Privacy Notice

1. Controller

The controller is Libersi Labs d.o.o., Gramača 2L, 10000 Zagreb, Croatia, Personal Identification Number (OIB): 24138540387 (referred to as “Libersi”, “we”, “us” or “our”). UŽIVAJ is a Libersi platform available through www.uzivaj.life.

Through a monthly or annual membership purchased in the mobile application, UŽIVAJ gives individuals access to a selected network of partner hospitality, wellness and other leisure venues and their special offers, which are redeemed through the application when visiting a partner.

For questions about this Notice, to exercise your rights or to withdraw consent, contact liban@libersiholding.com.

2. Personal data we process

When you subscribe to UŽIVAJ news or the pre-launch list, we process your email address and, if you provide it voluntarily, your first name. We also record your selected language, the time and version of your consent, subscription or unsubscribe status and technical attribution data, including campaign UTM parameters, the referring page and landing-page path.

To protect the form, prevent misuse and demonstrate valid consent, we may store a one-way cryptographic hash of the IP address and browser identifier. We do not store their raw values in the subscription record. When you use the website, we may also process device and browser information, approximate location derived from an IP address, access time, pages viewed and website interactions. Optional analytics and marketing processing is activated only after the corresponding consent.

We receive most data directly from you when you submit the form, choose cookie settings or contact us. We receive technical data from your device and browser, and campaign-attribution data from the link through which you reached the website.

We do not request special categories of personal data. Please do not submit such information through the form or ordinary correspondence.

3. Purposes and legal bases

News and marketing communications

We use your email address and first name to send information about the launch, early access, benefits and offers on the UŽIVAJ platform. The legal basis is your consent under Article 6(1)(a) GDPR. You may withdraw consent at any time through the unsubscribe link in a message or by contacting us. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Website operation and security

We process essential technical data to deliver the requested website and functionality, protect forms and systems, prevent fraud and misuse and maintain security logs. Depending on the circumstances, the legal basis is taking steps at your request, performance of a contract or our legitimate interest in providing a secure and reliable service under Article 6(1)(b) and (f) GDPR.

Analytics and advertising

If you allow it in cookie settings, we process website-usage data to measure visits, understand how content is used, improve the service and measure marketing campaigns. The legal basis is consent under Article 6(1)(a) GDPR. You can accept or reject Analytics and Marketing separately and change your selection later. See our Cookie Policy for details.

Legal obligations and claims

We may process data to comply with legal obligations and to establish, exercise or defend legal claims. The legal basis is compliance with a legal obligation or our legitimate interest in protecting our rights under Article 6(1)(c) and (f) GDPR.

4. Further processing for new purposes

If we intend to use personal data for a new purpose not covered by this Notice, we will provide information about that new purpose and the applicable processing conditions before the processing begins and, where required, obtain new consent.

5. Recipients and processors

We do not sell personal data. Access is limited to recipients that need it for the purposes described above:

• FastComet and related infrastructure providers for website hosting, storage, security and availability;
• The Rocket Science Group LLC d/b/a Mailchimp, an Intuit group company, for contact-list management, subscriptions, unsubscribes and message delivery;
• Google Ireland Limited and its affiliates, including Google LLC, for Google Analytics 4 and Google Tag Manager only where you have consented to Analytics processing;
• Meta Platforms Ireland Limited and Meta Platforms, Inc., for Meta Pixel and advertising measurement only where you have consented to Marketing processing;
• IT maintenance and support providers, professional advisers, accountants and auditors to the extent necessary for their contracted work;
• courts, competent regulators and other public authorities where required by law or necessary to protect our rights.

We contractually require processors to preserve confidentiality and security and to process data only on our instructions.

6. Transfers outside the European Economic Area

Some providers, including Mailchimp and Google and Meta group companies, may process data in the United States or other countries outside the European Economic Area. Such transfers use a mechanism permitted by data-protection law: a European Commission adequacy decision, including the EU–U.S. Data Privacy Framework where it applies to the particular recipient, European Commission Standard Contractual Clauses and, where appropriate, supplementary contractual, organisational and technical safeguards.

You may contact us to request information about the applicable transfer mechanism and a copy of the relevant safeguards, subject to necessary redactions protecting confidential information.

7. Retention

• We retain data used to send news until you withdraw consent or unsubscribe, or until the original purpose ends.
• After an unsubscribe request, we may retain a minimal record of the address and unsubscribe status to honour your choice and prevent an unwanted resubscription.
• We keep consent records and data necessary for legal claims for the applicable limitation period, generally five years. If judicial, administrative or similar proceedings are initiated, relevant data is retained for the proceedings and for ten years after the final decision, or as long as required by law.
• Security and technical logs are kept only for as long as reasonably necessary to detect misuse, investigate incidents and protect the service.
• Cookie and similar-technology durations are described in the Cookie Policy.

At the end of the applicable period, we delete or anonymise the data unless longer retention is required by law.

8. Your rights

Subject to the conditions in the GDPR, you may request access to your personal data, rectification, erasure, restriction of processing and data portability. You may object to processing based on legitimate interests and may withdraw consent at any time where processing is based on consent.

To exercise a right, contact liban@libersiholding.com. We may request information needed to verify your identity. We will respond without undue delay and within the period required by law.

If you believe the processing infringes data-protection law, you may lodge a complaint with the Croatian Personal Data Protection Agency, Ulica Metela Ožegovića 16, 10000 Zagreb, azop@azop.hr, azop.hr.

9. Automated decision-making

We do not make decisions producing legal or similarly significant effects concerning you based solely on automated processing of data collected through this website.

10. Changes to this Notice

We may update this Notice when our processing changes or the law requires it. The current version will always be published on this page with its last-updated date.

11. Contact

For questions or comments about this Notice and our data-protection practices, or to make a complaint about our compliance with data-protection law, contact liban@libersiholding.com. We will consider and investigate every complaint we receive.

Last updated: 2 October 2026.