Information on the Processing of Personal Data

1. INTRODUCTION

Through this Privacy Statement, we provide you with information about which personal data we collect, how we process your personal data, what rights you have regarding the processing and protection of your data, and how you can exercise those rights.

We process your personal data in accordance with the provisions of Regulation (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (hereinafter: the General Data Protection Regulation or GDPR), as well as the national Act on the Implementation of the General Data Protection Regulation.

The General Data Protection Regulation contains a set of rules ensuring that personal data is processed in accordance with the rights and fundamental freedoms of individuals. The General Data Protection Regulation also enables the free movement of personal data within the European Union without restrictions or prohibitions.

This Privacy Statement on the processing of personal data (hereinafter: the Statement) incorporates the requirements of the General Data Protection Regulation and the Act on the Implementation of the General Data Protection Regulation.

We process and use your personal data lawfully, fairly and transparently, while protecting the security of your personal data against unauthorised or unlawful processing and applying the highest technical, security and organisational protection measures.

2. WHOSE DATA DO WE PROCESS?

This Statement applies to every natural person who uses the services of Webpower Adria d.o.o., operating under the Webpower by Spotler brand (hereinafter: Webpower by Spotler), as well as to all other natural persons who participate in direct or indirect business relationships with Webpower Adria d.o.o. or who are in any way connected or may become connected with Webpower Adria d.o.o. as the data controller.

Webpower Adria d.o.o. processes personal data provided by its website visitors, newsletter subscribers, clients and partners, as well as natural persons who have completed a form on our website.

3. INFORMATION ABOUT THE DATA CONTROLLER

Who are we?
Webpower Adria d.o.o., operating under the Webpower by Spotler brand, provides professional email marketing and digital communication services and offers its clients Webpower and other tools from the Spotler Group portfolio. Webpower Adria d.o.o. is part of Spotler Group, the parent group founded in 2016 and headquartered in the Netherlands. Tools and solutions such as Webpower and other products within the Spotler portfolio are owned by Spotler Group. Webpower by Spotler provides local support for the use of the software as well as training related to the use of the tools. The registered office of Webpower Adria d.o.o. is located at Zavrtnica 17, Zagreb, Croatia.

Who is responsible for processing your data and whom can you contact regarding this?
The data controller is Webpower Adria d.o.o., Zavrtnica 17, Zagreb, OIB (Personal Identification Number) 19973542832, registered with the Commercial Court in Zagreb under company registration number (MBS) 081017998.

Contact details:

Webpower Adria d.o.o.
Zavrtnica 17
10000 Zagreb (City of Zagreb)
Tel. +385 95 617 3006

4. PERSONAL DATA, COLLECTION AND USE

4.1. Which categories of personal data do we process?
We obtain information about your personal data directly from you as a user of our services. Through our website registrations, newsletter subscriptions, requests for software demonstrations, registrations for our events and requests for consultations with our experts, we collect personal data and company information. Personal data means personal information that you have voluntarily provided through forms on our website, social media or through the user profile form within our newsletter, which is necessary for the purpose of providing services or establishing a business relationship and, in the case of newsletter subscriptions, for sending marketing communications.

When you browse our website or use our services, we may collect information about your visit to our website, your use of our services and your web browsing activity. This information may include your IP address, operating system, browser ID, browsing activity and other information about how you interact with our website or services. We may collect this data as part of log files and through the use of cookies or other tracking technologies. Read more about cookies here.

To ensure that our prospective customers and clients receive the most relevant information, we use certain automated processes for sending communications. These processes may help us create email content or indicate the most appropriate time to contact you.

For the purpose of providing services (preparing offers and establishing business contacts), we process the following data:

• first name
• last name
• e-mail address
• company
• mobile number

For the purposes of the opt-in process, i.e. sending newsletters, we process the following data:

• e-mail address
• first name
• last name
• company

In such cases, the legal basis for processing personal data under Article 6(1)(b) is that processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

For what purposes do we process personal data?
We use your data only for the purposes specified at the time of collection and/or in this Statement. We collect personal data through the contact form on our website, including first and last name, email address, telephone/mobile phone number and the content of the enquiry, in order to send offers to prospective clients and establish business contacts. We also collect email addresses through newsletter subscriptions. We process data provided through newsletter subscriptions in order to send (personalised) newsletters in which subscribers receive exclusive reports, case studies, blog articles and news related to email marketing and digital communication, as well as promotional communications from Webpower by Spotler. Data is accessible to employees who require it to perform their work. You may unsubscribe from our newsletter at any time using the unsubscribe link included in each newsletter. Apart from the above, we collect personal data only when you voluntarily make it available to us by providing your personal data through our contact form. We also process your personal data for the purpose of initiating and/or conducting proceedings, based on the legal ground that processing is necessary for the legitimate interests pursued by the data controller, namely the establishment, exercise or defence of legal claims.

Information about the data processor
For the management of newsletter subscriptions and newsletter delivery, Webpower by Spotler uses the MailPro platform and the services of Spotler Group B.V. in the Netherlands, the parent company of Webpower Adria d.o.o., which, pursuant to an agreement with Webpower Adria d.o.o., acts as a data processor, acts solely on our instructions and takes all necessary measures to protect personal data.

The service provider is:

Spotler Group B.V.
Henri Faasdreef 312
2492 JP The Hague
The Netherlands

Legal basis for processing
Consent for direct marketing, i.e. for sending newsletters – Article 6(1)(a).
For personal data collected through the contact form on the website, including first and last name, email address, telephone/mobile phone number and the content of the enquiry, for the purpose of sending offers to prospective clients and establishing business contacts, as well as data collected through newsletter subscriptions, the legal basis for processing personal data is the legitimate interest of the Data Controller in establishing business cooperation or responding to enquiries submitted through the website contact form.

Period for which personal data will be stored
We retain your data for as long as there is a purpose for its storage and processing:

• Newsletter subscriber data: for the duration of the consent to receive the newsletter
• Data contained in contractual documentation (business cooperation) is retained for 5 years, unless legal proceedings have been initiated in relation to a particular business relationship, in which case personal data is processed for 5 years following the final and binding conclusion of the legal proceedings
• In the event of late payment of invoices, the Data Controller processes personal data for the purpose of collecting outstanding claims. The legal basis for processing personal data is that processing is necessary for the legitimate interests of the Data Controller, and the data is retained for 3 years from the date on which the claim becomes time-barred.

Where no retention period for personal data has been specified above for other purposes of personal data processing, the criteria for determining the personal data retention period include the following:

1. For what purpose do we collect personal data?
2. What is the legal basis for processing personal data?
3. How long is the personal data required to fulfil a specific lawful purpose?
4. Are we subject to a legal obligation to retain personal data? (In such cases, we retain the data for the period prescribed by law.)

Security and storage of personal data
Personal data is stored within the European Economic Area. Personal data in digital form is stored on the Company’s premises and within its IT systems, as well as on the servers of trusted partners located at BIT B.V., Galileïlaan 19, 6716 BP Ede, the Netherlands (hosting data centre for the MailPro software), and IT JEDAN d.o.o., Ulica Ive Drmića 10, Zagreb (mobile marketing services). We take all necessary organisational and technical measures to ensure that your personal data is secure and protected against loss, destruction, alteration, falsification, manipulation and/or unauthorised access. We undertake to notify you and the competent authority in the event of a personal data breach. We take measures to ensure that the data we collect and process is handled in accordance with the provisions of this Statement and applicable legal requirements. Where we share personal data with third parties, we use appropriate legal and technical mechanisms to protect your personal data against breaches.

COOKIE POLICY

What are cookies?
Cookies are small files that your browser stores on your computer or mobile device when you visit our website. Cookies allow the website to remember your actions and preferences over a longer period of time, so you do not need to re-enter them each time you return to the website or browse its different pages.

How do we use cookies?
We use cookies on our website to enable certain technical features and provide you with a positive user experience. We also use statistical cookies that enable web analytics, i.e. analysis of the use of our website in order to monitor website performance and user experience and improve the quality and content of the services we provide.We do not use cookies or similar technologies to track your interests and send marketing materials. For the processing of this data for analytical purposes, we use the cloud-based Google Analytics service.

The service provider is:

Google LLC
1600 Amphitheatre Pkwy
Mountain View, California 94043
USA

Which cookies do we use?

How can cookies be disabled?
If you wish, you may disable or delete cookies from your browser or from a specific website at any time. You can delete or block cookies through your web browser or by using specialised software. More detailed information about cookies and browser settings is available at www.allaboutcookies.org.

RIGHTS OF DATA SUBJECTS

You may contact Webpower Adria d.o.o. as the data controller at any time to exercise your rights under the General Data Protection Regulation using the contact details provided in this Statement.

Webpower Adria d.o.o. will inform you of any action taken without undue delay and no later than one month after receiving your request. In exceptional cases, this period may be extended by a further two months where necessary, taking into account the complexity and number of requests. In such a case, Webpower Adria d.o.o. will inform you within one month of receiving the request and explain the reasons for the delay.

If you submitted your request electronically, the information will be provided electronically where possible, unless you have requested otherwise.

All communications and actions undertaken by Webpower Adria d.o.o. in connection with the exercise of the rights listed below will be free of charge. However, where your requests are manifestly unfounded or excessive, particularly because of their repetitive nature, Webpower Adria d.o.o. may refuse to act on your requests.

You may contact Webpower Adria d.o.o., as the data controller, to exercise the following rights:

(1) Right of access
You have the right to obtain confirmation from Webpower Adria d.o.o., as the data controller, as to whether your personal data is being processed and, where that is the case, you have the right to access your personal data and the information specified in Article 15 of the General Data Protection Regulation, including, for example, the purposes of processing, categories of personal data and retention periods.

Personal data, with the exception of Google Analytics data, is not transferred to third countries or international organisations, and you have the right to be informed of the appropriate safeguards relating to such transfers.

At your request, Webpower Adria d.o.o. will provide you with a copy of the personal data being processed. For any additional copies requested, Webpower Adria d.o.o. may charge a reasonable fee based on administrative costs. Where the request is submitted electronically, and unless otherwise requested, Webpower Adria d.o.o. will provide the information in a commonly used electronic format.

(2) Right to rectification
You have the right to obtain from us, without undue delay, the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you also have the right to have incomplete personal data completed, including by providing a supplementary statement.

(3) Right to erasure (“right to be forgotten”)
You may request that Webpower Adria d.o.o., as the data controller, erase your personal data where one of the grounds set out in Article 17 of the General Data Protection Regulation applies (for example, where the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; where the consent on which the processing is based has been withdrawn and there is no other legal ground for the processing; where personal data must be erased in order to comply with a legal obligation under EU law or the laws of the Republic of Croatia; where the data has been unlawfully processed; or where an objection to direct marketing has been submitted).

Please note that Webpower Adria d.o.o. may not erase your personal data where its processing is necessary, for example, for compliance with a legal obligation requiring retention or for reasons relating to the establishment, exercise or defence of legal claims.

(4) Right to restriction of processing
You may request that Webpower Adria d.o.o. restrict the processing of your personal data where one of the circumstances specified in Article 18 of the General Data Protection Regulation applies, including, for example, where the accuracy of your personal data needs to be verified.

(5) Right to data portability
Where the processing of your personal data is based on consent or is necessary for the performance of a contract or in order to take steps prior to entering into a contract, and where the processing is carried out by automated means, you may request to receive the personal data you have provided in a structured, commonly used and machine-readable format.

(6) Right to object
Where the processing of personal data is based on our legitimate interests, you have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you.If you submit such an objection, we will no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or where the processing is required for the establishment, exercise or defence of legal claims. At the end of this Statement, as required by Article 21(4) of the General Data Protection Regulation, we additionally draw your attention to this right.

(7) Automated individual decision-making, including profiling
In the case of automated decision-making, including profiling (e.g. calculating an overall score as part of an assessment), Article 22 of the General Data Protection Regulation gives you the right not to be subject to a decision based solely on automated processing of your personal data, including profiling, which produces legal effects concerning you or similarly significantly affects you, unless the decision:

a) is necessary for entering into, or performance of, a contract between you and Webpower Adria d.o.o.;
b) is authorised by the law of the Republic of Croatia or the law of an EU Member State to which the data controller is subject and which also lays down suitable measures to safeguard the data subject’s rights, freedoms and legitimate interests;
c) is based on your explicit consent.

In the cases referred to in points a) and c), Webpower Adria d.o.o. will implement appropriate measures to safeguard your rights, freedoms and legitimate interests, and you may exercise your right to obtain human intervention from Webpower Adria d.o.o., express your point of view and contest the decision.

(8) Right to lodge a complaint with the competent data protection authority

Without prejudice to your right to seek an administrative or judicial remedy, if you believe that the processing of your personal data by Webpower Adria d.o.o. infringes the General Data Protection Regulation and/or applicable legislation of the Republic of Croatia, you may lodge a complaint with the Croatian Personal Data Protection Agency, Ulica Metela Ožegovića 16, 10 000 Zagreb.

FINAL PROVISIONS

Contact information for exercising your rights
Croatian law applies to all matters relating to this Privacy Statement.
These rules entered into force on 1 January 2022.
Please contact us by telephone at +385 95 617 3006.
We will process your enquiries and requests without undue delay and in accordance with our legal obligations and will inform you of the measures we have taken.

Webpower Adria d.o.o. reserves the right to amend this Privacy Statement. Any changes will be published on this page. In the event of significant changes, we will notify you by email or by other appropriate means, for example when you next access the website. This page was last updated on 11 September 2026.

All your questions, comments or requests regarding this Statement and Privacy Policy are welcome. You can contact us by email at info@webpower.hr.

Our location:
Webpower Adria d.o.o.
Webpower by Spotler
Zavrtnica 17
10 000 Zagreb, Croatia