Privacy Policy
1. Who We Are and What This Policy Covers
This Privacy Policy explains how Traverse d.o.o. Beograd-Stari Grad collects, uses and protects personal data when you use our websites, create an account, buy our digital products or subscribe to our newsletters.
Effective date: October 6, 2026 · Last updated: October 6, 2026
1.1 Controller. Traverse d.o.o. Beograd-Stari Grad, registered in English as Traverse Ltd. Belgrade-Old City (“Traverse,” “we,” “us” or “our”), is the controller of the personal data described in this policy.
- Address: Nikole Spasića 3/1, 11000 Belgrade – Stari Grad, Republic of Serbia
- Company registration number: 20767855
- Tax identification number (PIB) and VAT number: 107171899
- Email: office@traverse.limited
- Phone: +381 63 289 480
1.2 Sites covered. This policy applies to every website we operate that links to it (each a “Site”), currently DARCKED (darcked.com), VARONIL (varonilmagazine.com) and traverse.limited. Each Site keeps its own user accounts and newsletter list, and we do not combine them across Sites.
1.3 Applicable law. We process personal data under the Law on Personal Data Protection of the Republic of Serbia (Official Gazette of the Republic of Serbia, No. 87/2018). If you are in the European Union, the European Economic Area or the United Kingdom, the GDPR or the UK GDPR may also apply to our processing of your data.
1.4 Purchases. Every purchase on the Sites is made from Paddle, our merchant of record. Paddle processes payment and billing data as an independent controller under its own privacy notice (Section 4).
1.5 Questions. Send any privacy question or request to office@traverse.limited or to our postal address above.
2. The Data We Collect
We collect only the data listed below. We never receive or store your full payment card details; Paddle handles them.
| When | What we collect | Where it comes from |
|---|---|---|
| You create an account | Username, first and last name, email address, password (stored only as a hash) | You |
| You buy a product | Transaction ID, the product, the date of purchase and the email address used | Paddle |
| You download a Digital Issue or E-book | Your email address, which we add to the file as a watermark | Your account |
| You subscribe to a newsletter | Email address, your name if you give it, the date you subscribed, and which newsletters you opened and which links you clicked | You and Hostinger Reach |
| You contact us or make a complaint | Your name, email address, the content of your message and any details you add | You |
| You visit a Site | IP address, browser and device type, pages requested and time of access, recorded in server logs | Your browser, recorded by Hostinger |
| You accept analytics cookies | Pages viewed, interactions, browser and device data, approximate location and cookie identifiers | Google Analytics |
2.1 Watermark. The watermark links each downloaded file to your purchase. If you share the file, anyone who receives it may see your email address; sharing purchased files also breaches our Terms and Conditions.
2.2 Special categories. We do not ask for special categories of personal data, such as data about health or religious beliefs.
3. Why We Use Your Data and Our Legal Bases
| Purpose | Data | Legal basis |
|---|---|---|
| Providing your account and access to the products you bought | Account and purchase data | Performance of our contract with you |
| Unlocking and delivering purchases after Paddle confirms payment | Purchase data | Performance of our contract with you |
| Watermarking downloaded files with your email address | Email address | Our legitimate interest in protecting our copyright and discouraging unauthorized sharing |
| Sending service messages about your account, purchases, subscription and changes to our terms | Email address, account and purchase data | Performance of our contract; legal obligation where the law requires notice |
| Answering questions and handling complaints and requests | Your messages, account and purchase data | Performance of our contract; legal obligation to keep a record of complaints |
| Sending newsletters and measuring opens and clicks | Newsletter data | Your consent |
| Measuring how the Sites are used | Analytics data | Your consent |
| Keeping the Sites and accounts secure and preventing fraud and account sharing | Technical data and account data | Our legitimate interest in protecting the Sites, our readers and our content |
| Complying with the law and establishing, exercising or defending legal claims | The records concerned | Legal obligation; our legitimate interest |
3.1 Where we rely on your consent, you can withdraw it at any time. Withdrawal does not affect processing that took place before it.
3.2 Where we rely on our legitimate interests, you can object to the processing (Section 7).
3.3 We do not make decisions about you based solely on automated processing that have legal or similarly significant effects on you.
4. Who Receives Your Data
We do not sell your personal data. We share it only with the recipients below.
4.1 Paddle. Paddle is our merchant of record and sells our products to you. It processes your payment, billing and tax data as an independent controller under its Privacy Notice. Paddle tells us that a purchase was completed and gives us the details we need to deliver it, such as the transaction ID and your email address.
4.2 Hostinger. Hostinger International Ltd. hosts the Sites and their databases, including account and purchase records, and processes this data on our behalf. See the Hostinger Privacy Policy.
4.3 Hostinger Reach. We send newsletters through Hostinger Reach, Hostinger’s email marketing service. It stores our subscriber lists and records, for each recipient, whether a newsletter was delivered and how many times it was opened and clicked.
4.4 Google. We use Site Kit by Google to connect the Sites to Google services. With your consent, Google Analytics collects data about how you use the Sites through cookies. Google Analytics uses your IP address only to estimate your approximate location and does not store it. See the Google Privacy Policy and how Google uses information from sites that use its services.
4.5 Meta. We advertise our publications on Facebook and Instagram. When you see or interact with our ads there, Meta processes your data as an independent controller under the Meta Privacy Policy. Meta gives us only aggregated reports on how our ads perform.
4.6 Social platforms. The Sites link to our profiles on Instagram, Facebook, X, YouTube and TikTok. If you follow those links, or view content from those platforms embedded on a Site, the platform processes your data under its own policy: Meta (Instagram and Facebook), X, Google (YouTube) and TikTok.
4.7 Others. We disclose data to public authorities when the law requires it, and to our legal and accounting advisers when needed to handle a dispute or meet a legal obligation. If another company takes over a Site or our business, it receives the related data and must protect it as this policy describes.
5. Transfers Outside Serbia
5.1 Some recipients process data outside Serbia: Paddle in the United Kingdom and other countries where it operates, Hostinger in the European Union and other locations of its infrastructure, and Google and Meta in the United States and other countries.
5.2 Serbian law treats as providing an adequate level of protection the countries that are parties to the Council of Europe Convention 108, which include all EU member states and the United Kingdom, as well as countries the European Union recognizes as adequate. For transfers to other countries, we rely on the safeguards the law provides, such as standard contractual clauses in our providers’ data processing terms.
5.3 You can ask us at office@traverse.limited for more information about these safeguards.
6. How Long We Keep Your Data
We keep personal data only as long as the purpose requires, then delete or anonymize it.
| Data | How long we keep it |
|---|---|
| Account data | While your account is open; deleted within 30 days after you close it, except the records listed below |
| Purchase records (transaction ID, product, date, email address) | 5 years from the purchase, to confirm your rights to products you bought and to handle complaints and claims |
| Complaints and our replies | 2 years from the date of the complaint, the period Serbian consumer law requires |
| Other correspondence with you | 2 years from our last exchange |
| Newsletter data | Until you unsubscribe; after that we keep only your email address on a do-not-contact list, so that we never email you again |
| Analytics data | Up to 14 months, according to our Google Analytics retention setting |
| Server logs | For the limited period set by Hostinger’s security logging |
| Data needed for a legal dispute | Until the dispute is finally resolved |
7. Your Rights
7.1 Under Serbian law and, where it applies, the GDPR or the UK GDPR, you have the right to:
- access your personal data and receive a copy of it;
- have inaccurate data corrected;
- have your data deleted when there is no longer a reason to keep it;
- restrict our processing in certain cases;
- receive the data you gave us in a structured, machine-readable format, or have it sent to another controller;
- object to processing based on our legitimate interests, and to direct marketing at any time; and
- withdraw your consent at any time.
7.2 How to exercise your rights. Email office@traverse.limited from the address linked to your account, or write to our postal address. We may ask you to confirm your identity. We respond free of charge within 30 days; if a request is complex, we may extend this by up to 60 days and will tell you why.
7.3 Data held by Paddle. For payment and billing data, you can contact Paddle directly as described in its Privacy Notice, or ask us and we will forward your request.
7.4 Complaints. You may complain to the Serbian supervisory authority:
- Commissioner for Information of Public Importance and Personal Data Protection
- Bulevar kralja Aleksandra 15, 11120 Belgrade, Republic of Serbia
- office@poverenik.rs · +381 11 3408 900 · poverenik.rs
If you are in the EU, the EEA or the UK, you may also complain to the data protection authority where you live or work. We would appreciate the chance to resolve your concern first.
8. Newsletters, Cookies, Age, Security and Changes
8.1 Newsletters. We send newsletters only to people who have subscribed to them. Every newsletter contains an unsubscribe link, and you can also unsubscribe by writing to office@traverse.limited. Unsubscribing does not stop service messages about your account or purchases.
8.2 Cookies. The Sites use cookies that are necessary for them to work, such as login cookies. Non-essential cookies, such as Google Analytics cookies, are used only with your consent, which you can change at any time in the cookie settings on each Site. Our Cookie Policy lists the cookies we use.
8.3 Do Not Track. The Sites do not respond to browser Do Not Track signals. You can control non-essential cookies through the cookie settings.
8.4 Minimum age. The Sites are for people aged 16 or older. We do not knowingly collect personal data from children under 16, and if we learn that we have, we delete it.
8.5 Security. We protect personal data with appropriate technical and organizational measures. Access is limited to people who need it, passwords are stored only as hashes, and our providers are bound by security and confidentiality obligations. If a breach affects your data and the law requires it, we will inform you and the competent authority.
8.6 Changes to this policy. We may update this policy to reflect changes in our Sites, our providers or the law. The current version and its date are always available on each Site, and we will tell account holders and newsletter subscribers about material changes by email before they take effect.
8.7 Contact.
- Traverse d.o.o. Beograd-Stari Grad (Traverse Ltd. Belgrade-Old City)
- Nikole Spasića 3/1, 11000 Belgrade – Stari Grad, Republic of Serbia
- Email: office@traverse.limited
- Phone: +381 63 289 480
