Privacy policy

This page explains which personal data I collect through this website, why I collect it, how long I keep it and which rights you have. The policy follows the General Data Protection Regulation (GDPR) and the Croatian Act on the Implementation of the GDPR.

Last updated:

Who is responsible for your data

The data controller is Vrh, obrt za digitalne usluge, owner Matija Terzić, Kulići 1, 51216 Viškovo, Croatia, OIB (tax number) 70680025658.

For any question about personal data, write to info@vrhagencija.com or call 095 371 1881. I reply within 30 days at the latest.

Which data I collect and why

WhenDataPurposeLegal basis
Call booking form and forms on landing pagesName, company, email, phone, city, answers to the form questionsReplying to your enquiry, preparing the call and the offerSteps taken at your request before entering into a contract
Booking a time slotName, email, chosen slot, noteArranging and holding the callSteps taken at your request before entering into a contract
Downloading the free guideName, emailSending the guide and occasional tips by emailYour consent, which you can withdraw at any time
Email or phone callThe data you choose to shareReplying to your enquiryLegitimate interest in answering a message
Analytics and ad measurementDevice and browser data, truncated IP address, pages visited, cookie identifiersVisit statistics and measuring ad performanceYour consent given in the cookie banner
Form protectionA hashed fingerprint of the IP address, deleted after 10 minutesPreventing spam and automated submissionsLegitimate interest in website security

With each enquiry I also record the page it was sent from, the referring page and campaign tags from the address (UTM, gclid, fbclid), so I know which channel brings enquiries.

I do not collect special categories of personal data and I do not make decisions by automated processing or profiling.

Who else processes the data

I do not sell your data or pass it to third parties for their own purposes. To run the website I use service providers who process data on my instructions:

ProviderWhat it is forBased in
Hostinger International Ltd.The server that hosts the website and formsCyprus, server in Germany
Brevo (Sendinblue SAS)Sending email: enquiry notification, the guide, occasional tipsFrance
Cal.com, Inc.Calendar for booking callsUSA
Google Ireland LimitedGoogle Tag Manager, Google Analytics, Google AdsIreland
Meta Platforms Ireland LimitedMeta Pixel and ad measurement on Facebook and InstagramIreland

For enquiries sent from landing pages you reached through an ad on Facebook or Instagram, I also send Meta a server-side confirmation that the enquiry was submitted (Conversions API). Email, phone and name are sent only in hashed form (SHA-256) and are used to measure ad performance.

Transfers outside the European Union

Cal.com, Google and Meta may also process data in the United States. The transfer relies on the European Commission adequacy decision (EU-U.S. Data Privacy Framework) and on standard contractual clauses.

How long I keep the data

  • Enquiries and call bookings: up to 24 months from the last contact, if we do not start working together.
  • Client data: for the duration of our work, and contracts and invoices for 11 years, as required by accounting and tax law.
  • Email address for the guide and tips: until you unsubscribe.
  • Analytics and marketing cookies: as listed in the cookie policy, 24 months at most.

Your rights

At any time you can ask for:

  • access to the data I hold about you and a copy of it,
  • correction of inaccurate or incomplete data,
  • erasure of your data,
  • restriction of processing,
  • transfer of the data to you or to another controller,
  • an objection to processing based on legitimate interest,
  • withdrawal of consent, which does not affect processing before the withdrawal.

Send your request to info@vrhagencija.com. You can unsubscribe from tip emails with the link at the bottom of each message or by replying to it.

If you believe the processing breaks the law, you have the right to lodge a complaint with the Croatian Personal Data Protection Agency (AZOP), Selska cesta 136, 10000 Zagreb, azop.hr.

Cookies

The list of cookies, their purpose and retention periods is in the cookie policy. You can also change your choice there.

Data security

The website uses an encrypted connection (HTTPS). Access to enquiries is limited to the people who need it to reply, and the tools I use are password protected.

Changes to this policy

I update the policy when the way I process data or the law changes. The date of the last update is at the top of the page.