ULPIAN AI d.o.o., Zelinska ulica 5, HR-10 000 Zagreb, OIB: 64992711010, društvo upisano u sudski registar Trgovačkog suda u Zagrebu, MBS: 081559175; osobe
ovlaštene za zastupanje: Filip Boltužić / Ozren Kobsa, temeljni kapital: 2.520,00 euro
PRIVACY POLICY ULPIAN AI
Dear user,
Your interest in our Privacy Policy clearly demonstrates how important privacy and the protection of personal data are
to you. We greatly appreciate your concern, and we are fully committed to safeguarding your privacy. Protecting your
personal data is a priority for us in the conduct and organisation of our business processes.
We respect the confidentiality of your personal data and always act in accordance with the relevant law provisions and
other regulations governing the protection of personal data, as well as the provisions of these Privacy Policy.
We hereby inform you that, in the context of comprehensive personal data protection, we have aligned our business
operations with all the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of April
27, 2016, on the protection of individuals concerning the processing of personal data and on the free movement of such
data, and repealing Directive 95/46/EC (General Data Protection Regulation or "GDPR"), as well as the corresponding
Law on the Implementation of the General Data Protection Regulation (Official Gazette No. 42/2018; hereinafter referred
to as the "Law").
In our Privacy Policy, we inform you transparently and comprehensively about the processing of your personal data. We
want to provide you with information about (i) the personal data we collect, (ii) who exactly processes your personal
ULPIAN AI d.o.o., Zelinska ulica 5, HR-10 000 Zagreb, OIB: 64992711010, društvo upisano u sudski registar Trgovačkog suda u Zagrebu, MBS: 081559175; osobe
ovlaštene za zastupanje: Filip Boltužić / Ozren Kobsa, temeljni kapital: 2.520,00 euro
data, (iii) the purpose for which we collect them, (iv) the transfer of your personal data to other individuals or possibly
to other countries and/or international organizations, (v) the period during which we process your personal data, and
(vi) your direct rights regarding the processing.
Definitions
Terms used in this Privacy Policy have the following meaning:
Infringement of
personal data
Means any breach of security or privacy leading to accidental or
unlawful destruction, loss, alteration, unauthorized disclosure,
or access to personal data. To avoid any doubt, this includes any
violation caused by employees, any person acting on behalf of
the company, or third parties.
Personal data
Means any information relating to an identified or identifiable
natural person (“data subject”); an identifiable
natural person is one who can be identified, directly or indirectly,
in particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or to
one or more factors specific to the physical, physiological,
genetic, mental, economic, cultural or social identity of that
natural person.
ULPIAN AI d.o.o., Zelinska ulica 5, HR-10 000 Zagreb, OIB: 64992711010, društvo upisano u sudski registar Trgovačkog suda u Zagrebu, MBS: 081559175; osobe
ovlaštene za zastupanje: Filip Boltužić / Ozren Kobsa, temeljni kapital: 2.520,00 euro
Data processing
Means any operation or set of operations performed on
personal data or sets of personal data, whether by automated or
non-automated means, such as collection, recording,
organization, structuring, storage, adaptation or alteration,
retrieval, consultation, use, disclosure by transmission,
dissemination, or otherwise making available, alignment or
combination, restriction, erasure, or destruction.
Services
This Privacy Policy describes our practices with respect to
Personal Data we collect from or about you when you use our
website and/or our web-based application called “Ulpian”
(collectively, “Services”).
Data controller
If you live in the European Economic Area (EEA) or Switzerland, Ulpian AI llc, with its registered office at Zelinska ulica 5,
Zagreb, Croatia, is the controller and is responsible for the processing of your Personal Data as described in this Privacy
Policy.
We are at your disposal at any moment and you can contact us regarding the processing of personal data by the Data
Controller.
ULPIAN AI d.o.o., Zelinska ulica 5, HR-10 000 Zagreb, OIB: 64992711010, društvo upisano u sudski registar Trgovačkog suda u Zagrebu, MBS: 081559175; osobe
ovlaštene za zastupanje: Filip Boltužić / Ozren Kobsa, temeljni kapital: 2.520,00 euro
For any questions related to the processing of your personal data and the exercise of rights provided by the GDPR, you
can reach out to us through the following methods:
● In writing, at the address: Zelinska ulica 5, 10 000 Zagreb, Croatia
● By email, at the address: info@ulpian.eu
Personal Data we collect
We collect personal data relating to you as described below:
1. Account Information
When you create an account with us, we collect information associated with your account, including your name, contact
information, account credentials, payment card information, and transaction history (collectively, “Account
Information”).
2. User Content
When you use our Services, we collect Personal Data that is included in the input or feedback that you provide to our
Services (“Content”).
3. Communication Information
If you communicate with us through a web-site form or email, we collect your name, email address, phone number, and
any other information you provide us and the contents of any messages you send so we can get in touch with you
(collectively, “Communication Information”).
ULPIAN AI d.o.o., Zelinska ulica 5, HR-10 000 Zagreb, OIB: 64992711010, društvo upisano u sudski registar Trgovačkog suda u Zagrebu, MBS: 081559175; osobe
ovlaštene za zastupanje: Filip Boltužić / Ozren Kobsa, temeljni kapital: 2.520,00 euro
4. Social Media Information
We have pages on social media sites like LinkedIn, Facebook, and X. When you interact with our social media pages, we
collect Personal Data that you choose to provide to us, such as your contact details (collectively, “Social Media
Information”).
5. Customer support information
When you contact us for customer support, feedback, or inquiries, we may collect your name, email address, phone
number, and any other information you provide us or that we request from you to assist you or resolve your issue
(“Support Information”).
6. Analytic
We may use a Google Analytics that use cookies to help us analyze how users use our Services and enhance your
experience when you use them.
7. Online Tracking and Do Not Track Signals
Our website currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy
whether or not a DNT signal is received.
8. Other Information You Provide
We collect other information that you may provide to us, such as when you participate in our events or surveys or
provide us with information to establish your age or identity (collectively, “Other Information You Provide”).
ULPIAN AI d.o.o., Zelinska ulica 5, HR-10 000 Zagreb, OIB: 64992711010, društvo upisano u sudski registar Trgovačkog suda u Zagrebu, MBS: 081559175; osobe
ovlaštene za zastupanje: Filip Boltužić / Ozren Kobsa, temeljni kapital: 2.520,00 euro
9. Personal Data We Receive Automatically From Your Use of the Services
When you visit, use, or interact with the Services, we receive the following information (“Technical Information”):
• Log Data
Information that your browser or device automatically sends when you use our Services. Log data includes your
Internet Protocol address, browser type and settings, the date and time of your request, and how you interact
with our Services.
• Usage Data
We may automatically collect information about your use of the Services, such as the types of content that you
view or engage with, the features you use and the actions you take, as well as your time zone, country, the dates
and times of access, user agent and version, type of computer or mobile device, and your computer connection.
• Device Information
Includes name of the device, operating system, device identifiers, and browser you are using. Information
collected may depend on the type of device you use and its settings.
• Cookies and Similar Technologies
We use cookies and similar technologies to operate and administer our Services and improve your experience.
For details about our use of cookies, please visit our Cookie Policy.
ULPIAN AI d.o.o., Zelinska ulica 5, HR-10 000 Zagreb, OIB: 64992711010, društvo upisano u sudski registar Trgovačkog suda u Zagrebu, MBS: 081559175; osobe
ovlaštene za zastupanje: Filip Boltužić / Ozren Kobsa, temeljni kapital: 2.520,00 euro
How we use Personal Data
We may use Personal Data for the following purposes:
● To provide and maintain our Services;
● To improve and develop our Services and new features and conduct research;
● To communicate with you, including to send you information or marketing about our Services and events;
● To prevent fraud, criminal activity, or misuses of our Services, and to protect the security of our systems
and Services; and
● To comply with legal obligations and to protect the rights, privacy, safety, or property of our users, us, our
affiliates, or any third party.
Aggregated or De-Identified Information
We aggregate or de-identify Personal Data so that it can no longer be used to identify you and use this information to
analyse the effectiveness of our Services, to improve and add features to our Services, to conduct research and for other
similar purposes. In addition, from time to time, we may share or publish aggregated information like general user
statistics with third parties. We collect this information through the Services, through cookies, and through other means
described in this Privacy Policy. We will maintain and use de-identified information in anonymous or de-identified form
and we will not attempt to re-identify the information, unless required by law.
ULPIAN AI d.o.o., Zelinska ulica 5, HR-10 000 Zagreb, OIB: 64992711010, društvo upisano u sudski registar Trgovačkog suda u Zagrebu, MBS: 081559175; osobe
ovlaštene za zastupanje: Filip Boltužić / Ozren Kobsa, temeljni kapital: 2.520,00 euro
Legal bases for processing
When we process your Personal Data for the purposes described above, we rely on the following legal bases:
Purpose of processing
Type of Personal Data processed,
depending on the processing
activity
Legal basis, depending on the
process activity
To provide and maintain our Services
● Account Information
● User Content
● Communication
Information
● Other Information You
Provide
● Log Data
● Usage Data
● Device Information
● Cookies and Similar
Technologies
To improve and develop our Services
and new features and conduct
research
● Account Information
● User Content
ULPIAN AI d.o.o., Zelinska ulica 5, HR-10 000 Zagreb, OIB: 64992711010, društvo upisano u sudski registar Trgovačkog suda u Zagrebu, MBS: 081559175; osobe
ovlaštene za zastupanje: Filip Boltužić / Ozren Kobsa, temeljni kapital: 2.520,00 euro
● Communication
Information
● Other Information You
Provide
● Data We Receive From
Other Sources
● Log Data
● Usage Data
● Device Information
● Cookies and Similar
Technologies
To communicate with you, including
to send you information or marketing
about our Services and events
● Account Information
● Communication
Information
● Social Media Information
● Other Information You
Provide
● Log Data
● Usage Data
● Device Information
● Cookies and Similar
Technologies
ULPIAN AI d.o.o., Zelinska ulica 5, HR-10 000 Zagreb, OIB: 64992711010, društvo upisano u sudski registar Trgovačkog suda u Zagrebu, MBS: 081559175; osobe
ovlaštene za zastupanje: Filip Boltužić / Ozren Kobsa, temeljni kapital: 2.520,00 euro
To prevent fraud, criminal activity, or
misuses of our Services, and to
protect the security of our systems
and Services
● Account Information
● User Content
● Communication
Information
● Social Media Information
● Other Information You
Provide
● Data We Receive From
Other Sources
● Log Data
● Usage Data
● Device Information
● Cookies and Similar
Technologies
To comply with legal obligations and
to protect the rights, privacy, safety,
or property of our users, us or any
third party
● Account Information
● User Content
● Communication
Information
● Social Media Information
ULPIAN AI d.o.o., Zelinska ulica 5, HR-10 000 Zagreb, OIB: 64992711010, društvo upisano u sudski registar Trgovačkog suda u Zagrebu, MBS: 081559175; osobe
ovlaštene za zastupanje: Filip Boltužić / Ozren Kobsa, temeljni kapital: 2.520,00 euro
● Other Information You
Provide
● Data We Receive From
Other Sources
● Log Data
● Usage Data
● Device Information
● Cookies and Similar
Technologies
Disclosure of Personal Data
In certain circumstances we may disclose your Personal Data to:
1. Vendors and Service Providers
To assist us in meeting business operations needs and to perform certain services and functions, we may disclose
Personal Data to vendors and service providers, including providers of hosting services, cloud services, content delivery
services, data warehouse services, support and safety monitoring services, email communication software, web analytics
services, payment and transaction providers, and other information technology services providers. Pursuant to our
instructions, these parties will access, process, or store Personal Data only while performing their duties to us.
ULPIAN AI d.o.o., Zelinska ulica 5, HR-10 000 Zagreb, OIB: 64992711010, društvo upisano u sudski registar Trgovačkog suda u Zagrebu, MBS: 081559175; osobe
ovlaštene za zastupanje: Filip Boltužić / Ozren Kobsa, temeljni kapital: 2.520,00 euro
2. Business Transfers
If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another
provider (collectively, a “Transaction”), your Personal Data and other information may be disclosed in the diligence
process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part
of that Transaction along with other assets.
3. Government Authorities or Other Third Parties
We may share your Personal Data, including information about your interaction with our Services, with government
authorities, industry peers, or other third parties in compliance with the law (i) if required to do so by law or in the good
faith belief that such action is necessary to comply with a legal obligation, (ii) to protect and defend our rights or property,
(iii) if we determine, in our sole discretion, that there is a violation of our terms, policies, or the law; (iv) to detect or
prevent fraud or other illegal activity; (v) to protect the safety, security, and integrity of our products, employees, or
users, or the public, or (vi) to protect against legal liability.
Retention
Your Personal Data will be retained solely for the time required to deliver our Service to you, or for other lawful business
purposes including dispute resolution, ensuring safety and security, or meeting our legal responsibilities.
ULPIAN AI d.o.o., Zelinska ulica 5, HR-10 000 Zagreb, OIB: 64992711010, društvo upisano u sudski registar Trgovačkog suda u Zagrebu, MBS: 081559175; osobe
ovlaštene za zastupanje: Filip Boltužić / Ozren Kobsa, temeljni kapital: 2.520,00 euro
How long we retain Personal Data will depend on a number of factors, such as:
● Our purpose for processing the data (such as whether we need to retain the data to provide our Services);
● The amount, nature, and sensitivity of the data;
● The potential risk of harm from unauthorized use or disclosure of the data;
● Any legal requirements that we are subject to.
Your rights
In order to keep effective control over the processing of your personal data, you are entitled to a variety of rights which
you may directly exercise with the Data Controller in situations as prescribed by law.
1. The right to be informed about the processing of your personal data
You have the right to request confirmation from the Data Controller whether personal data concerning you is being
processed, the purpose of processing, the categories of your personal data that the Data Controller retains, and/or third
parties or categories of third parties with whom your personal data is shared.
Additionally, you have the right to know the time period during which the data is retained, as well as the source of your
personal data if it was not collected directly from you.
2. The right to rectification of your personal data
If we process your personal data that is incomplete or inaccurate, you have the right to request correction and/or
supplementation.
ULPIAN AI d.o.o., Zelinska ulica 5, HR-10 000 Zagreb, OIB: 64992711010, društvo upisano u sudski registar Trgovačkog suda u Zagrebu, MBS: 081559175; osobe
ovlaštene za zastupanje: Filip Boltužić / Ozren Kobsa, temeljni kapital: 2.520,00 euro
3. The right to the erasure of your personal data
You have the right to request the erasure of your personal data if one of the following conditions is fulfilled:
● Your personal data are no longer necessary to fulfil the purpose for which we collected or processed them;
● You have withdrawn the consent on which the processing is based in accordance with point (a) of Article
6(1) or point (a) of Article 9(2) and there is no other legal basis for processing;
● You have objected to the processing of your personal data in accordance with Article 21(1) of the General
Data Protection Regulation and if there are no legitimate reasons for processing;
● Your personal data have been illegally processed;
● Your personal data must be erased in order to comply with a legal obligation under Union or State law to
which the controller is subjected
● Your personal data have been collected in relation to the provision of information society services referred
to in Article 8(1).
4. Right to restrict the processing of personal data
You can request the restriction of processing of your data:
● If you dispute the accuracy of data during the period allowing the Data Controller to verify the accuracy
of such data.
● If data processing was unlawful, and you request restriction instead of data deletion.
● If the Data Controller no longer needs the collected data for the intended purposes, but you still need it
to assert legal claims.
● If an objection to the processing of this data has been filed.
ULPIAN AI d.o.o., Zelinska ulica 5, HR-10 000 Zagreb, OIB: 64992711010, društvo upisano u sudski registar Trgovačkog suda u Zagrebu, MBS: 081559175; osobe
ovlaštene za zastupanje: Filip Boltužić / Ozren Kobsa, temeljni kapital: 2.520,00 euro
5. Right to object to the processing of personal data
You have the right to object at any time to processing of personal data concerning him or her which is based on the
legitimate interest.
6. Right to data portability
You have the right to request that the Data Controller provide you with the data you have entrusted to them in a
structured, commonly used, and machine-readable format if:
● The Data Controller processes data based on your previously given consent.
● Processing is carried out using automated processes.
7. Right to lodge a complaint with the supervisory authority
If you believe that the Data Controller has violated relevant legislation during the processing of your data, please contact
the Data Controller immediately to clarify any contentious issues. You also have the right to file a complaint with the
Croatian Personal Data Protection Agency, Selska cesta 136, Zagreb, azop@azop.hr, tel: 01 4609-000.
You can submit your request to exercise your rights in writing or verbally. You can also use the Request Form for Data
Subject Rights available at the following link - FORM. The completed form should be sent to the email address:
info@ulpian.eu or submitted in writing to the Data Controller's headquarters.
The Data Controller will consider each such request in accordance with all applicable laws and regulations on personal
data protection. The exercise of the aforementioned rights is entirely free of charge. In case your requests are deemed
unreasonable, unfounded, or excessive (e.g., due to frequent repetition within a short time frame), we reserve the right
to, at our discretion, (i) charge a reasonable fee based on administrative costs or (ii) refuse to comply with the request.
ULPIAN AI d.o.o., Zelinska ulica 5, HR-10 000 Zagreb, OIB: 64992711010, društvo upisano u sudski registar Trgovačkog suda u Zagrebu, MBS: 081559175; osobe
ovlaštene za zastupanje: Filip Boltužić / Ozren Kobsa, temeljni kapital: 2.520,00 euro
Users have the right to be informed based on a submitted request, and after successful verification of their identity,
about the following:
• The purpose of processing personal data.
• The source of personal data if it was not obtained from the user.
• The categories of personal data.
• Recipients or categories of recipients to whom personal data has been or may be transferred, along with
the location of these recipients.
• The envisaged period for the storage of personal data or the rationale for determining the storage period.
• The use of any automated decision-making, including profiling.
All requests for access or correction of personal data must be directed to the Data Protection Officer. A response to each
request is provided within 30 days of receiving the written request from the user.
Links to other websites
Our website may contain links to other websites that are not under our control. Clicking on links to third-party websites
will take you to those third-party websites. We are not responsible for the policies and practices of other companies. We
do not control and we are not responsible for the content, privacy policies, and privacy warnings of any third-party
websites or services. Therefore, we are not responsible for the policies and practices of other companies. We recommend
that you familiarize yourself with the privacy settings of those third-party websites when visiting them.
ULPIAN AI d.o.o., Zelinska ulica 5, HR-10 000 Zagreb, OIB: 64992711010, društvo upisano u sudski registar Trgovačkog suda u Zagrebu, MBS: 081559175; osobe
ovlaštene za zastupanje: Filip Boltužić / Ozren Kobsa, temeljni kapital: 2.520,00 euro
Our website features social media elements such as buttons for Facebook, LinkedIN or X. These elements may collect
certain data about you, such as your IP address and the pages you visit and may also store cookies for the proper
functioning of the site. The collection of data through interactions with these elements is governed by the privacy
notice/policy of the company to which they belong, and it is not entirely under our control. You can view the privacy
policies or confidentiality statements of social media networks and how they use your personal data at the following
links:
FACEBOOK ONLINE
hps://www.facebook.com/privacy/policy/
LINKEDIN ONLINE
hps://www.linkedin.com/legal/privacy-policy
X ONLINE
hps://twier.com/en/privacy
If you have any questions regarding the collection and processing of data by Facebook, LinkedIN, and/or X, or if you wish
to exercise any of your rights guaranteed by the General Data Protection Regulation, please contact:
• FOR FACEBOOK:
META PLATFORMS IRELAND Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland,
https://www.facebook.com/policy.php Data Protection Officer contact:
https://www.facebook.com/help/contact/540977946302970.
If you are not satisfied with how your personal data is collected and processed, you can contact Meta's lead supervisory
authority, the Irish Data Protection Commissioner, or the Croatian Personal Data Protection Agency.
ULPIAN AI d.o.o., Zelinska ulica 5, HR-10 000 Zagreb, OIB: 64992711010, društvo upisano u sudski registar Trgovačkog suda u Zagrebu, MBS: 081559175; osobe
ovlaštene za zastupanje: Filip Boltužić / Ozren Kobsa, temeljni kapital: 2.520,00 euro
• FOR LINKEDIN:
LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland, https://www.linkedin.com/legal/privacy-policy;
Data Protection Officer contact: https://www.linkedin.com/help/linkedin/ask/TSO-DPO.
If you are not satisfied with how your personal data is collected and processed, you can contact LinkedIn's lead
supervisory authority, the Irish Data Protection Commissioner, or the Croatian Personal Data Protection Agency.
• FOR X:
X International Unlimited Company, Attn: Data Protection Officer, One Cumberland Place, Fenian Street, Dublin 2, D02
AX07 IRELAND, https://twitter.com/en/privacy; Data Protection Officer contact: https://help.twitter.com/forms/privacy.
If you are not satisfied with how your personal data is collected and processed, you can contact X's lead supervisory
authority, the Irish Data Protection Commissioner, or the Croatian Personal Data Protection Agency.
Changes to the Privacy Policy
To comply with the requirements of the GDPR and other applicable regulations, this Privacy Policy comes into effect on
26 March 2024.
As existing processes for the processing of personal data may change over time and new processes may be implemented,
it will be necessary to revise or amend this Privacy Policy. The revised or amended version of the Privacy Policy will be
published on our website upon its adoption.
ULPIAN AI d.o.o., Zelinska ulica 5, HR-10 000 Zagreb, OIB: 64992711010, društvo upisano u sudski registar Trgovačkog suda u Zagrebu, MBS: 081559175; osobe
ovlaštene za zastupanje: Filip Boltužić / Ozren Kobsa, temeljni kapital: 2.520,00 euro
How to contact us
Please contact support if you have any questions or concerns not already addressed in this Privacy Policy.
Concerning the processing of your personal data, please reach out to us at the addresses listed in the section Data
Controller.