PRIVACY POLICY

X-Wing Digital, vl. Tomislav Ručević (“X-Wing Digital,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, store, share, and protect personal information when you visit our website, contact us, use our services, or interact with us online.

This policy is intended to provide transparency in line with applicable privacy laws, including the General Data Protection Regulation (GDPR), other European data protection laws, and applicable United States privacy laws.

1. Who We Are

X-Wing Digital, vl. Tomislav Ručević is a digital marketing, SEO, and website development business based in Croatia.

• Company: X-Wing Digital, vl. Tomislav Ručević
• Website: https://x-wingdigital.com/
• Email: info@x-wingdigital.com
• Address: Vladimira Nazora 23, 32284 Stari Mikanovci, Croatia

For the purposes of applicable data protection laws, X-Wing Digital is the data controller for personal data we collect directly through our website, forms, communications, and business activities.

2. Personal Data We Collect

We may collect personal data directly from you, automatically through our website, or through third-party tools we use to operate and improve our business.

Information You Provide Directly

• Name
• Email address
• Phone number
• Company name
• Website URL
• Message content submitted through contact forms
• Information provided during calls, emails, proposals, onboarding, or project work
• Billing and business details when required for invoicing

Information Collected Automatically

• IP address
• Browser type and version
• Device type
• Operating system
• Pages visited
• Time spent on pages
• Referral source
• Approximate location based on IP address
• Cookie and tracking preferences

Information From Third-Party Tools

We may receive information from tools and platforms used for website analytics, contact forms, email communication, security, spam protection, advertising, social media, or client service delivery.

3. How We Use Personal Data

We may use personal data for the following purposes:

• To respond to enquiries
• To communicate with you about services
• To prepare proposals, quotes, and project plans
• To provide SEO, website development, content, analytics, and digital marketing services
• To manage client relationships
• To improve our website and services
• To monitor website performance and user experience
• To protect our website from spam, abuse, security risks, and unauthorized access
• To comply with legal, tax, accounting, and regulatory obligations
• To send service-related communications
• To send marketing communications only where legally permitted or where you have given consent

4. Legal Bases for Processing Personal Data

If you are located in the European Economic Area, United Kingdom, or another region with similar data protection laws, we process your personal data based on one or more legal bases.

Consent

We may process your data when you have given consent, such as accepting optional cookies or subscribing to marketing communications.

Contract

We process personal data when necessary to provide services, respond to service requests, prepare proposals, or perform a contract with you.

Legitimate Interests

We may process data where necessary for our legitimate business interests, such as improving our website, responding to business enquiries, securing our systems, and managing client relationships.

Legal Obligation

We may process data where required to comply with legal, accounting, tax, or regulatory obligations.

5. Cookies and Tracking Technologies

Our website may use cookies and similar technologies to support website functionality, analytics, performance measurement, security, and user experience.

Cookies may be used to:

• Remember your preferences
• Understand how visitors use our website
• Measure website performance
• Improve content and navigation
• Support security and spam prevention
• Enable analytics or marketing tools, where used

Where required by law, we will ask for your consent before placing non-essential cookies on your device. You can control or delete cookies through your browser settings or manage your preferences through our cookie banner, where available.

6. Analytics and Third-Party Tools

We may use third-party tools such as Google Analytics, Google Search Console, Google Tag Manager, or similar services to understand website performance and user behaviour.

These tools may collect information such as device type, browser, approximate location, visited pages, traffic source, and interaction data. Where required, analytics tools will only be activated after you have provided consent.

7. Contact Forms and Email Communication

When you submit a contact form, send us an email, or request information, we use the information you provide to respond to your enquiry and communicate with you.

We may keep these communications for business records, project management, legal compliance, and future reference where appropriate. Please do not send sensitive personal data through contact forms unless it is necessary.

8. Marketing Communications

We may send marketing emails only where we have a lawful basis to do so, such as your consent or an existing business relationship where permitted by law.

You can unsubscribe from marketing communications at any time by using the unsubscribe link in the email or by contacting us directly.

9. How We Share Personal Data

We do not sell your personal data.

We may share personal data with trusted third parties where necessary for the operation of our business and services, including:

• Website hosting providers
• Email service providers
• Analytics providers
• Security and spam prevention tools
• Project management tools
• Payment, accounting, or invoicing providers
• Legal, tax, or professional advisors
• Contractors or service providers who help deliver client work

We only share personal data where necessary and, where required, under appropriate contractual and data protection safeguards. We may also disclose personal data if required by law, court order, regulatory authority, or to protect our legal rights.

10. International Data Transfers

Because we may use service providers located outside Croatia, the European Union, or the European Economic Area, your personal data may be transferred internationally.

Where personal data is transferred outside the EU or EEA, we will take steps designed to ensure appropriate safeguards are in place, such as Standard Contractual Clauses, adequacy decisions, data processing agreements, or other lawful transfer mechanisms permitted by applicable law.

11. How Long We Keep Personal Data

We keep personal data only for as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

• Contact form enquiries: retained for as long as needed to respond and manage potential business relationships
• Client project records: retained for the duration of the project and for a reasonable period afterwards
• Invoices and accounting records: retained as required by tax and accounting laws
• Analytics data: retained according to the settings of the analytics tools used
• Marketing data: retained until you unsubscribe or withdraw consent

When personal data is no longer needed, we will delete, anonymize, or securely store it according to applicable requirements.

12. How We Protect Personal Data

We use reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, disclosure, or destruction.

• Secure hosting
• Access controls
• Password protection
• Software updates
• Security monitoring
• Limited access to personal data
• Use of trusted service providers

No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

13. Your Privacy Rights

Depending on where you live, you may have privacy rights under applicable data protection laws.

• The right to access your personal data
• The right to correct inaccurate personal data
• The right to request deletion of your personal data
• The right to restrict processing
• The right to object to processing
• The right to data portability
• The right to withdraw consent at any time
• The right to object to direct marketing
• The right to lodge a complaint with a data protection authority

To exercise your rights, contact us at [Insert contact email]. We may need to verify your identity before responding to a request.

14. GDPR and EEA/UK Privacy Rights

If you are located in the European Economic Area, United Kingdom, or a jurisdiction with similar privacy laws, you may request access, correction, deletion, restriction, objection, portability, or withdrawal of consent.

You also have the right to lodge a complaint with your local data protection authority. If you are in Croatia, you may contact the Croatian Personal Data Protection Agency.

15. United States Privacy Rights

Privacy rights in the United States vary by state. Depending on your state of residence and whether the relevant law applies to our business, you may have rights to:

• Know what personal information we collect
• Access personal information we hold about you
• Request correction of inaccurate information
• Request deletion of personal information
• Opt out of certain types of data sharing, targeted advertising, or sale of personal information
• Limit the use of sensitive personal information, where applicable
• Not be discriminated against for exercising privacy rights

We do not sell personal information in the traditional sense. If we ever use technologies that may be considered “sharing” or “targeted advertising” under certain U.S. state laws, we will provide appropriate notices and opt-out mechanisms where legally required.

16. California Privacy Notice

If you are a California resident, this section applies to the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies to our business.

Categories of Personal Information We May Collect

• Identifiers, such as name, email address, phone number, IP address, and company details
• Commercial information, such as services requested or purchased
• Internet or electronic network activity, such as website usage and analytics data
• Professional or business information, such as company name, role, website, or business contact details
• Inferences, such as preferences based on website interactions, where applicable

Purposes for Collection

We collect personal information for the purposes described in this Privacy Policy, including responding to enquiries, providing services, improving our website, securing our systems, and complying with legal obligations.

Sale or Sharing of Personal Information

We do not sell personal information for money. If we use analytics, advertising, or tracking technologies that may be considered “sharing” under California law, we will provide appropriate consent or opt-out options where required.

California Consumer Rights

• Know what personal information we collect, use, disclose, or share
• Request access to personal information
• Request correction of inaccurate personal information
• Request deletion of personal information
• Opt out of sale or sharing of personal information
• Limit use of sensitive personal information, where applicable
• Not be discriminated against for exercising privacy rights

17. Children’s Privacy

Our website and services are not directed to children under the age of 13 in the United States or under the applicable age of consent in the European Union.

We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will take appropriate steps to delete it.

18. Links to Other Websites

Our website may contain links to third-party websites, social media pages, or external resources. We are not responsible for the privacy practices, security, or content of third-party websites.

19. Data Processing on Behalf of Clients

When we provide services to clients, we may process personal data on behalf of those clients, for example through analytics, website forms, SEO tools, advertising platforms, or website management systems.

In those cases, the client may be the data controller and X-Wing Digital may act as a data processor or service provider. Where required, we will process such data according to a written agreement and the client’s instructions.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, legal requirements, technologies, or business practices.

The updated version will be posted on this page with a revised “Last modified” date.

21. Contact Us

If you have questions about this Privacy Policy or how we handle personal data, contact us at:

• Company: X-Wing Digital, vl. Tomislav Ručević
• Email: info@x-wingdigital.com
• Address: Vladimira Nazora 23, 32284 Stari Mikanovci, Croatia
• Website: https://x-wingdigital.com/