This policy explains which personal data this website and our service process, why, and what rights you have. In short: this website sets no cookies for visitors and loads nothing from other companies. It keeps its own visitor statistics on our server, without cookies and without storing your IP address.
1. Who is responsible
KInnovativ, trading as Investing in Montenegro, Thomas Nenad Leibel, Bar, Montenegro. E-mail: thomas@investinginmontenegro.com.
We are based in Montenegro. The Montenegrin Law on Personal Data Protection applies. If you live in the European Union, the EU General Data Protection Regulation (GDPR) can also apply when we offer our service to you.
2. Visiting this website
When you open a page, your browser sends technical data to our web server: IP address, date and time, the page requested, the referring page, browser and operating system. The server needs this data to deliver the page and to protect the website against attacks. The legal basis is our legitimate interest in a secure and working website (Art. 6(1)(f) GDPR). Our host stores these log files for a short period and then deletes them. We do not combine them with other data.
Our host is ALL-INKL.COM - Neue Medien Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany. The servers are located in Germany. We have a data processing agreement with the host.
3. No cookies, no third-party content
This website sets no cookies for visitors and stores nothing in your browser. It uses no advertising tools, no social media plugins, no analytics services of other companies and no maps or videos from other providers. The fonts are stored on our own server, so your browser does not contact Google or any other font service.
Two cookies exist only for the owner of the website: when the owner logs in to the private editing area, a session cookie keeps the login, and a marker cookie tells our visitor statistics not to count the owner. Visitors never receive them.
4. Visitor statistics
We count visits to this website with our own small program on our own server, so that we know which pages and articles are read and how visitors find us. No other company receives these data. The legal basis is our legitimate interest in understanding and improving our website (Art. 6(1)(f) GDPR).
How we count without a cookie. When a page is delivered, the server computes a short code from your IP address and the identification of your browser (user agent), mixed with a random key. The key changes every day at midnight (Montenegro time) and the old key is deleted. The code therefore changes every day, codes of different days can not be linked, and the code can not be turned back into your IP address. For IPv6 addresses only the network part is used. Your IP address and the user agent themselves are not stored. A new visit begins after 30 minutes without activity.
What we store for each page view: date and time, the address of the page (without parameters), for articles the article number, the domain of the website you came from (not the full address), campaign values in the link (utm_source, utm_medium, utm_campaign, utm_content), the device type (phone, tablet or desktop), the browser and operating system family without version number, the first language set in your browser, an estimated country as a two-letter code, the daily code and a random visit number. The country is looked up from your IP address in a table on our own server (IP Geolocation by DB-IP, CC BY 4.0). The address is only compared in memory; only the country code is stored. If the table does not know the address, the country is estimated from the region in your browser language setting (for example en-GB).
While a page is open, it reports about every 30 seconds and once when you leave: the address of the page, how many seconds it was visible, how far down you scrolled (in percent), whether you scrolled at all, and once the width class of your browser window (under 480 pixels, 480 to 767 pixels, 768 to 1023 pixels, 1024 to 1439 pixels, 1440 or more pixels). The server adds these values to the page view above, using the same daily code. Nothing else is sent.
Clicks and actions we count (each with date, time, page, article number, daily code and visit number):
- a click on "Book an inspection" or another button that leads to the contact form (detail: where on the page)
- a click on "See packages and prices" (detail: where on the page)
- the packages and prices section came into view
- the contact form was sent (detail: only the package chosen, never what you typed)
- a question in a FAQ was opened (detail: short name of the question)
- a section of the homepage reached the middle of the window (detail: name of the section)
- a click in the table of contents of an article (detail: the heading anchor)
- a click on a "Read next" article (detail: address of that article)
- a click on a link to another website in an article (detail: only the domain of that website)
- an article was read to 75 percent of its length
- a click on our e-mail address
We never store what you type into the contact form, never your e-mail address and never your IP address in the statistics.
Not counted: search engines, AI crawlers and other programs (we only count how often each program visits per day, without any address or code), the owner of the website and pages loaded in advance by the browser. For addresses that do not exist we only count the date, the address and the number of calls. For our short links (/go/…) we only count the clicks with date and time.
Protection against abuse: to stop floods of requests, the server keeps short counters keyed by a daily code of your IP address (without the browser identification). They are deleted when their time window ends, after one day at the latest.
How long: all statistics data are deleted automatically after 395 days. The whole website, including the statistics (without the daily key), is backed up once a day; these backups are kept on our server for 7 days and then deleted.
Your choice: the page works fully without JavaScript; if you block JavaScript for this website, no clicks, reading time or scroll depth are sent. You can object to this processing at any time (Art. 21 GDPR) by writing to us. Because the data contain no name, no address and only a code that changes daily, we usually can not find data that belong to you.
5. When you contact us
If you write to us by e-mail or phone, or send a request with the form on this website, we process the data you give us (name, e-mail address, the link to a property, the chosen package, your language and your questions) to answer you and, if you wish, to prepare and carry out an order. The legal basis is the performance of a contract or steps before a contract at your request (Art. 6(1)(b) GDPR).
A request from the form is sent to us by e-mail and a copy is kept on our server for 180 days so that no request gets lost; then it is deleted automatically. Daily backups of the website may contain it for up to 7 more days. To protect the form against spam we use a hidden field and check the time between loading the page and sending the form. We do not use a captcha and do not set a cookie. To limit abuse we count requests per connection with a short-lived, one-way hashed value, never the IP address itself. We delete your data when it is no longer needed, unless tax or commercial law requires us to keep it longer, for example invoices.
6. When you use our service
For an inspection or purchase support we process the data needed for the order: your contact details, details of the property, documents such as title deed extracts, contracts and identity documents, and photographs and videos we take on site. If the order requires it, we pass data to the people involved in the purchase: the lawyer you instruct, the notary, a court interpreter, and authorities such as the real estate cadastre. We do this only as far as your order requires (Art. 6(1)(b) GDPR) or because the law obliges us (Art. 6(1)(c) GDPR).
7. RSS feed
Our blog offers an RSS feed. Your feed reader loads it like a normal page. We do not see who subscribes.
8. Your rights
You have the right to access your data, to have it corrected or deleted, to restrict its processing, to receive it in a common format, and to object to processing based on legitimate interest. To use these rights, write to thomas@investinginmontenegro.com.
You can also complain to a supervisory authority. In Montenegro this is the Agency for Personal Data Protection and Free Access to Information (Agencija za zaštitu ličnih podataka i slobodan pristup informacijama), Podgorica. If you live in the EU, you can also contact the data protection authority in your country.
9. Changes
We update this policy when the website or our service changes. The date at the top shows the current version.