This policy explains how CEAREM, obrt za digitalni marketing (“CEAREM”, “we”, “us”) collects and uses personal data when you visit cearem.io, book a call, contact us or use our services. We are established in Croatia, so we process personal data under the EU General Data Protection Regulation (GDPR). This policy also covers rights you may have under the privacy laws of US states and other countries we serve.
1. Who Is Responsible for Your Data
The data controller is CEAREM, obrt za digitalni marketing, OIB 78837451774, Put Bokanjca 64, 23000 Zadar, Croatia. Email: info@cearem.io.
2. What We Collect
- Details you give us when you book a call, fill in a form or write to us: your name, email address, phone number, business name and anything you include in your message.
- Records of calls and messages with us, including call recordings where you have been told the call is recorded.
- Customer account details if you become a customer: billing contact, account users and settings. Card payments are handled by our payment processor; we do not store full card numbers.
- Technical data when you visit the site: IP address, browser, device and pages viewed. Analytics and advertising data is collected only as described in Cookies.
3. How We Use It and Our Legal Bases
- To answer your enquiry and hold your demo or consult call, at your request before a contract (GDPR Art. 6(1)(b)).
- To provide our services, bill you and support you, under our contract with you (Art. 6(1)(b)).
- To follow up on enquiries and keep our records accurate, based on our legitimate interests (Art. 6(1)(f)). You can object at any time.
- To send marketing messages, only with your consent where the law requires it (Art. 6(1)(a)). You can withdraw consent at any time.
- To measure our website and advertising with cookies, only with your consent where required (Art. 6(1)(a)).
- To meet accounting, tax and other legal obligations (Art. 6(1)(c)).
We do not make decisions about you based solely on automated processing that have legal or similarly significant effects.
4. Text Messages
If you give us your mobile number and tick the consent box when you book or contact us, CEAREM may text you about your booking, your enquiry and your account. If you separately agree to marketing texts, we may also send occasional offers and product updates. Message frequency varies. Message and data rates may apply. Reply STOP to opt out at any time, or HELP for help. Consent to texts is never a condition of purchase.
No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent will not be shared with any third parties.
Full SMS terms are in our Terms and Conditions.
5. Who We Share Data With
We share personal data only with service providers that help us run our business and process it on our instructions, under data processing agreements:
- CRM, telephony and messaging platform providers, which also power the CEAREM platform
- Telecom carriers and messaging providers that deliver calls and texts
- Email delivery providers, including the service that delivers our website contact form to our inbox
- Payment processors
- Website hosting and content delivery providers
- Analytics and advertising providers (Google and Meta), only as described in Cookies
- Our accountants, lawyers and authorities, where the law requires it
We do not sell personal data for money.
6. International Transfers
Some of our providers are based in, or access data from, the United States and other countries outside the European Economic Area. When data is transferred, we rely on an adequacy decision such as the EU–US Data Privacy Framework, or on Standard Contractual Clauses approved by the European Commission, together with appropriate safeguards.
7. Data in Our Customers’ Accounts
Businesses that use CEAREM decide what data they put into their accounts, such as their own customers’ contact details and conversations. For that data, the business is the controller and we act as its processor under our data processing terms. If a US healthcare business has our HIPAA Mode add-on, we also handle its patients’ health information as its business associate, under the Business Associate Agreement we sign with that business. If you are a customer of a business that uses CEAREM, please contact that business to exercise your rights.
8. Cookies and Similar Technologies
Our website uses a small amount of storage that it needs to work, such as remembering your privacy choice. Where allowed, it also loads analytics and advertising tools through Google Tag Manager: Google Analytics, Google Ads and the Meta Pixel. These may set cookies and send device and browsing data to Google and Meta, so we can measure visits, see which ads bring enquiries and show our ads to people likely to be interested. When you send us a form, we may also tell these platforms that a lead came in, without sending the content of your message.
- Visitors in the EEA, the UK and Switzerland: analytics and advertising cookies stay off until you select Allow. You can change your mind at any time.
- Visitors elsewhere: these cookies are on by default. You can switch them off at any time with Your Privacy Choices in the footer of every page. We also treat a Global Privacy Control (GPC) signal from your browser as a request to opt out of advertising cookies.
Booking calendars on our site are provided by our CRM platform provider and may use storage that is necessary to complete a booking.
Our site does not respond to browser “Do Not Track” signals, because there is no common standard for them. We do honor Global Privacy Control, as described above.
9. How Long We Keep Data
We keep enquiry and booking data for up to 24 months after our last contact with you, unless you become a customer. We keep customer and billing records for as long as the contract lasts and afterwards for as long as accounting and tax law requires. Opt-out records are kept so we can honor them.
10. Security
We protect personal data with access controls, encryption in transit and providers that maintain recognized security standards. No system is perfectly secure, and we will notify you and the authorities of a breach where the law requires it.
11. Your Rights Under the GDPR
You have the right to access your personal data, correct it, have it deleted, restrict or object to its processing (including at any time to direct marketing), and receive it in a portable format. Where we rely on consent, you can withdraw it at any time without affecting earlier processing. Email info@cearem.io and we will respond within one month.
You can also complain to the Croatian Personal Data Protection Agency (Agencija za zaštitu osobnih podataka, azop.hr) or to the supervisory authority where you live or work.
12. Your US State Privacy Rights
Depending on the state you live in, including California, Colorado, Connecticut, Virginia and others with comprehensive privacy laws, you may have the right to:
- know what personal information we collect, use and disclose, and get a copy of it
- correct inaccurate personal information
- delete personal information we hold about you
- opt out of the sale of personal information, of “sharing” for cross-context behavioral advertising and of targeted advertising
- appeal our decision if we decline your request
We do not sell personal information for money and do not knowingly collect personal information from anyone under 16. If you allow advertising cookies, our advertising partners may receive device and browsing data, which some state laws treat as “sharing” or targeted advertising. You can opt out with Your Privacy Choices in the footer, and we honor Global Privacy Control signals.
Notice at collection. In the last 12 months we have collected these categories of personal information: identifiers and contact details (such as name, email, phone number and IP address), commercial information (such as the plan you buy), internet activity (such as pages viewed and ad interactions) and approximate location derived from your IP address. We use them for the purposes in section 3 and keep them for the periods in section 9. We disclose them to the service providers in section 5. We do not sell any of them for money; internet activity and identifiers may be “shared” with Google and Meta for advertising if you allow advertising cookies. We do not collect sensitive personal information for the purpose of inferring characteristics about you.
To make a request, email info@cearem.io with the subject “Privacy request”. We will verify your identity by matching details you give us with the details we hold, and you may use an authorized agent. We will not discriminate against you for exercising your rights. To appeal a decision, reply to our response with the subject “Privacy appeal”.
13. Children
Our website and services are for businesses and are not directed at children. We do not knowingly collect personal data from children under 16.
14. Changes to This Policy
We will post any changes on this page and update the date at the top. If a change is significant, we will tell customers by email.
15. Contact
CEAREM, obrt za digitalni marketing, Put Bokanjca 64, 23000 Zadar, Croatia. Email info@cearem.io.