Privacy Policy

This Privacy Policy explains how Progress Point Direct ("we", "us", "our"), operating from Ilica 71, 10000 Zagreb, Croatia, collects, uses, stores and protects personal data in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation, GDPR) and applicable Croatian legislation.

1. Data Controller

The data controller is Progress Point Direct, Ilica 71, 10000 Zagreb, Croatia. You can contact us regarding data protection matters at: info@progress-point-direct.com or by phone at +385 95 366 9522.

2. Personal Data We Collect

We collect personal data in the following circumstances:

2.1 Contact and enquiry data

When you submit an enquiry through our contact form, we collect your name, email address, phone number (if provided), and the content of your message. This data is used solely to respond to your enquiry.

2.2 Service delivery data

When you engage our services, we may process personal data contained within the documents we help you organise. This data is processed strictly for the purpose of providing the organisational service. We do not retain copies of client documents after the project is complete.

2.3 Website usage data

We may collect technical data such as IP address, browser type, pages visited and time of visit through analytics cookies, if you have consented to their use. See our Cookie Policy for details.

3. Legal Basis for Processing

We process personal data on the following legal bases:

• Contract performance (Article 6(1)(b) GDPR): processing necessary to provide our services to you.
• Legitimate interests (Article 6(1)(f) GDPR): responding to enquiries and maintaining basic website functionality.
• Consent (Article 6(1)(a) GDPR): for optional analytics cookies, where you have given explicit consent.
• Legal obligation (Article 6(1)(c) GDPR): where processing is required by applicable Croatian or EU law.

4. How We Use Your Data

We use the personal data we collect to respond to enquiries, deliver our document organisation service, maintain records as required by law, and improve our website based on anonymised usage data (with consent).

We do not use your personal data for automated decision-making or profiling. We do not sell or rent your personal data to third parties.

5. Data Sharing

We do not share your personal data with third parties except in the following limited circumstances: where required by law or by order of a competent authority; where necessary to protect the rights, property or safety of Progress Point Direct or others; with service providers who assist us in operating our website (such as hosting providers), under appropriate data processing agreements.

6. Data Retention

Enquiry data is retained for up to 12 months after the last communication, unless a longer retention period is required by law or by an ongoing service relationship. Data processed as part of service delivery is not retained after project completion. Website analytics data (where consented) is retained in accordance with the analytics provider's standard retention periods.

7. Your Rights

Under GDPR, you have the following rights regarding your personal data:

• Right of access: you may request a copy of the personal data we hold about you.
• Right to rectification: you may request correction of inaccurate data.
• Right to erasure: you may request deletion of your data, subject to legal retention obligations.
• Right to restriction: you may request that we limit processing of your data in certain circumstances.
• Right to data portability: you may request your data in a structured, machine-readable format.
• Right to object: you may object to processing based on legitimate interests.
• Right to withdraw consent: where processing is based on consent, you may withdraw it at any time.

To exercise any of these rights, contact us at info@progress-point-direct.com. We will respond within 30 days. If you believe your rights have been infringed, you have the right to lodge a complaint with the Croatian Personal Data Protection Agency (AZOP), Martićeva 14, 10000 Zagreb, www.azop.hr.

8. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration or destruction. These include secure communication channels, access controls and regular review of our data handling practices.

9. International Transfers

We do not routinely transfer personal data outside the European Economic Area. Where any transfer does occur, we ensure appropriate safeguards are in place in accordance with GDPR requirements.

10. Changes to This Policy

We may update this Privacy Policy from time to time. The date at the top of this page indicates when it was last revised. Continued use of our website or services after changes take effect constitutes acceptance of the updated policy.

11. Contact

For any questions about this Privacy Policy or our data practices, contact us at:
Progress Point Direct, Ilica 71, 10000 Zagreb, Croatia
Email: info@progress-point-direct.com
Phone: +385 95 366 9522