Privacy Policy

Last updated: October 18, 2025

1. Introduction

This Privacy Policy explains how Refresh (“we”, “our company” or “agency”) collects, uses, and protects your personal data when you use our website or contact us through the contact form.
We respect your privacy and are committed to protecting your personal data in accordance with the General Data Protection Regulation (GDPR) and applicable laws of Croatia and the European Union.

2. Data We Collect

Through our contact form, we collect the following data:

  • Full name (required)
  • Email address (required)
  • Company name (optional)
  • Phone number (optional)
  • Project budget (required)
  • Message / project description (required)

This information is used solely for communication purposes and to prepare a proposal based on your inquiry.

3. Analytics

We use Umami Analytics to monitor website performance.
Umami does not use cookies and does not collect any personal data. All analytics are based on anonymous, aggregate information that cannot identify individual users.

4. Purpose of Data Processing

We process your data only for the following purposes:

  • Responding to your inquiries sent via the contact form
  • Preparing and sending project offers
  • Internal analysis to improve our services

We do not use your data for marketing purposes without your explicit consent.

5. Legal Basis for Processing

We process personal data in accordance with Article 6(1)(b) and (f) of the GDPR — processing is necessary to take steps at your request prior to entering into a contract and for our legitimate business interests.

6. Data Storage

Your data is stored securely on our servers and is not shared with third parties unless required by law.
We keep your data only as long as necessary to respond to your inquiry, for a maximum of 12 months from the last communication.

7. Your Rights

At any time, you have the right to:

  • Access your personal data
  • Request correction of inaccurate data
  • Request deletion (“right to be forgotten”)
  • Restrict processing
  • Object to processing
  • Request data portability

To exercise your rights, please contact us at contact@refresh.hr

8. Data Security

We implement technical and organizational measures to protect your data against unauthorized access, loss, or misuse.

9. Changes to This Policy

This Privacy Policy may be updated periodically. The updated version will always be available on this page with the date of the last modification.