Legal
Privacy Notice
Version 2.3 · Effective 24 October 2026
This notice explains how we process personal data when you visit yourdigitalworker.com, book a call or write to us through its form, or talk to its site assistant. If you use the Digital Worker platform itself, the Digital Worker Privacy Policy applies to that: it comes with your contract and is published in every Digital Worker instance at /legal/privacy.html.
1.Who we are
Apex Academy d.o.o., trading as Digital Apex, publishes this website and is the controller for the personal data processed through it.
- Company
- Apex Academy d.o.o., trading as Digital Apex
- Registered seat
- Stepinčeva 79, 21000 Split, Croatia
- OIB · VAT ID
- 77296720425 · HR77296720425
- Court register
- Trgovački sud u Splitu, MBS 060446318
- Data protection
- legal@apexacademy.hr, or by post to the registered seat, attn. "Data Protection"
- Everything else
- info@apexacademy.hr
We have not appointed a statutory Data Protection Officer, because our processing does not meet the thresholds of GDPR Article 37. The data-protection contact above is the single point of contact for data-protection questions and rights requests.
2.What we process, why, and for how long
| What | Examples | Why | Legal basis (GDPR) | How long |
|---|---|---|---|---|
| Server logs | IP address, browser type, page requested, time | Keeping the site running and secure, and detecting abuse | Art. 6(1)(f), legitimate interest in a secure website | 14 days, then deleted automatically |
| Call and contact form | Name, email, and if you give them your phone number and company; the best time to call, your message, the page you sent it from | Calling you back or answering your inquiry and, if you ask, preparing an offer | Art. 6(1)(b), steps before a contract; Art. 6(1)(f), legitimate interest in answering | 2 years after our last contact |
| Free plan form | Name, work email and company, and what you would like to build first; if you give them, your phone number, the size of your team, your role and industry, the tools you use and how you heard about us | Setting up your Free plan, and learning what companies want to build | Art. 6(1)(b), steps before a contract you asked for; Art. 6(1)(f), legitimate interest in improving our service | 2 years after our last contact |
| Free plan reminders | Your email, your free server's address, and how many days it has not been used | Telling you twice before an unused free server is deleted, so you can keep it | Art. 6(1)(b), the Free plan you asked for | As the Free plan form |
| News and offers, only if you tick the box | Your name and email | Sending you news, tips and offers about Digital Worker | Art. 6(1)(a), consent, which you can withdraw at any time | Until you unsubscribe or withdraw consent |
| Emails about your request | The details above, in an email to our company mailbox, and a confirmation email to you | Letting the right person know at once, and confirming that your request arrived | As the call and contact form | As the call and contact form |
| Site assistant | What you type, the answers, the time, a random conversation id | Answering your questions, and checking answers to fix mistakes | Art. 6(1)(f), legitimate interest in answering visitors | Up to 12 months |
| Contact through the assistant | The name, email, company and message you confirm in its form | As the call and contact form | As the call and contact form | As the call and contact form |
| Analytics, only if you accept | Pages viewed, visits, device and browser type, approximate location | Understanding which content is useful | Art. 6(1)(a), consent, which you can withdraw at any time | Cookies up to 2 years, see the cookie policy |
| Ad measurement, only if you accept | Which Google ad brought you here, and whether you then booked a call or wrote to us | Seeing which of our ads work, so we spend only on useful ones | Art. 6(1)(a), consent, which you can withdraw at any time | Cookies up to 90 days, see the cookie policy |
Your request is stored in our own Digital Worker platform, on our server in the EU. Within a few minutes it is also emailed to our company mailbox, and you receive a confirmation by email. What this site keeps in your own browser is listed in the cookie policy.
3.The site assistant
The assistant is an AI and says so, as the EU AI Act (Article 50) requires: you are never led to believe you are talking to a person. It runs on our own Digital Worker platform, on our server in Frankfurt, Germany. To write each answer, the conversation is sent to an AI model provider, currently OpenAI, under a data-processing agreement (see section 5).
- Please do not type sensitive personal data, passwords or confidential information into the chat. It is a sales assistant, not a secure channel.
- Nothing becomes an inquiry until you press send in its contact form yourself. The form is filled in with what you already told it, and you can change it.
- A copy of the conversation stays in your own browser for up to 6 hours, so it is still there if you open another page and come back. The clear button in the assistant removes it at once.
4.What we do not do
- We do not sell or rent personal data.
- We do not use cookies to personalise ads or to follow you with ads on other sites. Our only advertising cookies measure which Google ad brought you here, and only if you accept.
- We do not build profiles of visitors, and we make no automated decisions about you with legal or similarly significant effects.
- We do not use your messages or inquiries to train AI models.
5.Recipients and transfers
| Recipient | What and why | Where | Safeguard |
|---|---|---|---|
| Our hosting provider | Runs the server this website, its forms and the site assistant are on | Frankfurt, Germany (EU) | Within the EU; no transfer |
| Google (Google Ireland Limited, with Google LLC) | Our company email (Google Workspace), which delivers your request to our mailbox and sends you the confirmation; and analytics and ad measurement (Google Analytics, Google Ads), only if you accept | May be outside the European Economic Area | EU-US Data Privacy Framework and the EU standard contractual clauses in Google's data-processing terms |
| Resend (Plus Five Five, Inc.) | Sends the reminders about your Free plan, such as the two emails before an unused free server is deleted | United States | EU-US Data Privacy Framework and the EU standard contractual clauses in Resend's data-processing agreement |
| AI model provider (currently OpenAI) | Writes the site assistant's answers from the conversation | May be outside the European Economic Area | The provider's data-processing agreement, with the EU standard contractual clauses |
Beyond these, personal data reaches only IT service providers bound by confidentiality when they help us run our systems, and authorities where the law requires it.
6.Your rights
Under GDPR Articles 15 to 22 you have the right to:
- Access: receive a copy of the personal data we hold about you.
- Rectification: have inaccurate data corrected.
- Erasure: have your data deleted, where no legal obligation requires us to keep it.
- Restriction: ask us to pause processing in defined circumstances.
- Data portability: receive the data you gave us in a structured, machine-readable format.
- Objection: object to processing based on our legitimate interest.
- Withdrawal of consent: withdraw your consent to analytics and ad measurement at any time, on the cookie policy page, without affecting what happened before.
- Complaint: lodge a complaint with the Croatian Personal Data Protection Agency (AZOP, azop.hr) or the supervisory authority in your EU country of residence.
Write to legal@apexacademy.hr. We answer verified requests within one month (Article 12(3)), which can be extended by two further months for complex requests.
7.Security
The site and its forms use TLS encryption, and the data is stored on our own server in the EU, with access limited to the people who need it. No system is completely secure. If a personal-data breach is likely to put you at risk, we notify the supervisory authority within 72 hours of becoming aware of it (Article 33), and you where Article 34 requires.
8.Children
This website is meant for businesses and is not directed at children under 16.
9.Changes to this notice
When our practices change, we update this notice and the version and date at the top. Earlier versions are available on request. Version 2.3 adds the Free plan reminders and Resend, which sends them. Version 2.2 added ad measurement with Google Ads, only with your consent. Version 2.1 added the call booking form and the emails about your request.
10.Related documents
- Cookie policy and imprint of this website
- Privacy notice of digitalapex.ai, our company website
- The Digital Worker Privacy Policy, Terms, Data Processing Agreement, Service Level Agreement, Acceptable Use Policy, sub-processor list and EU AI Act statement: part of your Digital Worker contract, and published in every instance under
/legal/