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Privacy Policy

Last updated: 3 April 2026

1. Who We Are

Momentiv is operated by Marko Lumbar, based in 6000 Koper, Slovenia (the “Operator”). For the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), Marko Lumbar is the data controller.

Contact: hello@momentivagency.com

2. What Data We Collect

We collect the following personal data:

Contact form:

  • Full name
  • Email address
  • Company name (optional)
  • Project description / message

Newsletter subscription:

  • Email address

Server logs (automatically collected):

  • IP address
  • Browser type and version
  • Operating system
  • Pages visited and timestamps

We do not collect sensitive data as defined under GDPR Article 9 (health data, political opinions, biometric data, etc.).

3. Why We Collect It / Legal Basis

DataPurposeLegal Basis
Contact form data (name, email, company, message)To respond to your enquiry and provide information about our servicesArt. 6(1)(b) — necessary for pre-contractual steps
Newsletter emailTo send occasional updates on web design, development, and building onlineArt. 6(1)(a) — your consent
Server logsTo ensure the security and proper functioning of our websiteArt. 6(1)(f) — our legitimate interest

4. Third-Party Data Processors

We use the following third-party processors to operate our services. Each has been engaged under a data processing agreement in accordance with GDPR Article 28.

ProcessorPurposeLocationTransfer Mechanism
Vercel Inc.Web hosting and content deliveryUSAStandard Contractual Clauses (SCCs)
Resend Inc.Delivery of contact form submissions and newsletter emailsUSAStandard Contractual Clauses (SCCs)
Calendly LLCMeeting scheduling (when you click “Book a call”)USAStandard Contractual Clauses (SCCs)

We do not share your personal data with any other third parties unless required by law.

5. International Data Transfers

Our processors Vercel, Resend, and Calendly are based in the United States. Data transfers to these processors are carried out under Standard Contractual Clauses (SCCs) as adopted by the European Commission Decision 2021/914 under GDPR Article 46(2)(c), providing appropriate safeguards for your personal data.

6. Data Retention

DataRetention Period
Contact form data2 years from the date of submission
Newsletter emailUntil you unsubscribe
Server logs90 days

After the applicable retention period, your data is securely deleted.

7. Minimum Age

Our website is not directed at children under the age of 15. In accordance with the Slovenian Personal Data Protection Act (ZVOP-2, Article 113), the minimum age for digital consent is 15. If you are under 15, please do not submit any personal data through this website.

8. Your Rights Under GDPR

Under GDPR Articles 15–21 and Article 7(3), you have the following rights:

  • Right of access (Art. 15) — You can request a copy of the personal data we hold about you.
  • Right to rectification (Art. 16) — You can ask us to correct inaccurate or incomplete data.
  • Right to erasure (Art. 17) — You can request deletion of your personal data (“right to be forgotten”).
  • Right to restriction (Art. 18) — You can ask us to limit how we process your data.
  • Right to data portability (Art. 20) — You can request your data in a structured, machine-readable format.
  • Right to object (Art. 21) — You can object to processing based on legitimate interests.
  • Right to withdraw consent (Art. 7(3)) — Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at hello@momentivagency.com. We will respond within 30 days.

9. No Data Selling

We do not sell, rent, or trade your personal data to any third parties, ever.

10. Security Measures

We implement appropriate technical and organisational measures to protect your personal data, including:

  • HTTPS/TLS encryption for all data in transit
  • Access controls limiting who can access your data
  • Secure processing by vetted third-party processors under data processing agreements

11. Data Breaches

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority within 72 hours in accordance with GDPR Articles 33–34. Where the breach is likely to result in a high risk, we will also notify affected individuals without undue delay.

12. Supervisory Authority

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Slovenian supervisory authority:

Informacijski pooblaščenec (IP RS)
Dunajska cesta 22, 1000 Ljubljana, Slovenia
gp.ip@ip-rs.si
www.ip-rs.si

13. Cookies

This website does not use cookies. For more information, see our Cookie Policy.

14. Changes to This Policy

We may update this Privacy Policy from time to time. For material changes, we will provide at least 30 days’ notice before the changes take effect. The “Last updated” date at the top of this page reflects the most recent revision.

Questions? hello@momentivagency.com

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