Legal

Privacy policy

Last updated: September 2026  ·  Adventure Spirit d.o.o.

1 Controller and contact

The controller of personal data is:

For any question about data protection, or to exercise your rights as a data subject, write to the address above.

2 What we collect and why

We collect only what is necessary to provide our services and to communicate with users:

We do not collect special categories of personal data (Art. 9 GDPR) and we do not knowingly collect data from anyone under 16.

3 Cookies

This website and the GRC platform use cookies to function correctly and to improve the user experience. Below is the complete list of what we set:

Note: for consent data we use localStorage (browser storage) rather than classic HTTP cookies, which means the data stays locally on your device and is never sent to the server.

Managing your consent

You can change or withdraw your consent at any time:

4 Notifications about new articles

The site offers a form for subscribing to notifications about new articles in the knowledge base. Subscribing is voluntary and the site can be used in full without it.

You may withdraw consent at any time, either by writing to info@adventurespirit.hr or through the unsubscribe link in every notice. Withdrawal does not affect the lawfulness of processing carried out before it.

We use the address for that purpose only. We do not pass it to third parties, do not use it for profiling, and do not combine it with the visit statistics described in the next section.

Forms on the site - contact, the report request from the self-assessment tool, and the notification sign-up - are delivered through a form-processing service, which acts as a processor for that purpose.

5 Cookieless visit statistics

We keep visit statistics using our own solution on our own server. We do not use Google Analytics or any other external measurement tool, so your data never leaves our infrastructure.

For this processing we set no cookies and store nothing on your device. The consent requirement under the electronic communications rules therefore does not apply, and the legal basis is our legitimate interest in understanding how the site is used (Art. 6(1)(f) GDPR).

What we record

Why an individual cannot be tracked

We do not store your IP address. It is used only at the moment of the visit, as input to a cryptographic hash function together with a secret value and browser data. The result is a 16-character string from which the IP address cannot be reconstructed.

The secret value changes every day at midnight UTC and the old one is deleted. The same visitor therefore receives a completely different fingerprint the next day, so visits cannot be linked across days or attributed to a particular person. The result is aggregate statistics, not a profile.

We respect the Do Not Track and Global Privacy Control settings in your browser. If either is enabled, we record nothing. No statistics are collected if you disable JavaScript either.

Records are kept in monthly files on our server, are not publicly accessible and are not shared with third parties.

6 Recipients and transfers outside the EU

We do not sell your personal data and do not pass it to third parties for marketing purposes.

For technical infrastructure we use the following processors:

Every processor we work with handles data solely on our instructions and in accordance with the GDPR.

7 Retention periods

8 Your rights as a data subject

Under the GDPR (Regulation (EU) 2016/679) you have the following rights:

Send requests to info@adventurespirit.hr marked "GDPR request". We reply within 30 days of receipt (Art. 12(3) GDPR).

If you believe we process your data unlawfully, you have the right to lodge a complaint with the supervisory authority:

9 Data security

We apply technical and organisational measures appropriate to the state of the art:

In the event of a breach presenting a high risk to data subjects, we will notify you without undue delay in accordance with Art. 34 GDPR.

10 Changes to this policy

We may update this privacy policy from time to time. Any material change will be published on this page with a new "Last updated" date. Users of the GRC platform will also be notified by email of material changes.

We recommend reviewing this page periodically.

11 Privacy contact