Privacy policy
The company [ROCOSO PRIMERO d.o.o., Cesta dr. Franje Tuđmana 394, 21213 Kaštel Gomilica, 01188988235] as the Data Controller, hereinafter: (“the Company”), in accordance with the principle of transparency and the provisions of the General Data Protection Regulation (GDPR), on 06 April 2021 issues the following:
1. Introduction
The protection of personal data of ROCOSO PRIMERO d.o.o. is of particular interest to the Company. The aim of the Privacy Policy is to explain, in a clear and simple manner, what personal data we collect, how long we store it, why we collect it, who has access to your data, what rights you have, and how can you exercise them. When we collect your personal data or when you share them with us, we use them in accordance with this Privacy Policy. You will be notified of any amendments to the Privacy Policy in a timely manner, including by posting them on the Company's website.
Carefully read this Privacy Policy, and if you have any questions or doubts concerning personal data, e-mail us at: info@castellone.com.
2. What is personal data?
Personal data is information that can be used to identify you directly (e.g. your name) or indirectly (e.g. through aliases). In other words, personal data includes information such as your email address, home address, mobile phone number, PIN, financial information, etc. Personal data may also include numeric identifiers such as your computer IP address, mobile phone MAC address or cookies.
3. How do we collect personal data?
We collect data directly from you (for example, when you are our client, when you request an offer from us, when you contact us by telephone and/or visit us at our places of business), automatically (through our websites), or from a third party (from publicly available sources such as open databases or other publicly available data).
4. Why do we collect your data?
(purpose of processing and legal grounds for processing)
A)
Purpose of collecting data: fulfillment of contractual obligations
Legal grounds: Processing is necessary for the execution of a contract you are a party to
Category of personal data: Full name, financial data, contractual data
B)
Purpose of collecting data:
Communication with you, which includes processing for the purposes of:
a. Responding to your queries
b. Suggesting products that we believe you are interested in
c. Sending offers
d. Sending/delivering notices from us during the term of a contract
e. Responding to your complaints arising from a business relationship with us
Legal grounds: Processing is necessary for the execution of a contract you are a party to
1./2./5./ Legitimate interest
3. Processing is necessary in order to take action at the request of the respondent prior to the conclusion of a contract
4. Processing is necessary for the execution of a contract you are a party to
Category of personal data:
1. Data provided in the contact form
2. Data on previous purchases, contact information
3. Contact information
4. Contact information
C)
Purpose of collecting data: Collection of accounts receivable
Legal grounds: Legitimate interest
Category of personal data: Full name, contact information, financial data
D)
Purpose of collecting data: Protection of our property and ensuring the safety of property and third parties
Legal grounds: Legitimate interest
Category of personal data: Data collected by video surveillance
E)
Purpose of collecting data: Sending promotional content via newsletters
Legal grounds: Your consent
Category of personal data: Full name, e-mail address
F)
Purpose of collecting data: Protection of our websites from cyber-attacks and other threats
Legal grounds: Legitimate interest – increasing the Company's level of security and preventing fraud
Category of personal data: Technical data (IP address, operating system information, information regarding visits to our website)
G)
Purpose of collecting data: Meeting our legal obligations
Legal grounds: Processing is necessary to meet the legal obligations of the data controller;
Category of personal data: Full name, financial data, information on concluded contract
H)
Purpose of collecting data: Performance and organization analysis of our business, including processing for the purpose of drafting reports and management analysis. We also process your personal data for internal management purposes, conducting business audits, implementing business controls.
Legal grounds: Legitimate interest
Category of personal data: Full name, information on your transactions, information on concluded contract
5. Who do we share your personal data with?
Depending on the purpose for which we are collecting your personal data, we may share it with third parties who assist us in providing digital and e-commerce services, advertising (including digital and social media advertising) and marketing agencies, third parties that are necessary to deliver products, e.g. mail/delivery services, third parties which assist us in providing technical support, payment service providers, legal representatives and similar third parties. We may also disclose personal data as part of a business transaction, such as a merger or sale of property, and to the competent state authorities and public authorities.
6. How long do we store your personal data?
We only store and process your personal data as long as it is necessary for the fulfillment of a particular legitimate purpose, unless applicable regulations stipulate a longer period for storing the data for a specific purpose, or in other criteria for determining the period for storing personal data, including the following:
A) For what purpose do we collect personal data?
B) What are the legal grounds for personal data processing?
C) For how long is the data necessary in order to fulfill a certain legitimate purpose?
D) Are we subject to a legal obligation to store personal data? (In this case, we retain the data for the time period prescribed by law)
7. Safety and storage of personal data
We process personal data within the European Economic Area. We take all necessary organizational and technical measures to keep your personal data secure and protected from loss, destruction, alteration, forgery, manipulation and/or unauthorized access. We undertake to inform you and the competent authority in case of a breach of your personal data. We implement measures to ensure that we collect and process data in accordance with the provisions of this Privacy Policy and legal regulations. If we disclose personal data to third parties, we use appropriate legal and technical mechanisms to protect your personal data from breach.
8. Links to third-party websites
If you visit other websites through the links provided on our website, please be aware that these websites have their own privacy policies and that we are not competent nor responsible for them.
9. Online searches
Our website uses cookies and similar technologies. The purpose of cookies is to ensure that our website is working properly, to improve our service in order for it to be as efficient as possible. Cookies are small text files that can be stored on your computer and are used by your web browser. Information collected by cookies and similar technologies may include information about your login, login details, location, IP address, browser information, device information, visit duration, ads you search, pages you visit, etc. Most cookies we use are so-called “session cookies” that are deleted when a browser session ends. There are some permanent cookies which can be used to identify you as a visitor. It is your right to turn off cookies in your browser settings. You can read more about cookies in our Cookie policy.
10. Your rights
10.1. Right to withdraw given consent
When the processing of personal data is based on your consent, it is your right to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of the processing conducted pursuant to the consent given before its withdrawal. You can withdraw your consent by sending an email to info@castellone.com or writing to the Company's registered office.
10.2. The right of access to personal data
You have the right to request confirmation on whether we are processing your data and, if so, to access it, as well any information regarding the purpose of the processing, categories of personal data, recipients or categories of recipients, the estimated period during which the data will be stored or the criteria for determining this period, the existence of rights, the existence of automated decision making.
You can send your data access request to the following email address: info@castellone.com or you can write to the registered office of ROCOSO PRIMERO d.o.o. In order to process your request, we have the right to request identity verification.
10.3. The right to rectification of incorrect or incomplete data and the right of erasure
If your data is incorrect and/or outdated, you have the right to ask us to correct the information. You can request a correction by sending an email to info@castellone.com. In certain cases, you have the right to request the deletion of your data, i.e. you have the so-called “right to be forgotten”. Note that the right to be forgotten is not an absolute right. In other words, we have the right to refuse your request for deletion of data if we have a legitimate interest and/or legal obligation and/or right to retain certain data. You can send your deletion request by email info@castellone.com. In order to process your request, we have the right to request identity verification.
10.4. The right to object to the processing based on the legitimate interests of the Data Controller
You can object to data processing at any time, even when data processing is based on legitimate interests. Following an objection, we can no longer process personal data unless we prove that there are compelling legitimate reasons for processing that supersede your interests, rights and freedoms, or that the data are processed to make, exercise or defend legal claims. In order to process your request, we have the right to request identity verification.
10.5. The right to be informed and data portability
We are obligated to process your personal data transparently and clearly, and you have the right to receive easily understandable information about how we use your data. This is why we have published this Privacy Policy in order to explain in a simple and transparent way what data we collect and why. Note that you can send us an email regarding any additional questions and/or explanations related to protecting your personal data at info@castellone.com. You also have the right to transfer data from our database to another Data Controller. This right applies only to the data you provide to us pursuant to a contract or consent and if the processing is performed by automated means. In order to process your request, we have the right to request identity verification.
10.6. Right of complaint to a competent authority
It is your fundamental right to file a complaint with the supervisory authority, i.e. the Croatian Personal Data Protection Agency, Martićeva 14, Zagreb, if you believe that your personal data has been breached. You are also welcome to contact us if you feel that we are infringing your rights in any way.
10.7. The right to restrict
It is your right to request a restriction of the processing of your data if you A) dispute the accuracy of personal data for a period allowing the Data Controller to verify the accuracy of personal data, B) if we no longer require the personal data, but you request it for the purpose of determining, exercising or defending legal rights, C) if you objected to processing pursuant to legitimate interests, in the period during which it is expected to confirm whether the legitimate interests of the Data Controller supersede your rights, and D) if the processing is illegal, but you object to the deletion of data and request a restriction. In order to process your request, we may request identity verification.
11. Conclusion
We will not misuse your personal data in any case. We process the data in accordance with the law and the General Data Protection Regulation. We process data only for a specific and lawful purpose. We respect your rights. If you have any questions on how we handle your personal data or would like to exercise your rights as described in item 6 of this Privacy Policy, contact us at info@castellone.com. or in writing to the registered office of ROCOSO PRIMERO d.o.o..
