Privacy Policy

Fakturio (“the app”, “we”, “us”) is an invoicing tool operated by ŽARKO MLADENOVIĆ PR RAČUNARSKO PROGRAMIRANJE ZMIT NIŠ (“ZMIT”), an entrepreneur (preduzetnik) registered in Serbia. It lets you store your company and client details and a catalog of what you sell, issue invoices and proformas, track which of them have been paid, email them to your clients and your accountant, export reports, download them as PDFs, optionally save those PDFs to your own Google Drive, optionally send e-invoices to Serbia’s Electronic Invoicing System (SEF) and delivery notes to eOtpremnica, and pay for the service by subscription. On the paid plan you can also connect an AI assistant, such as Claude or ChatGPT, that reads your account and prepares draft invoices.

Our registered details, as recorded in the Serbian business register:

Business name

ŽARKO MLADENOVIĆ PR RAČUNARSKO PROGRAMIRANJE ZMIT NIŠ

Trading as

ZMIT

Legal form

Entrepreneur (preduzetnik)

Registered seat

Bulevar Zorana Đinđića 4, Niš, Republic of Serbia

Registration number (matični broj)

68717248

Tax Identification Number (TIN)

115883832

Register

Register of Business Entities, Serbian Business Registers Agency (APR)

Email

zarko@fakturio.app

For any privacy question, or to exercise any right described below, contact zarko@fakturio.app. We answer in Serbian or English.

Our two different roles

Data protection law distinguishes the party who decides why data is processed (the controller) from the party who processes it on someone else’s instructions (the processor). We are both, depending on whose data it is:

• We are the controller of your own account and business data — your sign-in email, the company profiles you create as the issuer of invoices, your subscription record, and your Google Drive connection. This policy is our notice to you about that data.
• We are the processor of the details you enter about your clients — their company name, contact person, address, tax numbers and email — of the invoices addressed to them, of delivery notes (including any driver name and vehicle plate you enter), of supplier details on invoices and delivery notes you receive through SEF and eOtpremnica, and of your accountant’s email address if you add one. You decide why you hold those details; we only store and display them so the app can work. For that data you are the controller, which means you are responsible for having a lawful basis to hold it and for answering your clients if they ask about it. The terms on which we process it for you are set out in our Data Processing Agreement, which forms part of the Terms of Service.

We collect only what the app needs to work. Specifically:

• Account information. When you sign in, our authentication provider (Clerk) gives us your user ID and email address, and your name and profile image if your sign-in method supplies them. We never see or store your password.
• Invoicing data you enter. Your company details (legal name, address, tax and registration numbers, bank account details such as IBAN, SWIFT and account number, logo), your clients’ details (company name, contact person, address, tax numbers, email), your catalog of products and services (names, descriptions, units, prices), the invoices and proformas you create (line items, amounts, currency, dates, notes) and whether each has been paid, your accountant’s email address if you add one, and your notification settings.
• Emails you send through the app. When you email an invoice, a payment reminder or a bundle of invoices, we pass the recipient’s address, the message and the attached PDFs to our email provider for delivery. We keep a record of which reminders and scheduled emails were sent and when, so that none is ever sent twice.
• Google account data. Only if you choose to connect Google Drive. See section 4 for exactly what this covers.
• SEF and eOtpremnica data. Only if you connect those state systems. We store your API keys (encrypted, see section 7), the environment you chose (test or production), the status of each invoice sent to SEF as SEF reports it, the list of invoices suppliers sent you through SEF (number, supplier name and TIN, amount, due date, status) and the delivery notes you issued or received through eOtpremnica (parties, addresses, goods and, as you enter them, driver name, vehicle plate and carrier).
• AI assistant connections. Only if you connect an assistant. Our authentication provider (Clerk) records which assistant you approved and issues it an access token tied to your account. Draft invoices the assistant creates are saved in your workspace like any other invoice. What the assistant can read is described in section 6.
• Billing information. If you subscribe to a paid plan, our payment provider (Polar) collects your payment details, billing address and email to process the charge. See section 5 for exactly what this covers.
• Technical data. The standard server and security logs our hosting provider records when you use the site — IP address, browser and device type, operating system, the pages and actions requested, timestamps and error reports — and the cookies described in section 9.
• Visit statistics. Our hosting provider’s Web Analytics counts page views without cookies. For each page view it records the page address, the referring site, the country, and the browser, operating system and device type. It tells visitors apart only by a hash of the request, which it discards after 24 hours, and we see only aggregated totals, never an individual visitor or what you enter in the app.

We do not collect special categories of personal data, we do not buy data about you from third parties, and the app is meant for businesses and is not directed at anyone under 18.

We use your data only to provide the service you asked for:

• To authenticate you and keep your workspace separate from every other account.
• To save your companies, clients, catalog and invoices so they are there when you return.
• To generate invoice PDFs and reports from the details you enter.
• To email invoices, proformas and payment reminders to your clients, and invoices to your accountant — when you press send, or on a schedule you have switched on yourself.
• To send you the morning digest of overdue invoices, if you switch it on.
• To fill in a company’s details from the public register when you look it up by Tax Identification Number (TIN) or registration number.
• To upload those PDFs to your Google Drive, when you ask us to.
• To send your invoices and delivery notes to SEF and eOtpremnica, and to show you their status and the documents you have received, once you connect those systems and press send.
• To answer what an AI assistant you connected asks for on your behalf, and to save the draft invoices it prepares.
• To process your subscription payment and manage your billing.
• To keep the service secure, debug faults, and prevent abuse.
• To see, in aggregate, which pages are visited and where visitors come from.
• To comply with legal obligations that apply to us.

We do not sell your data, we do not share it with data brokers, we do not use it for advertising, ad targeting or profiling, and we do not send you newsletters or marketing email. We do not use your data — including any data obtained through Google APIs — to develop, improve or train generalised artificial intelligence or machine learning models.

What an AI assistant you connect does with the data it receives is governed by its provider’s terms and privacy policy, and by your settings there, not by this policy. See section 6.

Our legal bases

We process personal data under the Serbian Law on Personal Data Protection (Zakon o zaštiti podataka o ličnosti, “ZZPL”, Official Gazette RS 87/2018) and, where you are in the UK or EEA, under the UK/EU GDPR. Because the ZZPL is closely modelled on the GDPR, the same bases apply under both:

• Performance of a contract (ZZPL Art. 12(1)(2); GDPR Art. 6(1)(b)) — to create your account, store your workspace, generate and send invoices, and process your subscription. This is the basis for most of what we do, and it is why we do not ask for your consent to it: without this data there is no service to provide.
• Consent (ZZPL Art. 12(1)(1); GDPR Art. 6(1)(a)) — for the optional Google Drive connection only. You give it by connecting Drive and may withdraw it at any time by disconnecting, without affecting anything processed before you withdrew.
• Legal obligation (ZZPL Art. 12(1)(3); GDPR Art. 6(1)(c)) — to keep our own billing and accounting records for the periods Serbian accounting and tax law requires of us. See section 8.
• Legitimate interests (ZZPL Art. 12(1)(6); GDPR Art. 6(1)(f)) — to keep the service secure, prevent abuse and debug faults, and to count visits in aggregate. We have weighed this against your interests and limited it to what security, reliability and cookieless visit counts actually require.

The Google Drive connection is entirely optional. The app works fully without it, and it stays off until you press “Connect Google Drive”.

Scopes we request, and why

We deliberately request drive.file rather than a broader Drive scope. This is the narrowest scope that supports the feature: we cannot read, list, modify or delete any pre-existing file in your Google Drive — only the invoice files the app created itself.

What we store

• Your Google account email address, and the name and ID of the destination folder, so we can show the connection status and put the next invoice in the same place.
• A Google refresh token, so uploads keep working without asking you to sign in to Google each time. It is encrypted with AES-256-GCM before it is written to our database, using a key held in our server environment and never stored in the database itself.

The contents of your invoice PDFs are streamed to your Drive at the moment you save them. We do not keep a copy of the uploaded file, and we never read files back out of your Drive.

Limited Use disclosure

Fakturio’s use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

In practice this means we use Google user data only to provide the Drive-saving feature you asked for; we do not transfer it to others except as needed to provide that feature, for security purposes, or to comply with applicable law; we do not use it for advertising; and we do not allow humans to read it, except with your explicit consent for support you have requested, for security purposes, to comply with applicable law, or where the data has been aggregated and anonymised.

Disconnecting

You can disconnect Google Drive at any time from the app’s settings. When you do, we delete the stored refresh token, email address and folder details from our database, and we ask Google to revoke the token so the grant also disappears from your Google account. You can additionally review and remove access yourself at myaccount.google.com/permissions. Invoices already saved to your Drive stay in your Drive, under your control.

Paid plans are billed through Polar, who acts as the merchant of record for your subscription. This means Polar, not Fakturio, is the seller you are contracting with for the purchase itself, issues your receipt, is responsible for charging and remitting any applicable sales tax or VAT, and handles refunds and chargebacks under its own terms.

We never see or store your full card number. Polar collects your payment method, billing address and email directly to process the charge; we receive back only your subscription status, plan, and renewal date, which we use to unlock the paid features of your account. See Polar’s privacy policy for how they handle payment data.

We share data only with the service providers that run the app, each acting on our instructions under a data processing agreement:

• Clerk — authentication and account management (privacy policy).
• Neon — the managed PostgreSQL database holding your workspace (privacy policy).
• Vercel — application hosting and delivery, and cookieless visit statistics (Web Analytics) (privacy policy).
• Resend — email delivery, for the invoices, reminders, accountant emails and digests the app sends (privacy policy).
• Google — only when you connect Drive, and only to upload the files you save (privacy policy).
• Polar — only if you subscribe to a paid plan, to process payment and manage billing (privacy policy).

State systems: SEF and eOtpremnica

If you connect SEF or eOtpremnica, every invoice or delivery note you send is passed on by us to that state system, using your API key and in your name. The state system is not our processor: it is the controller of that data under the rules that govern it, and once a document has reached it we can neither recall nor delete it. We send nothing to those systems except when you start a send, or when we refresh the overview of your received documents and the status of those you sent.

AI assistants you connect

If you connect an AI assistant, such as Claude (Anthropic), ChatGPT (OpenAI) or another assistant that supports MCP connectors, we pass it the data it asks for while it answers you: your companies, clients, catalog, invoices and their payments, receivables, flat-rate turnover limit and KPO book. That includes personal data about your clients and their contact persons. The assistant can also create draft invoices. It cannot issue, send, change or delete anything, and it cannot reach SEF or eOtpremnica.

The assistant’s provider is not our processor. You choose it, you instruct it, and you use it under your own agreement with that provider. Whether it keeps the data, for how long, and whether it uses it to train its models is governed by its terms and privacy policy and by your settings there. We send an assistant nothing except in answer to a request it makes with the access you approved, and only while you have the paid plan. Data an assistant has already received stays with its provider after you disconnect it.

People you send documents to

When you email an invoice, a reminder or a bundle, the recipient — your client or your accountant — receives it because you told us to send it. Emails go out from our address with the reply-to set to your company’s email, so any answer reaches you, not us.

Public registers we look things up in

When you look a company up by TIN or registration number, our server sends that number — and nothing else — to the National Bank of Serbia’s public Unified Register of Accounts (Jedinstveni registar računa) and reads back the company’s registered details. To show foreign-currency totals in dinars, we fetch the NBS middle exchange rate from kurs.resenje.org, sending only a currency and a date. Neither service receives any information about you or your account.

We may also disclose data if required by law, or to protect our rights and the safety of our users. If the service is ever transferred to another owner, we will tell you before your data is transferred, and this policy continues to apply until you are notified otherwise.

Data is stored on servers operated by our hosting and database providers. Our providers — Clerk, Neon, Vercel, Resend, Polar and Google — are companies based in the United States, so some data may also be processed there.

International transfers. We operate from Serbia, which is outside the EEA. Under ZZPL Art. 64, personal data may be transferred without further authorisation to countries on the Serbian Government’s list of countries providing an adequate level of protection, which includes the EU and EEA member states and the other parties to Council of Europe Convention 108. For transfers from the EEA or UK to us, and for transfers by us or our providers to countries not on those lists, such as the United States, we and they rely on the European Commission’s Standard Contractual Clauses or an equivalent safeguard offered by the provider. If you are an EEA or UK business and need the Standard Contractual Clauses executed with you directly, contact zarko@fakturio.app.

Our safeguards include:

• Encryption in transit (HTTPS/TLS) across the whole site and all API traffic.
• Encryption at rest for the database, plus additional AES-256-GCM encryption applied to Google refresh tokens and to SEF and eOtpremnica API keys before they are stored. The keys are never sent to the browser.
• Strict per-user isolation: every database query is keyed to your own account ID, so one account’s workspace is never readable by another.
• Secrets held in the server environment, never in client-side code or the repository.

Who on our side can see your data

We want to be straightforward about this, because it is the question most policies avoid. As the operator of the database, we are technically able to read the data stored in it. We restrict ourselves to doing so only when there is a specific reason:

• to investigate a support request you have raised;
• to diagnose a fault, data-loss incident or security problem;
• where we are legally required to.

We do not browse user workspaces out of curiosity, we do not read your invoices to build profiles or analytics about you, and the app’s administrative tools deliberately do not include any screen that lists or searches other users’ invoices, clients or companies — administration covers accounts and feature settings only. Google user data is additionally covered by the stricter Limited Use commitment in section 4.

If something goes wrong

No system is perfectly secure. If a personal data breach occurs, we will notify the Commissioner within 72 hours of becoming aware of it, as ZZPL Art. 52 requires (GDPR Art. 33), and we will notify you without undue delay where the breach is likely to result in a high risk to your rights and freedoms (ZZPL Art. 53; GDPR Art. 34). Where we act as processor for your client data, we will notify you promptly so that you can meet your own obligations as controller.

• Workspace data (companies, clients, catalog, invoices) — until you delete it, or until you close your account.
• Google Drive connection data — until you disconnect Drive or close your account, whichever comes first.
• SEF and eOtpremnica connection data — API keys, statuses and received documents, until you disconnect or close your account, whichever comes first. Documents you have already sent stay in the state system, which is outside our control.
• AI assistant connections — until you remove the connector in your assistant or close your account. If you want us to cut a connection off on our side, email zarko@fakturio.app. Data the assistant has already received is held by its provider, outside our control.
• Billing data — subscription status and plan history are kept for as long as your account exists; records that are our own accounting documents are kept for the period the law requires of us. Your payment method and receipts are held by Polar, not us.
• Email records — the note of which reminders and scheduled emails were sent, and when, is kept as long as the invoice or account it belongs to. The messages themselves are held by our email provider only for the limited period of its delivery logs.
• Account data — until you close your account.
• Security and server logs — a short rolling period, typically no more than 30 days.

When you close your account

Deletion is automatic: as soon as the account is deleted (in your account settings, or at your request by email), the subscription is cancelled, the Google permission is revoked, and we delete your whole workspace — company profiles, clients, catalog, invoices, delivery notes, drafts, settings, reminder configuration, your Google Drive, SEF and eOtpremnica connections and subscription records. Any AI assistant you connected loses access at the same moment. Everything is deleted within 30 days of the request at the latest. Copies may persist a little longer in encrypted backups until they are overwritten on their normal cycle. We keep only what the law requires of us for our own accounting, and only for as long as it requires.

Your invoices are your records

Serbian accounting and tax law requires the business that issued an invoice — you — to keep it for the period the law prescribes, which runs for years after the invoice was issued. Fakturio is a convenient working copy, not a substitute for that archive: download or export your invoices before you delete them or close your account, because once they are deleted we cannot restore them. Your accountant can tell you exactly how long you must keep them.

We use strictly necessary cookies only. They are set by our authentication provider to keep you signed in and to protect against cross-site request forgery, and by the app to carry the short-lived state value that secures the Google sign-in redirect. One preference cookie remembers the language you chose for the app’s interface. We use no advertising or analytics cookies and no cross-site tracking. The visit statistics described in section 2 work without cookies, so there is nothing here to opt out of.

In your browser (localStorage and sessionStorage) the app remembers only your display choices: light or dark theme, that you dismissed the “install app” prompt, and a short-lived value that carries your sign-in between tabs. We do not keep invoices or client data there. The service worker caches only the app’s static files and the offline page, with no personal data. You can clear all of this in your browser settings.

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

• Access a copy of the data we hold about you (ZZPL Art. 26; GDPR Art. 15).
• Correct data that is wrong or incomplete (ZZPL Art. 29; GDPR Art. 16).
• Delete your data (ZZPL Art. 30; GDPR Art. 17), as described in section 8.
• Restrict processing, or object to processing based on our legitimate interests (ZZPL Arts. 31 and 37; GDPR Arts. 18 and 21).
• Receive your data in a portable format (ZZPL Art. 36; GDPR Art. 20).
• Withdraw consent for the Google Drive connection at any time (ZZPL Art. 15(3); GDPR Art. 7(3)).

Most of these you can exercise directly in the app: your companies, clients and invoices are editable and deletable at any time, invoices download as PDFs, and Drive can be disconnected in one click.

For anything else, email zarko@fakturio.app. We will respond within 30 days, as ZZPL Art. 21 requires; if a request is complex we may extend this and will tell you why. We will not charge you or discriminate against you for exercising these rights.

Note that if you are a client of one of our users rather than a user yourself, we hold your details as a processor on that user’s behalf. Please direct your request to the business that invoiced you; if you contact us instead, we will pass it on to them.

Complaining to a supervisory authority

If you are in Serbia and are unhappy with our response, you may lodge a complaint with the 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 Belgrade, office@poverenik.rs, poverenik.rs. If you are in the UK or EEA, you may complain to your local data protection authority instead.

If we change this policy we will update the date at the top of the page, and for material changes — particularly any change to what Google data we access or how we use it — we will notify you in the app or by email before the change takes effect.

Questions, requests or complaints: zarko@fakturio.app. The controller is ŽARKO MLADENOVIĆ PR RAČUNARSKO PROGRAMIRANJE ZMIT NIŠ, Bulevar Zorana Đinđića 4, Niš, Serbia, registration number 68717248, TIN 115883832.

See also our Terms of Service.