This Privacy Policy explains how Retoba d.o.o. collects, uses, shares, stores and protects personal data when you visit our websites, contact us, use a Retoba-operated AI demo, interact with our social media pages or respond to our campaigns on third-party platforms.
It applies to retoba.ai, related Retoba subdomains and online services, and Retoba's business presence on platforms such as LinkedIn, Facebook, Instagram, Messenger and YouTube. A client-branded AI assistant or service may have an additional privacy notice identifying the client as the controller and Retoba as its processor or technology provider.
1. Data controller and contact
Controller: Retoba d.o.o.
Registered office: Tehnološki park 18, 1000 Ljubljana, Slovenia
Company registration no.: 9962760000
Tax no.: 11508736
Privacy contact: [email protected]
Retoba acts as a controller when it decides why and how personal data is processed for its own websites, communications, marketing and business relationships. When Retoba processes data solely on a customer's documented instructions, the customer is normally the controller and Retoba acts as a processor under the relevant agreement and, where required, a data processing agreement.
2. Personal data we collect
2.1 Data you provide directly
Depending on how you contact or work with us, we may collect:
- your name, business email address and other contact details;
- company name, role, professional profile and the organisation you represent;
- website address, project requirements, enquiry category and agency status;
- messages, attachments, meeting notes, feedback and other information you choose to provide;
- information submitted through contact forms, event or campaign forms, AI demos and business communications;
- contract, billing and transaction information where you become a customer, supplier or partner.
Please do not submit special categories of personal data, confidential information or third-party personal data through public forms or AI demos unless this is necessary, lawful and expressly agreed with Retoba.
2.2 Data collected automatically
When you use our websites or online services, technical systems may process:
- IP address, date and time of access, requested page and referring page;
- browser, device, operating system, language and approximate screen information;
- security events, error logs, form-submission metadata and anti-abuse signals;
- page views, navigation events and aggregated website-usage statistics.
2.3 Data from third parties and public sources
We may receive professional contact and business information from:
- LinkedIn, Facebook, Instagram, Messenger, YouTube and other platforms when you interact with Retoba;
- lead-generation forms, advertising campaigns, event registrations and platform messaging tools;
- public business websites, company registers, professional directories and publicly visible professional profiles;
- customers, partners, agencies, event organisers and referrals, where they are permitted to share the information.
3. Why we process personal data and our legal bases
We process personal data only when we have an appropriate legal basis under applicable data-protection law.
| Purpose | Typical data | Legal basis |
|---|---|---|
| Responding to enquiries, arranging meetings and preparing proposals | Identity, contact, company and enquiry information | Steps requested before entering a contract and our legitimate interest in business communication |
| Providing services, customer support and account access | Business contacts, account, project, contract and service data | Performance of a contract, legitimate interests and legal obligations |
| Operating, securing and improving websites, forms and AI demos | Technical, usage, security and interaction data | Our legitimate interests in reliable, secure and useful services |
| Managing social media pages, messages, campaigns and leads | Platform profile, interaction, message, campaign and lead-form data | Your requested pre-contractual steps, consent where required, and our legitimate interest in communicating with professional audiences |
| Sending relevant business communications and measuring campaign performance | Business contact, preference, campaign and engagement data | Consent where required or legitimate interests permitted by law; you may object at any time |
| Accounting, compliance, dispute resolution and enforcement | Contract, transaction, correspondence and audit data | Legal obligations and legitimate interests in establishing, exercising or defending legal claims |
Where processing is based on consent, you may withdraw it at any time. Withdrawal does not affect processing that was lawful before withdrawal. Where processing is based on legitimate interests, we balance those interests against your rights and reasonable expectations.
4. Website contact forms and email
Our contact forms may ask for your name, email address, company, website, message and relevant project context. We also record the submission time and source IP address for delivery, security and abuse-prevention purposes. We use this information to respond, understand your request, prepare a proposal and maintain an appropriate record of the communication.
Fields marked as required are necessary for us to respond. If you do not provide them, we may be unable to process your enquiry. Submitting an enquiry does not automatically subscribe you to marketing communications.
5. AI demos and conversational services
If you use a Retoba-operated AI demo, we may process the text you submit, generated responses, technical session data and feedback to provide the conversation, protect the service and improve quality. Do not enter health information, financial credentials, identification documents, confidential business data or other sensitive information into a public demo.
Some AI assistants are operated for Retoba customers. In those cases, the customer's privacy notice may apply and Retoba may process conversation data on the customer's behalf. The relevant service interface or customer should identify the responsible controller and any additional terms.
6. Analytics, cookies and third-party website services
6.1 Audience measurement
Selected Retoba pages use a privacy-oriented analytics script delivered from pl.sinusiks.com. It measures page views and website events using information such as the visited URL, referring page, browser or device information and event time. The current script does not set an analytics cookie. It can read an optional browser flag used to exclude a visitor from measurement. Technical request data, including an IP address, may still be processed when the browser contacts the analytics service.
6.2 Google reCAPTCHA
Forms may use Google reCAPTCHA to distinguish legitimate submissions from automated abuse. When reCAPTCHA loads, Google may process device, browser, IP-address, cookie and interaction data under its own privacy terms. You can review the Google Privacy Policy.
6.3 Google Fonts and external resources
Some pages request fonts or other technical resources from Google or other external providers. The provider receives the technical information required to deliver the resource, which normally includes the requesting IP address, browser information and time of request.
6.4 Advertising pixels and insight tags
At the effective date of this policy, retoba.ai does not load Meta Pixel or the LinkedIn Insight Tag. If we introduce advertising pixels, conversion tags or other non-essential tracking technologies, we will update this policy and provide consent controls where required by law.
You can control or delete cookies and site data through your browser. Blocking some technologies may affect form security or other website functions.
7. Facebook, Instagram, Messenger and other Meta platforms
When you visit or interact with a Retoba page, advertisement or campaign on Facebook, Instagram or Messenger, Meta collects data under the Meta Privacy Policy. Depending on your activity and settings, Retoba may receive:
- your public profile name, username, profile image and other information you make visible;
- comments, reactions, follows, shares, event responses and public posts involving Retoba;
- the content and metadata of messages you send to Retoba;
- contact and qualification information you submit through a Meta lead form or messaging campaign;
- campaign source, advertisement and response information;
- aggregated Page Insights, reach, engagement and audience-demographic statistics.
We use this data to answer you, manage the relevant campaign, evaluate interest in Retoba services and measure content or campaign performance. When you submit a Meta lead form, the information you choose to send is transferred to Retoba and is processed under this policy. Meta remains responsible for its own platform processing. For certain Page Insights processing in the EEA, Retoba and the relevant Meta entity may act as joint controllers as described in Meta's applicable controller terms.
8. LinkedIn
When you visit or interact with Retoba's LinkedIn Page, content, advertisements or Lead Gen Forms, LinkedIn processes data under the LinkedIn Privacy Policy. Depending on your activity and settings, Retoba may receive:
- professional profile information that is visible to Retoba;
- follows, reactions, comments, shares and other Page interactions;
- messages and InMail communications;
- information you choose to submit in a LinkedIn Lead Gen Form;
- campaign and conversion information provided through LinkedIn's business tools;
- aggregated Page Insights about audience and engagement trends.
We use this information for professional communication, responding to enquiries, campaign management, business development and aggregate performance measurement. LinkedIn remains responsible for its own platform processing. For EEA or Swiss member data used to generate LinkedIn Page Insights, Retoba and LinkedIn may act as joint controllers under LinkedIn's applicable Page terms.
9. YouTube and other platforms
If you interact with Retoba content or profiles on YouTube or another platform, the platform processes your account, device and interaction data under its own policy. Retoba may see public comments, profile information, messages and aggregated performance statistics made available to channel or account administrators. YouTube is a Google service and is covered by the Google Privacy Policy.
Links from our website to third-party platforms do not give Retoba control over those platforms' data practices. Review your privacy and advertising settings directly with the relevant provider.
10. Who receives personal data
We may disclose personal data only where necessary to:
- hosting, security, analytics, email, collaboration and other technology providers acting for us;
- social media, advertising and communication platforms where you use those services to interact with us;
- professional advisers such as accountants, auditors, insurers and legal counsel;
- customers or project partners where your enquiry or interaction relates to their service and disclosure is expected and lawful;
- public authorities, courts or regulators where required by law;
- a successor in connection with a merger, reorganisation or transfer of business, subject to appropriate safeguards.
Our service providers are permitted to process personal data only for agreed purposes and subject to appropriate contractual, confidentiality and security obligations.
11. International data transfers
Some technology and social-media providers may process data outside Slovenia or the European Economic Area. Where personal data is transferred to a country without an adequacy decision, the relevant controller or processor must use an appropriate transfer mechanism, such as European Commission standard contractual clauses, and supplementary safeguards where required. Information about platform transfers is available in the relevant Meta, LinkedIn and Google privacy documentation.
12. How long we keep personal data
We retain personal data only for as long as necessary for the purpose for which it was collected:
- enquiries, proposals and social-media messages are kept while the request or potential business relationship remains active and afterwards only as needed for follow-up, accountability or legal claims;
- customer, supplier, accounting and contract records are kept for the periods required by applicable commercial, tax and accounting law and limitation periods;
- marketing contact data is kept until consent is withdrawn, you object, the purpose ends or the data is no longer accurate; limited suppression information may be retained to respect an opt-out;
- security logs and analytics data are retained for a proportionate period based on security, troubleshooting and measurement needs;
- data held by third-party platforms is also subject to their retention settings and policies.
We may retain data for longer where necessary to comply with law, investigate abuse or establish, exercise or defend legal claims.
13. Your data-protection rights
Subject to the conditions and limits in applicable law, you may have the right to:
- request access to your personal data and information about its processing;
- request correction of inaccurate or incomplete data;
- request deletion of data;
- request restriction of processing;
- receive data you provided in a structured, commonly used and machine-readable format and request portability where applicable;
- object to processing based on legitimate interests;
- object at any time to processing for direct marketing;
- withdraw consent at any time where consent is the legal basis;
- lodge a complaint with a competent supervisory authority.
To exercise your rights, contact [email protected]. We may need to verify your identity before responding. If your request concerns processing controlled by a Retoba customer or a third-party platform, we may direct or forward the request to the appropriate controller.
In Slovenia, the supervisory authority is the Information Commissioner of the Republic of Slovenia.
14. Automated decision-making
Retoba does not use personal data collected through its public website or business social-media interactions to make decisions based solely on automated processing that produce legal or similarly significant effects. Third-party platforms may use automated systems, recommendations and advertising profiles under their own policies and user controls.
15. Security
We use reasonable technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure, loss or destruction. No internet transmission or storage system can be guaranteed completely secure. Please use public forms and AI demos accordingly and notify us if you suspect a security issue.
16. Children
Retoba's websites and services are primarily intended for business users and are not directed to children. Do not submit a child's personal data through our forms or AI demos unless you have lawful authority and the processing has been expressly agreed.
17. Changes to this policy
We may update this Privacy Policy when our services, providers or legal obligations change. The effective date at the top identifies the current version. Material changes will be highlighted where appropriate.
18. Legal framework and further information
This policy is designed to provide the information required by the EU General Data Protection Regulation, including Articles 13 and 14, and applicable Slovenian data-protection law, including ZVOP-2.
- EU General Data Protection Regulation
- Slovenian Personal Data Protection Act (ZVOP-2)
- Meta Privacy Policy
- LinkedIn Privacy Policy
- Google Privacy Policy
19. Contact
For privacy questions or requests, contact:
Retoba d.o.o.
Tehnološki park 18
1000 Ljubljana
Slovenia
Email: [email protected]