Privacy policy

Who is responsible

The controller of the personal data described here is Društvo sa ograničenom odgovornošću « BUSINESS OS PODGORICA » Podgorica, trading as TrackJoin, Slovačka 19, 81000 Podgorica, Montenegro, registration number 5-0136784/001, tax ID 04390580. Contact: contact@smart-flights.com.

When you visit this site

We measure how the site is used with Umami, an analytics tool we run on our own server. It sets no cookies and does not follow you across other sites. For each page view it records the page, the referring site, the browser, the type of device and the country. The country is derived from your IP address, which is not stored.

If your browser sends a "Do Not Track" signal, no visit is recorded.

Like any web host, our hosting provider processes technical data, such as your IP address and the time of the request, to deliver the pages and protect the site against abuse.

We keep these statistics only as long as they help us improve the site.

When you write to us

If you email us, we use your address and your message to answer you, and we keep them as long as the conversation needs, plus any period required by law.

When you use the TrackJoin service

Accounts are not open yet: the demo on this site uses example data only. When the service opens, we will process:

• Your account data, such as your name, email address and sign-in details, to run your account.
• Billing data, handled by our payment provider. We do not store card numbers.
• Data about the people who click your links, such as Telegram identifiers, join and leave events, click identifiers from ad platforms and the technical data of the click. We process it on your behalf and on your instructions, to measure your campaigns and send the events you choose to the platforms you connect. For this data, you are the controller and we act as your processor, under a data processing agreement.

Why we are allowed to process it

• Legitimate interest for cookie-free site statistics, security and answering your messages.
• Contract to provide the service to customers.
• Legal obligation for accounting and tax records.

Who receives it

• Netlify, Inc. (United States), which hosts the site.
• Cloudflare, Inc. (United States), which manages our domain name.
• Hetzner Online GmbH (Germany), which hosts the server of our analytics tool.
• Google, which provides our email.

When customers connect them, events are also sent to the ad platforms and tools they choose, such as Meta, Google Ads, TikTok or a postback address. We do not sell personal data.

Transfers outside your country

We are based in Montenegro, outside the European Union, and some providers are in the United States. Where the law requires it, these transfers rely on safeguards such as the standard contractual clauses of the European Commission.

Your rights

You can ask to access, correct or delete your data, to restrict or object to its processing, and to receive it in a portable format. Write to contact@smart-flights.com. If you are someone who clicked a link run by one of our customers, you can also contact that customer, who decides what is done with your data.

You can complain to the Agency for Personal Data Protection and Free Access to Information of Montenegro, or to the data protection authority of the country where you live.

Cookies

This site sets no cookies.

Changes

We will update this policy when the service changes, in particular when accounts open. The date below shows the latest version.

Last updated on November 4, 2026.