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Privacy Policy

Effective Date: July 10, 2026

This Privacy Policy explains how SVALINN, obrt za usluge, vl. Luka Svalina ("we," "our," or "us") collects, uses, and protects your personal information when you visit svalinn-games.eu.

1. Data Controller Information

The entity responsible for processing your personal data is:

  • Legal Name: SVALINN, obrt za usluge, vl. Luka Svalina
  • OIB (Personal Identification Number): 64204847022
  • Address: Smiljanićeva 2, 21000 Split, Croatia
  • Contact Email: luka@svalinn.hr

2. Our Privacy Principles

We adhere to a minimalist approach to data privacy, following the standards:

  • Minimal Collection: We do not collect more information than is strictly necessary to provide our services.
  • Purpose Limitation: Your data is used only for the specific purposes stated at the time of collection.
  • Storage Limitation: We do not keep your personal data longer than is required to fulfill its purpose.

3. Data Collection and Usage

We follow a minimalist approach to data collection. We do not use advertising trackers, profiling cookies, remarketing pixels, or third-party behavioral advertising monitors.
We process data in the following ways:

  • Contact Forms: We collect your name, email address, and the content of your message to respond to your inquiries regarding our TTRPG games.
  • Subscription Forms: We collect your email address to send you newsletters and updates about our projects.
  • Privacy-Friendly Website Analytics: We use a self-hosted instance of Plausible Analytics at `metrics.svalinn.hr` to understand how visitors use our website and to improve our pages, content, and newsletter signup flow.

Plausible Analytics is configured as a privacy-friendly, cookie-less analytics tool. It does not use tracking cookies and does not create personal profiles of visitors. The analytics data we review is aggregated and includes information such as page views, referrers, device/browser type, approximate location, and interactions such as newsletter signup clicks or outbound social link clicks.

4. Cookies and Analytics

Our public website does not use analytics cookies.

Our self-hosted Plausible Analytics setup is cookieless and is used only for aggregate website statistics. Because it does not use cookies or similar tracking technologies for cross-site tracking or advertising purposes, we do not ask for cookie consent for Plausible Analytics.

If we add non-essential cookies, advertising pixels, embedded third-party media, or similar tracking technologies in the future, we will update this policy and request consent where legally required.

5. Legal Basis for Processing

  • Legitimate Interest: For responding to your contact form inquiries, privacy-friendly website analytics (Art. 6(1)(f) GDPR).
  • Consent: For sending you newsletter updates, based on your explicit opt-in (Art. 6(1)(a) GDPR).

6. Data Retention

  • Inquiry Data: Up to 12 months after the last communication, unless a contract is established.
  • Subscription Data: Until you choose to unsubscribe or withdraw your consent.
  • Analytics Data: We retain aggregate website analytics data only for as long as it is useful for understanding website performance and improving our content. Plausible Analytics does not store personal profiles or tracking cookies.
  • Legal Records: In accordance with Croatian accounting law, any financial or transactional records are kept for at least 11 years.

7. Service Providers

We may use trusted service providers to operate our website and communications, including:

  • Brevo: used for newsletter email delivery. If you subscribe to our newsletter, your email address and subscription preferences may be processed through Brevo.
  • Zoho — used for email hosting and IMAP/email account services. If you contact us by email or through a contact form that forwards messages to our email inbox, your message and contact details may be processed through Zoho.
  • Hetzner — used for website hosting, server hosting, and related infrastructure. Website files, server logs, databases, and self-hosted services may be hosted on Hetzner infrastructure.
  • Self-hosted Plausible Analytics — hosted at `metrics.svalinn.hr` (Hetzner) and used for privacy-friendly aggregate website analytics. Plausible is configured without analytics cookies and is used to understand page views, referrers, device/browser type, approximate location, and selected website interactions such as newsletter or outbound link clicks.

Depending on how you interact with us, these providers may process information such as your email address, contact-form messages, newsletter subscription status, server log data, or aggregate website analytics data.


We do not sell personal data.

8. Your Rights Under GDPR

You have the following rights regarding your personal data:

  • Right of Access: Request a copy of the data we hold about you.
  • Right to Rectification: Request the correction of inaccurate information.
  • Right to Erasure: Request the deletion of your personal data.
  • Right to Withdraw Consent: Unsubscribe from our communications at any time.
  • Right to Object: Object to our processing based on legitimate interests.

To exercise these rights, please contact us at the email provided in Section 1.

9. Regulatory Authority

If you have concerns about your data, you have the right to lodge a complaint with the Croatian supervisory authority:

Agencija za zaštitu osobnih podataka (AZOP)
Selska cesta 136, 10 000 Zagreb, Croatia
Email: azop@azop.hr
Web: www.azop.hr

This policy includes the mandatory elements required by the Croatian Personal Data Protection Agency (AZOP), such as specific controller identifiers (OIB), legal bases for processing, and clear retention timelines.

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