Version: 2026-06-03
Last updated: 3 June 2026
Effective date: 3 June 2026
Privacy Policy
This Privacy Policy (the "Policy") describes how HM DIGITAL, obrt za programiranje i digitalne usluge ("HM Digital", "we") collects, processes and protects the personal data of visitors to the hmdigital.hr website (the "Website"), in accordance with Regulation (EU) 2016/679 (GDPR) and the Croatian Act on the Implementation of the GDPR (NN 42/2018). This Policy applies only to the Website; the HM Digital Medical cloud system is governed by a separate privacy policy available to users of that system.
1. Data controller and contact
The controller of personal data collected through the Website is:
- Name: HM DIGITAL, obrt za programiranje i digitalne usluge (sole proprietorship)
- Owner: Hrvoje Matošević
- Registered office: Mašić 58, 35428 Dragalić, Republic of Croatia
- OIB (tax ID): 15881939647
- MBS: 99053861
- Privacy contact and exercise of rights: info@hmdigital.hr
- Phone: +385 97 7120 800
2. What data we collect
- Contact form data — when you send us an inquiry via the contact form or the free assessment form, we collect the data you enter yourself: name, e-mail address and the contents of your message (including any details you voluntarily provide in the project description).
- Technical data — when you visit the Website, the server hosting it automatically records standard technical data (IP address, browser type, date and time of access) for security and technical operation purposes.
- Analytics data — only with your consent, Google Analytics 4 collects data about how the Website is used (pages visited, visit duration, approximate location, device type). Details are described in our Cookie Policy.
We do not collect special categories of personal data (Art. 9 GDPR) or data about children, and we ask you not to enter such data into the forms.
3. Purposes and legal bases of processing
- Responding to inquiries and preparing quotes — legal basis: steps prior to entering into a contract at the data subject's request (Art. 6(1)(b) GDPR).
- Security and technical operation of the Website — legal basis: legitimate interest (Art. 6(1)(f) GDPR).
- Website usage analytics (Google Analytics) — legal basis: consent (Art. 6(1)(a) GDPR). You may withdraw your consent at any time without consequence.
4. Recipients and processors
We use the following service providers to operate the Website:
- GitHub, Inc. (USA) — Website hosting (GitHub Pages); processes technical access data.
- Formspree, Inc. (USA) — processing and delivery of messages submitted via the contact forms.
- Google Ireland Ltd. / Google LLC (Ireland/USA) — Google Analytics 4, only with your consent.
We do not sell your personal data or share it with third parties for marketing purposes.
5. Data transfers outside the EU/EEA
The above US-based service providers (GitHub, Formspree, Google LLC) are certified under the EU-U.S. Data Privacy Framework, or the transfer is based on the European Commission's Standard Contractual Clauses (Art. 46 GDPR), ensuring an adequate level of data protection.
6. Retention periods
- Form inquiries — kept for a maximum of 2 years from the last communication, unless the inquiry results in a business engagement (in which case statutory retention periods for business records apply).
- Server logs — according to the hosting provider's policies, as a rule short-term.
- Analytics data — according to Google Analytics settings; cookie lifetimes are described in the Cookie Policy.
7. Your rights
Under the GDPR, you have the right to:
- access your personal data (Art. 15),
- rectification of inaccurate data (Art. 16),
- erasure ("right to be forgotten", Art. 17),
- restriction of processing (Art. 18),
- data portability (Art. 20),
- object to processing based on legitimate interest (Art. 21),
- withdraw consent at any time, without affecting the lawfulness of processing prior to withdrawal (Art. 7(3)).
To exercise your rights, contact us at info@hmdigital.hr. We respond to requests without undue delay and at the latest within one month. If you believe your data is being processed unlawfully, you have the right to lodge a complaint with the supervisory authority — the Croatian Personal Data Protection Agency (AZOP), Selska cesta 136, 10000 Zagreb, azop.hr.
8. Cookies
Detailed information about the cookies and similar technologies used by the Website, including how to manage your consent, is available in our separate Cookie Policy.
9. Changes to this Policy
We may amend this Policy from time to time. The current version, with its last-updated date, is always published on this page. Significant changes will be clearly highlighted on the Website.