Privacy notice for administration users

Status: draft for legal review. English translation of Privacy_admin_users_hr.md. If the two differ, the Croatian text prevails. The text describes how the platform works on 24 October 2026. The technical descriptions must stay true: when the platform changes, this text changes too. Items marked [CHECK] depend on facts not yet confirmed.

This notice does not replace the visitors' notice (/Privacy). For visitors, the institution is the controller and Smak kolektiv d.o.o. only the processor.


1. Who this is for

This notice is for people who open an account on the Aristoqle platform or work in it for an organisation, as owners or editors ("you").

The notice for visitors who play the content is on the Visitors' privacy page (/Privacy).

2. Controller

Smak kolektiv d.o.o., [address], OIB [ ] Privacy contact: [e-mail] [CHECK: same address as PRIVACY_CONTACT]

3. What we process

When Data
Sign-up the organisation's name and web address; the kind of organisation (e.g. museum, heritage, nature), if you choose one; your first name, surname and e-mail address; your password, only as an irreversible cryptographic record (PBKDF2, 600,000 iterations); the chosen language; version and time of accepting the terms of use; the web page and campaign you came from, if the link carries them
Your account username; role (owner or editor); time the e-mail address was confirmed; time of the last password change; whether you have been shown the guided tour of the administration; a technical session marker, which changes when the password or role changes
If you enter them title, position, phone, mobile
Work in the administration who started an AI generation, when, which step and what it cost; who marked content as verified or returned it to draft, and when; who granted credit
Quote request the organisation's legal name and address, country, VAT number and the result of its check in the VIES system (the name and address VIES returns, the consultation number), the e-mail address for invoices, whether a purchase order is needed, the name of an EU project, the wished start and your description of your needs; who sent the request
"Report a problem" the kind of report (something does not work, a question, an idea) and your text; the page you were on, the error reference (if you sent it from an error page), the browser and the language; your username and e-mail address, to which we reply
Errors you see when the application shows you an error with a reference: the reference, the time, the page address, your username and organisation, the kind and description of the error
Abuse prevention a pseudonymised record of the network you signed up from (see point 5); a pseudonymised record of your e-mail address and domain once a starting credit is granted; counters of sign-in and sign-up attempts, in memory only
Server logs a shortened IP address. The full address is recorded only briefly, on a technical error

We do not collect date of birth, home address, location or card payment data.

4. Purposes and legal bases

Purpose Legal basis (GDPR Art. 6)
Opening and running the account, sign-in, address confirmation, password reset, providing the service performance of a contract (1.b)
Charging AI credit and paid plans; reminders that a plan ends performance of a contract (1.b)
A quote for a paid plan, at your request steps prior to entering a contract (1.b)
Checking the VAT number in VIES; invoices and accounting records for paid plans legal obligation (1.c) [CHECK: VIES may rather be legitimate interest]
Answering your problem report, question or idea legitimate interest (1.f): supporting users and fixing errors
Preventing abuse: multiple free accounts, automated sign-ups, password guessing legitimate interest (1.f): protecting the service and the costs abuse causes
System security and fixing errors legitimate interest (1.f)
Records of who approved AI-generated content legitimate interest (1.f) of your organisation and of us: editorial responsibility
Handling content reports and telling you about content taken off public access legal obligation (1.c): Digital Services Act (Regulation (EU) 2022/2065), Art. 16 and 17

We do not send you marketing without your consent, and we do not sell data.

5. Review before the starting credit is granted

The starting AI credit is granted only after you confirm your e-mail address and a person on our team has reviewed the account. To help with that decision, the platform shows:

A person decides, not the system. The platform itself neither refuses nor grants credit. A refused credit does not end the account: it keeps working without artificial intelligence. You may object to this review (point 11).

6. Who receives data

Recipient Why Which data Where
Hetzner Online GmbH [CHECK] server and storage all data in point 3 [Germany / Finland] [CHECK]
Mailjet SAS [CHECK] sending platform messages your e-mail address, name and the message European Union [CHECK]
OpenAI [CHECK: legal entity] AI content generation only material you send for processing, and a pseudonymised organisation identifier (HMAC) so the provider can limit abuse by one organisation. Your name, e-mail address and username are not sent. USA
European Commission, VIES system checking the VAT number in a quote request the organisation's VAT number, and ours as the requester European Union
accountant, tax authority [CHECK] accounting invoice data for paid plans Croatia

When you start an AI generation, the documents, texts and web pages you name are sent to the AI provider. Do not send material containing personal data you may not pass on.

The administration pages load nothing from other servers: fonts, icons and scripts are served from our own server.

7. Transfers outside the European Economic Area

The AI provider is based in the USA. The transfer relies on [the EU–US Data Privacy Framework / standard contractual clauses]. [CHECK]

8. How long we keep data

Data Period
The account and sign-up data while the account exists; after closing or deletion at most 30 days, plus [14] days in backups
An account whose address was never confirmed deleted after 30 days
A closed account deleted with all its content and media 30 days after closing, whether the owner or we closed it
The answer to the question when an account is closed (reason, your text, plan, days as a client) kept after the account is deleted, with no link to the account or a person; do not put personal data in it
The public demo (/demo): the page address you pasted, the games made from it, and a value computed from your network with a secret key the games and the address are deleted after 48 hours, the build record after 3 days; if you open an account, the games move into it
Sign-up and usage steps for the funnel (e.g. "confirmed the address", "first unit"; no names or addresses) while the account exists; after deletion without a link to the account
The network record from sign-up 30 days
Address and domain records after a starting credit 3 years
Sign-in and sign-up attempt counters up to 1 hour, in memory only
Records of content approval while the account exists
Records of AI credit use (the cost and charge of each call) and of credit grants while the account exists; after the account is deleted they stay with no link to the organisation or a person (no username, no notes), to reconcile with the AI provider's invoices
A quote request while the account exists [CHECK: period after the quote has been sent]
Problem reports, questions and ideas 180 days after they were handled
Records of errors you saw 90 days
Messages in the sending queue the recipient's address is cleared as soon as the message has been sent; the message record 30 days
Decisions on reported content (a unit taken off and put back on public access, the ground and the reasons) while the account exists
Invoices and accounting records [11 years] under accounting law [CHECK]
Record of accepting the terms while the account exists and [5 years] after, for possible disputes [CHECK: the platform currently deletes it with the account]
Server logs limited in size (five files of 10 MB per part of the system) and overwrite themselves; the application's log is saved on the server at each update and kept 30 days

9. Cookies and local storage

The administration uses only necessary cookies:

For our own administrators only, one more cookie lets them work during maintenance while the platform is closed to others (up to 3 days).

Your browser's storage (not our server) keeps only display settings: the width of the menu, the open branches of the menu, and whether you closed the maintenance notice.

There are no advertising or analytics cookies.

10. Messages we send you

The platform sends only messages needed for the account:

Planned maintenance is announced in the administration. The number of messages per recipient per day is limited.

11. Your rights

You may ask for:

You may object to processing based on legitimate interest (points 4 and 5).

Send requests to [e-mail]. We reply within one month. If you believe your data are not processed lawfully, you may complain to the Croatian Personal Data Protection Agency (azop.hr) or to the supervisory authority in your country.

12. Security

The protection measures are:

13. Changes

We change this notice when the way the platform works changes. We inform account owners of significant changes by e-mail.


Applies from [date].