Legal
Privacy Policy
1. Who holds your data
The operator of MontaGemTok is the controller for account data. Registered company details will be stated here before the service is offered publicly. Until then, contact the operator directly.
2. What we hold, and why
| Data | Why | Lawful basis |
|---|---|---|
| Email address, display name, password hash | To have an account at all | Contract |
| Company name and registration number | Optional. To connect you to a company record | Contract |
| Preferred language | To show the interface in the language you chose | Contract |
| A single-use email-confirmation token | To prove you control the address you registered. Held only as a hash, unusable to read the link back, and it expires after seven days | Contract |
| Two-factor secret and recovery codes | Only for accounts with moderation rights. Encrypted at rest | Contract, and our duty to secure the service |
| Claims, offers and messages you submit | They are the service | Contract |
| Login attempts, lockouts, moderation decisions | To stop abuse, and to record who approved what | Legitimate interest |
| Database backups | So a failure does not lose your data | Legitimate interest |
We do not profile you, do not advertise to you, and send no marketing. If that ever changes it will require a separate, explicit opt-in — not a version bump of this document.
3. Cookies
Two cookies, both strictly necessary: one keeps you signed in, one remembers your language. There is no analytics, no tracking pixel and no third-party advertising cookie — which is why you are not being shown a cookie banner. A banner asking consent for cookies we do not set would be theatre.
4. Plant and company records
The directory is compiled from public registries, operator disclosures and company websites, and each record carries its sources. Most of it is information about legal entities rather than people — but a sole trader's business name can also be a person's name, and we treat it accordingly. Our basis is legitimate interest in maintaining an accurate public directory of energy infrastructure.
If a record identifies you and you object, tell us. We will correct it, hide it, or remove it. We do not require you to justify the request.
5. Who else sees it
No data is sold, and none is shared for anyone else's marketing.
Processors that will hold data on our behalf once the service is deployed — hosting, database and an email provider — are not yet chosen. This section will name them before the service is offered publicly. Today no email leaves the platform, because no email provider is configured. Where a message would have been sent, its content — including the confirmation link and the address it was for — is written to the server's own application log instead, which only the operator can read. No third party receives it.
6. How long we keep it
- Your account: until you delete it.
- Security and login logs: 12 months. This covers the security events recorded against your account: password and two-factor changes, email confirmation, account approval, administrator resets and data exports. After that the record no longer says whose account it was or who acted, and any note is removed; only the kind of event and its date remain.
- Moderation audit trail: 24 months. After that the record no longer says who made a decision, and any note written with it is removed, but the decision itself is kept: what was decided, about which record, and when. We keep the decision because the directory's value rests on being able to show how a record was verified.
- Both of these steps run automatically once a day.
- Backups: 35 days, then they age out.
7. Deleting your account
You can delete your account from your profile page. It happens immediately and cannot be undone: your email address is replaced with a random one at an unusable domain, your display name becomes "Deleted user", and your company name, registration number and password are cleared, all in a single database transaction. Your sessions stop working at once.
Two honest caveats. Content you contributed to shared records — a claim you made, an offer you sent — may remain, no longer connected to you, because deleting it would alter another party's record of a dealing they were part of. And backups taken before your deletion still contain the old row until they age out, after 35 days.
An account that is the last one able to administer the platform cannot be deleted, because that would leave the service with nobody able to moderate it. Contact us and we will arrange it.
8. Your rights
Under the GDPR you may ask for a copy of your data, ask us to correct it, ask us to delete it, object to processing based on legitimate interest, and ask for your data in a portable form.
You can download a copy of your data yourself from your profile page, using "Download my data". It is a JSON file, a common machine-readable format, so it also serves as the portable copy. It contains your account details, the records you created, claimed or posted, the messages you sent, the security events recorded against your account and the moderation decisions you made. It never contains your password, your two-factor secret or your recovery codes, and it does not contain other people's personal data.
For anything else under this section, or if you prefer to ask by hand, contact the operator. We aim to answer within 30 days, which is the period the GDPR allows.
You may also complain to the Croatian data protection authority (AZOP) or to the authority where you live.
9. Where your data is
Currently on a single machine in Croatia. When the service is deployed the intention is EU-region hosting, and this section will say where before that happens.
10. Security
Passwords are stored hashed, never in a form we can read. Two-factor secrets and recovery codes are encrypted. Traffic is over HTTPS. Access to moderation requires two-factor authentication. Backups are taken daily and have been test-restored.
We do not claim to be unbreachable. If a breach affects your data we will tell you and the supervisory authority as the GDPR requires.
11. Changes
This policy carries a version. Material changes bump it, and you will be asked to accept the new version; we record which one you accepted and when.
Version 2026-10-10. For any request under section 8, contact the operator of this service directly.