Privacy Policy
1. Who is responsible for your data
This website (zurka.me) is operated by the company below, which acts as the data controller:
- DRUŠTVO ZA USLUGE DOO „SPARK STUDIOS“ HERCEG NOVI (short name: SPARK STUDIOS DOO)
- Registered seat: Aleksandrova obala 33, Zelenika, Herceg Novi, Montenegro
- Registration number 5-1091626/002, entered in the Central Register of Business Entities (CRPS) of the Tax Administration of Montenegro on 30 November 2022
- Tax number (PIB): 03502392. The company is not registered for VAT.
- Represented by Dmitrii Kontsov, Executive Director
- Contact for privacy matters:
Given the limited scale and nature of the processing, no Data Protection Officer has been appointed. All enquiries go to the address above.
2. Scope and applicable law
This policy covers personal data processed through the zurka.me website. It is written to comply with the Montenegrin Law on Personal Data Protection (Zakon o zaštiti podataka o ličnosti) and, for visitors located in the European Union or the European Economic Area, with Regulation (EU) 2016/679 (GDPR).
3. What zurka.me is — and what it is not
zurka.me is a free informational listing of public events in Montenegro. As of the date of this policy the site has no registration, no user accounts, no comment forms, no newsletters, no payments and no advertising. We do not sell, rent or trade personal data, and we do not use it for automated decision-making or profiling.
If advertising or any other feature that changes what data is collected is introduced, this policy will be updated and the cookie notice will be shown again before the change takes effect.
4. What data we process
4.1. Server access logs
Our hosting provider records technical data on every request: IP address, browser and device identification string, requested address, referring page and the date and time of the request.
- Purpose: keeping the site available, diagnosing faults, detecting and preventing abuse.
- Legal basis: legitimate interest in operating and securing the service (GDPR Art. 6(1)(f)).
- Retention: 10 days, after which the logs are rotated and deleted.
4.2. Analytics — Google Analytics 4
If, and only if, you give consent, we use Google Analytics 4 (measurement ID G-QMVM4N7F5B) to understand how the site is used. It records a pseudonymous identifier stored in a cookie, the pages you view, approximate location derived from a shortened IP address (country and city, never a precise address), device and browser type, and how you reached the site.
- Purpose: understanding which events and cities interest visitors, so the listing can be improved.
- Legal basis: your consent (GDPR Art. 6(1)(a)). You may withdraw it at any time — see section 8.
- Retention: 14 months in the Google Analytics interface, then automatic deletion.
Until you consent, Google's tags run in a restricted mode that sets no analytics cookies and transmits no identifiers. If you decline, they stay in that mode.
4.3. Cookies set by us
Two cookies are strictly necessary and are set without consent, because the site cannot deliver what you asked for without them: one remembers your chosen interface language, the other remembers your decision about cookies so we do not ask again on every page. Details are in the Cookie Policy.
5. Who else receives the data
| Recipient | Role | What they receive |
|---|---|---|
| Webrain OÜ (is*hosting), reg. no. 16236489, Estonia | Hosting provider (processor) | Server access logs, site files and database |
| Google Ireland Limited / Google LLC | Analytics provider (processor) | Analytics data, only after your consent |
Hosting is provided under a data processing agreement concluded in accordance with Article 28 of the GDPR, which limits processing to documented instructions, requires notification of any data breach within 72 hours, and holds the provider fully liable for any subprocessors it engages.
We disclose data to no one else, except where we are legally required to do so by a competent authority.
6. Where data is processed, and international transfers
The site is hosted by Webrain OÜ, a company established in Estonia, on a server located in the Netherlands — both within the European Economic Area. The data processing agreement with the provider expressly limits processing to the EEA, so server access logs do not leave it.
Analytics data — only where you have consented to it — is processed by Google and may be transferred outside the EEA, including to the United States. For those transfers Google relies on the safeguards available under Chapter V of the GDPR: the EU–US Data Privacy Framework and the European Commission's Standard Contractual Clauses.
The operator is established in Montenegro, which is outside the EEA and is not covered by an adequacy decision of the European Commission. Access to the data by the operator, for the purposes described in this policy, therefore takes place from Montenegro. The data involved is limited to technical log data and pseudonymous analytics, and no special categories of data are processed.
You may request further information about the safeguards applied using the contact address in section 1.
7. Your rights
Under the GDPR and Montenegrin law you have the right to:
- be informed about, and obtain a copy of, the personal data we hold about you;
- have inaccurate data corrected;
- have your data erased;
- restrict how we process your data;
- object to processing based on legitimate interest;
- receive your data in a portable format;
- withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal.
To exercise any of these, write to the address in section 1. We reply within one month.
Please note a practical limitation: because we do not operate accounts and analytics identifiers are pseudonymous, we are often unable to link a request to a specific record. In that case we may ask for information that lets us identify the data, and if identification remains impossible we will say so rather than act on a guess.
8. Withdrawing or changing your consent
Use the Cookie settings link in the footer of any page. Your choice takes effect immediately. You can also delete cookies through your browser settings, or install Google's opt-out browser add-on.
9. Complaints
If you believe your data has been handled unlawfully, you may lodge a complaint with the Montenegrin supervisory authority, the Agency for Personal Data Protection and Free Access to Information (Agencija za zaštitu ličnih podataka i slobodan pristup informacijama), azlp.me. Visitors resident in the EU or EEA may instead complain to the supervisory authority of their country of residence.
10. Children
The site is not directed at children and we do not knowingly process data of persons under 16. If you believe a child's data has reached us, please write to the address in section 1 and it will be deleted.
11. Changes to this policy
We may update this policy as the site develops or the law changes. The date at the top always shows the current version. Material changes affecting your rights will be announced on the site before they take effect.