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Privacy policy

Effective 4 October 2026. Replaces the version dated 26 July 2026. This is a translation; the Slovenian version prevails.

01Data controller

This policy explains what personal data we process, why and on what legal basis, who has access to it, how long we keep it and what rights you have. It is issued under Regulation (EU) 2016/679 (GDPR) and the Slovenian Personal Data Protection Act (ZVOP-2, Official Gazette RS no. 163/22).

The data controller is:

  • Full name: Dejavnost oglaševalskih agencij, Mirko Tomić, Alra, s.p.
  • Short name: Mirko Tomić - ALRA, s.p. ("Alra")
  • Registered address: Stolnik 12C, 1242 Stahovica, Slovenia
  • Registration number: 7352018000
  • Tax number: 31830242
  • Contact email: hello@alra.si

02Cookies and browser storage

This website does not use cookies. We use no tracking, advertising or profiling cookies, which is why there is no consent banner.

When you move a calculator result into the contact form, your browser keeps it in session storage (sessionStorage) so it stays in the form on another page. It is deleted when you send the form or close the tab, and it never leaves your device. We store nothing else in your browser.

03Analytics

We measure traffic with Vercel Web Analytics (Vercel Inc., USA). It works without cookies and without persistent identifiers, counts visits in aggregate and cannot identify an individual or track them across websites. We measure page views and a few on-page events, such as button clicks, calculator use and form submissions.

Legal basis: our legitimate interest in understanding how the site is used and improving it (Art. 6(1)(f) GDPR).

04Server logs

Our hosting provider (Vercel) automatically records technical access data such as IP address, browser type and time of access. These logs are used for security, abuse detection and troubleshooting, on the basis of legitimate interest (Art. 6(1)(f) GDPR), and are deleted automatically after a short period.

05Data you provide to us

When you submit the form on the website, we process:

  • your email address,
  • your message, if you write one,
  • the page and language you sent it from, and the time of submission,
  • campaign tags from the link (such as utm_campaign), if you came to the site through one of our emails or posts.

What happens when you submit

We store your email address and message as a contact in our customer management system (Brevo), and the system notifies us of the new enquiry. We send you an automatic confirmation that we received your message. A person replies to your enquiry.

We use the data only to answer your enquiry and to prepare a possible quote. The legal basis is steps taken at your request before entering into a contract (Art. 6(1)(b) GDPR). We do not use your email address for newsletters or marketing without your explicit consent.

If you become a client

To deliver the services you order and to invoice them, we also process your name, phone number, company details and billing details (address, tax and registration number).

If you apply for the reply speed test

When you apply for the reply speed test, we also process your name, company, website, the channels you pick, your Instagram or Facebook profile and the numbers you enter in the form. We send a test enquiry to the channels you pick, record when you reply and keep your reply. From the public information on your website we prepare an AI agent's reply and a reply pack.

We publish the results on a private page with a random address that search engines don't see. The results page deletes itself 30 days after it is published, and the application at most 44 days after it was sent. The legal basis is steps taken at your request before entering into a contract (Article 6(1)(b) GDPR).

06Processors

To run the site and handle enquiries we work with the following processors, under data processing agreements:

  • Vercel Inc. (USA): website hosting, processing of the submitted form and traffic analytics.
  • Brevo (Sendinblue SAS, France): customer management system (CRM) and email delivery. Data is processed in the EU.
  • Google Ireland Limited (Google Workspace, Ireland): business email, including enquiry notifications. Data may also be processed outside the EU.

Transfers outside the EEA

Transfers to processors outside the European Economic Area rely on the European Commission's adequacy decision (EU–US Data Privacy Framework) or the European Commission's Standard Contractual Clauses. We may update this list; the current version is always published on this page.

07Our clients' contacts

For services such as database reactivation, a client provides us with personal data of their own contacts. In that case:

  • the client is the controller of that data and Alra is a processor within the meaning of Art. 28 GDPR,
  • before any processing we conclude a data processing agreement with the client,
  • we process the data only to deliver the ordered service and on the client's instructions,
  • when the cooperation ends we return or delete the data, as the client requires.

08Purposes and legal bases

Contract and pre-contractual steps

Answering enquiries, preparing quotes, concluding contracts, delivering services, informing you of changes and resolving issues or complaints (Art. 6(1)(b) GDPR). For invoicing we process the data required by tax law (Art. 6(1)(c) GDPR).

Legitimate interest

Secure and stable operation of the site and services, abuse prevention, traffic analytics and, where needed, debt recovery (Art. 6(1)(f) GDPR).

Consent

Where you give us consent, for example to receive news, we process data on that basis (Art. 6(1)(a) GDPR). You can withdraw it at any time by emailing us. Withdrawal does not affect processing carried out before it.

09Sharing data

We do not sell personal data or share it for advertising. We share it only with the processors listed here, to the extent each purpose requires, and with competent authorities where the law requires it.

10How long we keep data

We keep data only as long as the purpose requires, or until statutory periods expire.

  • Enquiries that did not lead to a cooperation: up to 12 months from the last contact.
  • Client data: for the duration of the cooperation and until limitation periods for any claims expire.
  • Invoices: 10 years after the end of the year they relate to, as required by tax law.
  • Data processed on the basis of consent: until withdrawn, and at most 2 years after the cooperation ends.

After the period ends

When the retention period ends we delete or anonymise the data, unless the law provides otherwise.

11Your rights

You have the right to:

  • access your data and information about its processing,
  • rectification of inaccurate or completion of incomplete data,
  • erasure ("right to be forgotten") where we no longer need the data or have no legal basis for it,
  • restriction of processing,
  • data portability in a structured, machine-readable format,
  • object to processing based on legitimate interest, and to direct marketing at any time,
  • withdraw consent, without affecting processing carried out before withdrawal.

How to exercise your rights

Send your request through the form at alra.si/en/privacy/request, by email to hello@alra.si or by post to Mirko Tomić - ALRA, s.p., Stolnik 12C, 1242 Stahovica, Slovenia. We decide within one month. For complex requests we may extend this by up to two months and will tell you so within the first month. If we have reasonable doubts about your identity, we may ask for additional information to confirm it.

12Complaints

If you believe we are processing your personal data unlawfully, please write to us first at hello@alra.si so we can try to resolve it directly.

You can also lodge a complaint at any time with the Information Commissioner of the Republic of Slovenia, Dunajska cesta 22, 1000 Ljubljana (www.ip-rs.si).

13Security

We protect data with technical and organisational measures such as encrypted transfer, access limited to authorised people and contracts with our processors. No system on the internet is completely secure, so please don't send us sensitive data through the form, such as health information.

14Automated decision-making

We don't make decisions based solely on automated processing of data from this site that have legal or similarly significant effects on you. We don't build advertising profiles.

15Children

This site and our services are meant for businesses. We don't knowingly collect personal data from children. If you believe we have received some, write to us and we will delete it.

16Changes to this policy

We may update this policy, for example when our processors change. The current version and its effective date are always published on this page. Matters not covered by this policy are governed by the law of the Republic of Slovenia and the European Union.