operating the app and its content as described below. You can send questions and requests about personal data to support@implayo.cz or to info@top09.cz ; where necessary, requests are forwarded between us.

2. What the app does

news and articles about TOP 09,
current events,
push notifications (e.g. about party congresses, meetings and voting),
sending questions and suggestions to expert guarantors,
features for members and supporters (including registration / sign-in where available),
QR code scanning with the device camera,
maps and location for showing event places.

3. Data we process

Depending on how you use the app, we may process in particular:

Account / registration data — e.g. name, email, credentials and user ID, member or supporter profile (if you register or sign in).
Messages and user content — the content of questions and suggestions you send through the app.
Device identifiers for push notifications — a device token provided by Firebase Cloud Messaging (Google) or Apple Push Notification service, used only to deliver notifications.
Technical, diagnostic and aggregated usage data — e.g. device type, operating system and app version, error and crash reports and basic usage statistics, which may be provided by the mobile app platform or the operating system (Google, Apple).
Camera — used only to scan QR codes on the device. Camera images are not sent over the network.
Location — used only for map features (e.g. showing an event place). Location is not used for continuous background tracking.

The app needs internet access to load content and communicate with servers. We do not request access to contacts, SMS, microphone or photo library beyond the above.

4. Data about political opinions

The app is intended for members and supporters of a political party. Using the app or registering in it may therefore reveal your membership in or support for TOP 09, or your political opinions, which is a special category of personal data. The app does not actively ask you about your political opinions.

We process such data only to the extent necessary for the app to function, in the course of the legitimate activities of a political party with respect to its members and persons in regular contact with it (Art. 9(2)(d) GDPR), or where applicable on the basis of your explicit consent (Art. 9(2)(a) GDPR). We do not disclose such data outside TOP 09 and the technical operation of the app without your consent.

5. Purposes and legal bases

creating and managing your account, member and supporter features — performance of a contract (the app's terms of use), Art. 6(1)(b) GDPR;
answering questions and suggestions — performance of a contract, Art. 6(1)(b) GDPR;
sending push notifications — consent given by allowing notifications in your device settings, Art. 6(1)(a) GDPR; you can withdraw it at any time by turning notifications off in your device settings;
security, stability and troubleshooting (technical logs, diagnostics) — legitimate interest, Art. 6(1)(f) GDPR;
improving the app based on aggregated usage statistics — legitimate interest, Art. 6(1)(f) GDPR, and your consent where required by law;
compliance with legal obligations — Art. 6(1)(c) GDPR.

We do not use data for advertising, advertising profiling or tracking across apps and websites of other companies.

6. Who can access the data

We do not sell personal data or share it with third parties for their marketing. Access may be given to:

TOP 09 — in connection with app content, questions and suggestions, and member and supporter features,
the hosting provider of the server from which the app loads content and where accounts are stored,
the provider of the mobile app platform on which the app is built (technical operation, notifications, diagnostics),
Google (Firebase Cloud Messaging) and Apple (Apple Push Notification service) — delivery of notifications; as operators of the operating systems and app stores, Google and Apple may also process diagnostic data and statistics,
public authorities where required by law.

7. Transfers outside the EU

Some providers, in particular Google and Apple, may process data outside the European Economic Area, for example in the USA. Such transfers are based on the European Commission's adequacy decision (EU-US Data Privacy Framework) or on standard contractual clauses approved by the European Commission.

8. How long we keep data

account data and related content — for the life of the account; deleted once the account is deleted,
deletion requests are completed within 30 days of receipt,
technical logs — no longer than 30 days,
push notification token — until you sign out, turn notifications off, uninstall the app or delete your account,
data that must be retained by law or are necessary to protect legal claims — for the period required by law, then deleted.

9. Security

We apply appropriate technical and organisational measures (e.g. access control, encrypted data transfer, updates and monitoring) to protect data against unauthorised access, loss or misuse. No system, however, is completely risk-free.

10. Account and personal data deletion

See the detailed steps on the account and data deletion page . You can submit a request at any time, even if the app is no longer installed.

Email support@implayo.cz with the subject “TOP 09 app — account & data deletion”.
Include the email or account identifier used in the app and confirm that you request deletion of the account and related personal data.
After verifying your identity, we permanently delete the account and related data.

We complete requests within 30 days and inform you of the outcome by email. If we must keep some data for legal reasons, we will tell you what is kept, why and for how long. You may also send the request to info@top09.cz .

11. Your rights

Under the GDPR you have the right to:

access your personal data and obtain a copy,
rectification of inaccurate data,
erasure (“right to be forgotten”),
restriction of processing,
data portability,
object to processing based on legitimate interests,
withdraw consent at any time where processing is based on consent.

To exercise your rights, contact support@implayo.cz or info@top09.cz . You also have the right to lodge a complaint with the Czech Office for Personal Data Protection ( ÚOOÚ , Pplk. Sochora 27, 170 00 Praha 7).

12. Age limit

The app is intended for persons aged 15 and over. We do not knowingly collect personal data from younger persons. If you believe that a person under 15 has provided us with data, contact us and we will delete it.

13. Changes to this policy

We may update this policy. The current version is always available at this URL. Last updated: 11 November 2026