Privacy
Privacy Policy
1. Controller
| Controller | Altoria FinSys d.o.o. |
|---|---|
| Address | Ulica Viktora Cara Emina 14, Croatia |
| info@altoria.hr | |
| Public author / representative | Daniel Budak, Prokurist |
| Supervisory authority | Croatian Personal Data Protection Agency (AZOP) for the Croatian company controller, and any other competent EU authority if applicable. |
2. What data we process
| Area | Data categories | Purpose |
|---|---|---|
| Website access | IP address, browser, device, URL, timestamps, security logs | Deliver the website, prevent abuse, diagnose errors, maintain security |
| Newsletter | Email address, name if provided, language, country/interest tags, consent timestamp, email engagement data | Send requested emails, segment by language/interests, keep suppression records |
| Contact and forms | Name, email, message, selected language, submitted topic, attachments if enabled | Respond to requests and prepare education sessions |
| Checkout and paid products | Name, email, billing details, country, product, price, tax status, invoice data, payment status | Process orders through Stripe, deliver products, issue receipts, maintain accounting records |
| Uploads and document intake | Uploaded files, file names, user-provided context, tool questions, derived text snippets if extraction is enabled | Provide the requested document explanation or education session, route unsupported files to needs-review/reference-only handling |
| AI-assisted tools | Questions, selected country/language, document snippets if enabled, output logs, feedback | Generate or improve informational explanations; never to make legal, financial, insurance, tax, or eligibility decisions |
| Affiliate and partner links | Click source, affiliate identifiers, consent status, coarse analytics | Attribute referrals where disclosed and consented if tracking is non-essential |
| Accounting | Invoice, payment, refund, tax, reconciliation, and settlement data | Bookkeeping, statutory records, financial controls via the Altoria Accounting Platform |
3. Legal bases under GDPR
| Processing | Legal basis |
|---|---|
| Website delivery, security, abuse prevention, basic logs | Legitimate interests, Art. 6(1)(f) GDPR |
| Answering contact requests and pre-contract questions | Contract/pre-contract steps, Art. 6(1)(b) GDPR |
| Paid products, education sessions, digital delivery, refunds | Contract performance, Art. 6(1)(b) GDPR |
| Invoices, tax, statutory accounting records | Legal obligation, Art. 6(1)(c) GDPR |
| Newsletter and optional marketing | Consent, Art. 6(1)(a) GDPR; unsubscribe anytime |
| Non-essential analytics, marketing pixels, affiliate cookies | Consent, Art. 6(1)(a) GDPR and Austrian cookie rules |
| Quality review of anonymized or minimized tool logs | Legitimate interests, Art. 6(1)(f) GDPR, unless consent is required for the specific tool |
| Optional partner handoff | Explicit user consent and/or contract steps, depending on the final flow; no handoff without a separate opt-in |
4. Payments: Stripe first
Checkout launches through Stripe Payment Links. Stripe processes payment data as an independent controller or processor depending on the specific checkout integration, fraud controls, tax handling, and account setup. Stripe privacy notices apply when you use its checkout. PayPal may be added later only after equivalent privacy, refund, order-export, and legal-acceptance handling is configured.
Wise may be used for business banking, settlement, or account operations. It is not offered as a consumer checkout method unless a separate, written manual-payment arrangement is made. Payment and accounting records may be reconciled in the Altoria Accounting Platform.
5. Uploads, documents, and sensitive data
- Upload only documents needed for the requested educational or informational service.
- Do not upload life insurance, health insurance, medical, criminal, children's, third-party, or special-category data unless the live form explicitly allows it and explains why it is needed.
- Uploaded documents are not sold, rented, shared with advertisers, or used for unrelated marketing.
- Uploaded documents are not used to train public AI models. Before production file upload is enabled, every AI/document processor must be configured under appropriate data processing terms and no-training settings.
- Malformed, incomplete, unsupported, suspicious, or unverified files may be quarantined, rejected, or treated as reference-only/needs-review instead of being processed automatically.
- If document upload is enabled, the live form must state the exact retention period and deletion path before submission, unless a longer period is legally required or needed for a dispute.
6. AI-assisted processing
AI tools may help summarize, structure, translate, or explain information. The output is educational/informational and must be verified by the user against original sources and qualified professionals where needed. We do not use AI to decide access to insurance, credit, employment, benefits, pricing, legal rights, tax liability, investment suitability, or any other matter with legal or similarly significant effects.
Before any live AI tool processes personal data or uploaded documents, the production build must name the AI provider, hosting region, data retention, DPA status, and whether data is used for model training. If that information is not ready, the intake should fail closed and route the request to manual review.
7. Cookies and analytics
Essential cookies may be used to operate the website, remember privacy choices, maintain security, or support checkout. Non-essential analytics, marketing, affiliate, remarketing, heatmap, or social-media pixels are off by default and may only load after opt-in. See the Cookie Policy.
8. Processors and recipients
| Recipient / processor | Role | Status before launch |
|---|---|---|
| Hetzner / server provider at IP 167.235.121.129 | Hosting and server infrastructure | Confirm exact contracting entity, DPA, region, logs and backups before launch |
| Newsletter provider to be selected | Newsletter and email automation | Do not enable signup automation until provider and DPA are confirmed |
| Stripe | Payment checkout, tax/fraud/payment records | Allowed checkout provider |
| PayPal | Future payment checkout and payment records | Not active at launch |
| Wise | Business banking and settlement | Business banking only |
| Altoria Accounting Platform | Accounting records, invoicing, reconciliation | Confirm operator, access roles, retention |
| AI provider to be selected | AI-assisted explanations if enabled | Must be named before live personal-data or document processing |
| Analytics provider to be selected | Optional consent-based analytics | No loading before opt-in |
| Licensed professional or partner | Only if the user explicitly requests/refers a case | No partner handoff without separate opt-in |
9. Retention
| Data | Draft retention period |
|---|---|
| Server/security logs | Up to 90 days unless needed for security investigation |
| Newsletter data | Until unsubscribe or deletion request; suppression data may be retained to prevent further sends |
| Contact requests | Up to 24 months after last interaction unless needed longer for a contract or dispute |
| Q&A/tool logs | Up to 90 days for quality/security, then delete or anonymize |
| Uploaded documents | To be confirmed before upload launch; the live form must state the exact retention period and deletion path |
| Invoices and accounting records | Retained according to Croatian/EU accounting and tax obligations; final retention schedule to be verified with the company accountant |
| Consent logs | For as long as needed to prove consent and defend claims |
10. International transfers
The production setup should prefer EU/EEA hosting and processors. If a provider transfers data outside the EEA, the provider must offer a lawful transfer mechanism such as EU Standard Contractual Clauses and appropriate safeguards. This must be checked for Stripe, email, hosting, AI, analytics, and banking providers before publication.
11. Your rights
You may request access, rectification, erasure, restriction, portability, objection, and withdrawal of consent. You may also lodge a complaint with the competent data protection authority.
Requests: info@altoria.hr.