Privacy Policy
Talk Time Cro | Tihana Klepač | talktimecro.com
Last updated: March 2026
1. Introduction
We are very pleased that you have shown interest in Talk Time Cro. Data protection is of a particularly high priority to us. The use of this website is possible without any indication of personal data; however, if you wish to use specific services — such as enrolling in a programme, subscribing to the newsletter, or using the AI chat assistant — processing of personal data may become necessary.
Where processing of personal data is necessary and there is no statutory basis for such processing, we obtain consent from you. All personal data is processed in line with the General Data Protection Regulation (GDPR) and applicable Croatian and EU data protection regulations.
This Privacy Policy explains what personal data we collect, how we use it, and what rights you have in relation to it.
2. Controller
The controller responsible for the processing of personal data on this website is:
Talk Time Cro Tihana Klepač Filipoviceva 31 10000 Zagreb Croatia Phone: +385 95 9052 650 Email: [email protected] Website: www.talktimecro.com
3. Definitions
Personal data means any information relating to an identified or identifiable natural person.
Processing means any operation performed on personal data, including collection, storage, use, disclosure, or deletion.
Controller means the natural or legal person who determines the purposes and means of the processing of personal data.
Consent means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which they signify agreement to the processing of personal data relating to them.
4. Cookies
This website uses cookies — small text files stored on your device by your browser. Cookies allow us to recognise returning visitors and improve your experience on the site. You may disable cookies through your browser settings at any time, though some features of the website may not function fully without them.
5. Collection of General Data and Information
When you visit this website, our servers automatically collect certain general data, including browser type and version, operating system, referring website, pages visited, date and time of access, and IP address. This data is stored in server log files and used solely to ensure the technical functioning of the website, optimise content, and protect against attacks. This data is not linked to any individual person and is stored separately from any personal data you provide.
6. Contact
When you contact us by email or through a contact form, the personal data you provide — including your name and email address — is stored for the purpose of responding to your enquiry. This data is not passed on to third parties.
7. Newsletter
If you subscribe to our newsletter, we collect your name and email address. We use the double opt-in procedure — you will receive a confirmation email and must click a link to confirm your subscription. This is to verify that you are the owner of the email address provided.
Your data is used solely to send the newsletter. You may unsubscribe at any time using the unsubscribe link in every newsletter, or by emailing [email protected]. Upon unsubscription, your data will be deleted from our mailing list.
Our newsletters may contain tracking pixels that allow us to see whether and when an email was opened and which links were clicked. This helps us improve future newsletters. You may prevent tracking by disabling HTML emails in your email client.
8. Online Courses and Programme Enrolment
When you enrol in a programme — including the Croatian Entry Point, Level Up Croatian, the Croatian Quadrant, or Croatian Nexus — we collect your name and email address for the purpose of creating your account and delivering the programme. This data is processed through our learning platform, Somba.io, which is headquartered in Switzerland and processes data in accordance with Swiss and EU data protection standards.
Your data is not sold or passed to third parties except where required by law or where necessary to deliver the service (for example, payment processing through Stripe — see Section 10).
9. AI Chat Assistant (August)
This website uses an AI-powered chat assistant called August, operated through Somba.io. When you interact with August, the content of your conversation — including any personal information you voluntarily share — is processed by Somba.io's systems in order to generate responses and, where applicable, to create a conversation summary for follow-up by Talk Time Cro staff.
Conversation data may be stored by Somba.io in accordance with their data retention policies. We encourage you not to share sensitive personal information (such as payment details or identification numbers) through the chat assistant.
If you have questions about how your chat data is handled, please contact [email protected].
10. Payment Processing — Stripe
Payments on this website are processed by Stripe. When you make a purchase, your payment data — including card details — is transmitted directly to Stripe and processed in accordance with their privacy policy (available at stripe.com/privacy). Talk Time Cro does not store your card details. Stripe uses your data solely for the purpose of processing payment and fraud prevention.
11. Social Media
This website contains links to and integrations with social media platforms including Facebook, Instagram, and YouTube. When you interact with these components or visit our profiles on these platforms, data may be collected and processed by those platforms in accordance with their own privacy policies. We encourage you to review the privacy policies of Facebook (facebook.com/about/privacy), Instagram (instagram.com/about/legal/privacy) and YouTube/Google (google.com/intl/en/policies/privacy).
12. Your Rights Under GDPR
As a data subject, you have the following rights:
Right of access — you may request confirmation of whether we process personal data about you and receive a copy of that data.
Right to rectification — you may request correction of inaccurate or incomplete personal data.
Right to erasure — you may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent.
Right to restriction of processing — you may request that we limit the processing of your data in certain circumstances.
Right to data portability — you may request your personal data in a structured, commonly used and machine-readable format.
Right to object — you may object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
Right to withdraw consent — where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
To exercise any of these rights, please contact us at [email protected]. We will respond to your request without undue delay and within one month at the latest.
You also have the right to lodge a complaint with a supervisory authority. In Croatia, the relevant authority is the Croatian Personal Data Protection Agency (Agencija za zaštitu osobnih podataka — AZOP), azop.hr.
13. Legal Basis for Processing
We process personal data on the following legal bases under Article 6 GDPR:
Consent (Art. 6(1)(a)) — for newsletter subscriptions and non-essential cookies.
Contract performance (Art. 6(1)(b)) — for processing necessary to deliver programmes and services you have purchased.
Legitimate interests (Art. 6(1)(f)) — for website security, fraud prevention, and improving our services.
14. Data Retention
We retain personal data only for as long as necessary for the purpose for which it was collected, or as required by applicable law. Newsletter subscriber data is retained until unsubscription. Course enrolment data is retained for the duration of your access and for a reasonable period thereafter for administrative and legal purposes.
15. Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure or destruction. However, no internet-based transmission is entirely secure, and we cannot guarantee absolute security. You are free to contact us by telephone if you prefer not to transmit personal data online.
16. Changes to This Policy
We reserve the right to update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The current version will always be available at talktimecro.com/privacy-policy. We encourage you to review this page periodically.
17. Contact
For any questions about this Privacy Policy or the processing of your personal data, please contact:
Tihana Klepač [email protected] +385 95 9052 650 Filipoviceva 31, 10000 Zagreb, Croatia