Personal data protection

Privacy Policy

Information about the processing and protection of personal data, users’ rights and how to exercise them.
Protecting privacy and confidential accounting data

Privacy Policy: Introduction

Računovodstvo.HR d.o.o., Zagreb, Ulica Đure Crnatka 12 (office: Zagreb, Radnička cesta 180) (hereinafter: Računovodstvo.HR), pays particular attention to protecting its users’ personal data and privacy (hereinafter: privacy protection), in accordance with applicable regulations and best European practice. Protecting users’ privacy is an integral part of our services and products and an important aspect of the user experience.

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

This Policy does not reduce users’ rights or impose obligations concerning the processing of personal data beyond those arising from applicable regulations and any contractual provisions on personal data protection. The Privacy Policy is 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. Combining personal data
  7. User consent
  8. Cookies
  9. How we protect personal data
  10. Where personal data is processed
  11. Conditions for disclosing personal data to third parties
  12. User rights (rectification, erasure, objection, access, restriction of processing, portability)
  13. Whom to contact
  14. Amendments, additions and transitional provisions of the Policy
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1. Scope

The Privacy Policy applies to all users’ personal data that Računovodstvo.HR collects, uses or otherwise processes, directly or through its partners. Personal data means any information relating to a natural person who is identified or identifiable, directly or indirectly (hereinafter: data or personal data). Data processing means any operation performed on personal data, such as collection, recording, storage, use, transfer and access.

The Privacy Policy does not apply to anonymous data. Anonymous data means data altered so that it cannot be linked to a particular natural person, or cannot be linked without disproportionate effort, and is therefore not considered personal data under applicable regulations. Računovodstvo.HR applies best European practice in data anonymisation.

The Privacy Policy applies to all Računovodstvo.HR services and products involving the processing of personal data. Računovodstvo.HR services means all services provided by Računovodstvo.HR. A user’s latest expression of wishes regarding personal data processing applies to all other Računovodstvo.HR services they use. For example, if a user did not give a particular consent when contracting one service but later gave that consent when contracting another service, they will be considered to have given that consent. The reverse also applies: if a user gave a particular consent when contracting the first service but subsequently withheld it when contracting an additional service, they will be considered not to have given that consent for the first service either. Računovodstvo.HR identifies users by a user identification number (ID), and generally one user has one ID to which the above rules apply. If a user has multiple IDs, consents may be collected and recorded separately for each.

Računovodstvo.HR is generally the controller of its users’ personal data within the meaning of applicable personal data protection regulations.

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

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2. Principles of personal data processing​

2.1. Trust

We want to be a reliable partner to Users in protecting their privacy and to justify the trust they place in us. We also want to be fully transparent and clear about the processing of Users’ personal data. This is one of the purposes of this Policy, particularly through the User’s active role in managing data. Users may always contact us to request changes to personal data concerning them or to state the purposes for which they do or do not wish their data to be processed.

2.2. Lawfulness and best practice

We process personal data in accordance with the law, while always striving to apply higher standards and best European practice.

2.3. Purpose limitation

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

2.4. Data minimisation

We always use only User data that is appropriate and necessary to achieve a particular lawful purpose, and no more data than that.

2.5. Processing in a non-identifiable form

Whenever possible and justified, we use data in a non-identifiable form. Such data primarily means anonymous data. However, whenever possible and justified, particularly to protect Users’ personal data, we pseudonymise personal data: through specific pseudonymisation procedures (e.g. substitution, hashing, etc.), we “mask” it so that it cannot be linked to an individual User without additional information kept securely and separately (e.g. the use of a key).

2.6. Integrity and confidentiality

We process personal data securely, including protection against unauthorised or unlawful processing and accidental loss, destruction or damage (for example, only authorised persons who need access to users’ personal data for their work have such access, not other employees).

2.7. Quality of personal data

We attach great importance to the quality of the data we process. Personal data must be accurate, complete and up to date to ensure maximum protection of Users’ data and prevent possible misuse. It is therefore important that Users notify us of any changes immediately or as soon as possible.

2.8. Storage limitation

We store and process Users’ data only for as long as needed to fulfil a particular legitimate purpose, unless applicable regulations provide for a longer or shorter retention period for a particular purpose, or in other cases expressly prescribed by law. After that, the data is permanently deleted or anonymised.

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3. How we collect personal data​

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

We primarily collect data from the User or Potential User when they provide it to us.

3.2. Automatically when the User uses services and/or products

For example, we collect data about the number called, call duration, internet connections, IP address, time of communication and similar information.

3.3. From publicly available sources

For example, data from the court register, public telephone directory, publicly available services or publicly available numbering. Any collection of Users’ personal data requires an appropriate legal basis established by law.

3.4. Types of personal data we collect

Depending on the contracted service or product, the User’s consents and the purpose for which particular data is used, Računovodstvo.HR is authorised to collect the types of User data listed below. We always collect only data necessary to achieve a particular lawful purpose. Service request forms also indicate which data is mandatory for entering into a contract; providing other data is voluntary.

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4. Types of personal data we collect​

Depending on the contracted service or product, the User’s consents and the purpose for which particular data is used, Računovodstvo.HR is authorised to collect the types of User data listed below. We always collect only data necessary to achieve a particular lawful purpose. Service request forms also indicate which data is mandatory for entering into a contract; providing other data is voluntary.

4.1. Contract data

Contract data, in a broader sense, includes master data, i.e. data the User has provided for the purpose of entering into and performing a contract.

4.2. Usage data

Usage data, in a narrower sense, arises automatically through the use of individual Računovodstvo.HR services and products because it is necessary to provide the service. It includes, for example: electronic communications traffic data (e.g. the date, time and duration of communication, the calling and called numbers, signalling, the device’s approximate location, information about the user’s device, the volume of data traffic used and IP address), data about how services are used, and Users’ habits when using Računovodstvo.HR products and services.

4.3. User communications with Računovodstvo.HR

For example, Users’ written or electronic communications with Računovodstvo.HR, communications with Računovodstvo.HR on social media, etc.

For example, data about views of the YouTube channel, posts on other social networks and similar information.

4.5. Data about Potential Users

This data includes master data, particularly contact details (e.g. first and last name, email address), as well as a Potential User’s interest in Računovodstvo.HR services. As a rule, Računovodstvo.HR records data about Potential Users who contact it wishing to receive information and/or an offer for particular products and/or services. Potential Users’ data is deleted or anonymised at their request.

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5. Purposes for which we use collected personal data​

5.1. Performance of a contract

Računovodstvo.HR collects and processes (hereinafter: uses) users’ data primarily to enter into and perform contracts between the User and Računovodstvo.HR. This particularly includes using data to verify the User’s identity and ability to pay, provide the contracted service, calculate and collect charges, deliver ordered products, contact the User when necessary in connection with providing a service, resolve complaints, monitor and ensure the quality and security of services and products, provide customer support, advice and assistance in using products and services, and carry out other activities connected with entering into and performing contracts in accordance with the law.

The legal basis for processing data for these purposes is its necessity for performing the User’s contract or taking steps at the User’s request before entering into a contract. If a user does not wish to provide data necessary for entering into and performing a contract, Računovodstvo.HR will not be able to enter into the contract and/or carry out certain actions related to its performance.

5.2. Internal purposes

Računovodstvo.HR also uses certain User data exclusively for its own records, to protect the legitimate interests of the User and/or Računovodstvo.HR. This includes, for example, using User data to prevent, detect and pursue misuse to the detriment of Users or Računovodstvo.HR; ensure the safety of employees, Users, products and services; create services and offers meeting Users’ needs and wishes; provide an excellent user experience and personalised customer support; and conduct market research and analysis, etc.

The legal basis for processing data for these purposes is Računovodstvo.HR’s legitimate interest, except where that interest is overridden by the User’s interests or fundamental rights and freedoms requiring protection of their data, and/or the legal basis of protecting the vital interests of the User or another natural person.

5.3. Direct marketing of services and products

Računovodstvo.HR may also use all User contact details to send promotional notices about all its services and products through all marketing channels, unless the User specifies otherwise. To provide notices matching the User’s wishes and habits, Računovodstvo.HR needs to use certain User data to prepare personalised promotional notices and offers. The User may state at any time that they no longer wish to receive promotional notices. In that case, their data will no longer be processed for direct marketing. Računovodstvo.HR will send the User promotional notices about third-party (partner) services and products only with consent.

5.4. Compliance with legal obligations

Based on a written request grounded in applicable regulations, Računovodstvo.HR must provide certain Users’ personal data, or access to it, to competent state authorities (e.g. courts, the police or the Tax Administration).

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6. Combining personal data​

Where necessary, we combine a User’s personal data relating to a particular Računovodstvo.HR service or product with the same User’s personal data relating to other Računovodstvo.HR services and products. We do so for the purposes stated above and in compliance with the stated legal bases, to obtain more accurate information about Users’ needs and habits and ultimately provide optimal support, services and/or products.

Where necessary, we process a User’s personal data together with other Users’ data. Such processing generally relies on fully anonymous data or the User’s explicit consent to processing a particular type of data. Only exceptionally does it rely on Računovodstvo.HR’s legitimate interest, and then only if the data is pseudonymised.

When entering into a contract, Računovodstvo.HR processes User data to assess the User’s profile in terms of their ability to meet future obligations. Accordingly, it decides whether to enter into a contract or request additional payment security for that purpose, all in accordance with specific regulations.

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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 personal data processing for specific purposes (opt-in). Consent may be given in writing or in another appropriate way. Without the User’s consent:

we will never use the following User data for purposes other than performing the contract, i.e. providing the service, preventing misuse, ensuring normal operation or fulfilling Računovodstvo.HR’s legal obligations, particularly not for direct marketing;
we will never send the User third-party promotional messages;
we will never process User data in other cases where consent is required by applicable regulations.
The User manages their wishes concerning the use of their data according to their needs and interests. For this purpose, we enable the User to give or withhold consents at any time, easily and free of charge, through various channels.

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8. Cookies​

To provide Users and visitors with better functionality and more interesting content when visiting our websites or our partners’ websites, and to create services and offers meeting Users’ needs and wishes, we use cookies and/or other common techniques (hereinafter: cookies) that collect certain User data (e.g. the IP address used to access the website, connection time, etc.). Users receive detailed information about the cookies used by each website on their first visit. Based on this information, the User gives or withholds consent to cookie use when visiting the website. Cookie settings can always be adjusted in the browser. Računovodstvo.HR is not responsible for cookies on other websites it does not own. We combine information about the User obtained through cookies with other User data to understand the User better and provide a better user experience only on the basis of consent.

Social media

Računovodstvo.HR publishes users’ personal data on social networks only with their consent. Personal data is published on social networks only when running prize games through those networks. A user wishing to participate will be informed of the conditions for using personal data for participation. Such data will not be used for other purposes. The type of personal data collected for prize games is the minimum set necessary to run each game. Personal data will be used for the purposes defined above only upon acceptance of the participation terms. The user may withdraw consent to participation at any time, and the data provided will be deleted.

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9. How we protect personal data​

We use various technical and organisational measures to protect Users’ data against unauthorised access by persons inside and outside Računovodstvo.HR, alteration, loss, theft and any other data breach or misuse, in accordance with best European practice. These measures include, among other things:

  • our services and products meet security and data protection requirements before we offer them to Users (privacy by design and security by design);
  • best practice in data anonymisation;
  • personal data protection agreements with all subcontractors;
  • implementation of all protection measures on systems containing User data;
  • regular checks of security and personal data protection measures;
  • continuous employee training.
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10. Where personal data is processed​

We generally process Users’ personal data in the Republic of Croatia. Exceptionally, we also process it in other countries (e.g. when a subcontractor from another country is engaged to provide a service or part of a service involving personal data processing), normally European Union Member States. Exceptionally, we also process it in other countries, but always ensuring appropriate personal data protection at least equivalent to processing in the Republic of Croatia (e.g. through the EU Standard Contractual Clauses for Processors in Third Countries).

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11. Conditions for disclosing personal data to third parties​

Users’ data is extremely important to Računovodstvo.HR. Računovodstvo.HR never sells Users’ personal data to anyone. It does not disclose or exchange Users’ data with any other legal or natural persons (hereinafter: persons), except in the following cases:

  1. a)
    where there is a statutory obligation or express authorisation under law (e.g. a court request);
  2. b)
    where we engage another person as a subcontractor, i.e. a processor, to perform certain tasks (e.g. printing and delivering invoices, market research, system maintenance, checking creditworthiness, or referring claims to debt collection agencies). It is important to emphasise that the subcontractor acts exclusively on Računovodstvo.HR’s instructions, and Računovodstvo.HR ensures all User data protection measures as if it performed these tasks itself.
  3. c)
    where data must be disclosed to third parties to perform the contract with the User (e.g. number porting);
  4. d)
    where another person holds the user contract for services used by the User;
  5. e)
    in the case of assignment of claims to third parties under Article 80 of the Civil Obligations Act;
  6. f)
    on the basis of the User’s consent.
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12. User rights (rectification, erasure, objection, access, restriction of processing, portability)​

In addition to their active role in managing consents, i.e. the right to give and withdraw consent at any time, Users also have the following active roles, all in accordance with applicable regulations:

  1. a)
    right to object: the User may request at any time that promotional notices about Računovodstvo.HR services and products stop. The User may also object to any other processing of their data based on Računovodstvo.HR’s legitimate interest, including profiling based on those provisions (opt-out). In that case, Računovodstvo.HR will not process data for those purposes unless otherwise provided by law.
  2. b)
    obligation to safeguard credentials: the User must keep all identifiers assigned by Računovodstvo.HR (e.g. username, password, etc.) confidential and exercise due care, because all actions taken using the User’s identifiers are considered the User’s own actions. The User must also change their password or other access credentials immediately upon suspecting unauthorised use and notify Računovodstvo.HR if they suspect misuse of their identifiers.
  3. c)
    right of access: the User may obtain confirmation as to whether their personal data is being processed and, if so, access to that data and information about the purposes of processing, categories of personal data, recipients or categories of recipients, the envisaged storage period or criteria used to determine it, the existence of Users’ rights, the existence of automated decision-making including profiling, information about the logic of processing and its significance and envisaged consequences, and safeguards where data is transferred to third countries.
  4. d)
    right to erasure: the User may obtain the erasure of personal data concerning them without undue delay and subject to the conditions set out in applicable data protection regulations.
  5. e)
    right to rectification: the User may obtain the rectification of inaccurate personal data concerning them.
  6. f)
    right to data portability: the User may receive the personal data concerning them that they have provided to Računovodstvo.HR in a structured, commonly used and machine-readable format and transmit that data to another controller where processing is based on consent or a contract and is carried out by automated means. Where technically feasible, the User may have the data transmitted directly from Računovodstvo.HR to another controller.
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13. Whom to contact​

Users may exercise their rights under Section 12 by submitting an appropriate request to [email protected] or to the postal address Računovodstvo.HR d.o.o., Radnička cesta 180, 10000 Zagreb, or by another method made available by Računovodstvo.HR, depending on the type of request.

If a User suspects a breach of their personal data, they should report their suspicion in writing to [email protected] or to the postal address Računovodstvo.HR d.o.o., Radnička cesta 180, 10000 Zagreb.

For any questions about this Policy and/or personal data protection at Računovodstvo.HR, users may contact [email protected].

The User is also entitled to lodge a complaint with the Croatian Personal Data Protection Agency.

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14. Amendments, additions and transitional provisions of the Policy​

The Privacy Policy enters into force and applies to users from 25 May 2018. It is available on Računovodstvo.HR’s website and at its business premises. Users will be notified of any amendments and additions in a timely manner, including through publication on Računovodstvo.HR’s website.

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