PRIVACY POLICY

According to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to 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, 4.5.2016, p. 1., hereinafter: 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: the Act), the Labour Act (Official Gazette No. 93/14 and 127/17), the Occupational Safety Act (Official Gazette No. 71/14, 118/14 and 154/14), i.e. in accordance with the legal framework for the protection of personal data in the Republic of Croatia and the European Union and best European practice, KLOPA I CUGA D.O.O..

registered at the Commercial Court in RIJEKA (hereinafter: KLOPA I CUGA D.O.O.), as the controller of personal data of its service users and customers, has prepared the Privacy Policy of personal data of service users and customers. The Privacy Policy of personal data is a unilaterally binding legal act based on fundamental principles of personal data processing, which regulates which user data is collected, how such data is processed, and for what purposes it is used. The Privacy Policy also informs service users and/or customers about their rights in the collection and further processing of personal data, all for the purpose of protecting their privacy in a broader sense.

The Privacy Policy is based on the following principles of personal data processing: the principle of lawfulness, transparency and best practice, the principle of limited processing and data minimization, the principle of accuracy and completeness of personal data, the principle of limited storage, the principle of integrity and confidentiality of data, the principle of accountability, the principle of trust and fair processing, the principle of purpose limitation, the principle of anonymized processing.

The Privacy Policy applies to all services offered by KLOPA I CUGA D.O.O., with the aim of clearly and transparently informing users about the processing of their personal data and their rights. Above all, users may at any time contact the Company with a request for modification, supplementation and/or updating of the data relating to them, as well as withdraw the given consent and request the cessation of further processing of personal data.

The controller of personal data is: KLOPA I CUGA D.O.O.

Contact details for data protection:

e-mail: [email protected]

Methods of collection and types of personal data collected

Directly from users themselves, in such a way that users provide data to KLOPA I CUGA D.O.O. as the controller to the extent necessary for the provision of appropriate services, sales, or another user link with KOOGLANA.HR. For the purpose of providing appropriate services, the user is obliged to provide KLOPA I CUGA D.O.O. with the following data necessary to establish a contractual relationship for the provision of a particular service and/or sale of certain products. The customer – user may provide the data orally or in writing at the headquarters of KLOPA I CUGA D.O.O., via e-mail sent to one of the e-mail addresses of KLOPA I CUGA D.O.O., or via the website of KLOPA I CUGA D.O.O., KOOGLANA.HR.

From other publicly available data sources about Klopa i Cuga d.o.o. and natural persons in Klopa i Cuga d.o.o. on internet portals, telephone directories containing such data, and other publicly available services, but only for the purposes for which they were originally collected.

Automatically, by visiting the KLOPA I CUGA D.O.O. internet (web) site, applications, and portal, which involves data associated with online identifiers (internet protocol addresses and cookie identifiers, such as Google Analytics for tracking user and/or customer interaction).

A cookie is a small data file that is stored on a computer or mobile device when visiting a certain website. Cookies are used to provide a better user experience for each user and/or customer, to save preferences of users and/or customers, so that websites function more efficiently, and for monitoring and analyzing the use and visits to the KLOPA I CUGA D.O.O. website.

By disabling and/or blocking cookies, the user and/or customer may still browse the KLOPA I CUGA D.O.O. website. However, some options and/or functionalities of the website may not be available to such a user and/or customer, or the time required to access certain functions may be longer than usual.

The mentioned network identifiers may leave traces which, in combination with other identifiers and information provided by internet service providers, may be used to identify the user and/or customer.

The amount and scope of personal data collected by KLOPA I CUGA D.O.O. depend on the type of service provided to its users and/or customers, as well as on the legal basis under which the data is collected. Klopa i Cuga d.o.o. continuously ensures that only the minimum scope of personal data necessary to achieve the legally prescribed purpose of processing is collected.

Data on potential users

Klopa i Cuga d.o.o. also collects data on potential users and/or customers of its services and/or products. This data includes basic data (name and surname, e-mail address), as well as the interests of potential Users and/or Customers who contact the company with the desire to be informed and/or offered certain products and services.

A cookie is a small data file that is stored on a computer or mobile device when visiting a certain website. Cookies are used to provide a better user experience for each user and/or customer, to save preferences of users and/or customers, so that websites function more efficiently, and for monitoring and analyzing the use and visits to the KLOPA I CUGA D.O.O. website.

By disabling and/or blocking cookies, the user and/or customer may still browse the KLOPA I CUGA D.O.O. website. However, some options and/or functionalities of the website may not be available to such a user and/or customer, or the time required to access certain functions may be longer than usual.

The mentioned network identifiers may leave traces which, in combination with other identifiers and information provided by internet service providers, may be used to identify the user and/or customer.

The amount and scope of personal data collected by KLOPA I CUGA D.O.O. depend on the type of service provided to its users and/or customers, as well as on the legal basis under which the data is collected. Klopa i Cuga d.o.o. continuously ensures that only the minimum scope of personal data necessary to achieve the legally prescribed purpose of processing is collected.

Types of personal data collected?

The data most commonly provided by the Customer – User are:

first and last name

address

personal identification number (OIB)

contact telephone and/or mobile number

contact e-mail address

data from the identity card

bank account details and card number for payment purposes

Where is personal data processed?

Personal data of Users – Customers is processed by KLOPA I CUGA D.O.O. in the Republic of Croatia.

Where is the collected data stored?

The data is processed in such a way that all or part of the information on Customers – Users – Data Subjects is stored in the databases of the controller.

Obligations of the controller regarding data security

TECHNICAL AND INTEGRATED DATA PROTECTION

The Controller implements technical and organizational measures to ensure an adequate level of security.

The Controller also ensures that each individual acting under the responsibility of the controller, who has access to personal data, does not process that data unless instructed by the Controller.

Taking into account the nature, scope, context and purposes of processing, as well as the risks of varying likelihood and severity for the rights and freedoms of individuals, the Controller implements appropriate technical and organizational measures in accordance with Security Policies to ensure and demonstrate that processing is carried out in accordance with the General Regulation.

Purpose of data collection and further processing

Klopa i Cuga d.o.o. collects and further processes personal data of users and/or customers for the purpose of concluding and executing contracts, carrying out purchases or service interventions on equipment, delivering ordered products, providing advice and assistance in using products, providing appropriate additional and/or extended warranties for products, handling complaints of users and/or customers, and other actions related to the conclusion and execution of contracts in accordance with applicable regulations.

The processing of personal data of users and/or customers for the above purposes is a necessity and a legal basis for concluding a contract. If the user and/or customer refuses to provide the necessary data, the company will not be able to conclude the contract and/or take certain actions related to the execution of the concluded contract.

Organization of prize games

Klopa i Cuga d.o.o. occasionally organizes prize games, and data is used to notify about the prize won.

Direct marketing

Contact data of users and/or customers may be used to send promotional notifications about products and services of KLOPA I CUGA D.O.O., if the Customer – User has given consent.

Video recordings

KLOPA I CUGA D.O.O. uses surveillance cameras for the protection of people and property.

Retention period of personal data

Depending on the purpose and legal basis under which personal data of users and/or customers is collected, KLOPA I CUGA D.O.O. is in some cases obliged to retain personal data for the period prescribed by the applicable regulations or until the purpose for which they were collected ceases. Upon expiry of the statutory retention period or the purpose ceasing, the data is deleted.

In cases where the basis for the collection and processing of data is the consent of the user and/or customer, personal data is retained for 10 years.

The data processed based on the consent of users and/or customers may also be deleted before the expiry of the period specified in this Policy, if such deletion is requested by the user and/or customer, or when the user and/or customer objects to such processing in writing via the published e-mail address: [email protected].

Ways of exercising rights

Rights may be exercised if the user believes that there has been an irregularity in the processing of their personal data, via the contact details or by e-mail to [email protected]. The user and/or customer also has the right to lodge a complaint with the national supervisory authority.

Under what conditions and for what reason personal data is transferred to third parties

Personal data of Customers – Users is transferred by KLOPA I CUGA D.O.O. to third parties (including competent authorities) in the following cases:

to comply with the legal obligations of KLOPA I CUGA D.O.O. when such processing is necessary to protect the vital interests of Customers – Users

to fulfill contractual obligations, perform work on behalf of the Customer – User where it is necessary to engage a third party – processor

Processing of personal data in the context of employment

Personal data of employees may be collected, processed, used, and disclosed to third parties only if required by law or if necessary for the exercise of rights and obligations arising from employment, or in connection with employment.

For the purpose of exercising rights and obligations arising from employment, the Controller will collect, process, use, and disclose to third parties only those personal data that are necessary for that purpose, and such data will be disclosed only at the request of courts and other state or public authorities.