Privacy Policy
Scope of This Notice
The Company is committed to protecting and respecting your privacy. Please read this Privacy Policy carefully to understand why and how the Company collects your personal data and how such data will be used. Concerning personal data, the Company is the “data controller”, meaning the entity that determines the purposes for which and the means by which personal data are processed.
This Privacy Policy explains how the Company collects, uses and manages your personal data contained on the website and made available to the Company through the use of the website.
In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (Official Journal of the European Union L 119, 4 May 2016, p. 1, hereinafter referred to as the “General Data Protection Regulation”), which has been fully applicable since 25 May 2018 in the Republic of Croatia and all Member States of the European Union, as well as the Act on the Implementation of the General Data Protection Regulation (Official Gazette No. 42/18, hereinafter referred to as the “Act”), that is, in accordance with the legal framework governing personal data protection in the Republic of Croatia and the European Union and European best practices, the Company, as the controller of the personal data of users of its services, has prepared this Privacy Policy.
The Privacy Policy is based on the following principles of personal data processing:
- the principle of lawfulness, transparency and best practices;
• the principle of processing limitation and data minimisation;
• the principle of accuracy and completeness of personal data;
• the principle of storage limitation;
• the principle of data integrity and confidentiality;
• the principle of accountability;
• the principle of trust and fair processing;
• the principle of appropriateness (purpose of processing); and
• the principle of processing in an unidentified (anonymised) form.
This Privacy Policy applies to all services offered by the Company, and its purpose is to inform you, as a user, clearly and transparently about the procedures for processing your personal data and about your rights. Above all, as a user, you may contact the Company at any time with a request to amend, supplement and/or update the data relating to you, as well as with a request to state the purposes for which you do or do not wish your data to be processed.
Should you wish to contact the Company regarding this Privacy Policy or your personal data, you may contact the Data Protection Officer at: e-mail or by sending post to the address of the Company’s registered office.
How and When Does the Company Collect Your Personal Data?
The Company collects your personal data when this is necessary to meet your needs as a user of the service or for the purposes of the Company’s business operations:
- when you access the website, the Company will collect your IP address, which is also considered personal data;
- situations in which the Company collects other types of data, such as (i) the date and time of access to the website, (ii) information concerning the hardware, software or internet browser you use, as well as (iii) your computer’s operating system, the version of the application and your language settings. The Company may collect information regarding clicks and your access to the website;
- when you contact customer service and request assistance or ask a question so that the Company can enable you to exercise any of your rights guaranteed by the applicable regulations;
- when you submit any enquiry relating to the service offering, the Company will process your contact details and/or other data you provide when submitting the enquiry;
- when providing the requested professional service, which includes data management, sending communications relating to the provision of the requested service and, where applicable, managing payment procedures for professional services, the Company processes your data;
- where there is an obligation to communicate data for reasons of public interest, the Company may process and share your personal data;
- during an informative interview with you as the data subject.
The Company collects the above-mentioned specific categories of your personal data either on the basis of consent presented to you through a pop-up window when you visit the website or on the basis of a legitimate interest, for example where cookies are necessary for the website to function or so that the Company can fulfil its obligations arising from the applicable regulations of the Republic of Croatia.
When providing the requested professional service, the Company processes your personal data on the basis of Article 6(1)(b). The relevant Article governs the controller’s right to process personal data where processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.
Where processing is based on your consent, you have the right to withdraw that consent at any time. The controller must be notified of the withdrawal of consent by e-mail or at the address of the registered office, marked for the attention of the controller. Such withdrawal will not affect the lawfulness of the processing of personal data carried out on the basis of the relevant consent before its withdrawal.
Please pay attention to the mandatory scope of the data requested from you by the Company because, where you as a user do not provide the requested information designated as mandatory for carrying out the requested or expected activity, you will unfortunately not be permitted to participate in the relevant activity because, without the requested data, that activity will be technically impossible to carry out.
What Data Does the Company Collect Directly From You and for What Purpose?
The typical categories of data that the Company collects from you as a user are as follows:
- first and last name;
• e-mail address;
• telephone number;
• other information you provide when completing a form on the website or when communicating with the Company by telephone or e-mail.
The Company collects your personal data for the purposes of:
- providing a service, performing a contract or otherwise ensuring the provision of the requested service;
• using all services available on the website;
• establishing a business relationship and/or entering into and/or providing a service, as well as ensuring the completeness and updating of personal data throughout the duration of the business relationship;
• responding to your enquiry and processing your requests as efficiently as possible;
• statistical data processing;
• sending materials and offers and contacting you;
• improving the quality of content, functionality and services;
• fulfilling legal obligations; and
• fulfilling obligations established by international agreements and EU law.
The personal data collected and processed by the Company are:
The Company does not collect personal data to an extent greater than necessary to achieve the established purpose.
The Company collects personal data on the basis of your statement or by inspecting your documents/instruments, or by making copies of documents/instruments where prescribed by law.
When establishing a business relationship and/or entering into and/or providing a service, the Company may also collect from third parties your personal data that you have disclosed to such third parties in accordance with the prescribed purpose and that the Company requires in order to fulfil legal obligations or obligations arising from a contractual relationship.
What Privacy Rights Do You Have?
Please note that you have the right, at any time, to request the following from the Company:
that the Company provide you with access to your personal data;
You may ask the Company which of your personal data it uses and you may also request access to such personal data. You have the right to know the purpose of the processing, which categories of your personal data are retained, the bodies or categories of bodies with which your personal data are shared, the retention period for your personal data, as well as the source of the data where the data are collected indirectly.
You may contact the Company should you require a copy of some or all of the personal data it holds about you.
request the rectification of inaccurate data;
The Company wishes to ensure that your personal information is accurate and up to date. You may request that the Company correct or remove information that you believe is inaccurate or outdated.
request the erasure of personal data;
You may request that the Company stop processing or even erase your personal data. If the Company requires your personal data in order to perform a contractual obligation towards you, the Company may no longer be able to perform such contractual obligations. Furthermore, if your personal data are required in order to fulfil certain legal obligations, for example tax obligations, it may not be possible to comply with your request.
Restriction of access to your data, by the Company and/or third parties, in certain processes or entirely;
Where you wish to contest the accuracy of the data, or the Company no longer requires your personal data for the purposes of processing, but you require them for the establishment, exercise or processing of legal claims, or where you have objected to processing on a basis that the Company considers legitimate, you have the right to request restriction of the processing of personal data.
object to the manner in which the Company uses your data;
Please remember that you have the right to object to the processing of personal data based on a legal basis that the Company considers legitimate.
request the transfer of data to another processor (right to data portability);
Where the processing is based on your consent or is carried out by automated means, you have the right to request that the Company transfer the data to another processor.
To exercise any of the rights listed above, please use the contact details provided at the beginning of this Privacy Policy.
If you believe that your rights are not being respected, you have the right to lodge a complaint with the Croatian Personal Data Protection Agency.
Where Are Your Personal Data Stored?
The personal data collected about you by the Company are stored in a secure environment. Your personal data are protected against unauthorised access, disclosure, use, alteration or destruction by any organisation or individual. The Company takes data protection seriously and takes various precautions to ensure that personal data are protected.
The processed data are stored on the Company’s premises and within the Company’s IT systems.
The Company will ensure that personal data are kept in a secure location, which includes reasonable administrative, technical and physical safeguards to prevent the unauthorised use of, access to, disclosure of, copying of or alteration of personal data, and which may only be accessed by authorised persons. All authorised persons sign a confidentiality statement.
Data collected for the purposes specified in this Privacy Policy will be stored only for as long as necessary to fulfil those purposes. Your personal data will not be retained in a form that allows you to be identified for longer than the Company reasonably considers necessary to fulfil the purpose for which they were collected or processed. The Company will retain certain personal data for the period prescribed by a law or regulation requiring the Company to retain the data. For further information, see “How Long Will the Company Retain Your Personal Data?”
Where you have provided your consent to the Company, for example where you have subscribed to a newsletter or selected a particular category of cookies for use, the Company will process your personal data until you withdraw your consent. Where you submit a justified objection to the processing of personal data, the Company will not process your personal data in the future.
In addition to all of the above, it is important to emphasise the following: where judicial, administrative or out-of-court proceedings have been initiated, personal data may be stored until the conclusion of such proceedings, including any applicable period for pursuing legal remedies.
Does the Company Share Data With Third Parties?
The protection of privacy is important to the Company and, therefore, the Company will never share your personal data with third parties except for the purposes described in this Privacy Policy. The Company will always notify you in advance of any sharing and transfer of data.
Personal data that you have provided to the Company or that the Company possesses on the basis of a business relationship may be made available or forwarded to companies and/or other legal or natural persons acting as processors and providing various services to the Company in order to enable the Company’s activities to be carried out.
The Company shares your personal data with third parties where this is necessary for the fulfilment of contractual and/or legal obligations, or with your consent. All processors of your data comply with appropriate technical and protective measures to ensure that your rights are protected.
The Company also cooperates with other companies. This means that it sometimes shares your personal data using secure IT systems. In such cases, the data are transferred to servers located in the EU or in a country that ensures an adequate level of protection in accordance with EU legislation.
In certain cases, the Company’s partners that provide services in the name of or on behalf of the Company may process your data outside the European Union. However, the contracts entered into by the Company with such entities require them to handle your data using specific security measures in accordance with the regulations in force in those Member States of the European Union. In the event of a transfer of data to the USA, the Company will first request your written permission, taking into account the consequences of the “Schrems II” judgment and the declaration that the Privacy Shield is invalid. Furthermore, where the Company’s contractual partner has its registered office in the USA, the Company will review the existing contracts and verify the security standards guaranteed by its partner in order to ensure the protection of all data subjects in accordance with the latest standards approved and recommended by the competent institutions.
The purposes for which the Company shares data with trusted partners include, for example, marketing, website maintenance and other services. Under the relevant contracts, such service providers are required to use the data entrusted to them only in accordance with the guidelines and exclusively for the purpose strictly determined by the Company. The Company also requires them to adequately protect your data and treat them as a business secret.
How Long Will the Company Retain Your Personal Data?
The Company will not retain your personal data for longer than the period for which the data are required to fulfil the purpose for which they are used, and for a maximum period of three years, except in exceptional cases where a longer retention period is prescribed by law. For example, data relating to the exercise of your privacy protection rights will be retained permanently, while invoice data will be retained for 11 years.
More detailed information concerning data retention periods may be obtained by contacting the Company’s Data Protection Officer at the e-mail address.
What Will the Company Use Your Personal Data For?
The Company may use your personal data in several different ways, primarily to perform its legal and other obligations towards you, but sometimes also to improve your experience of using the website and for security reasons.
The purposes for which the Company uses your personal data are described in this Privacy Policy. Where your data are to be processed for other purposes, you will be informed before such new processing is carried out.
Cookies
In order to maintain the website and ensure that its functionalities remain at the expected level, the Company uses technology known as “cookies”.
Cookies are small files that are sent to your computer and which the Company may subsequently access. They may be temporary or permanent. Cookies enable you to browse the Company’s websites without difficulty. Cookies indicate what interests you and other visitors to the website, which helps to improve the website.
For further information about cookies, please read the Cookie Policy.
Other Websites
This Privacy Policy applies only to the use and handling of data collected by the Company from users (data subjects). Other websites that may be accessed through the Company’s website have their own privacy and data collection statements and their own methods of using and disclosing data.
The Company is not responsible for the operating methods and terms of third parties.
Entry Into Force and Amendments to the Privacy Policy
This Policy enters into force upon its publication on the website.
The Company reserves the right to amend and supplement the Privacy Policy, and the amended and/or supplemented Privacy Policy will be published on the website.