The data controller responsible for your personal data is:
"Zubalenok" is the brand operated by ZUBALENOK d.o.o. Where this policy says "we", "us" or "our", it refers to ZUBALENOK d.o.o. as the data controller responsible for your personal data.
This policy covers personal data we process through the Zubalenok lead questionnaire ("the quiz"), the personalised report we send you, our email communications, and the checkout and delivery of our digital programs. It does not cover third-party websites or platforms that we link to — those services have their own privacy policies, which we encourage you to read.
Under the GDPR we must have a lawful basis for every use of your data. Our uses and bases are:
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Generating and sending your personalised mini report and matched program | Performance of a service you requested / your consent — Art. 6(1)(b) & (a) |
| Sending marketing emails, offers and materials from Zubalenok | Your consent — Art. 6(1)(a) |
| Processing your order and giving you access to a purchased program | Performance of a contract — Art. 6(1)(b) |
| Keeping accounting, tax and transaction records | Legal obligation — Art. 6(1)(c) |
| Measuring quiz performance, campaign results and improving our funnel | Our legitimate interest in running and improving our business — Art. 6(1)(f) |
| Detecting fraud, abuse and securing our systems | Our legitimate interest in security — Art. 6(1)(f) |
Where we rely on legitimate interests, we have weighed those interests against your rights and freedoms. You can object to this processing at any time — see Your rights.
When you continue past the email step of the quiz, you consent to receive emails from Zubalenok — your report, educational materials, and special offers. Your consent is entirely voluntary and you can withdraw it at any time, with no effect on programs you have already purchased.
To stop receiving marketing emails you can:
Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal. We may still send you essential service messages (for example, order confirmations or access details) where you have purchased a program, as these are necessary to perform our contract with you.
Some of our providers are based outside the European Economic Area, including in the United States. Where personal data is transferred outside the EEA, we ensure an appropriate safeguard is in place — typically the European Commission's Standard Contractual Clauses, an adequacy decision, or an equivalent approved mechanism — so that your data continues to receive a level of protection essentially equivalent to that within the EU. You can request more detail on these safeguards using the contact details below.
We keep personal data only as long as necessary for the purpose it was collected for:
Under the GDPR you have the following rights regarding your personal data:
To exercise any of these rights, email Zubalyevhen@gmail.com. We will respond within one month, as required by the GDPR. Exercising your rights is free of charge, and we may ask you to verify your identity before we act on a request.
We apply appropriate technical and organisational measures to protect your personal data against loss, misuse and unauthorised access — including encryption of data in transit, access controls limiting who can view personal data, and the use of reputable processors that maintain recognised security standards. No method of transmission or storage is completely secure, but we work to protect your data and to detect and address any incident promptly. If a personal data breach is likely to result in a high risk to your rights, we will notify you and the relevant supervisory authority as required by law.
The quiz and our programs are intended for adults. They are not directed at children, and we do not knowingly collect personal data from anyone under the age of 16. If you believe a child has provided us with personal data, please contact us and we will delete it.
The quiz matches you to a recommended program based on the answers you give. This is a simple, rules-based recommendation designed to help you choose — it is not a decision that produces legal or similarly significant effects on you, and you are always free to choose a different program or none at all. We do not carry out profiling that has a legal or similarly significant effect within the meaning of GDPR Article 22.
We may update this Privacy Policy from time to time to reflect changes in our practices or for legal reasons. The "Last updated" date at the top of this page shows when it was last revised. If we make a material change, we will take reasonable steps to inform you. We encourage you to review this page periodically.
For any privacy question or to exercise your rights, contact us at:
ZUBALENOK d.o.o.
Radnička cesta 52, 10000 Zagreb, Croatia
If you are not satisfied with how we have handled your data, you have the right to lodge a complaint with a data protection supervisory authority. In Croatia this is the Croatian Personal Data Protection Agency (Agencija za zaštitu osobnih podataka — AZOP), Selska cesta 136, 10000 Zagreb — azop.hr. You may also contact the supervisory authority in your own EU country of residence.