Privacy Policy

1. Data Controller

The controller of personal data on montenegrotravel.guide within the meaning of Article 4(7) of Regulation (EU) 2016/679 (General Data Protection Regulation — "GDPR") and Slovak Act No. 18/2018 Coll. on Personal Data Protection is SIDTEC Entwicklung s. r. o., Karpatské námestie 7770/10A, 831 06 Bratislava – Rača, Slovak Republic (Company ID / IČO: 57537747, Tax ID / DIČ: 2122805685).

For all privacy and data protection matters, please write to us at [email protected] or use the Contact Form at the bottom of this page.

2. Pre-Trip Checklist Form & Marketing / Book Updates

Purpose: When you submit your email address in the "Free Pre-Trip Checklist" form, we process your data to: (a) send you the requested Montenegro pre-trip checklist and answer your travel questions, and (b) send you occasional travel updates, insider tips, and promotional offers regarding our digital book "Montenegro Insider Travel Guide" and related travel guides.

Data processed: Your email address, the language of the page, the source URL where the form was submitted, the date and time of submission, and your IP address and browser user-agent string (recorded in our MySQL database to document consent and protect the form against automated spam).

Legal basis: Your explicit consent given by ticking the checkbox in the form (Article 6(1)(a) GDPR for email updates/marketing and Article 49(1)(a) GDPR for instant notification via Telegram) as well as taking steps at your request to deliver the checklist (Article 6(1)(b) GDPR).

Unsubscribing & Retention: Providing your data is voluntary. You can withdraw your consent and unsubscribe from future emails at any time by replying "Unsubscribe" to any of our emails or by writing to [email protected]. We keep checklist lead records for up to 12 months after our last interaction, or until you withdraw your consent / request deletion.

3. Contact Form & Support Enquiries

Purpose: Handling and answering your enquiry, customer support request, or legal/privacy request.

Data processed: Your name, email address, message content, page language, source URL, date and time of submission, IP address, and browser user-agent string.

Legal basis: Our legitimate interest in answering enquiries and, where your question relates to a purchase or contract, steps prior to or during performance of a contract (Article 6(1)(f) and (b) GDPR), together with your explicit consent for forwarding the message notification via Telegram (Article 49(1)(a) GDPR).

Retention: Up to 12 months after the last communication; if a commercial contract or statutory obligation applies, records are kept for as long as required by Slovak accounting and tax legislation (generally 10 years under Slovak Act No. 431/2002 Coll. on Accounting).

4. Instant Message Delivery via Telegram & Email Correspondence

Submissions sent through our Contact Form and Pre-Trip Checklist Form are stored in our database and immediately forwarded to us as notifications via Telegram (Telegram Messenger Inc., British Virgin Islands / Dubai, UAE; EEA representative pursuant to Art. 27 GDPR: European Data Protection Office — EDPO, Avenue Huart Hamoir 71, 1030 Brussels, Belgium).

Telegram acts as an independent controller of its messaging service. Telegram is located outside the EU/EEA, there is no European Commission adequacy decision for it, and we have no standard contractual clauses with Telegram. Because of this, your data may potentially be accessible to authorities of third countries and you may have fewer rights and legal remedies than in the EU. We therefore forward form submissions to Telegram only with your explicit consent (Article 49(1)(a) GDPR), which you grant by ticking the checkbox in the form. You may withdraw your consent at any time (without affecting the lawfulness of processing prior to withdrawal); if you prefer not to have your request forwarded via Telegram, please write to us directly by email at [email protected]. We delete notification messages in Telegram within 12 months.

When we send you the pre-trip checklist or reply to your enquiries by email, our email correspondence is processed via Google Workspace / Gmail (Google Ireland Limited, Dublin, Ireland, and Google LLC, USA, certified under the EU–US Data Privacy Framework).

5. Hosting, Content Delivery Network (CDN) & Server Logs

Hosting & Database (IONOS): This website and its MySQL database are hosted on a server of IONOS (United Kingdom), which processes data on our behalf under a Data Processing Agreement (Article 28 GDPR). Data transfers to the United Kingdom are covered by the European Commission adequacy decision for the UK (valid until 27 December 2031).

Media CDN & Security (Cloudflare): Website photographs (.webp) and the free 11-page PDF sample on media.montenegrotravel.guide, as well as DNS and DDoS/WAF protection, are delivered through Cloudflare, Inc. (101 Townsend St, San Francisco, CA 94107, USA / EU edge servers) under a Data Processing Agreement, Standard Contractual Clauses, and the EU–US Data Privacy Framework.

Server Logs & Abuse Protection: Our web server automatically records your IP address, date and time, requested URL, HTTP status code, and browser user-agent string to ensure network security, rate-limiting against spam (throttle middleware), and stable operation (legitimate interest, Article 6(1)(f) GDPR). Server logs are automatically deleted after 14 days.

6. Checkout & Payment Processing (Gumroad)

When you click to purchase "Montenegro Insider Travel Guide", checkout and payment processing are carried out directly by our Merchant of Record, Gumroad, Inc. (USA). We never see, collect, or store your credit card numbers or bank account details on our servers.

Gumroad processes your payment data as an independent controller in accordance with its own Privacy Policy (https://gumroad.com/privacy) and shares your purchase email address, order reference, and transaction status with us so that we can verify purchases, provide author email support, and deliver book updates (Article 6(1)(b) and (c) GDPR).

7. Web Analytics (Google Analytics 4)

We use Google Analytics 4 ("GA4"), a web analytics service provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) and Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, certified under the EU–US Data Privacy Framework).

GA4 uses cookies to help us understand how visitors interact with our travel guides (such as pages visited, reading time, approximate geographic region by country/city, referring website, and device/browser type). In Google Analytics 4, IP addresses of users in the European Union are used only transiently to derive coarse location data and are immediately discarded before any data is logged or stored on Google servers.

Legal basis: Your consent pursuant to Article 6(1)(a) GDPR and Section 109(8) of the Slovak Electronic Communications Act No. 452/2021 Coll. Analytics data in GA4 is retained for up to 14 months. You can prevent Google Analytics from collecting data at any time by blocking or deleting cookies in your browser settings or by installing the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout).

8. Cookie Policy

Our website uses strictly necessary technical cookies required for security and form protection (which do not require consent under Section 109(8) of the Slovak Electronic Communications Act No. 452/2021 Coll. and Article 5(3) of the ePrivacy Directive) as well as Google Analytics cookies for measuring readership.

9. Your Rights under GDPR & Supervisory Authority

Under the GDPR (Articles 15 to 22), you have the following rights regarding your personal data:

• Right of access (Art. 15 GDPR): To obtain confirmation as to whether we process your personal data and to receive a copy of it.
• Right to rectification (Art. 16 GDPR): To request correction of inaccurate or incomplete personal data.
• Right to erasure / "Right to be forgotten" (Art. 17 GDPR): To request deletion of your personal data where it is no longer necessary or where you withdraw consent.
• Right to restriction of processing (Art. 18 GDPR) and Right to data portability (Art. 20 GDPR).
• Right to object (Art. 21 GDPR): To object at any time to processing based on our legitimate interests (Art. 6(1)(f) GDPR) or to direct marketing.
• Right to withdraw consent (Art. 7(3) GDPR): To withdraw any consent you have given at any time, without affecting the lawfulness of processing prior to withdrawal.
• How to exercise your rights & lodge a complaint: Write to [email protected]; we will respond within one month. You also have the right to lodge a complaint with our lead supervisory authority, the Office for Personal Data Protection of the Slovak Republic (Úrad na ochranu osobných údajov Slovenskej republiky), Galvaniho 7/B, 821 04 Bratislava (Námestie 1. mája 18, 811 06 Bratislava), Slovak Republic, https://dataprotection.gov.sk, or with the supervisory authority in the EU Member State of your habitual residence.