Privacy Policy
Last updated: 1 October 2026
This policy explains what personal data Adionika receives through adionika.me and while delivering its services, why, who we share it with, how long we keep it and how you can control it. It is written under Montenegro's Personal Data Protection Act (Zakon o zaštiti podataka o ličnosti) and Electronic Communications Act (Zakon o elektronskim komunikacijama).
1. Who is responsible for your data
The data controller is Društvo sa ograničenom odgovornošću "Adionika" Budva (Adionika DOO), PIB 03411184, Narodnog Fronta bb, 85310 Budva, Montenegro.
For any question about your data, email aleksei@adionika.me or call +382 67 571 556.
Adionika is a private consulting company. We are not a government agency and do not decide on permits, visas or registrations.
2. What we collect, why and for how long
| Source | Data | Purpose | Legal basis | Retention |
|---|---|---|---|---|
| Enquiry form | name, phone, @telegram or email, preferred channel, your question; page and traffic source (UTM tags, ad click marker) | reply to your enquiry, prepare an offer, see which ads bring enquiries | steps prior to a contract at your request; legitimate interest in knowing the enquiry source | 12 months from last contact; if you become a client, your name and contact are kept with your client data |
| Website chat | messages, name and contact if you leave them, page you wrote from, traffic source | reply in the chat or via the contact you left | steps prior to a contract; legitimate interest | 12 months from last message |
| Chat service: visits | pages of the site, traffic source, country and city from the IP address, clicks on contact links | show our operator who is on the site and see where enquiries come from | your consent in the cookie banner | 90 days from the last visit; if you wrote in the chat, as long as the conversation |
| Email, calls, messengers | what you send us and your number or account | reply and keep the conversation | steps prior to a contract or performance of a contract | 12 months from last message; documents you sent us for the service are moved to your client file and kept as client documents |
| Client documents | passport data, address, employment, income, property and family details, residence permit data (number, basis, validity dates) and other documents filings require | deliver the service and keep supporting you: prepare and file documents, track residence and other permit deadlines, remind you about renewals, prepare the next filings, answer authorities' requests | performance of a contract; legal obligations; legitimate interest in renewal reminders (you can opt out at any time) | for as long as you use our services and have not told us you no longer wish to work with us; then 12 months, after which we delete it. Contract and invoices: 5 years from the end of the year the contract ended (Accounting Act) |
| Client companies' employees (HR support) | passport data, residence and work permit data, deadlines, filing documents | track employees' deadlines and filings under the contract with their employer | contract with the employer company; legal obligations | for as long as the contract with the company is in force and 12 months after it ends or after the employee leaves the company |
| Website statistics | cookie identifiers, IP address, browser and device, pages viewed, clicks, session recording (Webvisor) | understand how the site is used and measure ad results | your consent in the cookie banner | per service settings: up to 14 months in Google Analytics; in Yandex Metrica per the service's rules |
Once personal data is deleted, we keep only anonymous statistics: month, enquiry topic, traffic source, country, response time and daily visit counts. They contain no message text, names, contacts, IP addresses or identifiers, so they cannot be linked to you.
Providing data through the site is voluntary. Without a contact we cannot reply; without documents we cannot deliver the service. There are no other consequences of refusal.
We do not ask for data we do not need to answer you. Please do not send passport scans or certificates through the form or chat: we accept documents only once the service is agreed, in the way we agree with you.
We do not store criminal record certificates or other documents about criminal history: you hand them to us for a specific filing, and the copy is deleted once the filing is made.
3. Who we share data with
We do not sell data. To run the site and reply to you we use services that process data on our behalf or under their own terms:
| Service | Used for | Where data may be stored |
|---|---|---|
| Railway | hosting the website and the chat service | United States |
| Website chat service (contractor) | receiving and handling website chat messages on our behalf | United States (on Railway servers); notifications via Telegram |
| Telegram | internal notifications to our team about new enquiries and chat messages | Telegram servers outside Montenegro |
| Resend | delivering enquiry emails to our inbox | United States |
| Google (Analytics, Ads) | website statistics and measuring ad results — only with your consent | United States and other countries |
| Yandex (Metrica) | website statistics, click maps, session recording (Webvisor) — only with your consent | Russia and other countries |
| Supabase | storing client records in Adionika's work system | EU (Frankfurt, Germany) |
If you write to us on Telegram, WhatsApp or Viber, that messenger's own terms also apply.
To deliver the service we pass client documents to Montenegrin authorities, notaries, translators and insurers, only to the extent a specific filing requires.
Otherwise we disclose data only when the law requires it.
4. Transfers outside Montenegro
Some services in section 3 store data outside Montenegro. We transfer data abroad on the grounds Montenegrin law allows (Article 42 of the Personal Data Protection Act):
- to EU and EEA countries and to countries the EU recognises as providing adequate protection;
- to providers in other countries, including the United States, under contracts with the EU standard contractual clauses on data protection;
- to Google and Yandex (website statistics, servers in the US and Russia) only with your consent, which you give in the cookie banner and can withdraw at any time;
- to the extent needed to perform our contract with you.
5. Cookies and analytics
The site uses two kinds of cookies.
- Technical cookies, needed for the site, the form and the chat to work. They are set without consent because the site does not work without them.
- Analytics and advertising cookies: Google Analytics, Google Ads, Yandex Metrica and visit tracking in the chat service. They are set only after you click "Accept" in the cookie banner. Until you consent, these services do not load, and the chat works only as a chat: it remembers your conversation but not your visits.
With your consent, Yandex Metrica records on-page activity (Webvisor): mouse movement, scrolling and clicks. The contents of the enquiry form and chat fields are not recorded.
You can withdraw consent at any time via the "Cookie settings" link in the site footer. You can also block cookies in your browser settings or install opt-out add-ons: Google Analytics, Yandex Metrica. The site keeps working either way.
6. Your rights
You can:
- find out what data we hold about you, where it came from and who it was shared with, and get a copy;
- correct inaccurate or complete incomplete data;
- ask us to delete data or restrict its use, unless the law requires us to keep it;
- object to processing based on legitimate interest;
- withdraw consent where processing relies on it; this does not affect processing done before the withdrawal;
- complain to Montenegro's Agency for Personal Data Protection and Free Access to Information (Agencija za zaštitu ličnih podataka i slobodan pristup informacijama, azlp.me). The Agency decides on a complaint within 60 days.
Send requests to aleksei@adionika.me. We reply within 15 days, free of charge, and may ask you to confirm your identity so that we do not disclose data to the wrong person.
7. Marketing messages
We do not send marketing messages without your consent. If you have consented, you can opt out via the link in any message or by emailing aleksei@adionika.me.
8. Family members and children
The site is intended for adults. We accept a spouse's or children's data, for example for a family residence permit, only from a client entitled to provide it. A child's data is provided by a parent or legal guardian.
9. Security
The site runs over HTTPS. Only staff who need enquiries and documents for their work can access them. Services that process data on our behalf (hosting, email, database, the chat service, Google) work under data processing agreements. We use Telegram and other messengers as communication channels under their own terms. No method of sending data over the internet is fully secure, so we ask you to hand over original documents in the way we agree with you.
10. Changes to this policy
We update this page when our services or data practices change. The date of the last update is shown at the top. From 19 March 2027 Montenegro applies a new Personal Data Protection Act; this policy will be updated before that date.