I/ RESPONSIBILITY FOR THE SECURITY OF COLLECTED PERSONAL DATA
The Company is responsible for the security of personal data collected.
In order to protect personal data, enable their processing and exercise your rights as a data subject whose personal data is processed, personal data may be provided to natural persons and legal entities with whom we cooperate under our contractual or legal obligations (eg. tax advisors, accounting services, law firm , competent public authorities).
II/ WHAT PERSONAL DATA DO WE PROCESS
The personal data we process may include:
– data for establishing and maintaining contact such as name and surname, residential address, residence, personal identification number, occupation-business function, postal address, business address, telephone number, fax number, mobile phone number, e-mail;
– data relating to the issuance of invoices and payment processing and the implementation of legal obligations in relation to the prevention of money laundering and terrorist financing such as bank account numbers, payment card data and other relevant information;
– further business data that is strictly necessary for the purpose of establishing a contractual relationship or that has been voluntarily provided to us, such as instructions, specific requirements and / or orders;
– previously published data that we collect through publicly available registers, records and archives;
– details of mutual communication (written correspondence, etc.) as well as conducted conversations to the extent necessary for the exercise of rights and obligations under the contractual relationship.
III/ HOW WE COLLECT PERSONAL DATA
We collect and process your personal data depending on the circumstances, including:
– when and if the collection of personal data is necessary for the purpose of establishing a contractual relationship and exercising the rights and obligations arising from it;
– when you contact us directly or through electronic communications and / or our employees with purpose of establishing a business relationship or expressing interest for the purpose of establishing a business relationship;
– when our employees contact you or a legal entity in which you are a shareholder, holder of direct or indirect economic interest or perform an appropriate function including employment, with the aim of establishing a business relationship or expressing interest to establish a business relationship;
– when you use any of our services or applications for the purpose of the functionality of those services and applications or to improve the functionality of those services and applications;
– for the purpose of distributing promotional material and advertising our products and services;
– in certain circumstances we collect and process your personal data through third parties. For example, we may collect personal information from a legal entity with which you have a business relationship, other legal entities with which your legal entity has a business relationship, other publicly available registers, records and archives.
IV/ ARE YOU OBLIGED TO GIVE US PERSONAL DATA
In principle, you provide all personal data to us voluntarily; as a rule, there are no negative or harmful consequences if you decide not to provide us with your personal data. However, there are circumstances when the Company cannot take business activities, provide its service or use of the Company’s application, take legal action without your personal data, for example when personal data is necessary to process your orders, instructions, requests and pleas, for the purpose of establishing a legal obligation. In all these cases, the collection and processing of your personal data is a condition for the provision of our services unless there is some other legal basis for their collection such as legal or contractual basis.
V/ PURPOSES FOR WHICH WE PROCESS PERSONAL DATA
We process personal data exclusively for the following purposes (hereinafter: Permitted purposes):
• for the purpose of establishing and exercising rights and fulfilling employment obligations;
• for the purpose of exercising the rights of employees prescribed by special laws;
• for the purpose of exercising the rights of the Company as an employer from the employment relationship and in connection with the employment relationship;
• for the purpose of protecting the safety and health of employees;
• for the purpose of production and delivery of promotional material;
• for the purpose of establishing a contractual relationship and exercising the rights and obligations arising from it;
• for the purpose of managing and administering business processes related to the fulfillment of contracts and the exercise of rights and obligations arising from it, including payment processing, bookkeeping purposes, auditing, collection of receivables and support services in connection with the above;
• for the purpose of harmonizing and fulfilling our legal obligations as well as obligations that may arise from the law of the European Union and the rights of third countries to the applicable extent and to the extent and content in which these rights do not contradict the law of the Republic of Croatia;
• for the purpose of analyzing and improving our services and applications and communicating with you;
• for the purpose of security protection and access control to our business premises, IT and communication system, online platforms, websites;
• for the purpose of identifying the person authorized to represent our contractual partners, signing orders and accepting offers and concluding a contractual relationship with us;
• for the purpose of respecting court decisions and decisions of public bodies and legal entities with public authority and exercising our rights and interests based on law;
• for the purpose of keeping records of statistics related to our business;
• for the purpose of marketing, promotion and propaganda;
• for any purpose deemed necessary in connection with the accomplishment of any of the foregoing purposes.
For the purpose of communication related to marketing services, provided that such an obligation is prescribed by law, we will send you only the information in relation to which you have given consent and only as long as you do not withdraw consent. We will not use your personal data to take any other action or create a profile except in the cases listed here.
Depending on the Permitted Purposes for which we process your personal data, we may process your personal data on the following legal grounds:
• if you have given your consent to the processing of your personal data for one or more Permitted purposes;
• processing is necessary for the execution of the contract to which you are a party or in order to take action at your request before conclusion of the contract;
• processing is necessary to comply with our legal obligations;
• processing is necessary to protect your key interests;
• processing is necessary for our legitimate interests in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data. 46 / EC (hereinafter: GDPR).
VI/ WHO CAN WE SHARE YOUR PERSONAL DATA WITH
We may share your personal data in the following circumstances:
If you are our business partner or user of our services or applications, we may share your personal data with external associates such as law firms, accounting services, tax advisors, credit bureaus and financial institutions, business entities with which cooperation is necessary to exercise rights and obligations under a contractual relationship (eg. printing works), debt collection agencies, public bodies and bodies with public authority, where this is necessary for the protection of contractual rights and / or claims, or when it is in the public interest or when it represents legal obligation.
We may share your personal data on a confidential basis with third parties for the purpose of obtaining your opinion on the quality of our products and services to help us improve the quality of our products and services.
We may share your personal data with third parties to whom we have transferred or assigned rights from the contractual relationship with you.
We are also authorized to instruct third parties to process your personal data in our name and on our behalf and in accordance with our instructions as the controller, in which case we assume responsibility for the confidentiality and security of your personal data. In this case, the Company remains fully responsible to you for the security and confidentiality of personal data and will use all necessary measures required by applicable regulations to ensure the integrity and security of your personal data.
We may also use your personal data for statistical purposes to monitor visits to and use of our websites and applications in order to develop our business and improve the quality of our websites and applications.
Otherwise, we may disclose your personal data to a third party only if you give us consent to such a thing, whether the consent is contained in a separate document or constitutes a separate clause in the contract, if it is a legal obligation or an obligation in accordance to a court order or other public authority or body with public authorities.
VII/ PERSONAL DATA OF THIRD PARTIES THAT YOU PROVIDE TO US
VIII/ PERSONAL DATA PROTECTION
We will protect your personal data by applying appropriate technical and organizational and security measures in accordance with internal regulations and procedures regarding the storage, access, disclosure and access to personal data. Personal data may be stored in paper form and stored in special electronic personal data protection systems.
IX/ PERSONAL DATA TRANSFER
If the Company needs to transfer personal data to a third country or international organization, we will take all necessary measures to ensure that the level of protection of your personal data meets the requirements of the Regulation and other applicable regulations of the Republic of Croatia. We ensure this, inter alia, by applying standard contractual clauses issued by the European Commission (Commission Decision of 15 June 2001 on standard contractual clauses for the transfer of personal data to third countries, in accordance with Directive 95/46 / EC and Commission Decision of 27 December 2004 amending Decision 2001/497 / EC as regards the introduction of an alternative set of standard contractual clauses for the transfer of personal data to third countries). In the event of such a transfer, the recipient of personal data in a third country or international organization shall ensure the level of protection required by the Regulation. In the case of transfer of personal data to third parties, the Company will ensure that these persons provide the same level of protection as provided by the Company.
X/ CHANGES IN PERSONAL DATA
If any personal data you provide to us changes (eg your e-mail, residential address, etc.) or if you learn that we have inaccurate personal data, please let us know by sending an e-mail to the next e-mail address: email@example.com.
The Company is not liable for any losses arising from inaccurate, untrue, defective or incomplete personal data provided to us.
XI/ HOW LONG DO WE KEEP PERSONAL DATA
Your personal data will be deleted when the reasonable need to keep them for Permitted purposes ceases or to the extent applicable when you withdraw your consent, provided that we are not obliged to keep personal data on the basis of legal obligations. In any case, we will keep your personal data as long as there is a need to keep them for the purpose of realizing the rights and obligations under the contract or business relationship, including the need to enforce the collection of the claim.
XII/ YOUR RIGHTS
Subject to the conditions prescribed by the Decree or regulations of the Republic of Croatia, you have the right to withdraw consent (if the processing of personal data is based on consent and there is no other legal basis), the right to inspect the collected personal data, the right to request a copy of personal data, the right to request a change in the collected personal data, the right to delete personal data, the right to transfer the collected personal data, the right to object to the processing of personal data. If you decide to do any of the above, please contact us by sending an e-mail to the following e-mail address: firstname.lastname@example.org. When sending, we may ask you to prove your identity by submitting a valid copy of your personal document from which your identity can be established in order to comply with applicable regulations and prevent unauthorized disclosure of personal data. We reserve the right to charge you additional fees if you abuse your right to access personal data, for example in the case of repeated requests or requests for additional copies of documents without a reasonable basis. We will review all your requests and complaints that we receive and respond to them in a timely manner. If you are not satisfied with our answer, you can send your remark to the body responsible for personal data protection – Personal data protection agency.
Contact details of the Personal Data Protection Agency:
Martićeva ulica 14
HR – 10000 ZAGREB
Tel. 00385 (0) 1 4609-000
Fax. 00385 (0) 1 4609-099
XIV/ HOW TO CONTACT US
Korčulanska ulica 2, Zagreb, Croatia
represented by the director