Privacy Policy
CockpitMod d.o.o. | AZLP registration: 05-030/26-2053 | Last updated: 1 August 2024
1. Data controller
CockpitMod d.o.o. (PIB: 73519284, CRPS: 4-0102578/X), with registered address at ul. Moskovska 14, 81000 Podgorica, Crna Gora, is the controller of personal data processed through the cockpitmod.org platform and related services. Our data protection contact is reachable at support@cockpitmod.org. We are registered with the Agencija za zaštitu ličnih podataka (AZLP) under registration number 05-030/26-2053.
2. Legal basis for processing
We process personal data on the following legal bases under GDPR Article 6: (a) performance of a contract, when processing is necessary to provide the subscribed Module services; (b) legitimate interest, for fraud prevention, security monitoring and product analytics; (c) legal obligation, when required by applicable tax, commercial or regulatory law; (d) consent, where explicitly obtained for marketing communications.
3. Data we collect
We collect and process the following categories of personal data:
- Account data: name, email address, company name, job title, VAT number, billing address and payment reference information provided at registration or checkout
- Usage data: CockpitMod account login events, Module configuration changes, API call logs and dashboard activity records
- Technical data: IP address, browser type and version, operating system, referral URL, pages viewed and session duration, collected via server logs
- Hotel operational data: reservation summaries, guest identification references, rate plan identifiers and occupancy figures received from the Dirs21 API to enable Module functionality. This data belongs to the Customer and is processed as a data processor on behalf of the Customer
- Communication data: the content of emails and support tickets sent to CockpitMod
4. How we use your data
Account data is used to provide access to your CockpitMod account, generate invoices, deliver support and send service notifications. We do not use account data for advertising or share it with third parties for marketing purposes. Usage and technical data is used to monitor platform performance, investigate security incidents and improve Module functionality. Hotel operational data is processed exclusively to deliver the functionality of your subscribed Modules and is not used for any other purpose.
5. Data retention
Account data is retained for the duration of your subscription plus 7 years to comply with Montenegrin commercial and tax law. Usage and technical data is retained for 12 months. Hotel operational data processed by active Modules is retained for the duration of the subscription plus 30 days, after which it is permanently deleted. Support ticket data is retained for 3 years after ticket closure.
6. Data sharing
We do not sell personal data. We share data only with: (a) infrastructure providers necessary to operate the Platform, currently operating under data processing agreements compliant with GDPR; (b) payment processing partners to facilitate subscription billing; (c) professional advisors such as legal counsel and accountants where necessary; (d) competent authorities when required by applicable law. All third-party processors are bound by contractual data protection obligations at least as protective as those required by GDPR.
7. International transfers
Our primary infrastructure is located within the European Economic Area. Where data is transferred outside the EEA, we ensure appropriate safeguards are in place including Standard Contractual Clauses approved by the European Commission.
8. Your rights
Under GDPR and the Montenegrin Law on Personal Data Protection you have the following rights with respect to your personal data: the right to access a copy of your data; the right to rectification of inaccurate data; the right to erasure ("right to be forgotten") subject to retention obligations; the right to restriction of processing; the right to data portability; the right to object to processing based on legitimate interest; the right to withdraw consent where processing is based on consent.
To exercise any of these rights, email support@cockpitmod.org with your registered email address and a description of your request. We will respond within 30 calendar days. You have the right to lodge a complaint with the AZLP (Agencija za zaštitu ličnih podataka) or with the supervisory authority in your EU member state.
9. Cookies
We use strictly necessary cookies to maintain your authenticated session in the CockpitMod account dashboard. No third-party tracking cookies or advertising cookies are set. Full details are in the Cookie Policy at cockpitmod.org/cookies.
10. Security
We implement technical and organisational measures to protect personal data including: TLS encryption in transit; AES-256 encryption at rest for sensitive credentials; access controls limiting data access to authorised personnel; regular security reviews; and incident response procedures. A summary of our security practices is available at cockpitmod.org/security.
11. Children
The CockpitMod Platform is a business-to-business service and is not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected such data, contact us immediately at support@cockpitmod.org.
12. Changes to this policy
We may update this Privacy Policy from time to time. Material changes will be notified to registered account holders by email at least 30 days before they take effect. The current version is always available at cockpitmod.org/privacy.
13. Contact
Data controller: CockpitMod d.o.o., ul. Moskovska 14, 81000 Podgorica, Crna Gora. Email: support@cockpitmod.org. Phone: +382 20 201 447. AZLP registration: 05-030/26-2053.