Privacy Policy

The controller of your personal data is Tortrivora d.o.o., headquartered at Savska cesta 41, 10000 Zagreb, Republic of Croatia, OIB: 45671234890.

For any questions regarding the processing of personal data, you can contact us via email at info@tortrivora.com or by post at the above address.

We collect the following categories of personal data: identification data (name, surname, OIB), contact data (email address, telephone number, postal address), financial data (transaction details, investment history), technical data (IP address, browser type, cookies), and platform usage data.

We collect data directly from you during registration, use of our services, or communication with us, as well as automatically through cookies and similar technologies.

We process your personal data for the following purposes: provision of real estate crowdfunding services, management of your user account, processing and tracking of investments, communication with you about projects and services, compliance with legal obligations (including AML/KYC regulations), improvement of our service quality, and fraud prevention.

We process data only to the extent necessary to achieve the aforementioned purposes and do not use it for purposes incompatible with the original purpose of collection.

The processing of your personal data is based on the following legal grounds under the General Data Protection Regulation (GDPR): contract performance (Art. 6(1)(b) GDPR) — for providing our services, legal obligation (Art. 6(1)(c) GDPR) — for fulfilling regulatory requirements, legitimate interest (Art. 6(1)(f) GDPR) — for service improvement and fraud prevention, consent (Art. 6(1)(a) GDPR) — for marketing communications and analytical cookies.

We retain your personal data for as long as necessary to achieve the purposes for which it was collected. Transaction data is retained for at least 10 years in accordance with Croatian accounting and tax regulations. AML/KYC data is retained in accordance with the Anti-Money Laundering and Terrorist Financing Act.

Upon expiry of the legally prescribed retention periods, your data will be securely deleted or anonymised.

We may share your personal data with trusted third parties only to the extent necessary for providing our services: payment service providers for transaction processing, regulatory bodies in compliance with legal obligations, auditing firms as part of legally required audits, and IT service providers who process data on our behalf.

All third parties with whom we share your data are bound by appropriate data processing agreements and are required to ensure an adequate level of protection.

Under the GDPR, you have the following rights: the right to access your personal data, the right to rectification of inaccurate data, the right to erasure ("right to be forgotten"), the right to restriction of processing, the right to data portability, the right to object, and the right to withdraw consent at any time.

To exercise your rights, you can contact us at info@tortrivora.com. We will respond to your request within 30 days. You also have the right to lodge a complaint with the Croatian Personal Data Protection Agency (AZOP).

We implement appropriate technical and organisational measures to protect your personal data from unauthorised access, loss, destruction, or damage. This includes data encryption, restricted data access, regular security audits, and staff training.

Despite our efforts, no data transmission or storage system is completely secure. In the event of a personal data breach, we will notify you and the relevant authorities within the statutory timeframes.

We reserve the right to amend this privacy policy at any time. You will be notified of significant changes through our platform or by email. We recommend regularly reviewing this policy to stay informed about how we protect your data.

For any questions, requests, or complaints regarding the protection of your personal data, please contact us at: Tortrivora d.o.o., Savska cesta 41, 10000 Zagreb, Croatia. Email: info@tortrivora.com. Phone: +385 1 234 5678.