PRIVACY POLICY
BOORA d.o.o. Zagreb
INTRODUCTION
Boora d.o.o., Zagreb, Maksimirska cesta 98, OIB: 27544643668 (hereinafter: “Boora”; “we”) is dedicated to protecting the privacy of our customers, employees, suppliers, visitors of our web sites as well as of all users of the services provided by us (hereinafter: „Client“; „User“; “you”).
This privacy policy is provided in order to explain how we, as a data processor, process your personal data. „Personal data“ means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly. The purpose of this policy is to provide clear and understandable information to you about the processing of your personal data. This policy does not in any way limit or restrict any rights which you may have in accordance with applicable regulations.
We only process your Personal Data in accordance with applicable law: 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 (hereinafter: “General Data Protection Regulation”, “GDPR”), the Croatian Act on implementation of the General Data Protection Regulation and other laws and regulations in force in Croatia.
NO OBLIGATION TO PROVIDE DATA
You are not obliged to provide us with any personal data.
However, to the extent that some data may be necessary for conclusion of contracts, provision of our services or fulfilling a request made by you, we will not be able to conclude a contract or provide the requested services if such data is not provided to us.
PRINCIPLES OF DATA PROCESSING
The fundamental principles by which we are guided in handling and processing your date, in order to ensure the protection of your rights and lawful processing of data, are:
Lawfulness, fairness and transparency. We shall process your data in accordance with the applicable regulations, fairly and transparently to the user.
Limitation of purpose. The data we collect shall be used solely for lawful purposes and in accordance with such purpose.
Accuracy. We shall endeavour to ensure that the data we have is accurate and up to date and shall update or delete data for which we learn is no longer such.
Limitation of data storage. We shall collect and process only data which is necessary for a lawful purpose. Data shall be stored only in so far as it is necessary for the purpose for which it is processed, after which time we shall delete it or anonymize it.
Integrity and confidentiality. We shall endeavour to protect your data from any forms of unauthorized access and processing, accidental loss, destruction or damage using appropriate technical and organizational measures.
DATA COLLECTION
Data shall be collected in the following manner, where there is legal basis for collection and processing of such data:
- directly from the user or potential user, when you contact us regarding information on services we offer, to engage our services or for other reasons and from documentation which you deliver to us;
- from publicly available sources such as public registers, contact listings, your website and other publicly available information;
- from our other clients, where such data is necessary for provision of our services.
CATEGORIES OF DATA
Depending on the nature of your relationship with us, we shall collect and process some of the following categories of personal data, to the extent that such data is necessary for fulfilment of a lawful purpose:
- Data necessary for conclusion or execution of a contract, such as your identification information (name, surname, address, personal identification number), data on services which are requested and details of the engagement, data necessary for payment of the services and similar;
- Data for communication with Clients, potential clients and other persons with which we have a business relationship, primarily email address, telephone number and postal address.
- Data on previously provided services, potential needs and interests of the Client or potential client;
- Your communication with us, such as letters or emails.
PURPOSE AND LEGAL BASIS FOR DATA PROCESSING
We shall collect and process your data for the following purposes:
- Conclusion of contract and execution of our contractual obligations to clients. Without this data it is not possible to conclude a contract or provide our services.
- Fulfilment of your request and answers to your queries.
- Direct marketing of our services, by sending information to persons which expressed an interest for some of our services or those of our clients for which we act as brokers, or if for some other reasons you represent a potential client or customer.
- Improvement of our internal procedures and organization of work, improvement of our services and business processes, such as analysis of previous engagements, types of engagements and similar.
- Fulfilment of our legal responsibilities, when we are obliged under applicable regulations to collect, process or retain data (such as under applicable anti-money laundering regulations, tax laws and similar).
- Based on your consent, in accordance with the purpose for which the consent was given.
DATA STORAGE AND RETENTION
We shall store your data in a manner appropriate for ensuring its security, considering the nature and type of data.
Data shall be collected only as long as there is a lawful basis for its retention and processing. We shall periodically as well as on your request revise the need for retention of data and if such a need no longer exists delete or anonymize the data.
Data collected based on your consent shall be stored only as long as your consent is not withdrawn.
LOCATION OF DATA PROCESSING AND THIRD PARTIES
Your data shall be processed in the Republic of Croatia.
Your data shall not be shared with third parties, except when we have engaged such third parties in accordance with the applicable regulations to act as data processor and such third party shall act on our account while ensuring all your rights as if we were processing the data ourselves (such as when we hire professional third party services, accountants, lawyers and similar).
Data shall also be given to authorities and other bodies where we are expressly obliged or authorized by law to share such data, for example in case of court orders, inspections by tax authorities and similar.
YOUR RIGHTS
Your right of access. If case of your inquiry, we’ll confirm whether we’re processing your personal data and, if so, provide you with a copy of that data (along with certain other details).
Your right to rectification. You should update the personal data held by us by contacting us directly by mail, email or by making a change through our website. We encourage you to update your data as and when there is a change to them. If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly. If appropriate, we may request suitable evidence of change of the data before rectification.
Your right to erasure. You can ask us to delete or remove your personal data where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to restrict processing. You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.
Your right to data portability. You have the right, in certain circumstances, to obtain personal data you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
Your right to object. You can ask us to stop processing your personal data, and we will do so, if we are: relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or processing your personal information for direct marketing.
Your rights in relation to automated decision-making and profiling. You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us, is authorised by Law of Republic of Croatia or based on your explicit consent.
Your right to withdraw consent. If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time.
Your right to lodge a complaint. If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can at any moment lodge a complaint with us as provided in this privacy policy or contact the Croatian Personal data Protection Agency (AZOP). You can find details about how to do this on the AZOP website www.azop.hr .
WEB SITE
This privacy policy applies to the use of our web site www.boora.hr, regardless if accessed through a personal computer, mobile device or other means.
Cookie Policy
Our web site contains cookies and other technologies you should be aware of, please visit our Cookie Policy for information about our use of these technologies.
CONTACT INFORMATION
You can file any request for information or with the aim of utilizing any of your rights as well as any complaint in regard to the processing of your personal data to the following email address: [email protected] or by post: Maksimirska cesta 98, 10000 Zagreb, Croatia.
PUBLICATION AND AMENDMENTS TO THIS POLICY
Any changes to this privacy policy shall be published on our website.
This privacy policy is available on our website as well as on request from any user.
Version: 1.0
Date of last amendment: [24.02.2022.]