Effective date: 23 September 2026 · Version: 1.1
1. Who we are
PLAVO NEBO ISTRA d.o.o.
Pošesi 95, 52203 Medulin, Republic of Croatia
Company ID (OIB): 01677103627
Email: office@pnidevelopment.hr
Phone: +385 99 4484 422
For any data protection question, contact us at office@pnidevelopment.hr.
2. What we collect, why, and on what legal basis
| What we collect | When | Purpose | Legal basis |
|---|---|---|---|
| Name, email, phone, message content | When you submit the contact form | Replying to your enquiry | Pre-contractual steps at your request — Art. 6(1)(b) |
| Content of your conversation with Lucija | While you chat with Lucija | Answering questions about the apartments and the project | Legitimate interest — Art. 6(1)(f) |
| Email, name (optional), conversation summary | When you leave your email in the chat | Keeping you informed and having our agent contact you | Pre-contractual steps — Art. 6(1)(b) |
| Questions Lucija could not answer | Automatically | Improving answer quality | Legitimate interest — Art. 6(1)(f) |
| IP address, access time, browser type | On every visit | Security, attack and abuse prevention | Legitimate interest — Art. 6(1)(f) |
We collect no special categories of personal data (Art. 9 GDPR). Lucija is built never to ask for national ID numbers, document numbers, health or financial details. Please do not enter them on your own initiative either. Providing data is always voluntary.
3. Lucija, the virtual assistant
Our website features Lucija — a virtual assistant. Lucija is not a human being; she is a computer program based on artificial intelligence. We state this in accordance with Article 50 of Regulation (EU) 2024/1689 on artificial intelligence.
- Your messages are processed by our processor Anthropic PBC (USA) to compose a reply. Anthropic does not use this data to train its models.
- The conversation is stored in your own browser and deleted when you close it. We have no access to it.
- If you give Lucija your email, the conversation is summarised and sent with your email to our agent.
- Lucija makes no automated decisions producing legal or similarly significant effects (Art. 22 GDPR).
- Lucija can make mistakes. Information about apartments, prices and availability is not a legally binding offer — only written information from our agent is binding.
4. Cookies and access to your device
We use no tracking, analytics or advertising cookies. There is no Google Analytics, Facebook pixel or comparable tool on this website. Fonts are served from our own server, not from Google’s. The Google map is not embedded in the page — the link opens Google Maps in a new window.
We use only storage strictly necessary to deliver the service you requested, which requires no consent:
| Name | Type | Purpose | Duration |
|---|---|---|---|
| lucija_messages | sessionStorage | Keeps your conversation when moving between pages | Until you close the browser |
| lucija_leadSubmitted | sessionStorage | Remembers that you already left your contact details | Until you close the browser |
| WordPress technical cookies | cookie | Basic site operation and language choice | Session |
5. Who we share data with
We do not sell your data and do not pass it to third parties for marketing purposes.
| Recipient | What they process | Location |
|---|---|---|
| Anthropic PBC | Content of conversations with Lucija | USA |
| Vercel Inc. | The server Lucija runs on | USA (data stored in the EU — Frankfurt) |
| Resend (Plus Five Five, Inc.) | Sending email notifications | USA (sending from the EU — Ireland) |
| Google Ireland Limited | Google Sheets (enquiry log) | Ireland / EU |
| Jackie’s agency, s.r.o. | Technical development and maintenance of Lucija | Slovakia |
| Websupport | Website hosting | Slovakia / EU |
Transfers outside the EEA: Anthropic, Vercel and Resend are based in the USA. These transfers rely on the European Commission’s Standard Contractual Clauses (Art. 46(2)(c)). Request a copy of the safeguards at office@pnidevelopment.hr.
6. How long we keep data
| Data | Retention |
|---|---|
| Contact form enquiries and details left with Lucija, including summaries | 24 months from our last communication |
| Questions Lucija could not answer | 12 months |
| Technical and security logs (IP address) | 30 days maximum |
| Conversation stored in your browser | Until you close the browser |
Contact form messages are not stored in the website database — they are forwarded by email only. If your enquiry leads to a contract, we retain the data for as long as accounting and tax law requires.
7. Your rights
You have the right of access (Art. 15), to rectification (Art. 16), to erasure (Art. 17), to restriction (Art. 18), to portability (Art. 20) and to object to processing based on legitimate interest (Art. 21).
Send your request to office@pnidevelopment.hr. We respond within one month at the latest, free of charge.
You may lodge a complaint with the supervisory authority:
Croatian Personal Data Protection Agency (AZOP)
Selska cesta 136, 10000 Zagreb, Croatia
azop@azop.hr
You may also lodge a complaint with the authority in your country of residence.
8. Security
Data is transmitted over an encrypted connection (HTTPS). The site uses a firewall and protection against unauthorised access. Access to the enquiry log is limited to those who need it for their work.
9. Changes to this policy
We update this policy from time to time. The version published on this page is the one in force; the effective date is stated at the top.