Privacy Policy

Introduction

nexolumira.top d.o.o. ("we," "our," or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website nexolumira.top and use our professional mentorship services.

We are the data controller for the purposes of the General Data Protection Regulation (GDPR) and other applicable data protection laws. Our registered office is located at Ilica 99, 52780 Pula, Istria, Croatia, and our registration number is 852369741.

Data Collection

The data we collect from you includes personal information that you voluntarily provide to us when you interact with our website and services. We collect the following categories of personal data:

• Contact Information: Name, email address, phone number, and postal address
• Professional Information: Career background, professional goals, industry experience, and educational qualifications
• Communication Data: Records of correspondence, enquiries, feedback, and support requests
• Technical Information: IP address, browser type, operating system, referring website, and pages visited
• Usage Data: Information about how you interact with our website and services
• Marketing Data: Your preferences for receiving marketing communications and information about our services

We collect this information when you contact us through our website forms, email, phone, or during mentorship consultations and sessions.

How We Use Your Information

We use your personal data for the following purposes, based on various legal grounds under GDPR:

• Service Provision: To provide mentorship services, match you with appropriate mentors, schedule sessions, and deliver personalised guidance (Legal basis: Contract performance)
• Communication: To respond to your enquiries, provide customer support, and send service-related notifications (Legal basis: Contract performance and legitimate interests)
• Service Improvement: To analyse usage patterns, improve our website functionality, and enhance our service offerings (Legal basis: Legitimate interests)
• Marketing: To send you information about our services, industry insights, and promotional materials, where you have consented (Legal basis: Consent)
• Legal Compliance: To comply with legal obligations, resolve disputes, and enforce our agreements (Legal basis: Legal obligation and legitimate interests)
• Security: To protect against fraud, unauthorised access, and other security threats (Legal basis: Legitimate interests)

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose.

Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner.

Our website uses the following types of cookies:

• Necessary Cookies: Essential for website functionality and cannot be disabled
• Analytics Cookies: Help us understand how visitors interact with our website (Google Analytics)
• Functional Cookies: Remember your preferences and settings
• Marketing Cookies: Used for advertising and remarketing purposes (Google Ads)

For detailed information about our cookie usage, please refer to our Cookie Policy.

Data Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following limited circumstances:

• Service Providers: With trusted third-party service providers who assist us in operating our website and providing our services (e.g., hosting providers, email services)
• Mentors: With assigned mentors as necessary to provide mentorship services, subject to confidentiality agreements
• Legal Requirements: When required by law, court order, or governmental authority
• Business Protection: To protect our rights, property, or safety, or that of our users or others
• Business Transfers: In connection with a merger, acquisition, or sale of assets, subject to confidentiality requirements

All third-party service providers are carefully vetted and required to maintain appropriate security measures and confidentiality obligations.

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Client Records: Maintained for the duration of the mentorship relationship and up to 7 years thereafter for legal and business purposes
• Communication Records: Retained for up to 3 years from the date of last contact
• Website Analytics: Aggregated and anonymised data may be retained indefinitely for statistical purposes
• Marketing Data: Retained until you withdraw consent or up to 2 years from last engagement
• Financial Records: Retained for 7 years in accordance with Croatian accounting and tax requirements

When personal data is no longer required, we will securely delete or anonymise it in accordance with our data retention and disposal procedures.

Your Rights

Under GDPR and applicable data protection laws, you have the following rights regarding your personal data:

• Right of Access: Request copies of your personal data and information about how we process it
• Right to Rectification: Request correction of inaccurate or incomplete personal data
• Right to Erasure: Request deletion of your personal data in certain circumstances
• Right to Restrict Processing: Request limitation of processing in certain circumstances
• Right to Data Portability: Request transfer of your data to another service provider in a structured format
• Right to Object: Object to processing based on legitimate interests or for direct marketing purposes
• Right to Withdraw Consent: Withdraw consent for processing where consent is the legal basis

To exercise any of these rights, please contact us using the information provided below. We will respond to your request within one month, though this may be extended in complex cases.

You also have the right to lodge a complaint with the Croatian Personal Data Protection Agency (AZOP) or your local data protection authority if you believe we have not handled your personal data properly.

Data Security

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication procedures
• Employee training on data protection and security
• Secure backup and disaster recovery procedures
• Regular monitoring for security breaches and incidents

While we strive to protect your personal information, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security but are committed to maintaining industry-standard protection measures.

International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA) where our service providers are located. When we transfer your data outside the EEA, we ensure appropriate safeguards are in place, including:

• European Commission adequacy decisions
• Standard Contractual Clauses approved by the European Commission
• Binding Corporate Rules or certification schemes
• Other legally recognised transfer mechanisms

We regularly review our international transfer arrangements to ensure they remain compliant with applicable data protection requirements.

Children's Privacy

Our services are not intended for individuals under the age of 16, and we do not knowingly collect personal information from children under 16. If we become aware that we have inadvertently collected personal information from a child under 16, we will take immediate steps to delete such information.

If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately so we can take appropriate action.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

• Post the updated Privacy Policy on our website
• Update the "Last Updated" date at the top of this policy
• Notify you by email or through our website if the changes are significant
• Obtain your consent if required by applicable law

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us:

For privacy-related enquiries, please contact us at [email protected], and we will respond within 30 days of receiving your request.