Privacy Policy

1. Data we collect

• Identity and contact data: your name, email address and phone number.
• Messenger data: when you contact us on WhatsApp or Telegram, your name and phone number or username as shown in the messenger, the content of your messages, and the photos, documents, voice messages and other media you send.
• Order details: the information you enter in a service intake form, such as a cadastre number, property address, municipality, the purpose of the request, and document details.
• Payment data: card payments are handled by Paddle; we do not receive or store your full card number. We receive confirmation of payment and limited transaction details.
• Technical and usage data: information about your device and how you use the website, including via cookies and similar technologies.

2. How and why we use your data

• To provide the service you ordered and deliver the result (performance of a contract).
• To process your payment and prevent fraud (contract / legitimate interests).
• To communicate with you about your order and respond to enquiries.
• To comply with legal, accounting and tax obligations.
• With your consent, to send you optional updates; you can withdraw consent at any time.

3. WhatsApp and Telegram

When you write to us on WhatsApp or Telegram, your messages and our agents’ replies are stored in your client record in our customer relationship management (CRM) system. We do this so that:

• we can answer your enquiry and advise you on properties and services (steps taken at your request before or under a contract);
• any of our agents can continue the conversation without asking you to repeat what you have already told us (legitimate interests);
• we can check the quality and accuracy of our agents’ advice, including with automated tools that summarise conversations and flag unanswered questions (legitimate interests).

We send WhatsApp template messages only to clients who already have a conversation with us, and we do not use messenger data for unrelated marketing without your consent. You can ask us at any time to stop writing to you on a messenger.

WhatsApp is provided by Meta and Telegram by Telegram Messenger. Their own privacy policies govern how they process your data as messenger providers.

4. Who we share data with

We share personal data only as needed to provide the service and run our business, including with:

• Paddle, our Merchant of Record, to process payments and issue receipts;
• government authorities, courts, notaries and sworn translators, where this is necessary to fulfil your order;
• Meta (WhatsApp Business Platform) and Telegram, which carry the messages between you and us;
• a WhatsApp Business Solution Provider, where we use one to connect our CRM to WhatsApp;
• providers of AI language models that process conversation content on our instructions to produce summaries and quality checks;
• service providers that host our website, CRM and databases, store media files, send email, and provide account/authentication functionality, acting as our processors under appropriate agreements.

We do not sell your personal data.

5. International transfers

Some of our providers may process data outside Montenegro. Where this happens, we rely on appropriate safeguards (such as adequacy decisions or standard contractual clauses) to protect your data.

6. How long we keep data

We keep order and contact data for as long as needed to provide the service and to meet legal, accounting and tax retention requirements, after which it is deleted or anonymised.

Messenger conversations are kept while you remain our client and for 3 years after our last contact with you, after which they are deleted or anonymised. Where the law requires longer retention — for example anti-money-laundering, accounting or tax records of a completed transaction — we keep only those records, and only for the period the law requires.

7. Your rights

Subject to applicable law, you have the right to access, correct, delete or restrict the processing of your data, to object to processing, to data portability, and to withdraw consent. You also have the right to lodge a complaint with the Montenegrin data-protection authority (Agencija za zaštitu ličnih podataka).

To ask us to delete your data, including your messenger conversations, follow the instructions on our Data Deletion page (linked at the bottom of every page of this website) or write to us using the contact details below. We respond within 30 days.

To exercise any of these rights, contact us using the details below.

8. Cookies

We use cookies and similar technologies to operate the website, remember your preferences and understand usage. You can control cookies through your browser settings; disabling some cookies may affect how the website works.

9. Security

We use appropriate technical and organisational measures to protect your data against unauthorised access, loss or misuse. No method of transmission or storage is completely secure, but we work to protect your information.

10. Contact

For any privacy question or to exercise your rights, contact us using the details below.