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 when you submit it yourself through the contact form or glossary question form. Depending on the form, the data may include:

• Full name
• Email address or telephone number
• Property name and location
• Property website (optional)
• Message content and information you choose to provide in your enquiry
• For glossary questions: email address, term or question and optional context

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 or promotional email campaigns. We do not sell form data. Optional analytics and marketing tools may, after consent, process visit and conversion data to measure effectiveness.

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) - for optional analytics and marketing conversion measurement through Google Analytics and Meta Pixel
• 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 website hosting and backend function execution. Technical data required for operation and security may be processed within the platform infrastructure.
• Resend - email delivery service. Used to forward enquiries to vlaho@direvconsulting.com and, where applicable, to send a receipt confirmation for glossary questions.
• Google Tag Manager, Google Analytics and Meta Pixel - tools used to measure website usage and conversion events. They are loaded only after the user accepts the optional "Analytics and marketing" category through the consent banner.

We do not sell information submitted through forms or share it with advertisers for ad targeting. Analytics and conversion tags are loaded only with the appropriate consent.

Some of the service providers listed above (Base44, Resend, Google tools and Meta) 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 withdraw analytics and marketing 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 make automated decisions that produce legal or similarly significant effects on you. Optional analytics and marketing tools may, after consent, process online identifiers and event data for measurement and audience functions.

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