Politika privatnosti

Privacy Policy: Introduction

Računovodstvo.HR d.o.o., Zagreb, Ulica Đure Crnatka 12 (office: Radnička cesta 180, Zagreb) (hereinafter: Računovodstvo.HR), places particular importance on the protection of personal data and the privacy of its users (hereinafter: privacy protection) in accordance with applicable legislation and European best practices. Protecting our users’ privacy is an integral part of our services and products and an important element of the overall user experience.

Through this User Privacy Policy (hereinafter: the Privacy Policy), we aim to provide users with clear information about the processing and protection of their personal data and enable them to easily control and manage their personal data and consents.

This Privacy Policy does not restrict users’ rights or impose additional obligations regarding the processing of personal data beyond those arising from applicable legislation and any contractual provisions concerning personal data protection. The Privacy Policy constitutes a unilateral legally binding act of Računovodstvo.HR.

  1. Scope
  2. Principles of Personal Data Processing
  3. How We Collect Personal Data
  4. Types of Personal Data We Collect
  5. Purposes for Which We Use Collected Personal Data
  6. Linking Personal Data
  7. User Consent
    Cookies
  8. How We Protect Personal Data
  9. Where Personal Data Is Processed
  10. Circumstances Under Which We Disclose Personal Data to Third Parties
  11. User Rights (Rectification, Erasure, Objection, Access, Restriction of Processing and Data Portability)
  12. Who to Contact
  13. Amendments,
  14. Supplements and Transitional Provisions of the Policy

1. Scope

This Privacy Policy applies to all personal data of users that Računovodstvo.HR collects, uses or otherwise processes, either directly or through its partners. Personal data means any information relating to an identified or identifiable natural person, whether directly or indirectly (hereinafter: data or personal data). Processing means any operation performed on personal data, such as collecting, recording, storing, using, transferring or accessing personal data.

This Privacy Policy does not apply to anonymous data. Anonymous data means data that has been modified in such a way that it can no longer be linked to a specific natural person, or cannot be linked without disproportionate effort, and therefore is not considered personal data under applicable legislation. Računovodstvo.HR applies European best practices in data anonymisation.

This Privacy Policy applies to all Računovodstvo.HR services and products involving the processing of personal data. Računovodstvo.HR services include all services provided by Računovodstvo.HR. The user’s most recent expression of preference regarding the processing of personal data applies to all other Računovodstvo.HR services used by that user. For example, if the user did not provide a particular consent when contracting one service but later provided that consent when contracting another service, the consent will be deemed to apply. Conversely, if the user initially gave consent but subsequently withdrew it when contracting an additional service, that consent will also be considered withdrawn in relation to the first service. Računovodstvo.HR generally identifies users through a unique user identification number (ID), and each user will normally have one ID to which the above rules apply. Where a user has more than one ID, consents may be collected and recorded separately for each ID.

As a general rule, Računovodstvo.HR acts as the data controller in relation to the personal data of its users within the meaning of applicable personal data protection legislation.

This Privacy Policy primarily applies to natural persons who request or use Računovodstvo.HR services (hereinafter: Users) and/or persons interested in using Računovodstvo.HR services (hereinafter: Potential Users). However, taking into account the legitimate interests of users that are legal entities, this Privacy Policy also applies, where appropriate and in accordance with applicable legislation, to legal entities. For the avoidance of doubt, this Privacy Policy applies in full to employees of legal entities that are users of Računovodstvo.HR where those employees are also in a contractual relationship with Računovodstvo.HR.

2. Principles of Personal Data Processing

2.1. Trust

We aim to be a reliable partner to our Users in protecting their privacy and to justify the trust they place in us. We also strive to be fully transparent and clear regarding the processing of Users’ personal data. This is one of the purposes of this Privacy Policy, particularly by enabling Users to play an active role in managing their data. Users may contact us at any time to request the amendment of personal data relating to them or to indicate the purposes for which they do or do not wish their data to be processed.

2.2. Lawfulness and Best Practice

When processing personal data, we comply with applicable legislation while also striving to apply higher standards and European best practices.

2.3. Purpose Limitation

We collect and process personal data only for specific and lawful purposes and do not subsequently process it in a manner incompatible with the purposes for which it was collected, unless otherwise required by law or based on the User’s consent.

2.4. Data Minimisation

We use only the User data that is appropriate and necessary to achieve a specific lawful purpose and do not collect more data than is required.

2.5. Processing in De-Identified Form

Whenever possible and appropriate, we use data in a de-identified form. This primarily includes anonymous data. Where possible and justified, particularly for the protection of Users’ personal data, we also pseudonymise personal data using appropriate techniques, such as substitution or hashing. This means that data is “masked” so that it cannot be attributed to a specific User without the use of additional information, which is stored securely and separately, for example by means of a key.

2.6. Integrity and Confidentiality

We process personal data securely, including protecting it against unauthorised or unlawful processing and against accidental loss, destruction or damage. For example, access to Users’ personal data is restricted to authorised persons who require such access to perform their duties.

2.7. Personal Data Quality

We attach great importance to the quality of the data we process. Personal data must be accurate, complete and up to date in order to ensure the highest possible level of protection and prevent potential misuse. For this reason, Users are requested to notify us immediately, or as soon as reasonably possible, of any changes to their personal data.

2.8. Storage Limitation

We store and process Users’ data only for as long as necessary to fulfil the relevant legitimate purpose, unless a longer or shorter retention period is required by applicable legislation or otherwise expressly prescribed by law. After that period, the data is permanently deleted or anonymised.

3. How We Collect Personal Data

Računovodstvo.HR collects Users’ personal data in the following principal ways:

3.1. Directly from Users

We primarily collect data directly from Users or Potential Users when they provide it to us.

3.2. Automatically When Users Use Services and/or Products

For example, we may collect data relating to use of our services, internet connections, IP addresses, communication times and similar technical information.

3.3. From Publicly Available Sources

For example, we may collect information from court registers, public directories, publicly available services or other publicly accessible sources. Any collection of Users’ personal data is subject to the existence of an appropriate legal basis under applicable law.

3.4. Types of Personal Data We Collect

Depending on the contracted service or product, the User’s consent and the purpose for which particular data is used, Računovodstvo.HR may collect the categories of User data described below. We always collect only the data necessary to achieve a specific lawful purpose. Where relevant, service applications indicate which information is mandatory for entering into a contract and which information may be provided voluntarily.

4. Types of Personal Data We Collect

Depending on the contracted service or product, the User’s consent and the purpose for which particular data is used, Računovodstvo.HR may collect the following categories of personal data. We always collect only the information necessary for a specific lawful purpose.

4.1. Contractual Data

Contractual data includes identification and other basic data provided by the User for the purpose of entering into and performing a contract.

4.2. Usage Data

Usage data may arise automatically when a User uses particular Računovodstvo.HR services or products where such information is necessary for providing the relevant service. This may include technical information such as the date and time of communication, information about devices used, IP addresses, internet connection data, the manner in which services are used and other information relating to Users’ interaction with Računovodstvo.HR products and services.

4.3. User Communications with Računovodstvo.HR

This may include written or electronic communications between Users and Računovodstvo.HR, communications through social media and similar channels.

This may also include information relating to interaction with Računovodstvo.HR content, such as YouTube channel views or interactions with content published on other social networks.

4.4. Potential User Data

This category includes identification and contact information, such as first and last name and email address, as well as information concerning a Potential User’s interest in Računovodstvo.HR services. As a general rule, Računovodstvo.HR records information relating to Potential Users who contact Računovodstvo.HR and request information and/or offers concerning particular products or services. Potential User data is deleted or anonymised upon request by the Potential User, subject to applicable legal requirements.

5. Purposes for Which We Use Collected Personal Data

5.1. Performance of a Contract

Računovodstvo.HR primarily collects and processes Users’ data for the purpose of entering into and performing contracts between the User and Računovodstvo.HR. This may include using data to verify the User’s identity, assess creditworthiness where appropriate, provide contracted services, calculate and collect fees, deliver ordered products, contact Users where necessary in connection with the provision of services, resolve complaints, monitor and ensure the quality and security of services and products, provide customer support, provide advice and assistance in using products and services, and perform other activities related to entering into and performing contracts in accordance with applicable law.

The legal basis for such processing is that it is necessary for the performance of a contract with the User or in order to take steps at the User’s request before entering into a contract.
If the User does not provide information necessary for entering into or performing the contract, Računovodstvo.HR may be unable to enter into the contract and/or perform certain obligations related to it.

5.2. Internal Purposes

Računovodstvo.HR may also use certain User data for its internal records and for the purpose of protecting the legitimate interests of Users and/or Računovodstvo.HR. This may include preventing, detecting and addressing misuse or fraud, ensuring the security of employees, Users, services and products, developing services and offers that reflect Users’ needs, improving the user experience, providing personalised customer support, and conducting market research and analysis.

The legal basis for this processing is the legitimate interest of Računovodstvo.HR, unless such interests are overridden by the interests or fundamental rights and freedoms of the User requiring the protection of personal data.

5.3. Direct Marketing of Services and Products

Računovodstvo.HR may use Users’ contact details to send promotional communications concerning Računovodstvo.HR services and products through permitted communication channels, unless the User has indicated otherwise. Where legally permitted, certain User information may be used to personalise promotional communications and offers so that they better reflect the User’s interests and needs. Users may object to receiving promotional communications at any time. In such cases, their data will no longer be processed for direct marketing purposes. Promotional communications concerning third-party products or services will be sent only where the User has provided the required consent.

5.4. Compliance with Legal Obligations

On the basis of a written request supported by applicable legislation, Računovodstvo.HR may be required to provide competent public authorities, such as courts, the police or the Tax Administration, with certain Users’ personal data or access to such data.

6. Linking Personal Data

Where necessary, personal data relating to a particular Računovodstvo.HR service or product may be linked with personal data relating to other services or products used by the same User.
Such processing is carried out only for the purposes and on the legal bases described above, with the aim of obtaining a more accurate understanding of Users’ needs and providing them with appropriate support, services and/or products.

Where appropriate, Users’ personal data may also be processed together with data relating to other Users. Such processing will generally be based on fully anonymised data or the User’s explicit consent. In exceptional cases, processing may be based on the legitimate interests of Računovodstvo.HR where the data has been appropriately pseudonymised.

Where relevant to entering into a contract, Računovodstvo.HR may assess information concerning a User’s ability to meet future financial obligations and, on that basis, decide whether to enter into a contract or request additional payment security, in accordance with applicable legislation.

7. User Consent

User consent means a freely given, specific, informed and unambiguous indication of the User’s wishes by which the User, through a statement or clear affirmative action, agrees to the processing of personal data for specific purposes. Consent may be provided in writing or by another appropriate method. Without the User’s consent, where consent is legally required:

  • we will not use personal data for purposes other than those necessary for performing a contract, providing services, preventing misuse, ensuring normal operation or complying with legal obligations;
  • we will not send promotional communications concerning third-party products or services;
  • we will not process personal data in other situations where applicable legislation requires consent.

Users control their preferences regarding the use of their personal data according to their own needs and interests. We therefore provide Users with a simple and free way to give or withdraw consent at any time through available communication channels.

8. Cookies

In order to provide Users and visitors with improved functionality and relevant content when visiting our websites or the websites of our partners, and to develop services and offers that meet Users’ needs and interests, we use cookies and/or similar technologies. These technologies may collect certain User information, such as the IP address from which the website is accessed, access time and similar information. Detailed information regarding cookies used by a particular website is provided when the User first visits that website. On the basis of this information, the User may grant or refuse consent to the use of non-essential cookies. Cookie preferences can also be adjusted through the User’s web browser. Računovodstvo.HR is not responsible for cookies used by third-party websites that are not owned or controlled by Računovodstvo.HR. Information obtained through cookies will only be linked with other User data for the purpose of improving the user experience where the appropriate legal basis, including consent where required, exists.

Social Media

Računovodstvo.HR publishes Users’ personal data on social media only with the User’s consent. Where personal data is published in connection with promotional competitions or similar activities organised through social media, Users will be informed in advance of the conditions governing the use of their personal data. Such personal data will not be used for purposes other than those specified. Only the minimum amount of personal data necessary to conduct the relevant competition or activity will be collected. Personal data will be used for the stated purpose only after the User accepts the applicable participation terms. The User may withdraw consent at any time, subject to applicable legal requirements, after which the relevant personal data will be deleted where there is no other legal basis for its continued processing.

9. How We Protect Personal Data

We use appropriate technical and organisational measures to protect Users’ personal data against unauthorised access by persons within or outside Računovodstvo.HR, alteration, loss, theft and any other form of data breach or misuse, in accordance with European best practices. These measures include, among others:

  • ensuring that our services and products meet applicable security and data protection requirements before being offered to Users, including the principles of privacy by design and security by design;
  • applying appropriate data anonymisation practices;
  • entering into appropriate personal data processing agreements with processors and service providers;
  • implementing appropriate safeguards on systems containing Users’ data;
  • regularly reviewing security and personal data protection measures;
  • providing ongoing training to employees.

10. Where Personal Data Is Processed

As a general rule, Users’ personal data is processed in the Republic of Croatia.
In certain cases, personal data may also be processed in other countries, for example where a subcontractor or service provider located abroad is engaged to provide a service or part of a service involving the processing of personal data. Such processing generally takes place within Member States of the European Union. Where personal data is transferred to or processed in other countries, Računovodstvo.HR ensures that appropriate safeguards are in place in accordance with applicable data protection legislation, including, where appropriate, the use of the European Commission’s Standard Contractual Clauses.

11. Circumstances Under Which We Disclose Personal Data to Third Parties

Users’ personal data is extremely important to Računovodstvo.HR. Računovodstvo.HR does not sell Users’ personal data. Računovodstvo.HR does not disclose or exchange Users’ personal data with other legal or natural persons except in the following circumstances:

a) where there is a legal obligation or express legal authority to do so, for example pursuant to a court request or order;

b) where another person or entity is engaged as a subcontractor or data processor to perform specific activities on our behalf, such as system maintenance, market research, printing and delivery of invoices, creditworthiness checks or debt collection. Such processors act solely on the instructions of Računovodstvo.HR, and appropriate measures are implemented to ensure the protection of Users’ personal data;

c) where disclosure to a third party is necessary for the performance of a contract with the User;

d) where another person is the holder of the relevant User agreement for services used by the User;

e) where claims are assigned to third parties in accordance with applicable legislation;

f) where the User has provided consent.

12. User Rights (Rectification, Erasure, Objection, Access, Restriction of Processing and Data Portability)

In addition to the right to manage consent, including the right to give and withdraw consent at any time, Users have the following rights in accordance with applicable legislation:

a) Right to Object: Users have the right to request at any time that they no longer receive promotional communications concerning Računovodstvo.HR services and products.
Users also have the right to object to other processing based on the legitimate interests of Računovodstvo.HR, including profiling based on such grounds.
Where a valid objection is made, Računovodstvo.HR will cease processing the relevant data for those purposes unless continued processing is permitted or required by law.

b) Responsibility for Safeguarding Data: Users are responsible for keeping confidential and appropriately protecting all identification credentials provided by Računovodstvo.HR, such as usernames and passwords.
Users must change their passwords or other access credentials immediately if they suspect unauthorised use and must notify Računovodstvo.HR where misuse of their identification credentials is suspected.

c) Right of Access: Users have the right to obtain confirmation as to whether their personal data is being processed and, where it is, to access that data and receive information concerning:

  • the purposes of processing;
  • the categories of personal data concerned;
  • recipients or categories of recipients;
  • the envisaged period for which the data will be stored, or the criteria used to determine that period;
  • the existence of applicable User rights;
  • the existence of automated decision-making, including profiling;
  • meaningful information concerning the logic involved and the significance and envisaged consequences of such processing;
  • safeguards applied where personal data is transferred to third countries.

d) Right to Erasure: Users have the right to request the deletion of personal data relating to them without undue delay, subject to the conditions and exceptions set out in applicable data protection legislation.

e) Right to Rectification: Users have the right to request the correction of inaccurate personal data relating to them.

f) Right to Data Portability: Users have the right to receive personal data concerning them that they have provided to Računovodstvo.HR in a structured, commonly used and machine-readable format and to transmit that data to another data controller where processing is based on consent or a contract and is carried out by automated means. Where technically feasible, Users may request the direct transfer of such personal data from Računovodstvo.HR to another data controller.

13. Who to Contact

Users may exercise their rights under Section 12 by submitting an appropriate request to:
Email: [email protected]
or by post to:

Računovodstvo.HR d.o.o.
Radnička cesta 180
10000 Zagreb
Croatia

Users may also exercise their rights through any other method made available by Računovodstvo.HR, depending on the nature of the request. If a User suspects a personal data breach, the matter may be reported in writing to [email protected] or by post to the address above. For any questions concerning this Privacy Policy and/or the protection of personal data by Računovodstvo.HR, Users may contact [email protected]. Users also have the right to lodge a complaint with the Croatian Personal Data Protection Agency (AZOP).

14. Amendments, Supplements and Transitional Provisions

This Privacy Policy entered into force and became applicable to Users on 25 May 2018 and is available on the Računovodstvo.HR website and at its business premises. Users will be informed in a timely manner of any amendments or supplements to the Privacy Policy, including through publication on the Računovodstvo.HR website.

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