Privacy

Privacy Policy

Last updated: June 4, 2026

This Privacy Policy governs the way in which the Service Provider – the company that operates and publicly distributes the TOGO digital platform (the “Platform”) – collects, uses, processes and protects the personal data of end users and visitors (the “Users”), in accordance with the Law on Personal Data Protection of Bosnia and Herzegovina and other applicable regulations.

TOGO is a centralized digital platform for hospitality, events, promotion and the digital presentation of hospitality venues, events, offers and related services. By using the platform, the User accepts this Privacy Policy as an integral part of their contractual relationship with the Service Provider.

For the purposes of this Policy: (i) the “User” means a person who accesses and uses the Platform to view content; (ii) the “Business Partner” means a hospitality venue, event organizer or other legal/natural person that uses the Platform to publish content and promote its services; (iii) the “Service Provider” means the entity that operates the Platform.

01

Personal data we collect

1.1. Data provided directly by the User

When concluding the Agreement on the use of the application and the provision of maintenance services, as well as during use of the platform, Users do not create user accounts on the Platform, and the Service Provider does not collect identifying data of Users for the purpose of registration or creation of user profiles. However, the Platform may process certain technical data necessary for the functioning of the system, and may also collect the following personal data of the account holder when creating an account for a hospitality provider or event organizer (the “Business Partners”):

  • First and last name of the authorized representative of the Business Partner
  • Contact details: email address, phone number, business address

1.2. Data collected automatically

During use of the platform and application, we automatically collect certain technical data, including:

  • IP address and device identifiers
  • Data on access and use of the platform (date, time, session duration)
  • Data on views, clicks and interactions within the application
  • Technical information about the device and operating system
  • Location data, where such functionality is enabled

1.3. Data collected from third parties

In certain cases we may collect data from third parties, such as payment processors, analytics providers or partner platforms, solely to the extent necessary to provide the contracted service.

1.4. Business Partners that provide their services through the Platform independently determine the purpose and means of processing the personal data they collect from end users via reservations, inquiries, applications or other forms of communication. In that respect, the Business Partner acts as a separate data controller and is solely responsible for the lawfulness of such processing.

02

Purpose and legal basis of processing

We process personal data solely for the following purposes and on the following legal bases:

2.1. Performance of the contract

Data processing is necessary for the conclusion and performance of the Agreement on the use of the TOGO digital platform, including:

  • Creating and managing a user account
  • Activating and providing the contracted service packages (Basic, Gold, Premium)
  • Initial entry of User data onto the platform

2.2. Legitimate interest of the Service Provider

We process certain data on the basis of legitimate interest, including:

  • Improving the functionality, stability and security of the platform
  • Preventing abuse, fraud and unauthorized access

2.3. Compliance with legal obligations

In certain cases we process data to comply with legal obligations applicable to the Service Provider, including accounting, tax and regulatory requirements.

2.4. Consent

For certain types of processing (e.g. sending marketing email campaigns) we request the User’s explicit consent. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out beforehand.

03

Sharing and disclosure of data

The Service Provider does not sell, rent or disclose Users’ personal data to third parties, except in the following cases:

3.1. Service providers and business partners

We may share data with carefully selected third parties that help us deliver the service, including:

  • Financial institutions for transaction processing
  • Data storage and cloud infrastructure providers
  • Analytics services for tracking platform usage
  • Marketing and communication platforms

All service providers are bound by a confidentiality agreement and may use the data solely for the purpose for which access was granted.

3.2. Legal obligations

We may disclose data to competent authorities where legally required to do so, including court orders, requests from regulatory bodies, or to protect legally protected rights and interests.

3.3. Business transfers

In the event of a merger, acquisition, reorganization or liquidation, data may be transferred to a new entity that assumes our obligations, with notice to the User.

3.4. Public access via the platform

Content that a User publishes on the platform (e.g. a venue profile, photos, menu, events, daily offers) is available to end users of the platform in line with the purpose of the TOGO digital platform. The User is responsible for the content they publish and holds all necessary rights for its publication.

04

Cookies and tracking technologies

The TOGO platform uses cookies and similar technologies to ensure proper functioning, analyze usage and personalize the experience. Cookies may be:

  • Essential – necessary for the basic functioning of the platform and cannot be disabled
  • Analytical – help us understand how the platform is used (e.g. Google Analytics)
  • Marketing – used for targeted advertising and promotional campaigns within the platform

For cookies that are not essential to the functioning of the Platform, the User will, where necessary, be able to give or withhold consent through a cookie management tool. The User can manage cookie settings through their browser or device. Disabling certain cookies may affect the functionality of the platform.

05

Data retention and deletion

We retain personal data only for as long as necessary to fulfil the purpose for which it was collected or as required by applicable laws.

5.1. Active user account

For the duration of the Agreement on the use of the TOGO digital platform, the user profile, data, content, menus, photos, reservations and all other User data are actively stored in the system and accessible to the User.

5.2. Period after termination of the contract

Upon termination of the contract, deactivation of the user account or cessation of use of the service, User data and content will not be permanently deleted immediately, but will be stored in an inactive status (“soft delete”) for a period of 6 (six) months from the date the service ends.

During that period, the User has the right to request reactivation of the account and access to the data, provided that all outstanding obligations towards the Service Provider have been settled.

5.3. Permanent deletion

After the 6 (six) month period expires, the Service Provider may permanently delete the data, except for data it is obliged to retain by law, without further notice. After permanent deletion, the Service Provider bears no responsibility for data recovery or for any consequences arising from its removal.

5.4. Backups

The Service Provider performs data backups and technical maintenance of the system in accordance with its technical capabilities and the platform’s security standards, and cannot guarantee complete protection against all possible risks beyond its control.

06

Data security

The Service Provider applies appropriate technical and organizational measures to protect personal data from unauthorized access, disclosure, alteration or destruction, including:

  • Access control for user accounts and databases
  • Regular security checks and system upgrades
  • Internal procedures for managing security incidents

The User and the Business Partner are responsible for safeguarding the security of their access credentials, including username and password, and bear responsibility for all activities carried out through their account. If unauthorized access is suspected, the User must notify the Service Provider immediately.

The Service Provider reserves the right to temporarily freeze or restrict access to a user account in the event of suspected unauthorized use, a security incident, or to protect the integrity of the system.

The Platform is not intended for persons under 18 years of age, and the Service Provider does not knowingly collect their data.

07

Your rights regarding personal data

In accordance with applicable personal data protection regulations, the User has the following rights:

7.1. Right of access

The User has the right to request confirmation as to whether the Service Provider processes their personal data, as well as access to that data, including information on the categories of data, the purposes of processing and the recipients to whom the data is disclosed.

7.2. Right to rectification

The User has the right to request the rectification of inaccurate or incomplete personal data relating to them, without undue delay.

7.3. Right to erasure

The User has the right to request the erasure of their personal data in the cases provided for by law, taking into account statutory retention periods and contractual obligations.

7.4. Right to restriction of processing

The User has the right to request the restriction of processing of personal data in certain circumstances, e.g. while a complaint about the accuracy of the data is being resolved.

7.5. Right to object

The User has the right to object to the processing of personal data carried out on the basis of legitimate interest or for direct marketing purposes. Upon receiving an objection, the Service Provider will stop processing the data unless there are legitimate grounds that override the User’s interests.

7.6. Right to data portability

To the extent technically feasible and legally applicable, the User has the right to receive their personal data in a structured, commonly used and machine-readable format.

7.7. Withdrawal of consent

Where data is processed on the basis of consent, the User has the right to withdraw consent at any time without affecting the lawfulness of processing carried out on the basis of consent before its withdrawal.

7.8. Right to lodge a complaint with the Agency

The User has the right to lodge a complaint with the Personal Data Protection Agency of Bosnia and Herzegovina, DubrovaÄŤka 6, Sarajevo 71000, if they consider that the processing of their personal data is not in accordance with applicable regulations.

Requests to exercise the rights listed above can be submitted via the contact details provided in the “Contact and complaints” section of this Policy.

08

Changes to this Privacy Policy

The Service Provider reserves the right to amend this Privacy Policy, in particular in the event of changes to applicable regulations, business processes, technical solutions or Platform functionality. All changes will be published on the Platform and take effect on the date of publication, unless otherwise indicated.

In the event of significant changes that may affect the way personal data is processed or the rights of Users and Business Partners, the Service Provider may additionally notify users through available communication channels, including email, in-Platform notifications or other available means of communication.

Continued use of the platform after the amended Privacy Policy takes effect is considered acceptance of the changes. We recommend that Users periodically review this Policy to stay informed of any changes.

09

Contact and complaints

For any questions, requests or complaints regarding the processing of personal data, the User may contact the Service Provider via the following channels:

The Service Provider will respond to every request within a reasonable time in accordance with applicable regulations.

10

Final provisions

This Privacy Policy applies to the processing of personal data within the use of the TOGO platform and is an integral part of the Agreement on the use of the application and the provision of maintenance services.

If any provision of this Policy becomes void or unenforceable, this does not affect the validity of the remaining provisions.

Disputes arising in connection with this Privacy Policy are governed by the provisions of the Agreement on the use of the digital platform and the provision of maintenance services, and the Municipal Court in Sarajevo has jurisdiction.

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