This page covers spyreagency.com — the website you are reading. For personal data collected here, Spyre is the controller: we decide what is collected and why.
Spyre is a registered obrt (Croatian sole trader), entered in the Obrtni registar on 29 July 2026. Not VAT-registered at this time.
Spyre also operates AI assistants on behalf of its clients, on their websites and phone numbers. In that role Spyre is a processor, not a controller — the client business decides what happens to those conversations, and their own privacy notice governs them, not this page. See AI assistants we run for clients below.
| What | Why | Legal basis | Kept for |
|---|---|---|---|
| Demo request formName, email, business name / website | To build the free demo assistant you asked for and reply to you about it | Steps taken at your request before entering a contract (Art. 6(1)(b) GDPR) | 24 months from last contact |
| Booking a callName, email, the time you pick, anything you type in the booking form | To schedule and hold the call | Steps taken at your request before entering a contract (Art. 6(1)(b) GDPR) | 24 months from last contact |
| Site chat assistantWhatever you type into it, plus contact details if you offer them | To answer your questions and pass a lead to us | Our legitimate interest in responding to enquiries (Art. 6(1)(f) GDPR) | 12 months |
| Email correspondenceYour address and whatever you write | To hold the conversation and keep a record of what was agreed | Contract, or our legitimate interest in keeping business records | As long as needed, then per statutory retention rules |
That is the entire list. We do not run advertising trackers, we do not build profiles, and we do not sell or rent personal data to anyone — ever, for any price.
This site sets no advertising or analytics cookies, so there is no consent banner to click through. The only browser storage in use is what the chat widget needs to remember your conversation while you are on the page — strictly necessary for a feature you chose to use, which is why it does not require consent.
If we ever add analytics, this page changes first and you get asked before anything non-essential is set.
We keep the list of processors deliberately short. Each one is bound by a data-processing agreement and may only act on our instructions.
| Who | What for | Where |
|---|---|---|
| Netlify | Website hosting and the demo request form | USA — SCCs |
| Calendly | Call scheduling | USA — SCCs |
| Anthropic | The AI model behind the site chat assistant | USA — SCCs. Does not train on our data. |
| Railway | Hosting for the chat assistant backend | EU / USA — SCCs |
| Resend | Notification email delivery | USA — SCCs |
Transfers outside the EEA rest on the European Commission's Standard Contractual Clauses and, where the recipient participates, the EU–U.S. Data Privacy Framework. You can ask us for a copy of the safeguards for any specific transfer.
When you talk to a Spyre-built assistant on another company's website, WhatsApp number or phone line, that company is the controller and we are only its processor. Practically:
Under the GDPR you can ask us to:
Email spyreagency@gmail.com and we will respond within one month. There is no charge, and we do not require a particular form of words.
If you think we have handled your data badly, please tell us first — we would rather fix it. You also have the right to complain to the Croatian supervisory authority: Agencija za zaštitu osobnih podataka (AZOP), Selska cesta 136, 10000 Zagreb, azop.hr.
Access is limited to those who need it, data in transit is encrypted, sessions are isolated per user, and admin access is password-protected with failed-login alerting. No system is perfect; if a breach ever affects your data and puts you at real risk, we will tell you.
If this policy changes materially, we update the date at the top and — where we hold your address and the change matters to you — tell you directly. We do not backdate changes.