Privacy policy

Protecting the privacy of our visitors is one of our priorities. We therefore invite you to review the privacy terms that we provide below.

PRIVACY POLICY

Protecting the privacy of our visitors and clients is one of the top priorities of Lumen Spei d.o.o. This Privacy Policy explains how we collect, use, disclose, and safeguard your Personal Data when you visit our website (lumenspei.com) or interact with our services, in full compliance with the General Data Protection Regulation (GDPR) and applicable local data protection laws.

1. Data Controller

The data controller responsible for your personal data is:

• Company Name: Lumen Spei d.o.o.
• Address: Ivana Gundulića 5, Osijek, Croatia
• Email: dpo@lumenspei.com

2. Which Personal Data Do We Collect and Why?

We collect and process your Personal Data under different legal bases, depending on how you interact with our website:

1. Browsing Data (Technical Logs)

During standard use, our website software automatically collects certain technical data transmitted via standard Internet communication protocols.

• Data collected: IP address, browser type, domain names, URI (Uniform Resource Identifier) addresses, time of the request, method used to submit the request to the server, file size received in response, server status code (success, error, etc.), and operating system details.
• Purpose: To ensure the correct functioning of the website, optimize user experience, and maintain cybersecurity (detecting potential malicious attacks).
• Legal Basis: Legitimate interest (Article 6(1)(f) GDPR).
• Retention: This data is primarily used for anonymous statistical purposes and is automatically deleted or anonymized shortly after processing.

1. Contact and Inquiry Data

When you voluntarily reach out to us via contact forms, request offers, download materials, or send us an email.

• Data collected: Full name, email address, company name (if applicable), and any information you provide within your message or offer request.
• Purpose: To respond to your inquiries, provide requested business offers, and manage potential or existing customer relationships.
• Legal Basis: Performance of a contract or taking steps prior to entering into a contract (Article 6(1)(b) GDPR).

1. Marketing and Newsletter Data

If you actively subscribe to receive updates from us.

• Data collected: Full name and email address.
• Purpose: To send information about our products, IT services, and marketing materials.
• Legal Basis: Explicit Consent (Article 6(1)(a) GDPR). You can withdraw your consent at any time by clicking the “unsubscribe” link in any email or by contacting us directly.

1. Photos and Video Footage

• Data collected: Images and video recordings captured during our official business presentations, workshops, and receptions.
• Purpose: Public relations, promoting the company’s achievements, and publishing event recaps on our website and social media channels.
• Legal Basis: Legitimate interest of the company to present its business activities (Article 6(1)(f) GDPR) or explicit Consent where required by law.

3. Cookies and Tracking Technologies

Cookies are small text files placed on your device to collect standard internet log information and visitor behavior patterns.

• How We Use Them: We utilize cookies to monitor website usage, compile statistical reports on site activity, and enhance your overall browsing experience.
• Your Choice & Consent: Necessary cookies are essential for the website to function properly and are active by default. For analytical, performance, and marketing cookies, we strictly require your explicit consent via our interactive Cookie Banner.

Cookie Preferences

You can manage, change, or withdraw your cookie preferences at any time by accessing the Cookie Settings available on our website. Through the Cookie Settings panel, you can review and modify your consent choices for different categories of cookies, including functionality, marketing, and third-party cookies.

4. Third-Party Websites

Our website contains links to external websites. This Privacy Policy applies strictly to lumenspei.com. When clicking on links to other websites, we strongly encourage you to read their respective privacy policies, as we hold no responsibility for third-party data processing practices.

5. Your Rights Under the GDPR

As a data subject, the GDPR guarantees you specific rights regarding your Personal Data. Lumen Spei d.o.o. ensures you can fully exercise the following rights:

1. a) Right to Access: You have the right to obtain confirmation as to whether or not your personal data is being processed, and where that is the case, access a copy of the data along with detailed information about the purposes of processing, categories of data involved, and recipients to whom the data has been disclosed.
2. b) Right to Rectification: You have the right to request the immediate correction of any inaccurate or incomplete Personal Data we hold about you. It is your responsibility to notify us of any significant changes to ensure your data remains up to date.
3. c) Right to Erasure (“Right to be Forgotten”): You can request the deletion of your Personal Data under certain conditions, such as when:

• The data is no longer necessary for the purposes it was collected.
• You withdraw your consent (where processing was based on consent) and there is no other legal ground for processing.
• You object to the processing and there are no overriding legitimate grounds to continue.
• The Personal Data has been unlawfully processed.

1. d) Right to Restriction of Processing: You have the right to request that we temporarily restrict the processing of your data, particularly if you contest the accuracy of the data, believe the processing is unlawful, or while an objection you raised is being verified.
2. e) Right to Data Portability: You have the right to receive the Personal Data you provided to us in a structured, commonly used, and machine-readable format, and have the right to transmit that data to another controller without hindrance.
3. f) Right to Object: You have the right to object at any time to the processing of your Personal Data based on our legitimate interests or for direct marketing purposes.
4. g) Right to Automated Decision-Making & Profiling: You have the right not to be subject to decisions based solely on automated processing, including profiling, which produce legal or similarly significant effects concerning you.
5. How to Exercise Your Rights & Response Times

To exercise any of your rights mentioned above, please submit a clear request via email to our Data Protection Officer (DPO): dpo@lumenspei.com

• Verification: Upon receiving your request, we will verify your identity to ensure security and prevent unauthorized disclosure.
• Timeline: We will respond to your request without undue delay, and at the latest within 30 days. In highly complex cases or during a large volume of requests, this period may be extended by an additional 60 days, about which you will be duly notified in advance.

7. Right to Lodge a Complaint

If you believe that Lumen Spei d.o.o. has processed your Personal Data in violation of applicable data protection laws, you have the right to file an official complaint with your local supervisory authority.

The competent lead authority in Croatia is:

• Croatian Data Protection Agency (Agencija za zaštitu osobnih podataka – AZOP)
• Address: Ulica Metela Ožegovića 16, 10000 Zagreb, Croatia
• Official Website: www.azop.hr
• E-mail: azop@azop.hr

8. Contact for Personal Data Processing issues

Lumen Spei is the controller for this processing procedure. If you have any questions regarding the Personal Data we gather and how we use it, please email us at the following address:

Lumen Spei Ltd.
Ulica Ivana Gundulića 5
HR-31000 Osijek, Croatia

Phone: +385 91 334 4443 

E-mail: dpo@lumenspei.com

Last updated: May 27, 2026.