Draft for the public beta. This text is not legal advice and must be reviewed by a lawyer before launch. Highlighted parts are placeholders to fill in.

Privacy Policy

Last updated: [date]

1. Who we are

Kaffa (“we”, “us”) is a website builder operated by [legal name of the operator], [address], [company ID / OIB]. Contact for privacy questions: [privacy e-mail].

For personal data in your account we are the controller. For data your visitors send through your published website (for example the contact form) you are the controller and we act as your processor.

2. What data we process and why

DataPurposeLegal basis (GDPR)
E-mail address and login recordsCreating and securing your accountContract, Art. 6(1)(b)
Website content you create (text, images, settings)Storing, editing and publishing your websiteContract, Art. 6(1)(b)
Messages from your website's contact formDelivering enquiries to youOn your behalf as processor, Art. 28
Technical logs (IP address, browser, errors)Security, abuse prevention, fixing bugsLegitimate interest, Art. 6(1)(f)
Feedback you send usImproving Kaffa during the betaConsent, Art. 6(1)(a)

We do not sell personal data and we do not use it for advertising.

3. Data stored in your browser

During the beta, the editor saves your work in your browser's local storage so nothing is lost while you edit. This storage is strictly necessary for the service and is not used for tracking. You can delete it at any time in your browser settings.

4. Service providers

We use the following processors, bound by data processing agreements:

Where data is transferred outside the EU/EEA, we rely on the EU Standard Contractual Clauses or an adequacy decision.

5. Published websites

Websites published with Kaffa load fonts and scripts from the same address as the website. They set no tracking cookies. Images or videos you embed from other services (for example YouTube) may be loaded from those services.

6. How long we keep data

7. Your rights

You have the right to access, correct, delete and export your data, to restrict or object to processing, and to withdraw consent. To use these rights, write to [privacy e-mail]. You also have the right to lodge a complaint with a supervisory authority; in Croatia that is the Agencija za zaštitu osobnih podataka (AZOP), azop.hr.

8. Changes

We will announce material changes to this policy in the editor and by e-mail before they take effect.