Client information

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CLIENT INFORMATION according to Article 7, Article 13, Article 14. and Article 21. General Regulation (EU) 2016/679 on the collection and processing of personal data and the rights of respondents in the process of providing a service from a registered activity.

The purpose of this information is to inform you in accordance with the provisions of the General Data Protection Regulation on all relevant features related to the collection of data, related to the provision of our service, their processing, the purpose of collection, storage, and your rights.

1. Processing manager:


Address: Marcilnica 70, 52220 Labin, Croatia

E-mail: [email protected]; Phone: +385 (0) 52 851 541.

Data protection officer: Phone: +385 (0) 52 851 541, E-mail: [email protected]

2. Purpose of collecting and processing personal data:

The main purpose and processing of your data is for purposes related to the conclusion of the contract, our legal obligation or to take action at your request or with consent.

In that sense, we collect data and further process it:

  1. In the process of pre-contractual relationship during your inquiries regarding the provision of the service, when concluding the contract with you, the execution of the contract we have concluded with you and for the purposes related to the provision of the contracted service;
  2. During your inquiries (objections, requests, complaints, guarantees) and answering or acting on your inquiries;
  3. To contact you during and immediately in connection with the contractual relationship;
  4. To act in accordance with applicable regulations in order to meet our legal obligations as well as to provide information that we are required to do by law;
  5. For the purpose of performing financial calculations, filing legal claims and defense in case of disputes, ensuring information and general security, including the security of facilities.

3. Categories and legal basis for personal data processing:

You are obliged to provide accurate and true data and to inform us in a timely manner about the change of data. In order to provide our service and keep records of clients, we process the following personal data:

  1. Basic personal data: Name, surname, address. Collection and processing of personal data about the defined purpose are a necessary condition for providing the service (the content of the invoice is prescribed by the General Tax Act, the Value Added Tax Act, the Income Tax Ordinance, and the Cash Fiscalization Act). If you refuse to provide certain mandatory information, we will not be able to fulfill our legal or contractual obligations, which will result in the inability to provide the service. We process your data when acting on your request, to meet our legal obligations, to take action before the conclusion of the contract or to execute the contract, to contract and execute orders, and based on legitimate interests.
  2. Additional personal data that you provide to us voluntarily: e.g. OIB data, title. The collection of the above data is not a condition of providing the service. We process your data when acting on your request and in the communication process.
  3. Contact information: mobile phone number, the e-mail address of the user, we process based on your consent exclusively for the purpose of contacting related to the execution of the contractual relationship, the provision of our services, and the improvement of our service. You are not obliged to provide the stated information (it is not a legal or contractual obligation), but you provide it voluntarily and it is not a condition for concluding a contract. You can withdraw your consent at any time. More about consents under the point of disposing of consents.

If you refuse to provide certain information based on consent or our legitimate interest, it will not affect the possibility of concluding a contract or fulfilling a contract, but it may affect the provision of quality of service such as timely contact.

Our legitimate interests as a basis for processing include:

  1. Processing an overview of the services provided, so that we can offer you the appropriate services tailored to your needs, provided that you have not objected to the use of your data.
  2. If you do not fulfill your legal obligations, in order to protect ourselves as a creditor, we may forward appropriate personal data and use the services of natural and legal persons to collect receivables (e.g. law offices). Before we take such action, we will notify you via the contact information you have provided to us.
  3. Protection of the safety of facilities and installations, clients, and employees (e.g. through video surveillance) and to provide evidence in the event of the commission of criminal offenses and their prevention.

4. Recipients/categories of recipients:

Your data is disclosed or transmitted to:

  1. External persons in cases with the execution of a contract concluded with you;
  2. When we are obliged by law to provide data, e.g. Ministry of Finance – Tax Administration, Financial Agency;
  3. Data processing service providers with which we have a contract;
  4. As a result of our legitimate interests (e.g. lawyers, courts);
  5. If you gave your consent.

The purpose of personal data processing will require that your basic personal data be disclosed and that it be processed by other companies and persons in our capacity as executors of processing (based on contracts for accounting services, postal services to providers, customer data processing program development services). Executors of personal data processing, with the exception of state and public authorities, process data exclusively according to our instructions, while respecting technical and organizational measures to ensure the protection of your rights.

Your individual information may be passed on to third parties as a result of our legitimate interests (e.g. lawyers, courts), and if you have given your consent.

5. Indication of whether the controller intends to transfer the data to a third country or to an international organization:

We will not transfer your data to third countries or international organizations.

6. Period of retention of personal data:

Your personal data will only be stored for as long as necessary for the purpose for which the personal data is processed. The retention period depends on the purpose and legal basis of the collection.

In principle, we keep telephone and email contact information to contact you during the contractual relationship, and during the termination of the contractual relationship for a period of 1 year, i.e. until the withdrawal of consent.

When concluding a contract, we store personal data for the duration of the contract and the period of contract collection. We point out that regarding the storage and documentation of data, we are subject to legal obligations due to which we must keep your certain data even after the termination of the contractual obligation, within the deadlines prescribed by special laws.

If your other data is no longer needed to fulfill contractual or legal obligations, answers to inquiries, they are regularly deleted as of a rule within 6 months, unless further processing is required for a limited time to meet our legitimate interests. If a forced collection procedure or court proceedings have been initiated in connection with the provision of the service, we do not delete the data until its completion following applicable regulations and to protect our legitimate interests.

We process personal data based on the consent until the respondent withdraws the consent, after which we store the document of consent and withdrawal for archival purposes for a period of 5 years from the withdrawal to prove lawful processing based on consent. Your personal data will only be stored for as long as necessary for the purpose for which the personal data is processed. The retention period depends on the purpose and legal basis of the collection.

7. Disposal of consents:

  1. You can revoke the consent you have given at any time. You may also object to our processing of your personal data at any time. You can change your consent and object by submitting a statement via our e-mail address, to the address of the registered office, or, if appointed, to the Data Protection Officer.
  2. If you wish to give your consent again, you can do so to our e-mail, headquarters address, or, if appointed, to the Data Protection Officer.
  3. If you revoke the given consent, we will no longer use it for the stated purposes.  When you give your data or consent for processing voluntarily – consent, then the denial of consent does not result in the impossibility of concluding a contractual relationship/provision of services, but in that case, you will not be able to obtain the benefits for which we requested consent.

8. The rights of users in relation to collected data:

  1. The right of access to data and correction
    At any time you have the right to receive confirmation from us whether we process your personal data, request access to personal data we process about you, or about children whose legal representative you are, and all rights and information prescribed by Art. 15. and Art. 16. EU Regulations and the applicable legislation of the Republic of Croatia. If the information is incomplete or inaccurate, you can ask us to correct or supplement it at any time.
  2. The right to delete
    You have the right to request the deletion of your personal data if:
    – Personal data are no longer necessary for the purpose for which they were collected or otherwise processed;
    – You withdraw the given consents and there is no other legal basis for processing;
    – File an objection to the processing, the legitimate reasons for the right to erasure have more weight for the legitimate reasons of the controller to process and/or keep personal data;
    – They have been processed illegally or personal data must be deleted to comply with the legal basis, and all rights and information prescribed by Article 17. EU Regulations and the applicable legislation of the Republic of Croatia. In doing so, we point out the circumstances that there are reasons that prevent immediate deletion, for example in the case of legally prescribed archiving obligations.
  3. The right to limit processing
    You have the right to request a restriction on the processing of your data if:
    – The disputed the accuracy of the data during the period which allows the controller to verify the accuracy of that data;
    – Data processing was illegal, but to refuse the deletion and instead seek a restriction on the use of the data;
    – If the data controller no longer needs the data for the intended purposes, but if you need additional radios to set, implement, or defend legal claims, or;
    – You have filed a complaint due to the processing of this data according to Art. 21st.1 of the Regulation, expecting whether the legitimate reasons of the controller exceed your reasons, and all rights and information prescribed by Article 18. EU regulations and the current legislation of the Republic of Croatia.
  4. Obligation to notify
    The controller shall communicate any rectification or erasure of personal data or restriction of processing proved under Article 16, Article 17 (1), and Article 18 of the Regulation to any recipient to whom personal data have been disclosed unless this proves impossible or requires disproportionate effort. The processing manager informs the respondent of these recipients if the respondent so requests.
  5. The right to transfer data
    You have the right to provide you with information relating to you, which you have provided to us in a structured form, in a common and machine-readable format:
    – If we process this data based on the consent you have given us and which you can revoke, i.e. to fulfill our contract
    – If the processing is performed using automated processes, i.e. under Article 20 of the EU Regulation and the applicable legislation of the Republic of Croatia
  6. The right to object
    You have the right to object to the processing of your personal data at any time. If you believe that we have violated Croatian or European data protection regulations during the processing of your data, you have the right to file a complaint with the Croatian Personal Data Protection Agency, or in case of changes in applicable regulations to another body that will take over its competence.
  7. Exercise of rights
    If you want to exercise any of these rights, please contact us using our contact details in Article 1 of this Statement.
  8. Confirmation of identity
    In case of doubt, we may request additional information to verify your identity. This serves to protect your rights from the private sphere.
  9. Abuse of rights
    If you exercise any of these rights too often and with an apparent intent to abuse, we may charge an administrative fee or refuse to process your request.

9. Information on the existence of automated decision making:

We do not apply an automated decision-making process.

You can find out more about the protection of your rights and obligations by reviewing our Privacy Policy published on our website, by reviewing our Policy on the protection of personal data from 22.05.2018. year; which is located in the premises of the company’s headquarters and by inspecting the General Regulation on Data Protection EU 2016/679.