PHOBS d.o.o. – Privacy Policy
Last updated: 16 June 2026
This Privacy Policy explains how PHOBS d.o.o. processes your personal data when you visit our website, contact us, or subscribe to our newsletter, and what rights you have under the General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”) and the Croatian Act on the Implementation of the GDPR.
1. Who we are
PHOBS d.o.o. is a Virtual Sales Office specialising in revenue generating solutions for the hospitality industry. PHOBS d.o.o. is the controller of the personal data described in this Policy. Our details are:
PHOBS d.o.o.
Vukovarska 19, 20000 Dubrovnik, Croatia
OIB: 09221756952
Telephone: +385 (0)20 358 344
E-mail: info@phobs.net
For any question about the processing of your personal data or to exercise your rights, you can contact us at support@phobs.net
2. What data we process, why, and on what legal basis
We process personal data only where we have a legal basis to do so.
Responding to enquiries (contact forms). We process your first and last name, e-mail address, telephone number and, where you provide it, your address, in order to respond to your enquiry and to take steps towards a business relationship at your request. Legal basis: taking steps prior to entering into a contract (Art. 6(1)(b) GDPR) and our legitimate interest in responding to enquiries (Art. 6(1)(f) GDPR). We keep this data for up to 2 years from our last contact, unless a contractual or legal obligation requires us to keep it longer. We do not use data submitted through contact forms for marketing purposes.
Newsletter. We process your name, e-mail address and, where you provide it, your company name, address and stated areas of interest, in order to send you our newsletter. Legal basis: your consent (Art. 6(1)(a) GDPR). We keep this data until you withdraw consent or unsubscribe, after which we delete it without undue delay.
Operating, securing and analysing our website. We process technical data through cookies and similar technologies, including your IP address, browser and device data, and usage data. Legal basis: our legitimate interest for strictly necessary cookies (Art. 6(1)(f) GDPR) and your consent for analytics and marketing cookies (Art. 6(1)(a) GDPR). Retention follows the cookie lifetimes set out in our Cookie Policy.
Legal obligations and legal claims. We may process any of the above data to comply with legal obligations and to establish, exercise or defend legal claims. Legal basis: compliance with a legal obligation (Art. 6(1)(c) GDPR) and our legitimate interest in defending claims (Art. 6(1)(f) GDPR). We keep this data for the duration of the applicable limitation period or any related proceedings.
3. Newsletter and Mailchimp
You can subscribe to our newsletter through our website. You may withdraw your consent at any time, with effect for the future, by using the unsubscribe link in any newsletter or by contacting us. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal. Once you unsubscribe, we delete the data held for this purpose without undue delay.
We use Mailchimp, operated by The Rocket Science Group LLC d/b/a Mailchimp (an Intuit company), 405 N. Angier Ave. NE, Atlanta, GA 30308, USA, to distribute our newsletter and to measure its delivery. The newsletter contains a small tracking pixel that records when a message is opened and whether links are clicked, and which transmits technical data such as your browser, approximate location and IP address to Mailchimp. Mailchimp processes this data on our behalf and does not use it for its own purposes.
Because Mailchimp is based in the United States, your data is transferred outside the European Economic Area. Mailchimp is certified under the EU-US Data Privacy Framework, and EU Standard Contractual Clauses apply as an additional safeguard. You can review Mailchimp’s privacy practices at https://www.intuit.com/privacy/statement/.
4. Cookies, analytics and marketing tools
Our website uses cookies and similar technologies. Cookies are small text files stored on your device by your browser, which allow the website to recognise your browser and remember certain settings, and help us understand how the website is used.
We use strictly necessary cookies, required for the website to function, on the basis of our legitimate interest. We use analytics and marketing cookies only with your consent, which you give through our cookie banner and may withdraw at any time. Non-essential cookies are not set until you have given your consent, and you can refuse them as easily as you can accept them. Disabling cookies may limit some functionality of the website. The specific cookies we use are listed in our Cookie Policy below.
Subject to your consent, we use the following third-party tools:
- Google Analytics and Google Tag Manager, provided by Google Ireland Ltd. and Google LLC, to measure and analyse how visitors use our website;
- Google Ads, provided by Google Ireland Ltd. and Google LLC, for advertising and campaign measurement;
- Meta Pixel, provided by Meta Platforms Ireland Ltd., to measure the effectiveness of our advertising and to support marketing;
- HubSpot, provided by HubSpot, Inc., for website analytics, contact forms and marketing.
- our cloud hosting and IT service providers, who host and maintain our website and systems (located in the European Union; where infrastructure outside the EEA is used, transfers are covered by Standard Contractual Clauses);
- Mailchimp, for newsletter distribution and analytics (United States; EU-US Data Privacy Framework and Standard Contractual Clauses);
- Google and Meta, for website analytics and advertising (European Union and United States; EU-US Data Privacy Framework and Standard Contractual Clauses);
- HubSpot, for website analytics, contact forms and marketing (European Union and United States; EU-US Data Privacy Framework and Standard Contractual Clauses);
- public authorities and our professional advisers, where required by law or to establish, exercise or defend legal claims.
- access your personal data and obtain a copy of it;
- have inaccurate data corrected and incomplete data completed;
- have your data erased (“right to be forgotten”) where the conditions are met;
- have processing restricted in certain circumstances;
- object to processing based on legitimate interest for reasons relating to your particular situation, and to object at any time to processing for direct marketing;
- receive the data you provided in a structured, commonly used and machine-readable format and have it transmitted to another controller where technically feasible;
- withdraw your consent at any time where processing is based on consent, without affecting the lawfulness of processing before withdrawal.
These tools may set cookies and process data such as your IP address and usage data. Where data is transferred to the United States, the transfer is covered by the EU-US Data Privacy Framework and by EU Standard Contractual Clauses. You can withdraw your consent at any time through our cookie settings.
5. Who we share your data with
We share your personal data only where necessary for the purposes described in this Policy, with:
Where personal data is transferred outside the European Economic Area, we rely on an adequacy decision, the EU-US Data Privacy Framework, or EU Standard Contractual Clauses. You may request further information about these safeguards using the contact details in this Policy.
6. Links to other websites
Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites, and we encourage you to review the privacy policy of any website you visit through such links.
7. How long we keep your data
We keep your personal data only for as long as necessary for the purposes for which it was collected, as set out in section 2, and thereafter only where a legal obligation requires retention or where data is needed to establish, exercise or defend legal claims. Where legal, administrative or out-of-court proceedings are initiated, the relevant data may be retained until those proceedings, including any period for legal remedies, are concluded.
8. Your rights
Under the GDPR you have the right to:
To exercise any of these rights, contact us at support@phobs.net
We may need to verify your identity before acting on a request, and we respond within the time limits set by the GDPR, in principle within one month.
9. Right to lodge a complaint
If you consider that our processing of your personal data infringes the GDPR, you have the right to lodge a complaint with the competent supervisory authority. In Croatia this is the Personal Data Protection Agency (Agencija za zaštitu osobnih podataka – AZOP), Selska cesta 136, 10000 Zagreb, e-mail azop@azop.hr.
10. Changes to this Policy
We may update this Privacy Policy from time to time to reflect changes in our processing activities or in applicable law. The current version, together with the date of the last update, is always available on our website.