Ask Dubrovnik — Privacy Policy
Version: 1.0 Effective Date: [DATE] Previous versions: none — see archive
Related document: Terms of Service
1. Introduction
This Policy explains how Argosy Technologies d.o.o. collects, uses, stores and shares personal data when you use Ask Dubrovnik (the "Service") through WhatsApp or at askdubrovnik.com.
We process personal data under Regulation (EU) 2016/679 ("GDPR") and the Croatian Act on the Implementation of the General Data Protection Regulation.
Data controller: Argosy Technologies d.o.o. Brune Bušića 30, 20000 Dubrovnik, Croatia Email: privacy@askdubrovnik.com
We have not appointed a Data Protection Officer, as we are not required to. Data protection enquiries go to the address above.
Capitalised terms not defined here have the meaning given in the Terms of Service.
2. Data We Collect
2.1 WhatsApp channel
- WhatsApp identifiers — your phone number and, where WhatsApp makes it available, your display name.
- Message content — the text you send, and any media you choose to send.
- Conversation metadata — timestamps, message identifiers, language of the exchange.
2.2 Web chat and website
- Message content — the questions you type into the chat.
- Session data — a technical conversation identifier, timestamps, browser and device type, and your IP address (from which an approximate location at country or city level may be derived).
- No email address, name or account is required to use the web chat.
2.3 Generated through use
- Conversation log — your questions together with the replies produced by the Service.
- Quality data — whether a verified entry was found, which entry was used, and whether the Service had to reply that it held no verified information.
2.4 What we do not collect
- We do not collect precise GPS location. If you choose to share a location, it is used only to answer that question and is not retained afterwards.
- We do not access your contacts, call history, or your messages with anyone else.
- We do not collect payment or card data, and we do not process payments from users.
- We do not ask for special categories of data (health, religious or political views, and similar) and ask you not to send them. If you send such data anyway, it is processed only to produce the reply and removed from our records in the ordinary course (Section 5).
2.5 Data about other people
We ask you not to send another person's personal data, including photographs of identifiable people (Terms, Section 9). We cannot prevent you from doing so.
Where we identify such material, we delete it. Media sent to the Service is not retained after the reply is produced. Where a message contains a third party's personal data in text, it is deleted with the raw conversation log and is not carried into any longer-retained record.
If you believe your personal data was sent to the Service by someone else, contact privacy@askdubrovnik.com and we will locate and delete it so far as we are able.
2.6 Questions about named people
The Service answers questions about public figures where our data covers them, and only in their public capacity. It does not answer questions about private individuals and does not supplement, confirm or deny information about them. Questions of that kind are not used to build any record about the person asked about.
3. Purposes and Legal Bases
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Delivering the Service — receiving your question, retrieving verified data, generating and sending the reply, maintaining context within the conversation | Art. 6(1)(b) — performance of a contract, namely the Terms, accepted as described in Section 3 of the Terms; and, for your very first message, steps taken at your request before that acceptance |
| Quality control and correction of the Verified Knowledge Database — identifying wrong, missing or outdated entries and failures of the Service | Art. 6(1)(f) — legitimate interest in the accuracy of an information service |
| Security, abuse prevention, and protecting the integrity and intellectual property of the Service | Art. 6(1)(f) — legitimate interest |
| Producing aggregated, anonymised statistics on demand, coverage and quality | Art. 6(1)(f) for the act of aggregation; the result is not personal data |
| Transmitting a safety notice from a competent public authority to an active conversation (Terms, 11.1) | Art. 6(1)(d) — protection of vital interests |
| Transmitting city and cultural information you have asked to receive (Terms, 11.2) | Art. 6(1)(a) — your consent, which you may withdraw at any time |
| Responding to your data protection requests | Art. 6(1)(c) — legal obligation |
| Establishing, exercising or defending legal claims | Art. 6(1)(f) — legitimate interest |
We do not send marketing messages, and we do not use your data for advertising or for profiling for advertising purposes.
A note on "opt-in". Processing to deliver the Service is based on the contract, not on consent, so there is no consent for you to withdraw. Initiating the conversation is how the contract is formed and how WhatsApp permits us to reply; it is not a GDPR consent. Section 3 of the Terms explains how acceptance works on each channel. You end the contract by ceasing to use the Service, by sending STOP, or by blocking the number.
Consent is used in one place only: the city and cultural notices in Section 11.2 of the Terms, and non-essential cookies (Section 10 below). Withdrawing it is as easy as giving it, takes effect immediately, and does not affect the lawfulness of processing before withdrawal.
Objecting to legitimate interest. You may object at any time to processing based on Article 6(1)(f) — see Section 8. Our assessment of each such interest is documented internally and available in summary on request.
4. Automated Processing, AI, and Human Review
You are talking to a machine. Ask Dubrovnik is an automated AI system. Every reply is machine-generated. This is disclosed in our first reply in every conversation, in accordance with Article 50 of Regulation (EU) 2024/1689.
How AI is used. Your message is transmitted to our infrastructure and processed with the assistance of third-party AI language models (Section 6) to interpret the question and phrase the reply. Operational facts are retrieved from the Verified Knowledge Database rather than generated by the model.
Human review does take place. Conversations are reviewed by us — in practice by a small number of authorised persons — in order to:
- find questions the Service answered wrongly, incompletely or not at all, and correct the underlying data;
- investigate a technical fault or a report of abuse;
- respond to a request or complaint from you.
Review is limited to what is necessary. Where we only need to know what was asked, we work with pseudonymised records from which direct identifiers have been removed.
Reaching a person. You can ask to be put in touch with a person at any time, by sending HUMAN in the chat or writing to hello@askdubrovnik.com. Doing so means an authorised person will read the relevant part of your conversation in order to help you.
Training. We do not use your messages to train or fine-tune AI models. Our AI providers operate under terms and, where available, data processing agreements under which content submitted through their business or paid interfaces is not used to train their models; we do not control their internal practices beyond those terms. Current providers are listed in Section 6.
No automated decisions with legal effect. The Service does not make decisions producing legal or similarly significant effects within the meaning of Article 22 GDPR. It produces information.
5. Retention
Principle. We keep identifiable data only for as long as it serves a purpose in Section 3, and we prefer pseudonymisation and aggregation over retention. Different elements of the same conversation are kept for different periods, because they serve different purposes: an identifier is needed only briefly, while the question asked remains useful for improving our data long after we stop needing to know who asked it. Periods are reviewed at least annually and are not extended without updating this Policy and its Effective Date.
| Data | Retention |
|---|---|
| Media (photographs, voice, files) you send | Not retained — used to produce the reply, then deleted; in any event within 7 days |
| IP address (web chat) | 30 days, for security and abuse prevention |
| Phone number and WhatsApp display name | While the conversation is active, plus 30 days — or, if you have asked to receive city and cultural notices, for as long as you remain subscribed |
| Your request to receive city and cultural notices, and its withdrawal | While subscribed, then 3 years, as proof that consent was given and honoured. This record includes the phone number, the date and time of the request, and the specific technical log/identifier of the opt-in action |
| A first message from someone who does not continue after our first reply, and so does not accept the Terms | 30 days |
| Conversation identifier (web chat) | 30 days, then replaced with an unlinked pseudonym |
| Message content and replies, in raw form | Up to 12 months from the end of the conversation, then deleted or pseudonymised |
| Pseudonymised conversation and quality records, with direct identifiers removed | Up to 5 years, corresponding to the general limitation period under Croatian law, then deleted or anonymised |
| Aggregated and anonymised statistics, containing no identifiers and no free text | Indefinitely — no longer personal data |
| Correspondence about a data protection request or complaint | 3 years, as evidence that it was handled |
| Data needed for a specific legal claim, or retained under a legal obligation | For as long as that claim or obligation lasts |
On anonymisation. Anonymisation means removing identifiers and any free text that could identify a person, so that the remaining data cannot be linked back to you by us or by anyone else using means reasonably likely to be used. Anonymised data is no longer personal data, is not subject to this Policy, and is retained, used and disposed of at our discretion as part of the company's own data.
Pseudonymised data — where identifiers are replaced but the record remains distinct — is still personal data, is treated as such here, and is subject to the 5-year limit.
Third-party copies. These periods govern our own systems. Copies held by the platforms through which the Service operates — WhatsApp on your device and on Meta's systems, and transient logs kept by AI providers for abuse detection — are governed by those providers' policies (Sections 6 and 11).
6. Recipients and Sub-Processors
We do not sell personal data. We share it only with providers processing it on our behalf under a data processing agreement, and only as necessary.
| Provider | Role | Processing location |
|---|---|---|
| Meta Platforms Ireland Ltd. / Meta Platforms, Inc. | WhatsApp Business Platform — message delivery on the WhatsApp channel | EU / US |
| [CONVERSATION PLATFORM] | Conversation orchestration and session handling | [EU / US] |
| [HOSTING PROVIDER] | Hosting of the application and database | [EU] |
| [LLM PROVIDER(S) ACTUALLY IN USE] | AI language model services — interpreting the question and phrasing the reply | [EU / US] |
Where we transmit a safety notice from a public authority (Terms, Section 11.1), we do not disclose your data to that authority. It supplies the text; we send it. The authority receives no identifiers, no message content, and no list of recipients — at most, aggregate counts. The same applies to anyone who brings a city or cultural item to our attention under Section 11.2.
We may also disclose data where required by law or by a competent authority, to protect our rights or the safety of others, and in connection with a sale or reorganisation of the business, in which case you will be informed.
Changes to this list. Where we add or replace a sub-processor handling message content or direct identifiers, we will update this Section and the Effective Date, and announce the change in the chat or on the website before it takes effect. Suppliers that do not process user personal data are not listed; the full list of processors is available at privacy@askdubrovnik.com.
7. International Transfers
Some providers process data outside the EEA, principally in the United States. Where that happens we rely on:
- the EU–US Data Privacy Framework, where the provider is certified under it; or
- Standard Contractual Clauses approved by the European Commission, with supplementary measures where required.
You may request details of the safeguards applying to a specific transfer at privacy@askdubrovnik.com.
8. Your Rights
Under the GDPR you may: access your data; have inaccurate data corrected; have your data erased; restrict processing; receive your data in a portable format; object to processing based on legitimate interest; and withdraw consent where processing is based on it.
How to exercise them. Write to privacy@askdubrovnik.com, or send the message DATA REQUEST in the chat.
Sending DATA REQUEST in the chat is the simplest route, because the Service already knows which conversation you are in. It will confirm your request and give you the reference for your conversation, which you should keep if you want to follow up by email later.
We respond within one month, and will tell you if we need to extend that by up to two further months.
Identifying your data.
- WhatsApp channel — we locate your data by phone number. Make the request from the same number, or tell us the number.
- Web chat — we hold no name or contact details for you, only a conversation identifier and, for 30 days, an IP address. Use DATA REQUEST in the chat, or quote the reference the Service gave you. Failing that, tell us the approximate date, time and subject of the conversation. If none of this allows us to identify the records with reasonable confidence, we are not required to obtain additional data solely to find you (Article 11(2) GDPR); we will say so and explain what would let us proceed.
Effect of our retention periods. Identifiers are removed on the schedule in Section 5. A request about an older conversation will often find nothing identifiable left to disclose or erase, and we will tell you when that is the case.
Complaints. You may complain to the Croatian Personal Data Protection Agency (AZOP), Selska cesta 136, 10000 Zagreb, azop@azop.hr, https://azop.hr, or to the supervisory authority of your country of residence.
9. Security
We apply technical and organisational measures appropriate to the risk, including encryption in transit and at rest, access control limited to persons who need it, separation of raw logs from analytical records, and scheduled deletion.
We maintain an internal procedure for detecting, assessing and reporting personal data breaches. No system is completely secure and we cannot guarantee absolute security. Where a breach is likely to result in a high risk to your rights, we will inform you as required by Article 34 GDPR.
10. Cookies, Local Storage and Affiliate Tracking
On askdubrovnik.com we use:
- Strictly necessary cookies and local storage — to maintain the chat session, balance load and protect against abuse. These are set without consent, as permitted under the Croatian Electronic Communications Act and Article 5(3) of the ePrivacy Directive.
- Analytics — [ANALYTICS TOOL]. Where analytics are not strictly necessary, they are set only after you consent through the cookie banner. You may withdraw consent at any time through the same banner, and the Service works fully without them.
We do not use advertising or retargeting cookies, and we do not track you across unrelated websites for our own purposes.
Affiliate links are an exception you should know about. Where a link is marked Partner, it normally carries a tracking parameter, and following it may result in the destination site or its affiliate network setting a cookie or identifier on your device to attribute the referral to us. That processing takes place on the destination site under its own terms, and we do not control it. What we receive back is attribution and commission data, not your identity. You can avoid it by not following the marked link.
11. WhatsApp Channel — Specific Points
- Meta's own role. Meta processes data relating to the operation of WhatsApp as an independent controller under its own privacy policy: https://www.whatsapp.com/legal/privacy-policy. That processing is outside our control.
- Starting and stopping. Sending your first message initiates the Service and allows us to reply. Send STOP or block the number to stop everything. To stop only the city and cultural notices while continuing to use the Service, send STOP NOTICES. Either takes effect immediately.
- Copies held elsewhere. Messages between you and the Service are also stored on your device and may be retained by WhatsApp under its own rules.
12. Children
The Service is not directed at children below the minimum age in the Terms (16 years in the EU/EEA). We do not verify age. We do not knowingly collect data from children below that age and delete it if we learn that we have. Contact privacy@askdubrovnik.com.
13. If the Service Is Discontinued
If we stop operating the Service, we will announce it in the chat and on the website before it closes. Personal data will then be deleted or anonymised within 90 days of closure, except what must be kept under a legal obligation or for a specific legal claim.
Anonymised and aggregated data is not personal data and remains the property of Argosy Technologies d.o.o., to retain, use or destroy as it sees fit.
If the Service is transferred to another company as part of a sale or reorganisation of the business, personal data may transfer with it. You will be informed before that happens, the acquirer is bound by this Policy until it lawfully adopts its own, and you may request erasure before the transfer.
14. Changes to This Policy
We may update this Policy. Material changes will be announced in the chat or on the website before they take effect, and the Version and Effective Date updated. Superseded versions remain at askdubrovnik.com/legal/archive.
15. Contact
Argosy Technologies d.o.o. Brune Bušića 30, 20000 Dubrovnik, Croatia Email: privacy@askdubrovnik.com