English Version 1.0 | Effective 1 October 2026

PrimePressQ d.o.o. (“PrimePressQ”, “we”, “us” or “our”) respects your privacy and is committed to protecting personal data in accordance with applicable data protection laws.

This Privacy Policy explains how we collect, use, disclose, store and protect personal data in connection with our website, applications, client relationships, media and communications services and other business activities.

1. WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?

The data controller is:

PrimePressQ d.o.o.
PrimePressQ društvo s ograničenom odgovornošću za usluge
Gradišće 7/E
10040 Zagreb
Republic of Croatia

OIB: 79053002914

Privacy contact: legal@primepressq.com

PrimePressQ is established in Croatia and processes personal data in accordance with Regulation (EU) 2016/679 (“GDPR”), applicable Croatian data protection legislation and, where applicable, other mandatory data protection laws.

2. WHO DOES THIS PRIVACY POLICY APPLY TO?

This Privacy Policy applies to individuals whose personal data we process in connection with our business, including:

• individuals submitting applications to PrimePressQ;

• representatives and contact persons of prospective and existing clients;

• representatives of hospitality brands, destinations, tourism organisations and other businesses or organisations;

• media and publishing contacts;

• business partners, suppliers and contractors;

• individuals who communicate with us; and

• visitors to our website.

PrimePressQ primarily operates on a business-to-business basis. Information relating solely to a company or other legal entity is not necessarily personal data. However, information that identifies or relates to an individual representing that organisation is personal data and is protected accordingly.

3. PERSONAL DATA WE COLLECT

The personal data we collect depends on how you interact with PrimePressQ.

Application information

When you submit a PrimePressQ application, we may collect:

• your name and surname;

• business or professional email address;

• telephone number;

• job title or role;

• the name of the business, brand, destination or organisation you represent;

• website and social media handles or profiles;

• information you provide about your business, brand, destination or organisation;

• your campaign, media or service interests and preferences;

• information provided in open-text application fields; and

• other information you choose to provide as part of your application.

Some information submitted through an application may relate primarily to a business or organisation rather than an identifiable individual. We nevertheless handle application information responsibly and apply appropriate safeguards where it contains personal data.

Client and service information

If an application progresses or you otherwise become a PrimePressQ client, we may additionally process:

• business contact information;

• correspondence and communications;

• campaign and project information;

• selections and preferences;

• approvals;

• signed agreements and confirmations;

• Media Authorization Forms;

• information and materials provided or approved for content production or publication; and

• records relating to the performance of our services.

Data Related to Content and Media Authorization Forms

In connection with the provision of our services, we may process personal data provided or approved by the Client for the purposes of communication, content preparation and delivery of the agreed service. Depending on the specific service, such data may include names, professional roles, professional biographical information, statements, quotes, photographs and other personal data relating to individuals relevant to content prepared by PrimePressQ.

For certain media placements, PrimePressQ may also require the Client to sign a separate Media Authorization Form confirming and authorizing the specific media placement. Such form may contain limited personal data relating to the Client’s authorized representative, such as the individual’s name, signature and date of signature.

PrimePressQ seeks to limit the personal data contained in a Media Authorization Form to the information necessary to evidence the Client’s authorization of the specific media placement.

Billing and financial information

We may process information necessary for billing, accounting and payment administration, including:

• billing name and address;

• company and tax information;

• invoice information;

• transaction information;

• payment status; and

• relevant financial correspondence.

Where payment is processed by a third-party payment provider, PrimePressQ may not receive or store complete payment-card information.

Communications

When you contact us, we may process your name, contact details, the contents of your communication and information necessary to respond to or administer your request.

Website and technical information

When you use our website, certain technical information may be processed, including, where applicable:

• IP address;

• browser and device information;

• operating system;

• website access information;

• pages visited;

• approximate technical location information derived from an IP address;

• security and diagnostic information; and

• cookie or similar technology identifiers.

The use of non-essential cookies and similar technologies is subject to applicable consent requirements and is further explained in our Cookie Policy.

4. WHY WE PROCESS PERSONAL DATA AND OUR LEGAL BASES

We process personal data only where we have an appropriate legal basis.

A. Reviewing applications

We process application information to:

• receive and administer applications;

• evaluate suitability for the relevant opportunity, campaign, listicle or service;

• assess availability, fit and relevant selection criteria;

• communicate with applicants; and

• take steps in connection with a potential business relationship.

Depending on the circumstances, we rely on steps necessary prior to entering into a contract and/or our legitimate interests in evaluating genuine business applications and potential business relationships.

B. Providing our services

We process personal data to:

• establish and administer client relationships;

• prepare and deliver agreed services;

• coordinate campaigns, media placements, listicles and agency services;

• produce and manage content;

• obtain and administer approvals;

• communicate with Client representatives; and

• manage the performance of our contractual obligations.

Depending on the relationship, processing is based on performance of a contract and/or our legitimate interests in properly administering and delivering services to our business clients.

C. Media Placements and Media Authorization

Where Client confirmation is required for a specific media placement, PrimePressQ may require the Client to sign a Media Authorization Form confirming and authorizing its participation in the relevant media placement.

Where necessary to carry out the specific media placement, the signed Media Authorization Form may be provided to the relevant media partner working with the publisher or directly to the relevant publisher.

PrimePressQ seeks to limit the personal data contained in the Media Authorization Form to the information necessary to evidence such authorization.

D. Business communications and relationship management

We process professional contact details and correspondence to communicate with prospective and existing clients, publishers, media partners, suppliers and other business contacts.

We rely on our legitimate interests in maintaining and administering appropriate professional and business relationships.

E. Payments, accounting and legal obligations

We process relevant personal data to:

• issue and administer invoices;

• record payments;

• maintain accounting and tax records;

• comply with applicable financial, tax and corporate obligations; and

• respond to lawful requests from competent authorities.

The applicable legal basis is compliance with our legal obligations and, where relevant, performance of contractual obligations.

F. Establishing and protecting legal rights

We may process relevant information where necessary to:

• document business transactions;

• manage disputes or complaints;

• prevent or investigate fraud or misuse;

• establish, exercise or defend legal claims; and

• protect PrimePressQ, its clients and relevant third parties.

We rely on our legitimate interests in protecting our business and legal rights.

G. Marketing communications

Where we send marketing communications requiring consent under applicable law, we will request that consent separately.

Where applicable law permits a particular B2B communication on another lawful basis, we may rely on that basis.

You may object to direct marketing or unsubscribe from applicable marketing communications at any time.

H. Website operation, security and analytics

We may process technical information necessary to operate, maintain and secure our website on the basis of our legitimate interests in providing a secure and functional website.

Where analytics, marketing or other non-essential cookies or tracking technologies require consent, they will not be used until the required consent has been obtained.

Further information is provided in our Cookie Policy.

5. LEGITIMATE INTERESTS

Where we rely on legitimate interests, we consider whether the processing is necessary for a legitimate purpose and whether your interests, rights or freedoms override that interest.

Our legitimate interests may include:

• evaluating genuine business applications and enquiries;

• managing professional and B2B relationships;

• administering and delivering our services;

• communicating with representatives of our clients and partners;

• maintaining appropriate business records;

• protecting the security and integrity of our business;

• preventing fraud and misuse;

• establishing, exercising or defending legal claims; and

• improving our business operations and services.

Where required, PrimePressQ assesses and documents the relevant legitimate interest before relying on it as a legal basis.

6. DO WE SELL PERSONAL DATA?

No. PrimePressQ does not sell personal data.

We also do not disclose personal data to unrelated third parties for their own purposes merely because an individual submitted an application to us.

We do, however, share information where this is necessary and lawful for the operation of our business or delivery of an agreed service, as explained below.

7. WHO MAY RECEIVE PERSONAL DATA?

Depending on the relevant activity, personal data may be disclosed to:

• relevant media partners working with the publisher, or directly to relevant publishers, where providing a signed Media Authorization Form is necessary to carry out the specific media placement;

• production and content partners;

• technology and website service providers;

• hosting and cloud service providers;

• email and communications providers;

• CRM and business administration providers;

• payment service providers and financial institutions;

• accountants, auditors, lawyers and other professional advisers;

• contractors and specialist service providers supporting PrimePressQ;

• competent public authorities, regulators, courts or law-enforcement authorities where disclosure is required or permitted by law; and

• relevant parties in connection with a lawful merger, acquisition, financing, corporate restructuring or transfer of all or part of our business.

We limit disclosure to information reasonably necessary for the relevant purpose. Where a service provider processes personal data on our behalf, we use appropriate contractual and data protection arrangements where required by law.

8. PUBLISHERS AND OTHER INDEPENDENT CONTROLLERS

Some organisations receiving information in connection with a PrimePressQ service may process personal data for their own purposes and under their own legal responsibilities.

This may include certain publishers, media companies, financial institutions, payment providers and other independent organisations.

Where another organisation acts as an independent controller, its processing is governed by its own privacy information and applicable law.

PrimePressQ remains responsible for its own processing of personal data but does not control independent processing undertaken by another controller.

9. INTERNATIONAL DATA TRANSFERS

PrimePressQ operates internationally and works with media partners, publishers and service providers that may be located outside the European Economic Area (“EEA”), including in the United States.

In connection with certain media placements, PrimePressQ may provide a relevant media partner working with the publisher, or directly the relevant publisher outside the EEA, with a signed Media Authorization Form through which the Client has confirmed and authorized the specific media placement. Such form may contain limited personal data relating to the Client’s authorized representative, such as the individual’s name, signature and date of signature.

PrimePressQ seeks to limit the personal data contained in a Media Authorization Form and transferred for this purpose to the information necessary to evidence the Client’s authorization of the specific media placement.

Where such transfer involves personal data, PrimePressQ acts in accordance with applicable data protection requirements governing international transfers and, where applicable, uses appropriate legal mechanisms or safeguards provided under applicable law.

For further information regarding international transfers of personal data, please contact legal@primepressq.com

10. HOW LONG DO WE KEEP PERSONAL DATA?

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected and for applicable legal, accounting, tax, contractual and compliance requirements.

The relevant retention period depends on the type of information and the relationship concerned.

In determining retention periods, we consider:

• whether an application was successful or unsuccessful;

• whether a business or contractual relationship was established;

• the duration of the relationship;

• whether information remains necessary to provide or document a service;

• applicable accounting, tax and corporate record-keeping requirements;

• applicable limitation periods;

• the possibility of legal claims or disputes; and

• whether continued retention is necessary for another lawful purpose.

Application information that does not result in a business relationship will not be retained indefinitely and will be deleted or anonymised when it is no longer reasonably required for the relevant business purpose, subject to applicable legal requireents.

Personal data contained in accounting, contractual or other legally required records may be retained for the period required by applicable law.

11. ACCURACY OF INFORMATION

We take reasonable steps to keep personal data accurate where necessary for the purposes for which it is processed.

Applicants, clients and their representatives are responsible for providing accurate and current information and should inform us if relevant personal data changes.

The accuracy and authorised use of information and materials provided for media or content purposes may additionally be governed by the applicable PrimePressQ General Terms & Conditions and Media Authorization Form.

12. DATA SECURITY

PrimePressQ implements appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, access or other unlawful processing.

Access to personal data is limited according to legitimate business need and appropriate access controls.

Where we use service providers to process personal data on our behalf, we take appropriate steps to select providers capable of providing appropriate data protection safeguards.

No electronic system or method of transmission can be guaranteed to be completely secure. Accordingly, while we take appropriate measures to protect personal data, absolute security cannot be guaranteed.

13. YOUR RIGHTS

Subject to the conditions and limitations provided by the GDPR and other applicable law, you may have the right to:

Access — obtain confirmation whether we process your personal data and receive access to it.

Rectification — request correction of inaccurate personal data and completion of incomplete information.

Erasure — request deletion of personal data where the legal requirements for erasure are satisfied.

Restriction — request restriction of processing in circumstances provided by law.

Data portability — receive certain personal data in a structured, commonly used and machine-readable format and, where applicable, have it transmitted to another controller.

Object — object, on grounds relating to your particular situation, to processing based on legitimate interests.

Object to direct marketing — object at any time to processing of your personal data for direct marketing purposes.

Withdraw consent — where processing is based on consent, withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

Complain to a supervisory authority — lodge a complaint with the competent data protection supervisory authority.

These rights are not absolute. Certain rights may not apply in particular circumstances, and PrimePressQ may retain or continue processing information where permitted or required by applicable law.

14. HOW TO EXERCISE YOUR RIGHTS

To exercise a data protection right or ask a privacy-related question, contact: legal@primepressq.com

Please provide sufficient information for us to identify the relevant processing and understand your request.

Where reasonably necessary, we may request additional information to verify your identity and protect personal data from unauthorised disclosure.

We will respond within the period required by applicable data protection law.

15. DIRECT MARKETING

You have the right to object at any time to processing of your personal data for direct marketing purposes.

Where an electronic marketing communication contains an unsubscribe mechanism, you may also use that mechanism to stop receiving such communications.

An objection to marketing does not necessarily require us to delete information that we are required or otherwise lawfully entitled to retain for another purpose, such as maintaining a suppression record to ensure that we respect your marketing preference.

16. AUTOMATED DECISION-MAKING

PrimePressQ does not currently use solely automated decision-making, including profiling, that produces legal effects concerning individuals or similarly significantly affects them within the meaning of Article 22 GDPR in connection with the processing described in this Privacy Policy.

Applications may be reviewed and assessed according to business and selection criteria, but final selection decisions are not made solely through automated processing producing such effects.

If this changes, we will provide the information required by applicable law.

17. IS PROVIDING PERSONAL DATA MANDATORY?

Some information is necessary for us to review an application, communicate with you, establish a business relationship, enter into or administer an agreement, issue invoices or provide the requested service.

Fields identified as mandatory in an application or other form must generally be completed for us to process that application or request.

If required information is not provided, we may be unable to process the application, respond fully to the request, enter into the relevant relationship or provide the requested service.

Optional information does not need to be provided unless you choose to provide it.

18. SENSITIVE PERSONAL DATA

PrimePressQ does not ordinarily request special categories of personal data through its general business applications.

Unless specifically requested for a lawful and clearly communicated purpose, please do not submit information concerning health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric identification data, sexual orientation or sex life through general application forms or open-text fields.

If such information is exceptionally required for a specific lawful purpose, we will determine the appropriate legal basis and provide any additional information required by law.

19. CHILDREN

PrimePressQ provides professional B2B services and our website, applications and services are not directed at children. We do not knowingly solicit personal data from children through our general business application processes.

20. COOKIES AND SIMILAR TECHNOLOGIES

Our website uses cookies and may use similar technologies.

Technologies strictly necessary for the operation, functionality or security of the website may be used without consent where permitted by applicable law.

Analytics, marketing and other non-essential technologies requiring consent will be activated only after the relevant consent has been obtained.

You can accept, reject or manage non-essential cookies through the cookie controls provided on our website and can change your preferences where supported.

Detailed information about the cookies and similar technologies actually used by PrimePressQ, including their purposes, providers and applicable duration, is provided in our separate Cookie Policy.

21. THIRD-PARTY LINKS AND WEBSITES

Our website, applications or communications may contain links to websites, publications, social media platforms or other services operated by third parties.

PrimePressQ does not control the independent privacy practices of those third parties.

If you interact directly with a third-party service, its processing of personal data is governed by its own privacy information and applicable law.

22. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy where necessary to reflect changes to our services, processing activities, technology, service providers or applicable legal requirements. The current version and effective date will be published on our website.

Where applicable law requires additional notice or consent in relation to a change, we will provide such notice or obtain such consent.

Continued use of our website does not by itself constitute consent to a new processing activity where consent is required by law.

23. COMPLAINTS

If you have a concern about our processing of your personal data, you may contact us at: legal@primepressq.com

You also have the right to lodge a complaint with the Croatian supervisory authority: Agencija za zaštitu osobnih podataka (AZOP) Croatian Personal Data Protection Agency.

You may also have the right to lodge a complaint with another competent supervisory authority under the GDPR or other applicable data protection law.

24. CONTACT

For questions concerning this Privacy Policy, your personal data or your data protection rights:

PrimePressQ d.o.o.
Gradišće 7/E
10040 Zagreb
Republic of Croatia

Email: legal@primepressq.com