Privacy Policy
Last updated: January 27, 2025 | Effective date: January 27, 2025
Data Controller: ITalk d.o.o. za informacijske tehnologije OIB: 54872935051 Address: IX. Južna obala 20, 10000 Zagreb, Croatia Email: privacy@italk.hr Phone: +385 98 967 9022
1. Introduction
ITalk d.o.o. (“we”, “our”, or “us”) is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website italk.hr or use our software consulting services.
This policy complies with the EU General Data Protection Regulation (GDPR) 2016/679 and Croatian Data Protection Act (Zakon o provedbi Opće uredbe o zaštiti podataka, NN 42/18).
2. Information We Collect
2.1 Personal Data You Provide
- Contact Information: Name, email address, phone number, company name
- Business Information: VAT number, company address, position/title
- Communication Data: Messages, inquiries, project requirements
- Financial Information: Billing address, invoice details (we do not store payment card details)
2.2 Automatically Collected Data
Our website runs no analytics and sets no cookies. The only data collected automatically is what our hosting provider records for every request:
- Server Logs: IP address, date and time, page requested, browser and operating system reported by your browser
- No usage profiling: we do not measure time on page, referring websites, or build visitor profiles
- No cookies: see our Cookie Policy for the one local-storage item we use
3. Legal Basis for Processing
We process your personal data based on the following legal grounds:
| Purpose | Legal Basis | GDPR Article |
|---|---|---|
| Providing consulting services | Contract performance | Art. 6(1)(b) |
| Invoicing and accounting | Legal obligation | Art. 6(1)(c) |
| Marketing to existing clients | Legitimate interest | Art. 6(1)(f) |
| Newsletter subscription | Consent | Art. 6(1)(a) |
4. How We Use Your Information
We use your personal data for:
- Delivering software consulting services
- Processing payments and managing accounts
- Communicating about projects and services
- Sending service updates and technical notices
- Complying with legal obligations (tax, accounting)
- Improving our services and website
- Marketing (with consent or legitimate interest for B2B)
5. Data Sharing and Disclosure
We may share your data with:
5.1 Service Providers
- Cloud Services: Google Workspace, Microsoft Azure
- Payment Processing: Revolut Business
- Accounting: Licensed Croatian accounting firm
- Development Tools: GitHub, Toptal platform
5.2 Legal Requirements
We may disclose your data to comply with legal obligations, court orders, or government requests.
6. International Data Transfers
Some of our service providers are located outside the EU. We ensure appropriate safeguards:
- EU-US Data Privacy Framework for US providers
- Standard Contractual Clauses (SCCs) where required
- Adequacy decisions for approved countries
7. Data Retention
| Data Type | Retention Period |
|---|---|
| Client project data | Duration of contract + 3 years |
| Financial records | 11 years (Croatian tax law) |
| Marketing contacts | Until consent withdrawn or 2 years of inactivity |
| Hosting server logs | As retained by Firebase Hosting for security and diagnostics |
8. Your Rights Under GDPR
You have the following rights regarding your personal data:
- Right of Access (Article 15): Obtain confirmation and copies of your data
- Right to Rectification (Article 16): Correct inaccurate or incomplete data
- Right to Erasure (Article 17): Request deletion (“right to be forgotten”)
- Right to Restrict Processing (Article 18): Limit how we use your data
- Right to Data Portability (Article 20): Receive your data in machine-readable format
- Right to Object (Article 21): Object to processing based on legitimate interests
- Right to Withdraw Consent: Withdraw consent at any time
To exercise these rights, contact us at privacy@italk.hr
9. Data Security
We implement appropriate technical and organizational measures:
- SSL/TLS encryption for all data transfers
- Secure password policies and two-factor authentication
- Regular security audits and updates
- Limited access on need-to-know basis
- Data backup and disaster recovery procedures
10. Children’s Privacy
Our services are not directed to individuals under 18. We do not knowingly collect personal data from children.
11. Cookies and Tracking
This website sets no cookies and runs no analytics or tracking of any kind. The only thing stored on your device is your light/dark theme choice, in local storage, which never leaves your browser. See our Cookie Policy for details.
12. Third-Party Links
Our website may contain links to third-party sites. We are not responsible for their privacy practices. Please review their privacy policies.
13. Updates to This Policy
We may update this Privacy Policy periodically. We will notify you of significant changes via email or website notice.
14. Complaints
If you have concerns about our data processing, you have the right to lodge a complaint with:
Croatian Personal Data Protection Agency (AZOP) Agencija za zaštitu osobnih podataka Selska cesta 136, 10000 Zagreb Email: azop@azop.hr Phone: +385 1 4609 000 Website: azop.hr
15. Contact Information
For any questions about this Privacy Policy or your personal data:
Data Protection Contact: ITalk d.o.o. Attn: Privacy Officer IX. Južna obala 20, 10000 Zagreb, Croatia Email: privacy@italk.hr Phone: +385 98 967 9022
16. Language
This policy is written in English. In case of discrepancies between the English and Croatian versions, the English version prevails.