TMG Development and Consulting (registered in Croatia as “TMG OBRT ZA RAZVOJ I SAVJETOVANJE”) is the controller of the personal data described in this notice. We are a one-person consultancy providing GenAI and Microsoft 365 training, workshops, and consulting.
Address: Ul. Ivana Gorana Kovačića 101, 32000 Vukovar, Croatia
OIB: 44996276436
Email: tomsickert@tmgdac.com
Telephone: +385 99 217 8602
Given our size, we are not required to appoint a Data Protection Officer, and we have not appointed one. You can raise any data-protection question using the contact details above.
This notice applies to personal data we handle as a controller — for example when you contact us, when we provide services to you, and when we carry out business development. Where we handle personal data on a client’s behalf while delivering a project, we act as a processor on that client’s instructions, and the client’s own privacy notice applies to that processing.
Enquiry data — name, email, phone, and the content of your message
Why we use it: to respond to your enquiry and correspond with you
Legal basis: legitimate interests, Art. 6(1)(f); or steps at your request before a contract, Art. 6(1)(b)
Client and engagement data — your contact details and any personal data within materials you share with us
Why we use it: to deliver and administer the services we agree
Legal basis: performance of a contract, Art. 6(1)(b); as a processor on the client's instructions, Art. 28
Business-development data — name, role, employer, and professional contact details, often obtained from LinkedIn or other public professional sources
Why we use it: to contact you about services that may be relevant to your role
Legal basis: legitimate interests, Art. 6(1)(f) — you may object at any time
Website technical data — IP address, browser type, and standard log data collected by our website host
Why we use it: to provide, secure, and maintain the website
Legal basis: legitimate interests, Art. 6(1)(f)
Supplier and partner data — names and contact details of the people we work with
Why we use it: to manage supplier and partner relationships
Legal basis: legitimate interests, Art. 6(1)(f); or performance of a contract, Art. 6(1)(b)
Most of the personal data we hold comes directly from you — when you contact us, engage us, or share materials with us. For business development, we may also collect professional contact data from public sources, principally LinkedIn and public company websites. Where we obtain your data this way, our legal basis is our legitimate interest in offering relevant services, and you can ask us to stop contacting you or to erase your data at any time (see “Your rights”).
We use enterprise and commercial generative-AI tools — principally Microsoft 365 Copilot within our own EU-based tenant, and, where appropriate, Google Gemini and Anthropic Claude — to help deliver our work. We use them under terms that do not permit the provider to train its models on your data. Before using any such tool, we remove personal details that are not needed for the task, and we do not enter special-category data or a client’s confidential business information into any AI tool without prior agreement.
We do not sell your personal data. We share it only where necessary, with:
• Service providers who process data on our behalf, principally Microsoft (Microsoft 365 for email, documents, and storage) and Google (Google Sites, which hosts this website). These providers act on our instructions under data-processing terms.
• Partners and clients, where a project is delivered together — for example our partners and their end-clients — and only to the extent needed to carry out the work.
• Authorities or advisers, where we are required to share data by law, or need to obtain professional (for example legal or accounting) advice.
Some of our providers (including Microsoft and Google) may process personal data outside the European Economic Area. Where they do, the transfer is covered by an appropriate safeguard — an adequacy decision, the European Commission’s Standard Contractual Clauses, or, for core Microsoft 365 processing, Microsoft’s EU Data Boundary. You can ask us for more detail on the safeguards that apply.
• Enquiry data: kept for up to 24 months after our last contact if no engagement follows, then deleted.
• Client and engagement data: kept for the duration of the engagement and for as long afterwards as we are required to by law, including Croatian accounting and tax retention rules.
• Business-development data: kept until you object or it is no longer relevant, and reviewed periodically.
• Website technical data: retained by our website host in line with its own policies.
Under the GDPR you have the right to:
• access the personal data we hold about you;
• have inaccurate data corrected;
• have your data erased;
• restrict or object to our processing;
• receive your data in a portable format; and
• withdraw consent at any time, where we rely on consent.
To exercise any of these rights, email us at tomsickert@tmgdac.com. We will respond within one month. Exercising your rights is free of charge in normal cases.
If you are concerned about how we handle your personal data, please contact us first so we can put things right. You also have the right to lodge a complaint with the Croatian supervisory authority: Agencija za zaštitu osobnih podataka (AZOP) — Ulica Metela Ožegovića 16, 10000 Zagreb, Croatia · azop@azop.hr · www.azop.hr
This website is hosted on Google Sites. As our hosting provider, Google may set cookies that are necessary to run and secure the site and may collect standard technical data (such as IP address and browser type) as part of providing the service. This is described in Google’s own privacy policy. We do not use the website to build marketing profiles of visitors.
We may update this notice from time to time. The version and date at the top show when it was last changed. Where a change is significant, we will make that clear on this page.
For any question about this notice or your personal data, email tomsickert@tmgdac.com or write to us at the address in section 1.