Qupola

Legal

Privacy Policy

Last updated: 10 July 2026

PARAD, a sole proprietorship for computer services, consulting and digital marketing, owned by Siniša Necko, Martina Kontuša 12, Rijeka, Croatia, Personal Identification Number (OIB): 08648845078, e-mail: info@savjetnik.net (hereinafter referred to as “PARAD”, “the Business” or “the Controller”), respects your privacy and processes personal data in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR), the Croatian Act on the Implementation of the General Data Protection Regulation, and other applicable laws and regulations of the Republic of Croatia and the European Union.

This Privacy Policy explains which personal data we collect, the purposes for which we process it, the legal bases on which we rely, with whom we share it, how long we retain it, and the rights you have in relation to your personal data.

This Policy is available to users to provide information about the processing of personal data when using our websites (including qupola.io), our web platform (the Qupola platform, available at app.qupola.io) and our services.

1. Data Controller

PARAD, a sole proprietorship for computer services, consulting and digital marketing, owned by Siniša Necko
Martina Kontuša 12, Rijeka, Croatia
Personal Identification Number (OIB): 08648845078
E-mail: info@savjetnik.net

2. Personal Data We Collect

Depending on how you use our website, web platform and services, we may collect the following categories of personal data:

  • identification data, such as your first and last name and the information required to identify a user or contracting party;
  • contact details, such as your address, e-mail address and telephone number;
  • data relating to contracted services and payments, such as the type of service, amount, payment method, information required to issue an invoice, service performance status, and information related to a complaint or claim;
  • communication data, such as the content of enquiries, complaints, claims and other communications you have with us by e-mail, telephone or through a contact form;
  • user account data, where the web platform allows user registration;
  • technical data and data concerning the use of the website or platform, such as IP address, device type, browser type, language, date and time of access, pages viewed and basic usage logs;
  • data collected through cookies and similar technologies, in accordance with your choices;
  • publicly available review data – when providing our services, we process guest reviews of our clients' properties that are publicly available on third-party review platforms, including the reviewer's display name and review content as published there;
  • feedback data – messages that guests voluntarily submit through feedback forms provided by the platform, which are delivered to the business they concern.

We do not collect special categories of personal data unless you exceptionally provide such data to us yourself and an appropriate legal basis exists for its processing.

3. How We Collect Personal Data

We collect personal data:

  • directly from you when you complete a form, engage our services, open a user account, or submit an enquiry, complaint or claim;
  • automatically when you use the website or web platform, through cookies and similar technologies;
  • from our contractual partners where this is necessary for the performance of a contract or provision of a service, to the extent required to process payments, provide support or resolve complaints;
  • from publicly available sources, where the service contracted by our client consists of collecting and analysing publicly available guest reviews of their properties.

4. Purposes and Legal Bases for Processing

We process your personal data only where an appropriate legal basis exists or where you have provided us with valid consent.

4.1. Performance of a Contract and Steps Prior to Entering into a Contract

We process your data in order to:

  • receive and process your enquiry or request for services;
  • prepare an offer, enter into a contract and provide the contracted services;
  • issue invoices and enable payment processing and payment recording;
  • respond to enquiries related to an offer, contract, web platform or services;
  • handle complaints, claims and user requests;
  • enable the use of a user account, where this option is available.

The legal basis is the performance of a contract or taking steps at your request prior to entering into a contract.

4.2. Compliance with Legal Obligations

We process certain data in order to comply with legal obligations arising from applicable laws and regulations, particularly in the areas of accounting, taxation, consumer protection and complaint handling. The legal basis for this processing is compliance with a legal obligation to which the Controller is subject.

4.3. Legitimate Interests

We process certain data on the basis of our legitimate interests, provided that those interests are not overridden by your rights and freedoms. This may include:

  • ensuring information and network security and preventing misuse of the website and web platform;
  • maintaining internal records and business administration;
  • establishing, exercising or defending legal claims;
  • basic analytics concerning business operations and the use of services in aggregated form;
  • collecting and analysing publicly available guest reviews in order to provide the contracted service to our clients.

When we rely on legitimate interests, we take your rights and reasonable expectations into account and allow you to object to such processing where applicable.

4.4. Consent

On the basis of your consent, we may process data for:

  • sending newsletters, promotional offers and marketing communications electronically;
  • using analytics, functional and marketing cookies that are not strictly necessary for the operation of the website or platform;
  • personalised marketing and remarketing, where such activities are used and you have consented to them;
  • taking photographs, making recordings and publishing content for marketing purposes, where applicable.

You may withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

5. Recipients and Categories of Recipients of Personal Data

We may share your personal data only where this is necessary and permitted by applicable law, with the following categories of recipients:

  • payment service providers and payment processors, where necessary to process payments;
  • providers of accounting, tax and legal services;
  • providers of IT support, hosting, website and web platform maintenance, and security systems;
  • providers of e-mail delivery, newsletter and customer support services;
  • business partners involved in providing the contracted service, to the extent necessary;
  • competent authorities and institutions where required by law.

Where required, we enter into appropriate data processing agreements with processors.

6. Transfers of Personal Data Outside the European Economic Area

As a rule, we seek to process personal data within the European Economic Area (EEA). If individual service providers process data outside the EEA, the transfer will take place only where an appropriate safeguard is in place in accordance with the GDPR, for example on the basis of a European Commission adequacy decision, Standard Contractual Clauses or another permitted safeguard. For further information, you may contact us at info@savjetnik.net.

7. Retention of Personal Data

We retain personal data only for as long as necessary to fulfil the purpose for which it was collected, unless we are legally required to retain it for a longer period. As a general rule:

  • data relating to invoices and other accounting documents is retained for as long as required by applicable accounting, tax and other laws and regulations;
  • data relating to a contractual relationship is retained for the duration of that relationship and thereafter for as long as necessary to establish, exercise or defend legal claims;
  • data from enquiries and user communications is retained for as long as necessary to process the enquiry and for a reasonable period thereafter for record-keeping and the protection of legal interests;
  • data processed on the basis of consent is retained until consent is withdrawn, unless another legal basis exists for further processing;
  • data collected through cookies is retained for the periods stated in the cookie notice or consent settings.

At the end of the relevant retention period, data is deleted, anonymised or securely archived, unless a legal basis exists for its further retention.

8. Cookies and Similar Technologies

Our website and web platform may use cookies and similar technologies for technical operation, improving the user experience, analytics and, where applicable, marketing. Strictly necessary cookies are used where required for the operation of the website or platform. Analytics, functional and marketing cookies are used only where you have provided consent, where such consent is required.

You can review and change your choices at any time via in the website footer.

Strictly Necessary and Functional Cookies

NameService providerPurposeRetention periodType
qupola-cookie-consentPARAD (first party)Stores your cookie consent choices for this websiteUntil deleted by youlocalStorage
Authentication / session cookies (app.qupola.io)PARAD (first party)Keeping you securely signed in to the Qupola platformFor the duration of your session or until sign-outHTTP cookie

Statistics Cookies

NameService providerPurposeRetention periodType
– (none)PARAD (first party, EU servers)With your consent we use privacy-friendly, cookieless analytics that stores no identifiers on your device; only aggregate statistics are keptn/a – no data stored on your deviceCookieless analytics

Marketing Cookies

NameService providerPurposeRetention periodType
– (none)Marketing cookies are not currently usedn/a

9. Security of Personal Data

We implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Depending on the nature of the processing, these measures include access controls, system protection, security protocols, backups, restricting access to authorised persons, and cooperation with reliable processors.

10. Data Subject Rights

Subject to the conditions laid down in the GDPR, you have the following rights in relation to your personal data:

  • the right of access to your personal data;
  • the right to rectification of inaccurate or incomplete data;
  • the right to erasure of personal data (the right to be forgotten);
  • the right to restriction of processing;
  • the right to data portability;
  • the right to object to processing based on legitimate interests;
  • the right to withdraw consent at any time, where processing is based on consent;
  • the right to object to processing for direct marketing purposes;
  • the right to lodge a complaint with a supervisory authority.

To exercise your rights, you may contact us at info@savjetnik.net. To protect your data, we may request additional verification of your identity before acting on your request. We will respond to your request within one month, with the possibility of extending this period by a further two months in complex cases, in which case we will notify you within the legally prescribed period.

11. Right to Lodge a Complaint with a Supervisory Authority

If you believe that the processing of your personal data is contrary to applicable law, you have the right to lodge a complaint with the Croatian Personal Data Protection Agency (AZOP). The current contact details of the supervisory authority are available on its official website.

12. Children and Minors

Our services and web platform are not intended for children under the age of 16, unless a particular service is expressly designed for them and an appropriate legal basis exists. We do not knowingly collect the personal data of children under the age of 16 on the basis of their own consent. If we become aware that such data has been provided to us without the appropriate consent or authorisation of a parent or legal guardian, we will take appropriate measures.

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in the law, our business operations or the manner in which we process personal data. The current version will be published on the relevant website or web platform, together with the date of the latest revision.

See also: General Terms · Legal Data