Privacy Policy

Effective date: July 19, 2026

This policy explains how personal data is processed when you visit upclick.me (the “Site”). We keep data collection deliberately small: nothing is tracked without your consent, and we only ask for what we need to answer you.

1. Who is responsible (data controller)

The Site is operated by Fortbit d.o.o., the company behind the upclick.me brand:

Fortbit d.o.o.
Gradiščak 31A
40313 Sveti Martin na Muri, Croatia
OIB: 84211962389
VAT ID: HR84211962389
E-mail: privacy@upclick.me

2. What we process, why, and on what legal basis

2.1 Server logs

When you open the Site, our hosting infrastructure (Vercel) automatically records technical data: your IP address, browser type and version, date and time of the request, and the page requested. We use these logs solely to keep the Site secure, stable and available.

Legal basis: legitimate interest (Art. 6(1)(f) GDPR) in operating a secure website. Logs are kept for a short period (no longer than 30 days) and then deleted, unless needed to investigate an incident.

2.2 Analytics — only with your consent

With your consent, we use PostHog (EU Cloud, eu.posthog.com) to understand how the Site is used: pages viewed, interactions with the offer configurator, device and browser information, approximate location derived from your IP address, and technical error reports. PostHog stores identifiers in cookies and local storage on your device — see the Cookie Policy for details.

Until you press “Accept analytics” in the cookie banner, the analytics tool remains switched off and writes nothing to your device.

Legal basis: consent (Art. 6(1)(a) GDPR). You can withdraw it at any time on the Cookie Policy page — withdrawal stops tracking immediately and deletes the analytics cookies from your device.

2.3 Offer requests (configurator)

If you request an offer through our configurator, we process the details you submit: your name, e-mail address, phone number, information about your property, and the configuration you selected. We use this data to prepare and send you the offer you asked for and to correspond with you about it. When a request is submitted, a record of the submission (including the contact details you provided) is also logged in our analytics system so we can follow up reliably.

Legal basis: taking steps at your request prior to entering into a contract (Art. 6(1)(b) GDPR). We keep offer-request data for as long as the conversation is live and afterwards for as long as statutory limitation periods require.

2.4 Contact via WhatsApp

If you choose to message us on WhatsApp (+385 98 964 1238), your communication is also subject to the privacy terms of WhatsApp Ireland Ltd. We process the content of your message to respond to your enquiry (Art. 6(1)(b) GDPR).

2.5 Prototype and website builds

If we prepare a prototype or build a website for you, the material you share with us for that build — your name and contact details, property details, texts and photographs — becomes part of the site’s source code and content, which we store in private source-code repositories hosted on GitHub (GitHub, Inc.). We use this material solely to build, maintain and host your prototype and the website that may grow out of it, and it is not publicly accessible.

Legal basis: performance of a contract, or steps taken at your request prior to entering into one (Art. 6(1)(b) GDPR).

3. Who receives your data

We share personal data only with service providers that help us run the Site:

  • PostHog— product analytics and error monitoring, only after your consent. We use PostHog’s EU Cloud; the data is hosted in the European Union (Frankfurt, Germany).
  • Vercel Inc. — hosts and serves the Site (content delivery, serverless infrastructure) and processes the server logs described above.
  • MongoDB, Inc. (MongoDB Atlas)— hosts the database behind our CMS, which stores the Site’s content and your offer requests.
  • Resend, Inc. — delivers transactional e-mail (for example, the offer we send you).
  • GitHub, Inc. — hosts the private source-code repositories of the prototypes and websites we build, which can include the content and contact details you provide for your site (see section 2.5).

We do not sell personal data, and we do not use it for third-party advertising.

4. Transfers outside the EU/EEA

Analytics data is stored on PostHog’s EU infrastructure (Frankfurt, Germany). Some of our other providers (Vercel Inc., MongoDB, Inc., Resend, Inc., GitHub, Inc.) are established in the United States, so personal data they process for us may be transferred outside the EEA. Such transfers are protected by the EU Commission’s adequacy mechanisms — the EU-U.S. Data Privacy Framework where the provider is certified, and otherwise Standard Contractual Clauses under Art. 46 GDPR.

5. How long we keep data

  • Server logs: up to 30 days.
  • Analytics data: no longer than 24 months, then deleted or aggregated.
  • Offer requests and correspondence: for the duration of our exchange and thereafter for the statutory limitation periods under Croatian law.
  • Prototype and website source material: for as long as we build, host or maintain your prototype or website, and thereafter for the statutory limitation periods.

6. Your rights

Under the GDPR you have the right to:

  • access the personal data we hold about you (Art. 15),
  • have inaccurate data corrected (Art. 16),
  • have your data erased (Art. 17),
  • restrict processing (Art. 18),
  • receive your data in a portable format (Art. 20),
  • object to processing based on legitimate interest (Art. 21),
  • withdraw consent at any time, without affecting prior processing (Art. 7(3)).

To exercise any of these rights, write to privacy@upclick.me. We respond within one month.

You also have the right to lodge a complaint with a supervisory authority. In Croatia this is the Croatian Personal Data Protection Agency (AZOP), Selska cesta 136, 10000 Zagreb, azop.hr.

7. No automated decision-making

We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects.

8. Changes to this policy

We will update this policy when our processing changes. The current version, with its effective date, is always published on this page.