Privacy Policy

1. Data Controller

The data controller responsible for your personal data is Velxode, operating at Radnička cesta 46, 10000 Zagreb, Croatia. You may contact us at info@velxode.com or +385 91 505 5701.

2. Legal Basis for Processing

We process personal data in accordance with Regulation (EU) 2016/679 (GDPR) and the Croatian Act on the Implementation of the General Data Protection Regulation (NN 42/18). We rely on the following legal bases:

• Consent (Article 6(1)(a) GDPR): Where you have given explicit consent, for example when submitting a contact form or accepting analytics cookies.
• Legitimate Interests (Article 6(1)(f) GDPR): For operating and improving our educational platform, including basic website analytics necessary to understand how our content is used.
• Legal Obligation (Article 6(1)(c) GDPR): Where processing is required to comply with applicable Croatian or EU law.

3. Data We Collect

3.1 Contact Form Data

When you submit our contact form, we collect: your name, email address, phone number (optional), subject, and message content. This data is used solely to respond to your enquiry.

3.2 Website Usage Data

If you consent to analytics cookies, we may collect anonymised data about how you interact with our website, including pages visited, time spent, and general geographic region. This data is not linked to your identity.

3.3 Cookie Data

We use cookies as described in our Cookie Policy. Your cookie preferences are stored as a cookie on your device. See our Cookie Policy for full details.

4. How We Use Your Data

• To respond to enquiries submitted through our contact form
• To improve the content and usability of our educational platform
• To comply with legal obligations applicable to our operations
• To maintain records as required by Croatian law

We do not use your personal data for marketing purposes, profiling, or automated decision-making. We do not sell or rent your data to third parties.

5. Data Retention

Contact form submissions are retained for a maximum of 24 months from the date of receipt, after which they are securely deleted. Website analytics data (where consented) is retained in anonymised aggregate form. Cookie preference data is retained for the duration of the cookie's validity (12 months).

6. Data Sharing

We do not share your personal data with third parties except in the following circumstances:

• Service Providers: Hosting and technical service providers who process data on our behalf under data processing agreements compliant with Article 28 GDPR.
• Legal Requirements: Where disclosure is required by Croatian or EU law, court order, or competent regulatory authority.

7. International Transfers

Where personal data is transferred outside the European Economic Area, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission, in accordance with Chapter V GDPR.

8. Your Rights

Under GDPR and Croatian data protection law, you have the following rights:

• Right of Access (Article 15): Request a copy of the personal data we hold about you.
• Right to Rectification (Article 16): Request correction of inaccurate personal data.
• Right to Erasure (Article 17): Request deletion of your personal data where no legal basis for retention exists.
• Right to Restriction (Article 18): Request restriction of processing in certain circumstances.
• Right to Data Portability (Article 20): Receive your data in a structured, machine-readable format.
• Right to Object (Article 21): Object to processing based on legitimate interests.
• Right to Withdraw Consent: Withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of these rights, contact us at info@velxode.com. We will respond within 30 days.

9. Right to Lodge a Complaint

You have the right to lodge a complaint with the Croatian Personal Data Protection Agency (Agencija za zaštitu osobnih podataka – AZOP), Selska cesta 136, 10000 Zagreb, Croatia (www.azop.hr), if you believe our processing of your personal data does not comply with applicable law.

10. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. These measures are reviewed and updated regularly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. The date at the top of this page reflects the most recent revision. We encourage you to review this policy periodically.

12. Contact

For any questions regarding this Privacy Policy or our data processing practices, contact us at:
Email: info@velxode.com
Phone: +385 91 505 5701
Address: Radnička cesta 46, 10000 Zagreb, Croatia