Legal

Privacy Policy

AGROO · Koper, Slovenia · Last updated: May 2026

1. Who We Are

This Privacy Policy describes how AGROO ("we", "us", or "our"), located in Koper, Slovenia, collects, uses, and protects your personal data when you visit our website, interact with us, or receive commercial communications from us.

We are committed to protecting your privacy and handling your data in accordance with the EU General Data Protection Regulation (GDPR) and applicable Slovenian law.

AGROO

Koper, Slovenia · EU

Email: info@agroo.si

Website: agroo.si

AGROO is the data controller responsible for your personal data collected through this website and through our commercial outreach activities.

2. Data We Collect

2a. Data you provide directly

2b. Data we collect automatically

2c. Data collected through commercial outreach (B2B)

As part of our business activities, AGROO proactively identifies and contacts companies that may benefit from our EU market-entry services. In this context we may process:

Legal basis for B2B outreach: We process business contact data under Legitimate Interest (Article 6(1)(f) GDPR). We only contact companies where there is a genuine and relevant business reason — specifically, manufacturers or buyers for whom EU market-entry services are directly relevant. Every commercial email includes an unsubscribe link. We honour all opt-out requests within 72 hours.

3. How We Use Your Data

4. Legal Basis for Processing

Purpose Legal Basis GDPR Article
Responding to website inquiries Legitimate Interest / Contract Art. 6(1)(b)(f)
B2B cold outreach to relevant companies Legitimate Interest Art. 6(1)(f)
Call recording and transcription Legitimate Interest + Notification Art. 6(1)(f)
CRM lead management and scoring Legitimate Interest Art. 6(1)(f)
Analytics and website improvement Consent Art. 6(1)(a)
Legal and regulatory compliance Legal Obligation Art. 6(1)(c)

5. Data Processors We Use

We use the following third-party services that may process personal data on our behalf. All processors are bound by data processing agreements and appropriate safeguards.

Service Purpose Data Processed Location
Google Analytics / GTM Website analytics IP (anonymised), usage data USA (DPF certified)
Airtable CRM — lead, supplier and buyer database Business contact data, interaction history, call transcripts USA (SCCs applied)
Smartlead Email outreach and campaign management Business email, name, company, interaction data USA (SCCs applied)
Vapi AI AI-assisted voice calls — reception and qualification Phone number, call audio, transcript USA (SCCs applied)
Apollo.io B2B contact discovery and enrichment Business contact data (publicly sourced) USA (SCCs applied)
Persana.ai / Kaspr Contact data enrichment Business email, LinkedIn, company data USA/EU (SCCs applied)
HeyReach LinkedIn outreach automation LinkedIn profile data, messages EU
n8n (self-hosted) Workflow automation and orchestration Contact data passed between services EU (Hetzner VPS)
Anthropic Claude / OpenAI AI text generation — proposals, summaries, scoring Business context data (no personal identifiers where avoidable) USA (SCCs applied)
PandaDoc Contract generation and e-signatures Name, email, company, contract terms USA (SCCs applied)
Cloudflare R2 Call recording storage Audio files, recording metadata EU region
Cal.com Meeting scheduling Name, email, meeting time EU (self-hosted option)
Telegram Bot API Internal notifications (not used for client data) Internal operational alerts only EU

SCCs = Standard Contractual Clauses (EU-approved transfer mechanism). DPF = EU-U.S. Data Privacy Framework.

6. Data Retention

Data TypeRetention Period
Website inquiry dataUp to 3 years from last interaction
B2B outreach contacts (no response)12 months from first contact, then deleted
B2B contacts (active pipeline)Duration of business relationship + 3 years
Signed contracts10 years (legal requirement)
Call recordings12 months, then permanently deleted
Call transcripts24 months
Unsubscribe records (Do Not Contact)Indefinitely (to prevent re-contact)
Analytics dataPer Google Analytics settings (max 26 months)

7. Your Rights

Under the GDPR, you have the following rights regarding your personal data:

✓ Access

Request a copy of the personal data we hold about you.

✓ Rectification

Request correction of inaccurate or incomplete data.

✓ Erasure

Request deletion of your data ("right to be forgotten"). Honoured within 72 hours for outreach contacts.

✓ Restriction

Request that we limit how we use your data in certain circumstances.

✓ Portability

Receive your data in a structured, machine-readable format.

✓ Object

Object to processing based on legitimate interest, including direct marketing.

✓ Withdraw Consent

Withdraw consent at any time where processing is consent-based.

✓ Opt-Out of Calls

Request to be excluded from voice outreach. We will add you to our Do Not Call list immediately.

To exercise any of these rights, contact us at info@agroo.si. We will respond within 30 days.

You also have the right to lodge a complaint with the Slovenian Information Commissioner: www.ip-rs.si

8. Cookies & Tracking

Our website uses cookies and similar technologies. For full details, please read our Cookie Policy. You can manage your cookie preferences at any time using the cookie settings icon at the bottom left of the page.

9. Call Recording & AI Transcription

AGROO uses Vapi AI to manage incoming and outgoing business calls. This system may:

You will always be notified at the start of a call if recording is active. You have the right to request that no recording takes place, in which case the call will proceed without recording. Call recordings are stored securely on EU-based infrastructure (Cloudflare R2, EU region) and deleted after 12 months.

10. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure or destruction. These include:

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our services, technology, or legal requirements. We will update the date at the top of this page when changes are made. For significant changes, we will notify active contacts by email where appropriate.

12. Contact

For any privacy-related questions, to exercise your rights, or to opt out of any communications:

AGROO

Koper, Slovenia · EU

Email: info@agroo.si

Phone: +386 69 827 588

Data Protection Authority: Slovenian Information Commissioner (ip-rs.si)