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Privacy Policy

Last revised on: 16 October 2026

1. Who is responsible for your data

The data controller for this website, justphoenix.io, is [COMPANY LEGAL NAME], registered address: [ADDRESS], Republic of Serbia, PIB: [PIB], MB: [MB] (“JustPhoenix”, “we”). Contact for privacy matters: [EMAIL].

We process personal data in accordance with the Serbian Law on Personal Data Protection (ZZPL) and, where applicable, the EU General Data Protection Regulation (GDPR).

2. What data we collect and why

Contact and quote requests (name, email, company, your message): to answer your inquiry and prepare a proposal. Legal basis: steps prior to entering a contract, and our legitimate interest in responding to inquiries.

Customer accounts and orders (name, email, company and billing details you enter, order history, license keys): to deliver purchased products, issue and validate license keys, provide updates and support, and meet accounting obligations. Legal basis: performance of a contract and legal obligations.

Payments: payments are processed by Paddle.com Market Ltd as merchant of record. Paddle collects and processes the payment data (including card details) under its own privacy policy — we never receive your full card number. We receive from Paddle the order information needed to deliver the product (e.g. your name, email, country, product purchased and tax status).

Service delivery (for Care Plans, server management, backups and development projects): access credentials, server data and logs you entrust to us, strictly to provide the agreed service. Where we process personal data contained in your systems on your behalf, we act as a processor under a data processing agreement. Legal basis: performance of a contract.

Technical data (IP address, browser, pages visited, server logs): to keep the Site secure and working. Legal basis: legitimate interest in security and operation.

Cookies and analytics: see our Cookies Policy. [LIST THE ANALYTICS TOOLS ACTUALLY USED — e.g. Google Analytics via MonsterInsights — AND KEEP THE COOKIE BANNER CONSISTENT.]

We do not sell personal data and we do not use it for automated decision-making that produces legal effects.

3. Who we share data with

  • Paddle.com Market Ltd — payment processing, invoicing and tax handling for purchases (merchant of record);
  • Hosting and infrastructure providers — [NAME PROVIDER(S) AND LOCATION];
  • Email provider — [NAME PROVIDER] — for transactional email and support;
  • Professional advisers (accounting, legal) and public authorities where the law requires it.

All processors act under contracts that bind them to confidentiality and data protection.

4. International transfers

Some recipients (for example Paddle, with entities in the UK/US, or hosting providers) may process data outside Serbia or the EU/EEA. Where that happens, transfers rely on appropriate safeguards such as adequacy decisions or standard contractual clauses.

5. How long we keep data

  • Inquiries that do not lead to a contract: up to [12] months;
  • Customer, order and license data: for the life of the account/license and as long as required by accounting and tax law (in Serbia, generally up to 10 years for financial records);
  • Server logs: up to [30/90] days;
  • Data processed on your behalf under a service contract: for the duration of the contract, then deleted or returned.

6. Your rights

You have the right to access your data, correct it, have it deleted, restrict or object to its processing, receive it in a portable format, and withdraw consent at any time where processing is based on consent (without affecting past processing).

To exercise these rights, write to [EMAIL]. We respond within the legal deadline.

You can also complain to a supervisory authority: in Serbia, the Commissioner for Information of Public Importance and Personal Data Protection (Poverenik); EU residents can contact their local data protection authority.

7. Security

We protect data with measures appropriate to the risk, including encrypted connections (TLS), access control, encrypted offsite backups and the same hardening practices we sell as a service. No system is perfectly secure; report suspected issues to [EMAIL].

8. Children

The Site and our products are intended for businesses and adults. We do not knowingly collect data from children under 15.

9. Changes to this policy

We may update this policy; the current version is always published here with its date.