Privacy policy – Instagram Secrets | Omer Filan
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Instagram Secrets · Omer Filan

Privacy policy

Valid from September 29, 2026.

1. Data controller

Spark Agencija j.d.o.o. (selling under the Omer Filan brand)
Kladare 19C, 33405 Pitomača, Croatia · OIB: 55113887151
Privacy contact: [email protected]

We process personal data in accordance with the General Data Protection Regulation (GDPR) and Croatian law.

2. What data we process and why

DataPurposeLegal basis
First and last name, e-mail addressDelivering the e-book, sending the download link, customer supportPerformance of a contract
Purchase data (product, amount, date, country)Sales records, accounting, handling complaintsPerformance of a contract, legal obligation
Messages you send usReplying to questions and complaintsLegitimate interest, performance of a contract
Cookies and website usage data (e.g. Meta Pixel, analytics)Measuring visits and advertisingConsent (only if you give it in the cookie banner)

We do not see or store your card and payment details. They are processed directly by Link (Stripe).

3. Who else receives data

  • Link / Stripe (Stripe Payments Europe Ltd. and affiliated companies): processes the payment and issues the invoice as the seller. For that part it is an independent controller under its own privacy policy.
  • Hosting and e-mail providers (e.g. Vercel): only to the extent needed to run the website and deliver the e-book.
  • Meta Platforms and analytics tools: only if you accept cookies.
  • Accounting service and competent authorities: when required by law.

Some of these providers also process data outside the EU, e.g. in the USA, with the safeguards required by the GDPR (standard contractual clauses or the EU–US Data Privacy Framework). We do not sell data to anyone.

4. How long we keep data

  • We keep purchase and accounting data for 11 years, as required by the Croatian Accounting Act.
  • We keep support messages for up to 2 years after the request is resolved.
  • We keep cookie data until you withdraw consent, and for no longer than 13 months.

5. Your rights

You have the right to access your data, rectification, erasure, restriction of processing, objection to processing and data portability. You can withdraw your cookie consent at any time. Send your request to [email protected], and we will reply within 30 days.

If you believe your rights have been violated, you can file a complaint with the Croatian Personal Data Protection Agency (AZOP).

6. Security

We apply appropriate technical and organizational safeguards: an encrypted connection (HTTPS), restricted access to data and vetted service providers.

7. Changes

We may update this policy. The current version is always published on this page.