Privacy Policy – adriom.me

Version: 09.10.2026

This Privacy Policy explains how ADRIOM DOO processes personal data when you visit the website adriom.me, contact us, or use our real estate brokerage services. We process personal data in accordance with:

  • Regulation (EU) 2016/679 (General Data Protection Regulation, "GDPR"), which applies to us under Art. 3(2) GDPR insofar as we offer our services to persons in the European Union or monitor their behaviour there;
  • the Montenegrin Law on Personal Data Protection (Zakon o zaštiti podataka o ličnosti, "Službeni list Crne Gore", Nos. 79/08, 70/09, 44/12, 22/17 and 77/24) and, from its date of application on 19 March 2027, the new Law on Personal Data Protection ("Službeni list Crne Gore", No. 133/2026);
  • the Serbian Law on Personal Data Protection (Zakon o zaštiti podataka o ličnosti, "Službeni glasnik RS", No. 87/2018, "ZZPL"), insofar as we offer our services to persons in the Republic of Serbia.

Where this Policy refers to provisions of the GDPR, the corresponding provisions of the Montenegrin and Serbian laws apply accordingly to the extent those laws are applicable.

1. Controller

The controller responsible for the processing of personal data is:

ADRIOM DOO
Zubački put b.b., Beljiši
85000 Bar, Montenegro
Tax identification number (PIB): 03760057
Registration number (MB): 5-1314606/001
Represented by the Director: Igor Maier
Phone: +382 68 752 559
E-mail: info@adriom.me

You can reach us at the above contact details with any questions about data protection and to exercise your rights.

2. Representative in the European Union (Art. 27 GDPR)

As our registered office is located outside the European Union, we are required, in principle, to designate a representative in the Union pursuant to Art. 27 GDPR.

Representative:
Prime Realty, owner: Igor Maier (sole proprietorship)
Panoramastraße 13
73765 Neuhausen, Germany
Phone: +49 711 252 55 610
E-mail: info@prime-realty.de

3. Categories of personal data and their sources

We process the following categories of personal data:

  • Identification data: first and last name, title, where applicable date of birth and nationality;
  • Contact data: e-mail address, telephone number, messenger identifier (WhatsApp/Viber), postal address;
  • Enquiry data: content of your enquiry, properties of interest, search criteria (location, size, budget, time frame), preferred language and contact channel;
  • Contract data: data required to prepare and perform a brokerage, reservation, purchase or rental contract, including details of the property, price and payment terms;
  • AML/KYC data: data we are legally obliged to collect to prevent money laundering and terrorist financing, in particular identity document data and copies, residential address, tax number, information on the beneficial owner, the origin of funds and assets, and status as a politically exposed person;
  • Communication data: content and metadata of e-mails, telephone calls (no recording), and messenger messages;
  • Chat data: the content of your conversation with the AI chatbot on our website and the details you provide there (e.g. name, telephone number, e-mail address, budget, property of interest) (see Section 4a);
  • Source data (campaign attribution): campaign parameters (UTM parameters), click identifiers of advertising platforms (e.g. fbclid, gclid), referring website and landing page (see Section 10b);
  • Technical data: IP address, date and time of access, browser type and version, operating system, referrer URL, and pages accessed (server log files);
  • Cookie and tracking data: where you have given consent (see Section 10).

We obtain this data from the following sources:

  • Website adriom.me: technical data generated automatically when you visit the website;
  • Contact form on the website: the data you enter in the form;
  • AI chatbot on the website: the data you enter in the chat (see Section 4a);
  • E-mail and telephone: the data you provide when you contact us;
  • WhatsApp and Viber: the data you provide when you communicate with us through these messengers. Please note that these services are operated by WhatsApp Ireland Limited and Viber Media S.à r.l., respectively, which process data under their own terms and privacy policies;
  • Meta lead forms (Facebook/Instagram): the data you enter in a lead form on Facebook or Instagram (see Section 4);
  • Third parties: to the extent necessary for a specific transaction, data from sellers, developers, partner agencies, notaries, and from public registers (e.g. real estate cadastre, business register).

4. Lead forms on Facebook and Instagram

We use lead forms (Lead Ads) on Facebook and Instagram. If you fill in such a form, the data you enter (e.g. name, e-mail address, telephone number, answers to questions in the form) is collected by Meta Platforms Ireland Limited ("Meta") and transmitted to us.

For the collection of data via the lead form and its transmission to us, we and Meta are jointly responsible within the meaning of Art. 26 GDPR. The essential content of the arrangement between us and Meta is set out in the Controller Addendum, available at: https://www.facebook.com/legal/controller_addendum. Under that arrangement, Meta is primarily responsible for providing information on its own processing and for enabling the exercise of data subject rights in relation to data processed by Meta. You may nevertheless exercise your rights against us as well as against Meta.

Information on how Meta processes data can be found in Meta's privacy policy: https://www.facebook.com/privacy/policy.

After the data has been transmitted to us, we are the sole controller for its further processing. We process it for the purposes and on the legal bases described in Section 5, in particular to handle your enquiry (Art. 6(1)(b) GDPR). If you have given your consent in the lead form to receive our e-mail newsletter, Section 6 applies.

4a. AI chatbot on the website

Our website offers a chat assistant that answers your questions about properties and our services automatically using artificial intelligence (AI). In the chat, you are initially answered not by a member of our staff but by an automated system; its answers may be incomplete or inaccurate and are not binding. Our staff are notified of chat conversations and may take over a conversation; in that case, a member of our staff will answer you.

Data processed. We process the content of the conversation and the details you provide in the chat, in particular your name, telephone number, e-mail address, budget, search criteria and the property you are interested in, as well as the selected language, the address (URL) of the page on which you use the chat, a session identifier and technical data (e.g. IP address). Please do not enter special categories of personal data (e.g. health data), identity document data or bank details in the chat.

Purpose and legal basis. The chat serves to answer your enquiry and, if you provide your contact details there, to record your enquiry (lead) in our CRM system so that we can contact you. The legal basis is Art. 6(1)(b) GDPR (handling your enquiry and pre-contractual measures taken at your request). The chat history is stored in our database (Google Cloud Firestore, see Section 7) and together with your enquiry.

AI provider. To generate the answers, we use a language model provided by OpenAI ("Chat Completions" programming interface); the provider is OpenAI, L.L.C., USA. Access to OpenAI is provided via our IT service provider AI711, owner Igor Maier (sole proprietorship), Panoramastraße 13, 73765 Neuhausen, Germany, which manages for us the technical accounts through which we obtain this service (see Section 7). For this purpose, the following is transmitted to OpenAI: your current question, up to 20 previous messages of the conversation, a summary of the conversation so far, the selected language, the address (URL) of the page visited, details of the property concerned and your search criteria, as well as any information you write in your messages, including your name and telephone number if you provide them in the chat. AI711 acts as our processor and OpenAI as a sub-processor. OpenAI processes the data in the USA; the data transfer is based on Standard Contractual Clauses or the EU–U.S. Data Privacy Framework in accordance with the OpenAI Data Processing Addendum (see Sections 7 and 8).

Storage in your browser. For the chat to work, we store the chat history and a session identifier in your browser's local storage. This is strictly necessary for the chat you use (see Section 10). You can delete this data at any time in your browser settings.

No automated decisions. The chatbot does not take any decisions that produce legal effects concerning you or similarly significantly affect you (Art. 22 GDPR). Decisions on your enquiry and any cooperation are made exclusively by our staff.

5. Purposes and legal bases of processing

We process your personal data for the following purposes and on the following legal bases under Art. 6(1) GDPR:

a) Handling enquiries and preparing and performing contracts (Art. 6(1)(b) GDPR)
We process your data to answer your enquiry, to provide you with property offers, to arrange viewings, and to prepare, conclude and perform brokerage, reservation, purchase or rental contracts. This also covers pre-contractual measures taken at your request and answering your questions via the AI chatbot (Section 4a).

b) E-mail newsletter and marketing communications on the basis of consent (Art. 6(1)(a) GDPR)
We send newsletters and offers by e-mail only if you have given your consent (see Section 6). The same applies to analytics and marketing cookies, the Meta Conversions API and the storage of campaign parameters in your browser (see Sections 10 and 10b).

c) Compliance with legal obligations (Art. 6(1)(c) GDPR)
As a real estate agency, we are an obliged entity under the Montenegrin Law on the Prevention of Money Laundering and Terrorist Financing (Zakon o sprečavanju pranja novca i finansiranja terorizma, "Službeni list Crne Gore", Nos. 110/23, 65/24, 24/25, 41/26 and 59/26). We are therefore obliged to identify and verify our clients and their beneficial owners (KYC), to carry out customer due diligence, to keep records, and, where required by law, to report to the competent authorities. In addition, we process data to comply with tax and accounting obligations. Insofar as these obligations arise from the law of a third country and are not recognised as a legal obligation within the meaning of Art. 6(3) GDPR, the processing is additionally based on our legitimate interest in complying with the legal requirements applicable to us at our registered office (Art. 6(1)(f) GDPR).

d) Legitimate interests (Art. 6(1)(f) GDPR)
We process data on the basis of our legitimate interests, in particular:
- to ensure the secure and stable operation of the website and to detect and defend against attacks (server log files);
- for internal administration of client relationships and customer care in our CRM system;
- to evaluate through which campaigns and channels enquiries reach us (campaign attribution, see Section 10b);
- to present the website in a consistent and functional manner, including map display and property images loaded from third-party servers (see Section 10a);
- to assert, exercise or defend legal claims;
- to maintain a suppression list following an unsubscribe or objection (see Section 6);
- for direct marketing to existing clients, to the extent permitted by law.

Where we rely on legitimate interests, we have weighed our interests against your interests and fundamental rights and freedoms. You may object to such processing at any time (see Section 11).

6. E-mail newsletter

We send newsletters and other promotional e-mails only with your express consent. You can give your consent, for example, via the website, a Meta lead form, or in writing.

You can withdraw your consent at any time with effect for the future, free of charge, by:
- clicking the unsubscribe link contained in every newsletter, or
- sending an e-mail to info@adriom.me.

Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

After you unsubscribe, we add your e-mail address to a suppression list (stop list). This list is used solely to ensure that you no longer receive any newsletters from us and to be able to demonstrate compliance with your request. The legal basis is our legitimate interest in complying with your objection and withdrawal on a lasting basis (Art. 6(1)(f) GDPR) and our duty of accountability (Art. 5(2) GDPR).

E-mails are sent via the service providers Resend, Inc. (USA) and Sendinblue SAS (Brevo, France) (see Sections 7 and 8).

7. Recipients and processors

Within our company, only those persons who need your data to perform the purposes described above have access to it.

We use the following service providers who process data on our behalf as processors (Art. 28 GDPR) on the basis of data processing agreements:

Service provider Purpose Location
Resend, Inc. Sending of e-mails (including newsletters) USA
Microsoft Ireland Operations Limited Microsoft 365 / SharePoint: CRM (including storage of enquiries from website forms and callback requests), document storage and e-mail Ireland / EU; access from the USA cannot be excluded
Google Cloud – Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland Server functions of the website (Cloud Functions), in particular receiving and forwarding enquiries from forms and the chat, operating the AI chatbot, the property catalogue and translation of website texts; all server functions run in the us-central1 region (USA) USA (us-central1 region, see Section 8)
Google Firebase – Google Cloud EMEA Limited (as above) Hosting of the website adriom.me; static content is delivered via a global content delivery network (CDN); Cloud Firestore database (including property data and chat histories); storage of images (Cloud Storage); push notifications to our staff (Firebase Cloud Messaging) CDN: servers distributed worldwide; Cloud Firestore: multi-region eur3 (EU: Belgium/Netherlands); Cloud Storage: us-central1 region (USA), see Section 8
AI711, owner Igor Maier (sole proprietorship), Panoramastraße 13, 73765 Neuhausen, Germany IT and advertising services for ADRIOM DOO (technical operation of the website, management of advertising campaigns); holder of the technical accounts (including Google Cloud/Firebase, Google Analytics, advertising accounts, OpenAI) through which the services listed in this table and in Section 10 are obtained Germany
OpenAI, L.L.C., USA (via AI711's account) Operating the AI chatbot and generating its answers (Section 4a); machine translation of website and property texts USA; data transfer on the basis of SCC/DPF in accordance with the OpenAI Data Processing Addendum (see Section 8)
Google Sheets (Google Workspace) – Google Cloud EMEA Limited (as above) Additional storage (copy) of enquiries (leads) from website forms in spreadsheets Google data centres in the EU and worldwide; access from the USA cannot be excluded (see Section 8)
Sendinblue SAS (Brevo), 17 rue Salneuve, 75017 Paris, France Sending of e-mails (including newsletters) EU (France, Germany, Belgium)

In addition, where necessary for the specific purpose, we disclose personal data to the following recipients, who act as independent controllers:

  • sellers, landlords and developers of the properties concerned, to arrange viewings and prepare contracts (Art. 6(1)(b) GDPR);
  • partner agencies, where a property is brokered jointly with another agency (Art. 6(1)(b) or (f) GDPR);
  • notaries and attorneys, for the drafting, certification and execution of contracts (Art. 6(1)(b) or (c) GDPR);
  • banks and payment service providers, for the execution of payments (Art. 6(1)(b) or (c) GDPR);
  • public authorities, in particular the real estate cadastre, tax authorities and the financial intelligence unit (FIU) under the AML law, where we are legally obliged to do so (Art. 6(1)(c) GDPR);
  • tax advisors, accountants and auditors, where required to fulfil our legal obligations (Art. 6(1)(c) or (f) GDPR).

We do not sell your personal data.

8. Transfers to third countries

Montenegro. Our registered office and our business operations are located in Montenegro. Montenegro is a third country within the meaning of the GDPR for which the European Commission has not adopted an adequacy decision (Art. 45 GDPR). Your data is therefore processed by us in a country where the level of data protection has not been formally recognised by the European Union as equivalent. Insofar as the processing of your data in Montenegro constitutes a transfer to a third country, it is based on Art. 49(1)(b) GDPR (transfer necessary for the performance of a contract or the implementation of pre-contractual measures taken at your request), and, where applicable, on Art. 49(1)(c) GDPR (contract concluded in your interest) or Art. 49(1)(e) GDPR (establishment, exercise or defence of legal claims). The transfer is limited to what is necessary for the respective purpose. We apply appropriate technical and organisational measures to protect your data.

USA. Where data is transferred to service providers in the USA (in particular Resend, Inc., Google in connection with our website's server functions and image storage (Cloud Storage), and Google and Meta in connection with the services described in Section 10) or may be accessed from the USA (Microsoft, Google), the transfer is based on the European Commission's adequacy decision for the EU–U.S. Data Privacy Framework (Art. 45 GDPR), insofar as the recipient is certified under that framework, and otherwise on the Standard Contractual Clauses adopted by the European Commission (Art. 46(2)(c) GDPR). You may request a copy of the relevant safeguards using the contact details in Section 1.

Google Cloud: server functions and image storage in the USA; database in the EU. All server functions of our website (Google Cloud Functions), in particular the receipt of enquiries from forms, the AI chatbot, the property catalogue and the translation of website texts, run in the Google Cloud region us-central1 (USA); images are stored in Cloud Storage in the us-central1 region (USA). The data you enter in forms or in the chat, as well as technical data, in particular your IP address, are therefore processed in the USA when the server functions are invoked. Our database (Cloud Firestore), which stores, among other things, property data and chat histories, is located in the multi-region eur3 (Belgium and the Netherlands) within the European Union. Transfers to the USA are based on the EU–U.S. Data Privacy Framework, under which Google LLC is certified (Art. 45 GDPR), and additionally on the Standard Contractual Clauses incorporated into Google Cloud's data processing terms (Art. 46(2)(c) GDPR).

OpenAI. For the AI chatbot and the machine translation of texts, we use services of OpenAI, L.L.C. (USA). The data transfer to the USA is based on Standard Contractual Clauses (Art. 46(2)(c) GDPR) or the EU–U.S. Data Privacy Framework (Art. 45 GDPR), in each case in accordance with the OpenAI Data Processing Addendum.

United Kingdom. When map tiles are loaded, your IP address is transmitted to the OpenStreetMap Foundation, which is based in the United Kingdom (see Section 10a). An adequacy decision of the European Commission exists for the United Kingdom (Art. 45 GDPR; Implementing Decision (EU) 2021/1772, as extended by Implementing Decision (EU) 2025/2574).

Other countries. If, in the course of a transaction, data must be transferred to recipients in other third countries (e.g. a buyer's bank abroad), this is done only where an adequacy decision or appropriate safeguards exist, or where an exception under Art. 49 GDPR applies, in particular Art. 49(1)(b) GDPR.

9. Retention periods

We store personal data only for as long as necessary for the respective purpose or as required by law:

  • Enquiries and leads (without a concluded contract): 24 months after the last contact, after which they are deleted or anonymised, unless you have consented to longer storage or another legal basis applies.
  • Contracts and related correspondence: for the duration of the contractual relationship and thereafter until the expiry of the statutory limitation periods for claims.
  • Accounting and tax records: for the retention periods prescribed by applicable accounting and tax law.
  • AML/KYC data: for the retention period prescribed by the Montenegrin Law on the Prevention of Money Laundering and Terrorist Financing.
  • Newsletter consent: until withdrawal; proof of consent is retained for as long as we may be required to demonstrate it.
  • Suppression list: for as long as necessary to ensure that no further advertising e-mails are sent to you.
  • Server log files: for a short period, generally no longer than necessary to ensure security, unless needed to investigate a specific incident.
  • Chat histories: where they form part of your enquiry, as for enquiries and leads; chat histories that do not result in an enquiry are deleted from our database (Cloud Firestore) no later than 90 days after the last message.
  • Source data (campaign attribution): as part of your enquiry, as for enquiries and leads; in your browser's local storage until you delete it in your browser settings.
  • Cookies: _ga and _ga_S1DJPGHGZ3 up to 13 months, _fbp up to 90 days (see Section 10).

Once the purpose ceases to apply and the retention periods have expired, the data is deleted or anonymised.

10. Cookies and similar technologies

Our website uses cookies and similar technologies (e.g. the browser's local storage, pixels and scripts). On your first visit, we show you a cookie banner in which you can consent to or refuse the use of analytics and marketing technologies. Both options are equivalent. Your choice is stored in your browser's local storage (cookieConsent); no cookie is set for this purpose.

Technically necessary technologies. Without your consent, we only store information in your browser's local storage that is strictly necessary for operating the website or for a service you have expressly requested:
- language – selected language;
- cookieConsent – your choice in the cookie banner;
- adriom_chatbot_history_v3, adriom_chatbot_session_id_v1 – chat history and session identifier of the AI chatbot (Section 4a);
- firestore_* – technical keys of the database software (Google Firebase) used to load property data.

The legal basis is our legitimate interest in a functioning website (Art. 6(1)(f) GDPR) or the provision of the service you use (Art. 6(1)(b) GDPR). Access to your device is governed by the national rules implementing Art. 5(3) of Directive 2002/58/EC (ePrivacy Directive), e.g. Section 25(2) no. 2 of the German TDDDG, which do not require consent for strictly necessary storage.

Analytics and marketing technologies – only with your consent. The following services are only loaded and activated after you have given your consent in the cookie banner. Before that, and after you decline, the related scripts are not loaded, no cookies are set and no data is transmitted to the providers. The legal basis is your consent (Art. 6(1)(a) GDPR and the national rules implementing Art. 5(3) of the ePrivacy Directive, e.g. Section 25(1) TDDDG).

  • Google Analytics 4 (measurement ID G-S1DJPGHGZ3). Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Purpose: statistical analysis of the use of our website (e.g. pages visited, time spent, source of the visit, device, approximate location). Cookies: _ga, _ga_S1DJPGHGZ3, storage period up to 13 months. Data may be transferred to Google LLC in the USA (see Section 8).
  • Meta Pixel (pixel ID 1406479144320747). Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, Ireland. Purpose: measuring the effectiveness of our advertising on Facebook and Instagram, showing advertising to visitors of our website (retargeting) and optimising our campaigns. Events recorded: page views (PageView) and views of property pages (ViewContent). Cookie: _fbp, storage period up to 90 days. Data may be transferred to Meta Platforms, Inc. in the USA (see Section 8).
  • Meta Conversions API (where activated by us). If you have given your consent and send us an enquiry via the website, our server may inform Meta directly of that enquiry ("Lead" event) and, where applicable, of its further processing status ("QualifiedLead", "Converted", "Unqualified" events). Only your e-mail address and telephone number in hashed form (SHA-256), where applicable Meta's lead identifier, and the time of the event are transmitted; IP address, browser identifier, cookie identifiers and page views are not transmitted via the Conversions API. Without your consent, no data is transmitted. Purpose: measuring the effectiveness of our advertising and optimising our campaigns.
  • Source data (campaign attribution) in local storage – see Section 10b.

For the collection of data using the Meta Pixel and the Conversions API and its transmission to Meta, we and Meta are joint controllers (Art. 26 GDPR); the subsequent processing is the sole responsibility of Meta. The arrangement is available at https://www.facebook.com/legal/controller_addendum, and information on how Meta processes data at https://www.facebook.com/privacy/policy.

Withdrawal. You can withdraw or change your consent at any time with effect for the future by clicking the "Cookie settings" link in the footer of every page. Withdrawing consent is as easy as giving it. You can also delete or block cookies and local storage in your browser settings; this may, however, restrict the functionality of the website.

10a. Embedded third-party content and services

To display our website, we load certain content from third-party servers. For technical reasons, your IP address (together with browser information and the page accessed) is transmitted to the respective provider; without this transmission the content could not be delivered to your browser. These providers process the data under their own responsibility.

  • OpenStreetMap (map tiles from tile.openstreetmap.org; OpenStreetMap Foundation, United Kingdom), to show the location of a property on property pages. The map tiles are loaded irrespective of your choice in the cookie banner. For the transfer to the United Kingdom, see Section 8.
  • Property images from third-party servers: some photos of properties and blog posts are loaded directly from the servers of property portals, partner portals, developers and image databases (currently, e.g., www.realitica.com, cdn.nadjidom.com, m2.spitogatos.gr, gemstone-residence.com, images.unsplash.com).

The legal basis is our legitimate interest in a consistent, attractive and functional presentation of our website and our property offering (Art. 6(1)(f) GDPR). We load fonts and the Leaflet map library from our own hosting (see Section 7); no data is transmitted to further third parties in this process. You may object to processing based on legitimate interests (see Section 11).

10b. Source of enquiries (campaign attribution)

If you reach our website via a link containing campaign parameters (UTM parameters, e.g. utm_source, utm_campaign), via an advertisement with a click identifier (e.g. fbclid from Meta, gclid from Google) or from another website, we store this information, together with the referring website and the landing page, in your browser's local storage (adriom_attribution_first_v1, adriom_attribution_last_v1, lastExternalReferrer). If you then send us an enquiry (contact form or chatbot), this information is transmitted to us together with your enquiry and stored in our CRM system.

Storage in your browser only takes place if you have given your consent in the cookie banner (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). Storing this information together with your enquiry is based on our legitimate interest in evaluating the effectiveness of our advertising and contact channels (Art. 6(1)(f) GDPR).

11. Your rights

Under the GDPR, you have the following rights:

  • Right of access (Art. 15 GDPR): you may request information as to whether and which personal data we process about you, and receive a copy.
  • Right to rectification (Art. 16 GDPR): you may request the correction of inaccurate data or the completion of incomplete data.
  • Right to erasure (Art. 17 GDPR): you may request the deletion of your data, unless we are obliged to retain it (e.g. under AML or tax law) or another exception applies.
  • Right to restriction of processing (Art. 18 GDPR): under certain conditions, you may request that we restrict processing.
  • Right to data portability (Art. 20 GDPR): you may receive data you have provided to us on the basis of consent or a contract in a structured, commonly used and machine-readable format, or have it transmitted to another controller.
  • Right to withdraw consent (Art. 7(3) GDPR): you may withdraw any consent given at any time with effect for the future.

Right to object (Art. 21 GDPR)
You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data based on Art. 6(1)(f) GDPR. We will then no longer process the data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.
You may object at any time to the processing of your data for direct marketing purposes, without giving reasons. In that case, we will no longer process your data for such purposes. An informal message to info@adriom.me is sufficient.

Right to lodge a complaint. Without prejudice to any other remedy, you have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR), in particular in the EU Member State of your habitual residence, place of work, or place of the alleged infringement. You may also lodge a complaint with:

  • the Montenegrin supervisory authority: Agencija za zaštitu ličnih podataka i slobodan pristup informacijama (Agency for Personal Data Protection and Free Access to Information), Bulevar revolucije 11, Podgorica, Montenegro, e-mail: azlp@azlp.me, www.azlp.me;
  • for data subjects in the Republic of Serbia: Poverenik za informacije od javnog značaja i zaštitu podataka o ličnosti (Commissioner for Information of Public Importance and Personal Data Protection), Bulevar kralja Aleksandra 15, 11120 Belgrade, Serbia, e-mail: office@poverenik.rs, www.poverenik.rs.

To exercise your rights, simply contact us using the details in Section 1. We may ask you to verify your identity in order to protect your data from unauthorised access.

12. Obligation to provide data; no automated decision-making

You are under no statutory or contractual obligation to provide us with personal data. However, without the data necessary to process your enquiry (in particular your name and a contact channel), we cannot respond to it. Data required for the conclusion and performance of a contract is necessary for the conclusion of the contract.

Where we are obliged under the AML law to identify you and verify your identity, you are legally required to provide the necessary information and documents. If you do not provide them, we are not permitted to establish or continue the business relationship or carry out the transaction.

We do not use automated decision-making, including profiling, within the meaning of Art. 22 GDPR; this also applies to the AI chatbot (Section 4a).

13. Changes to this Privacy Policy

We may amend this Privacy Policy if this becomes necessary due to legal changes, changes in our services, or changes in the processing of data. The current version is always available on our website adriom.me. Where a change requires your consent, we will request it separately.

Version: 09.10.2026