Privacy Policy

The data controller for personal data processed on this website is:

DIRECT REVENUE CONSULTING, obrt za savjetovanje, marketing i digitalne usluge, vl. Vlaho Kmetović

Address: Ispod Minčete 3, 20000 Dubrovnik, Croatia

Email: vlaho@direvconsulting.com

Telephone: +385 99 329 1128

This website primarily collects personal data that directly identifies you when you submit it yourself through the enquiry forms (commercial review form and qualification form). The data we collect includes:

• Full name
• Business email address
• Hotel, property or company name
• Telephone number (qualification form only, optional)
• Role or position
• Property type or business type
• Property location
• Property website (optional)
• Number of accommodation units
• Areas of support or interest
• Current commercial challenge or objective
• Cooperation goal
• Preferred cooperation start time
• How you heard about us (qualification form only, optional)

In addition to the data you submit through the forms, the website automatically collects basic technical data necessary for security and reliable operation, including IP address, browser type and version, operating system and interface language. This data is not used for user profiling.

The website does not collect credit card data, identity document numbers or other special categories of personal data (Article 9 GDPR).

We process your personal data exclusively for the following purposes:

• Responding to your enquiries and providing requested information
• Assessing potential cooperation and taking steps before entering into a contract
• Providing requested services if cooperation is agreed
• Maintaining business correspondence
• Protecting the website from abuse, fraud and technical threats
• Complying with legal obligations where applicable

The website does not run newsletter, promotional or marketing email campaigns. We do not sell or share your data with third parties for marketing purposes.

Processing of personal data is based on the following legal bases:

• Pre-contractual measures (Article 6(1)(b) GDPR) - responding to enquiries, assessing potential cooperation and taking steps before entering into a contract
• Legitimate interests (Article 6(1)(f) GDPR) - maintaining reasonable business correspondence, preventing abuse and protecting the website and technical infrastructure
• Consent (Article 6(1)(a) GDPR) - only for genuinely optional processing such as analytics cookies (Google Analytics)
• Legal obligation (Article 6(1)(c) GDPR) - where laws require retention of certain records

We do not sell or transfer your data to third parties for their own purposes. We use the following processors who act solely on our instructions:

• Base44 - platform for hosting, database storage and backend function execution. Data is stored within the platform infrastructure.
• Resend - email delivery service. Used exclusively to send enquiry notification emails to vlaho@direvconsulting.com.
• Calendly - scheduling tool. Loaded only after a user submits a qualified enquiry and explicitly requests scheduling. At that point Calendly may set its own cookies.
• Google Analytics - analytics tool. Loaded only after the user explicitly accepts analytics cookies through the consent banner.

We do not use marketing networks, advertising pixels or user-tracking tools for targeted advertising.

Some of the processors listed above (Base44, Resend, Calendly, Google Analytics) may process data in the United States or other countries outside the European Economic Area (EEA).

In such cases, data transfers are protected by appropriate safeguards, including Standard Contractual Clauses approved by the European Commission or other recognised guarantees under the GDPR.

We retain your personal data only for as long as necessary for the purpose for which it was collected:

• Enquiry data is retained during the assessment and potential cooperation period, and afterwards for a reasonable period required for business record-keeping (typically up to 24 months from the last interaction), unless legal obligations require longer retention.
• Consent records are retained for as long as the consent is valid, i.e. until you withdraw it.
• Technical logs (IP address, browser data) are retained for a limited period, typically up to 90 days, exclusively for security and technical operation purposes.

After the retention period expires, data is deleted or anonymised.

You have the following rights regarding your personal data:

• Right of access
• Right to rectification of inaccurate or incomplete data
• Right to erasure ("right to be forgotten")
• Right to restriction of processing
• Right to data portability
• Right to object to processing
• Right to withdraw consent at any time

To exercise your rights, contact vlaho@direvconsulting.com. We will respond to your request within the statutory period.

Where processing is based on your consent, you may withdraw it at any time by emailing vlaho@direvconsulting.com.

Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal. You can also withdraw analytics cookie consent at any time through the cookie settings link in the page footer.

You have the right to object to the processing of your personal data that is based on legitimate interests, for reasons relating to your particular situation.

If you object, we will stop processing your data unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or where processing is necessary for the establishment, exercise or defence of legal claims.

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Croatian Personal Data Protection Agency (AZOP):

Agencija za zaštitu osobnih podataka (AZOP)

Website: azop.hr

Email: azop@azop.hr

This website does not perform automated decision-making, profiling or similar processing that produces legal or similarly significant effects on you.

We take reasonable technical and organisational measures to protect your personal data from unauthorised access, loss, misuse or alteration.

The website uses HTTPS encryption for data transmission. Access to collected data is restricted to authorised persons.

Technical logs are used exclusively for security, abuse prevention and ensuring the reliable technical operation of the website.

We reserve the right to update this Privacy Policy periodically to reflect changes in business, technical setup or applicable regulations.

All changes will be published on this page with an updated "last updated" date. We recommend reviewing this page periodically.

For any questions regarding privacy and data protection, you can contact us at:

Email: vlaho@direvconsulting.com

Telephone: +385 99 329 1128