Solita Privacy Policy

Last updated: 29 October 2026

This Privacy Policy explains how personal data is processed in connection with Solita, the website solita.app and related services (the "Service").

We process personal data in accordance with the Law on Personal Data Protection of the Republic of Serbia (Zakon o zaštiti podataka o ličnosti, "Službeni glasnik RS", no. 87/2018, the "ZZPL"). Where the EU General Data Protection Regulation (GDPR) applies, we also apply it.

1. Who we are

The Service is operated by:

SERGEI PRONIN PR RAČUNARSKO PROGRAMIRANJE AI BEOGRAD
Sole proprietor (preduzetnik) registered with the Serbian Business Registers Agency (APR)
Registration number (matični broj): 68694779
Tax ID (PIB): 115857359
Registered address: Jurija Gagarina 231, lokal 329, 11073 Beograd (Novi Beograd), Serbia
Brand: Solita
Privacy contact: privacy@solita.app
Support: support@solita.app
Phone: +381 61 2695 226

In this policy, "Solita", "we" and "us" mean the operator above.

We have not appointed a Data Protection Officer. For any data protection question, contact privacy@solita.app.

2. What Solita does and our two roles

Solita is an AI sales assistant for travel and tour businesses (tour operators, excursion agencies and similar). Our customers are businesses (the "Client" or "Clients"). On behalf of a Client, Solita answers the Client's own customers (for example, tourists) in messaging channels, qualifies leads, sends follow-up messages, and hands conversations over to the Client's human staff. Clients use dashboards and CRM tools to manage these conversations.

We act in two different roles:

Role A — Solita as controller. We decide how and why we process personal data about:

This Privacy Policy fully applies to Role A.

Role B — Solita as processor. When a Client uses Solita to communicate with its own customers ("End Users"), the Client is the controller of the End Users' data. We process that data only on the Client's documented instructions, under our Terms of Service and Data Processing Addendum (DPA). The Client decides what data is collected, which End Users are contacted and for what purpose.

If you are an End User (for example, a tourist who wrote to a travel company), please read that company's privacy notice and send requests about your data to that company first. We will assist the company in answering you. See section 10 and our Data Deletion page.

3. Data we process (Role A — controller)

CategoryExamplesSource
Account and contact dataname, business email, phone, job title, company name, login credentials (hashed)you or your employer
Business and billing datacompany details, tax ID, billing address, invoices, payment status, subscription planyou; our payment service provider
Communication datasupport requests, emails, messages to us, call or meeting notesyou
Usage and technical dataIP address, device and browser type, log-in times, actions in the dashboard, error logsautomatically, from the Service
Website datapages visited, referrer, cookies (see section 12)automatically, from solita.app
Marketing datawhether you subscribed to updates, responses to our messagesyou

We do not ask for special categories of personal data (for example, health, religion, biometric data) in Role A.

4. Data we process on behalf of Clients (Role B — processor)

To provide the Service, we process on the Client's behalf:

Clients must not use Solita to collect special categories of personal data or identity document numbers unless strictly necessary and lawful. The AI Assistant does not ask End Users for passport or other identity documents. If an End User sends such a document in a conversation, it is stored as part of that conversation, is accessible only to the Client, and is deleted together with the conversation. Clients should ask End Users to share identity documents through their own secure booking process, not in chat.

5. Purposes and legal bases (Role A)

PurposeLegal basis (ZZPL / GDPR)
Creating and managing Client accounts; providing the Serviceperformance of a contract, or steps before entering into a contract
Billing, invoicing, accounting and tax recordscompliance with a legal obligation
Customer support and service communicationsperformance of a contract; legitimate interest
Security, fraud and abuse prevention, enforcing our Terms (including messaging policy enforcement)legitimate interest; legal obligation where applicable
Improving the Service using aggregated usage statistics (not message content)legitimate interest
Answering enquiries and demo requestssteps before entering into a contract; legitimate interest
Sending marketing emailsconsent, or legitimate interest for existing business contacts where allowed by law; you may opt out at any time
Non-essential cookies and analyticsconsent
Establishing, exercising or defending legal claimslegitimate interest

Where we rely on legitimate interest, we have balanced our interests against your rights. You can ask us for details and you can object (section 10).

In Role B, the legal basis for processing End User data is determined by the Client as controller.

6. AI processing

7. Who receives data

We share personal data only as needed to provide the Service:

ProviderPurposeLocation
Meta Platforms Ireland Ltd. / Meta Platforms, Inc. (WhatsApp Business Platform / Cloud API)message deliveryEU / USA
Telegrammessage deliveryUAE / global
Anthropic PBC; OpenAI, L.L.C.AI reply generationUSA
Contabo GmbHhosting, storage, backupsGermany (EU)
Stripe, via a third-party payment service providerpayments and billingEU / USA
Meta Platforms (Meta Pixel); Google LLC (Google Tag Manager, Google Analytics)website analytics and advertising measurement, only with consentEU / USA
Zoho Corporationbusiness emailUSA

Channels currently supported: WhatsApp Business Platform and Telegram. We will update this list before adding new channels. This table is our current list of sub-processors.

We do not sell personal data.

8. International transfers

Our servers and some providers are located outside the Republic of Serbia: our servers are hosted by Contabo GmbH in Germany (European Union); our LLM providers (Anthropic, OpenAI) and some messaging and payment providers process data in the USA. We transfer personal data abroad only where permitted by ZZPL, namely:

You can request information about the safeguards used by contacting privacy@solita.app.

9. How long we keep data

DataRetention
Client account datafor the duration of the contract, then deleted within 30 days after the export period ends
End User data (Role B)as instructed by the Client; after contract end, available for export for 30 days, then deleted from production systems within 7 days and from backups within 60 days
Invoices and accounting recordsfor the period required by Serbian accounting and tax law (up to 10 years)
Support correspondence24 months after the last contact
Security and access logs12 months
Marketing datauntil you unsubscribe or withdraw consent
Website analyticsup to 14 months

We may keep data longer when needed to establish or defend legal claims, or when required by law.

10. Your rights

Under ZZPL (and GDPR where it applies) you have the right to:

How to exercise them. Email privacy@solita.app. We may ask you to confirm your identity. We answer within 30 days. This period may be extended by up to 60 days for complex requests; we will tell you if it is.

End Users of our Clients. Send your request to the business you communicated with. It is the controller. If you contact us, we will forward your request to that business or help it respond, as required by our agreement with it.

11. Complaints

You may lodge a complaint with the Serbian supervisory authority:

Commissioner for Information of Public Importance and Personal Data Protection (Poverenik za informacije od javnog značaja i zaštitu podataka o ličnosti) Bulevar kralja Aleksandra 15, 11000 Beograd, Serbia www.poverenik.rs

If you are in the EU/EEA, you may also complain to your local data protection authority. We ask that you contact us first so we can try to resolve the issue.

12. Cookies

solita.app uses strictly necessary cookies to run the website and the dashboard (for example, session and security cookies). These do not require consent.

With your consent, solita.app also uses Google Tag Manager and Meta Pixel and Google Analytics to measure visits and the effectiveness of our advertising. These are loaded only after you accept them in the cookie banner, and you can withdraw consent at any time via the "Cookie settings" link in the website footer.

You can manage cookies in your browser settings.

13. Security

We use technical and organisational measures appropriate to the risk, including encryption in transit, access control based on roles, logging of staff access to conversation content, backups, and two-factor authentication for staff accounts with access to personal data. Solita staff access conversation content only when necessary to provide support or at the Client's request, or for security reasons.

If a personal data breach occurs, we will notify the Commissioner and affected persons where required by ZZPL, and will notify affected Clients without undue delay.

14. Children

The Service is intended for businesses. It is not directed to children under 16. We do not knowingly collect data from children in Role A. If you believe a child has given us personal data, contact privacy@solita.app and we will delete it.

15. Changes

We may update this policy. We will post the new version on this page with a new "Last updated" date. For material changes we will notify Clients by email or in the dashboard at least 14 days in advance.

16. Contact

Questions about this policy: privacy@solita.app
Postal address: Jurija Gagarina 231, lokal 329, 11073 Beograd (Novi Beograd), Serbia