General information
This Privacy Policy explains how we collect, use, and protect your personal information when you contact us or use any of our services.
Specifically, this notice outlines:
- the reasons we process your personal information
- the purposes for which your information is used
- whether providing your personal information is mandatory
- how long we retain your personal information
- whether your personal information is shared with other recipients
- whether your personal information is transferred to other countries
- whether we carry out automated decision-making or profiling using your personal information
Who are we
This website is owned and operated by C.M.G.C. d.o.o. Pula (hereinafter referred to as “CMGC”, “we”, “us”, or “our”). CMGC is registered with the Commercial Court in Pazin under company registration number (MBS) 130026814, with Tax Identification Number (OIB) HR80346735478.
Our registered office is located at:
Labinska 2C
52100 Pula
Croatia
For the purposes of applicable data protection laws, including the General Data Protection Regulation (GDPR), CMGC acts as the data controller of your personal data collected through this website.
How do we get information
We collect most of the personal information we process directly from you. We obtain your personal data in the following situations:
- when you contact us via the contact form on our website;
- when you subscribe to our e-newsletter;
- when you engage with us as a business partner; and
- when you download documents or materials made available on our website.
We may also automatically collect certain technical information when you use our website (such as IP address or browser information), as described in the relevant sections of this Privacy Policy.
Your data protection rights
Under applicable data protection laws, including the GDPR, you have a number of rights regarding your personal data. The rights available to you may depend on the legal basis on which we process your information.
Right of access – You have the right to request copies of your personal data. This right always applies, although certain legal exemptions may mean that you do not always receive all the information we process.
Right to rectification – You have the right to request that we correct inaccurate personal data and to complete any incomplete personal data. This right always applies.
Right to erasure – You have the right to request the deletion of your personal data in certain circumstances.
Right to restriction of processing – You have the right to request that we restrict the processing of your personal data in certain circumstances.
Right to object to processing – You have the right to object to the processing of your personal data where we rely on legitimate interests as our legal basis for processing.
Right to data portability – This right applies only to personal data you have provided to us. You may request that we transfer your data to another organization, or directly to you, where processing is based on your consent or on steps taken to enter into a contract and is carried out by automated means.
You are not required to pay any fee to exercise your rights. We will respond to your request within one month.
If you receive our newsletter, you may exercise your rights to rectification or erasure and unsubscribe at any time by updating your preferences or opting out via the link included in each newsletter message, which is managed by our newsletter service provider.
You can also exercise your rights by contacting us at legal@cmg.digital.
Data sharing and disclosure
We do not share your personal data with third parties for the purposes of direct marketing.
We use selected third-party service providers (data processors) to support the operation of our business and website, such as email marketing and analytics providers (for example, Mailchimp and Google). We have written contracts in place with all our data processors. These providers may process your personal data only on our documented instructions and are required to keep your information secure and confidential. They may not use your personal data for their own purposes or share it with other organizations, except as required by law.
Our data processors will retain your personal data only for the period we instruct and in accordance with our retention policies.
Where personal data is transferred outside the European Economic Area (EEA), we ensure that appropriate safeguards are in place, including the use of standard contractual clauses approved under applicable data protection laws.
Links to other websites
Our website may contain links to websites operated by other organizations (for example, Magnet or Talentlyft). This Privacy Policy does not apply to those external websites and we are not responsible for their privacy practices. We encourage you to read the privacy policy of any external websites you visit.
Legal basis for processing
We process your personal data only when we have a valid legal basis to do so under applicable data protection laws. Depending on the circumstances, we may rely on one or more of the following legal bases:
- Consent – where you have given us clear consent to process your personal data for a specific purpose (for example, subscribing to our newsletter);
- Performance of a contract – where processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract;
- Legal obligation – where processing is necessary for us to comply with a legal or regulatory obligation; and
- Legitimate interests – provided that your fundamental rights and freedoms do not override those interests (for example, responding to inquiries or maintaining the security of our website), the purpose of processing is to maintain and monitor the performance of our website and to continuously improve the site and the services it provides to our users. The legal basis for processing your personal data is either Article 6(1)(a) of the GDPR, where we rely on your consent (for example, for the use of optional cookies), or Article 6(1)(f) of the GDPR, where processing is necessary for our legitimate interests, such as maintaining the integrity of our IT systems and ensuring the continuity of our business.
Where we rely on your consent, you have the right to withdraw that consent at any time.
Contact form on our website
Purpose and lawful basis for processing – We collect personal data submitted through our website contact form in order to respond to your inquiries. The lawful basis for this processing is your consent in accordance with Article 6(1)(a) of the GDPR.
- What data do we collect? Your name and email address.
- Why do we need it? We use your email address to send you a reply to your inquiry.
- How do we use it? – We use your personal data solely for the purpose of responding to your request and providing the related service.
- How long do we keep it? – We retain this data only for as long as necessary to provide you with a complete response to your inquiry.
- What are your rights? – Because we rely on your consent to process the personal data submitted through the contact form, you have the right to withdraw your consent at any time. If you wish to withdraw your consent, you may contact us at legal@cmg.digital.
Visitors to our website
Analytics – When you visit our website, we use Google Analytics, a third-party analytics service, to collect standard internet log information and aggregated details about visitor behavior. We use this information to understand how visitors use different parts of our website and to help us improve its performance and functionality.
The information is processed in a way that does not directly identify individual users. We do not attempt, and do not permit Google to attempt, to identify the identities of visitors to our website.
If we collect personal data through our website, we will clearly inform you at the point of collection. We will explain what information is being collected and how it will be used.
Cookies – We use a cookies tool on our website to gain consent for the optional cookies we use. Cookies that are necessary for functionality, security, and accessibility are set and are not deleted by the tool. You can read more about how we use cookies, and how to change your cookie preferences, on our Cookie Policy page.
Hosting – We host our website on Azure, Microsoft Ireland Operations, Ltd. Our hosting servers are located in the EU. For more information, please visit https://azure.microsoft.com/en-us/explore/trusted-cloud/privacy or contact Microsoft via Support and Privacy Protection Requests.
Data retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
The retention period depends on the type of data and the purpose of processing. When personal data is no longer required, we will securely delete or anonymize it. In determining appropriate retention periods, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, and applicable legal requirements.
What are your rights? – As we process your personal data for our legitimate interests as stated above, you have the right to object to our processing of your personal data. There are legitimate reasons why we may refuse your objection, which depends on why we are processing it.
Our newsletter and other email communications
Purpose and legal basis for processing – We collect your personal data to provide you with our newsletter and other email communications, including information about our services and upcoming events. If you subscribe to our newsletter, we process your personal data on the basis of your consent in accordance with Article 6(1)(a) of the GDPR. Where you receive our newsletter as a business partner, we process your data on the basis of our legitimate interests under Article 6(1)(f) of the GDPR.
What data we collect – Your name and email address.
How we use your data – We use your email address to send you our newsletter and related communications. We also collect aggregated statistics on email openings and clicks using standard industry technologies (such as tracking pixels) to monitor and improve our communications. After subscribing, you will receive a confirmation email, and newsletters are typically sent once per month.
How long do we keep it – We retain your personal data for as long as you remain subscribed to our newsletter or continue to receive our email communications.
Your rights – Where processing is based on consent or legitimate interests for marketing purposes, you have the right to withdraw your consent or object to the processing of your personal data at any time. You may do so by contacting us at legal@cmg.digital or by unsubscribing via the link included in each newsletter.
Do we use any data processors? Service providers (data processors) – We use third-party email service providers, including Mailchimp and Brevo, to manage and deliver our newsletters. These providers process personal data on our behalf under contractual agreements that require them to protect your data and use it only in accordance with our instructions.
International data transfers – Your personal data may be transferred to and processed by Mailchimp (The Rocket Science Group LLC) and Brevo (Sendinblue SAS). Where personal data is transferred outside the European Economic Area, we ensure appropriate safeguards are in place, including the use of Standard Contractual Clauses or other lawful transfer mechanisms in accordance with applicable data protection laws.
Document download
Purpose and legal basis for processing – When you download documents from our website, we collect your email address in order to provide you with the requested materials and to inform you about our services and offers. The legal basis for processing your personal data is your consent in accordance with Article 6(1)(a) of the GDPR.
Your rights – Because we rely on your consent, you have the right to withdraw that consent at any time. If you wish to withdraw your consent, you may contact us at legal@cmg.digital.
Data retention – We retain your email address for a period of one year from the date of collection.
Data storage and security – Your email address is stored securely on our servers located in Pula, Croatia, or on Microsoft servers located within the European Union.
Service providers and international transfers – Apart from Microsoft, which provides hosting and infrastructure services as our data processor, we do not use additional data processors in connection with document downloads. Your personal data is not transferred outside the European Union.
Changes to privacy policy
We review our Privacy Policy regularly to ensure it remains accurate and up to date. We reserve the right to amend this Privacy Policy at any time. We encourage you to review this page periodically to stay informed of the latest version. The previous revision was dated March 2025, and the current revision is dated February 2026.