PRIVACY POLICY HEDONIA EXPERIENCE d.o.o.

1. INTRODUCTORY INFORMATION

HEDONIA EXPERIENCE d.o.o. respects the privacy and protects the personal information of its users, employees, business partners or other persons with whom it conducts business cooperation and whose personal data is collected and processed in their daily business.

Privacy Policy is a fundamental act that describes the purpose and goals of collecting, processing and managing personal data within the company HEDONIA EXPERIENCE d.o.o.

This Policy defines the basic principles and rules for the protection of personal data in accordance with the business and security requirements of HEDONIA EXPERIENCE d.o.o., as well as legal regulations, best practices and internationally accepted standards. This Privacy Policy includes the requirements of the General Data Protection Act and the Implementation Act of the General Data Protection Regulation.

We process your personal information in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, on the non-application of Directive 95/46 / (hereinafter: the General Data Protection Regulation) and in conjunction with the National Implementation Act of the General Data Protection Regulation.

The Universal Data Protection Regulation contains a number of rules to ensure that personal data processing is carried out in accordance with the rights and fundamental freedoms of individuals. Also, the General Data Protection Regulation allows free movement of personal data within the EU without restriction and ban.

Pursuant to Articles 13 and 14 of the General Data Protection Regulation, we hereby inform you of how we process your personal information, which rights you have in connection with data processing and protection, and how you can exercise these rights.

We process and use your personal information legally, fairly and transparently, while protecting the security of your personal data from unauthorized or illegal processing, applying the most technical, security and organizational protection measures.

1. DATA ON THE COMPANY

The head of the processing is HEDONIA EXPERIENCE d.o.o. headquartered in Zagreb , Višnjica 11, VAT(OIB): 20028734687, registered in the Court Registry of the Commercial Court in Zagreb under the registration number MBS 081258672 (“HEDONIA EXPERIENCE d.o.o.”). HEDONIA EXPERIENCE d.o.o. processes your personal information for the purposes specified in item IV. of this Policy.

Contact information:

HEDONIA EXPERIENCE d.o.o.

Višnjica 11,  10000 Zagreb, Croatia

Phone: +385 99 6000 860

E-mail: info@hedonia.hr

III. CONTACT DETAILS OF THE RESPONSIBLE PERSON

HEDONIA EXPERIENCE d.o.o. has appointed a responsible person.

Regarding all matters relating to the processing of your personal data and / or the exercise of the rights provided for in the General Data Protection Regulation, as referred to in Point X. Privacy Policy, you can contact the responsible person at the following address:

HEDONIA EXPERIENCE d.o.o.

Suzana Arapović

Višnjica 11, 10000 Zagreb

E-mail address: info@hedonia.hr

1. PERSONAL DATA CATEGORIES WHICH WE DO AND DRAW

Within its business activities, HEDONIA EXPERIENCE d.o.o. may collect the following categories of personal data by categories of respondents:

Interested parties:

• Contact information (e.g. name, last name, e-mail address etc.)
• The information needed to conclude the contract (e.g. name, surname, address, VAT(OIB), etc.).

Users:

• Contact information (e.g. name, last name, e-mail address etc.)
• The information required for the conclusion of the contract (e.g. name, surname, address, VAT(OIB), etc.)
• The data needed to execute the contract (e.g. name, surname, e-mail, IBAN, etc.)

Candidates for Employment:

• Contact information (e.g. name, last name, e-mail address, cell phone number, etc.)
• Resume data (e.g. data on education, previous employment, work experience, photography, etc.)
• Test results

Former and current employees:

• All data prescribed by positive regulations relating to labor law, accounting and bookkeeping regulations (e.g. name, surname, address, VAT(OIB), year of birth,etc.),
• Data for the need for internal communication within the company (e.g. name, surname, employment, travel document number, driver’s license, number of children, etc.).

Associates and business partners:

• Contact information (for example: name, surname, e-mail address, cell phone number, etc.)
• Resume data (for example, data on education, previous employment, employment, etc.)
• The information needed to execute the contract (for example: name, surname, e-mail, IBAN, etc.)
• The data required to fulfill the legal requirements for entry into the Republic of Croatia or another country (name, surname, employment, travel document number, etc.).

The processing of the above categories of personal data will be carried out by HEDONIA EXPERIENCE d.o.o. exceptionally under the following conditions:

• The respondent has given explicit permission to process these personal data for one or more specific purposes;
• Processing is necessary for the purposes of fulfilling the obligations and the realization of the special rights of HEDONIA EXPERIENCE d.o.o. or the respondents in the area of ​​labor law and social security and social protection rights to the extent that it is granted under European Union law, the law of the Republic of Croatia or collective agreement in in accordance with the Law of the Republic of Croatia, which prescribes appropriate protective measures for the fundamental rights and interests of the respondent
• processing is necessary for the protection of vital interests of the respondent or another individual
• processing refers to the personal information that is apparently disclosed by the respondent
• processing is necessary for the establishment, realization or defense of legal requirements.

1. METHODS OF COLLECTING PERSONAL DATA

HEDONIA EXPERIENCE d.o.o. can collect personal information in various ways, including:

• As part of the business process and during the fulfillment legal obligations or obligations from a service contract;
• During web site tracking, including e-mail communication directed to and from HEDONIA EXPERIENCE d.o.o.;
• By your job application,

When you provide us with information on the publication of the content on our site or during your direct communication with HEDONIA EXPERIENCE d.o.o., including personal communication and online communication via the site or e-mail;

1. PERSONAL DATA PROCESSING PURPOSES

HEDONIA EXPERIENCE d.o.o. may process personal information for the following purposes:

• Alignment with legal and regulatory regulations within and outside the territory of the Republic of Croatia
• Contracting and using the products and services provided by HEDONIA EXPERIENCE d.o.o. fulfillment of its obligations under the contract for the sale of services and products of HEDONIA EXPERIENCE d.o.o.;
• Offer services and products of HEDONIA EXPERIENCE d.o.o. in the market;
• Website analysis and administration and site usage control;
• Improvement of services and products of HEDONIA EXPERIENCE d.o.o., measurement of service satisfaction;
• Relationship management with respondents (site users and/or service providers) and other persons in the conduct of their business;
• Selection of candidates for employment
• For marketing activities (if you give consent)

VII. PERSONAL DATA PROCESSING BASIS

HEDONIA EXPERIENCE d.o.o. handles your personal information based on the following basis:

Executing a contract on the sale of the service of HEDONIA EXPERIENCE d.o.o. or another contract concluded between the respondents and HEDONIA EXPERIENCE d.o.o.;

Legitimate interest in providing and managing the Internet site for statistical purposes for the purpose of determining, resolving disputes and conducting proceedings between the respondents and HEDONIA EXPERIENCE d.o.o., for the purpose of sharing personal data with third parties in accordance with this Privacy Policy for the purpose of implementing the selection procedure candidates for employment purposes;

Introduce Privileges to Receive Marketing Messages, Newsletters, Email Service Notifications, or Service Satisfaction Survey to Process Your Inquiries

In order to fulfill the legal obligations of HEDONIA EXPERIENCE d.o.o., in particular with regard to accounting, bookkeeping, regulations of labor law and other legal obligations.

VIII. PERSONAL DATA RETENTION

Your personal information is kept in the period or by a specific regulation or not longer than what is necessary to achieve the purpose for which it is processed – if the storage period is not prescribed or a minimum storage period is prescribed.

We store personal information only when we need them for the purposes for which we collect them, that is, for the purpose of fulfilling contractual relations or statutory obligations and the longest to the following criteria:

Personal data collected for the purpose of fulfilling its legal and regulatory obligations are stored according to the prescribed deadlines,

Personal data collected for the purpose of selling the goods and services are stored in the duration of the contractual relationship;

We store your personal information collected for marketing activities until you withdraw your privation, cancel your subscription or ask for deletion of your subscription, or after a certain period of inactivity

Personal data will be deleted upon discontinuation of contractual or employment relationship and no later than the expiration of any statutory obligation to store, except in the event of a court or other similar proceedings requiring data retention.

1. PERSONAL DATA TRANSFER AND SHARING

HEDONIA EXPERIENCE d.o.o. may share your personal information with third parties only in the following cases:

If there is a statutory obligation or explicit authorization under the law;

If we engage another person as a so-called ” subcontractor, i.e. processing agent, who acts solely upon the order of HEDONIA EXPERIENCE d.o.o., whereby HEDONIA EXPERIENCE d.o.o. secures all data protection measures as if doing these tasks alone;

If the data need to be forwarded to third parties for the performance of the contract with the respondent;

On the basis of the privilege of the respondent.

Such third parties include:

Legislative, supervisory and regulatory bodies within and outside the territory of the Republic of Croatia Financial institutions with which HEDONIA EXPERIENCE d.o.o. collaborated Auditors inside and outside HEDONIA EXPERIENCE d.o.o. and other bodies authorized to audit

Suppliers that HEDONIA EXPERIENCE d.o.o. engages to perform services on behalf of and for the account of HEDONIA EXPERIENCE d.o.o., for the fulfillment of the contractual obligations with the respondents

Other agencies, institutions, associations, insurance companies and partner companies with whom HEDONIA EXPERIENCE d.o.o. has concluded a business cooperation agreement based on which business users can negotiate and use the products and services that HEDONIA EXPERIENCE d.o.o. provides etc.

When transmitting the data of the respondent, HEDONIA EXPERIENCE d.o.o. strictly adheres to the principle of the processing limitation with the transmission of the minimum amount of data needed to realize the requested service and respecting all other relevant data protection principles.

We handle personal data in the Republic of Croatia. Exceptionally, we can handle them in other countries (for example, when a subcontractor from another country is engaged in providing a particular service or part of a service that includes processing of personal data), as a rule, to the member states of the European Union. Exceptionally, we can handle them in third countries as well, but in such situations, appropriate personal data protection measures are always applied, as far as personal data is processed in the Republic of Croatia (e.g. by applying the so-called EU Standard Contract Clauses for third country processors , other legally binding and enforceable instruments, binding corporate rules, certification, etc. )

1. USER RIGHTS

HEDONIA EXPERIENCE d.o.o. respects the right to privacy and data collected and processed only with the existence of legal basis for processing these subjects at all times retain certain rights in relation to the ceremony in their data.

At any time, you can contact HEDONIA EXPERIENCE d.o.o. as the manager of the processing in order to carry out your rights in accordance with the General Data Protection Regulation at the contact addresses of point II. of these Privacy Policy. Your application can submit in writing to the address of HEDONIA EXPERIENCE d.o.o. or address of the person:  info@hedonia.hr

About the actions you have taken regarding your request, HEDONIA EXPERIENCE d.o.o. will inform you, without unnecessary delay and no later than one month from the receipt of the request, of the actions taken. Exceptionally, this deadline may be extended, if necessary, taking into account the complexity and number of requests. In this case, HEDONIA EXPERIENCE d.o.o. will notify you within one month of receipt of the request for the reasons for the delay.

If you have submitted your application electronically, the information will be provided electronically if possible unless you have requested otherwise in your request. If HEDONIA EXPERIENCE d.o.o. does not act on your request within one month, without delay and no later than one month after the receipt of the request, it will notify you of the reasons for not doing so and of the possibility of submitting the complaint to the supervisory authority.

Any communication and actions that HEDONIA EXPERIENCE d.o.o. undertakes regarding the carrying out of the rights listed below shall be free of charge. However, if your claims are manifestly unfounded or excessive, in particular because of their recurring character, HEDONIA EXPERIENCE d.o.o. may charge you a fee, taking into account the costs incurred or refusing to comply with your requirements.

You can contact HEDONIA EXPERIENCE d.o.o., as the manager of the processing, in order to exercise the following rights:

(1) The right to access data – From HEDONIA EXPERIENCE d.o.o., as a processing manager, you can obtain confirmation of whether your personal data are handled, if processed, you have the right to access personal information and information as provided by Article 15 of the General Data Protection Regulation, such as: processing purposes, personal data categories, deadlines, etc.

If your personal data is eventually transmitted to a third country or an international organization, you have the right to be notified of the appropriate transfer security measures.

If you ask for it, HEDONIA EXPERIENCE d.o.o.  will provide you with a copy of the personal data processed. For all further requested copies, HEDONIA EXPERIENCE d.o.o. may charge you a reasonable fee based on administrative costs. If the application is filed electronically, and unless otherwise requested, HEDONIA EXPERIENCE d.o.o. will deliver them in the usual electronic form.

(2) Right to Correction – You may request from HEDONIA EXPERIENCE d.o.o. correction of your personal information that is incorrect as well as, taking into account the purpose of the processing, their , if the data is incomplete, giving an additional statement.

(3) Right to Delete (“Right to Forget”) – You can request from HEDONIA EXPERIENCE d.o.o. as a processing manager deleting your personal data if one of the reasons set out in Article 17 of the General Data Protection Regulation is fulfilled (e.g. if personal data is no longer necessary for purposes for which they have been collected or otherwise processed or if they are which is based on the processing of your personal data withdrawn or if there is no other legal basis for processing or if the personal data has to be deleted for compliance with a legal obligation under EU law or under the regulations of the Republic of Croatia or if the data is unlawfully processed or filed objection to direct marketing).

We hereby inform you that HEDONIA EXPERIENCE d.o.o.  may not delete your personal information if their processing is necessary, for example, to comply with the statutory obligation of custody or for reasons of public interest to set up, enforce or defend the legal requirements.

(4) The right to limit processing – You can request from HEDONIA EXPERIENCE d.o.o. limitation of the processing of your personal data if one of the cases referred to in Article 18 of the General Data Protection Regulation is met, including, for example, if it is necessary to check the accuracy of your personal data.

(5) Right to Data Transfer – If the processing of your personal data is based on the consent or is required to execute a contract or to take action before the conclusion of the contract and if the processing is carried out by automated means, you may: request the obtaining of personal data obtained in a structured, in a standard format and in a machine-readable format, or transfer your personal information to another processing manager. In addition, you may request that your personal information be transmitted directly from HEDONIA EXPERIENCE d.o.o. to the other manager provided that this is technically feasible for HEDONIA EXPERIENCE d.o.o. In that case, HEDONIA EXPERIENCE d.o.o. provide you with all the correct information about the new processing manager whom you intend to transfer your personal information, giving your written consent to HEDONIA EXPERIENCE d.o.o..

(6) The right to complain – At any time, you can submit a complaint to the processing of personal data on the contact address referred to in items II. and. III. of these Privacy Policy if the processing is performed for public interest purposes or is necessary for the legitimate interest of HEDONIA EXPERIENCE d.o.o. as a processing manager (including profiling) or if your data is processed for direct marketing purposes. If you decide to file an objection, HEDONIA EXPERIENCE d.o.o. will refrain from further processing of your personal information, unless HEDONIA EXPERIENCE d.o.o.does not demonstrate that there are convincing legitimate grounds for processing (basics overriding the interests, rights and freedoms of the respondent) or the processing required for the establishment, execution or defense of legal requirements.

(7) The right to complain and the right to file a complaint with the data protection authority – Notwithstanding your right to contact the administrative body or the court, if you consider that processing your personal data by HEDONIA EXPERIENCE d.o.o. it is a violation of the General Data Protection Regulation and/or applicable regulations of the Republic of Croatia, you may file a complaint with the Personal Data Protection Agency . Regardless of the foregoing, if you consider that the processing of personal data carried out by HEDONIA EXPERIENCE d.o.o. you may contact their responsible person at the following address:   info@hedonia.hr  so that we jointly try to resolve your complaint.

(8) Automatic data processing – HEDONIA EXPERIENCE d.o.o. does not perform automatic data processing.

1. PERSONAL DATA PROTECTION

In order to protect the personal data collected, HEDONIA EXPERIENCE d.o.o. carries out the appropriate physical, technical and organizational protection measures, taking into account the nature, scope, context and purpose of processing, as well as the risks of different levels of probability and severity for the rights and freedoms of the respondent.

The access to the data within HEDONIA EXPERIENCE d.o.o. is limited to those data necessary to perform certain business tasks, exclusively to authorized persons who are directly engaged in providing or maintaining the service, and to improve the quality and collection of services, in accordance with clearly defined roles and Responsibilities within HEDONIA EXPERIENCE d.o.o. All employees of HEDONIA EXPERIENCE d.o.o. are bound by confidentiality contracts and engage exclusively with the partners with whom we are dealing with the appropriate protection measures.

HEDONIA EXPERIENCE d.o.o. can not guarantee 100% security of data transfer over the internet, websites, mobile applications, computer systems or any other public network.

XII. COOKIES

In order for HEDONIA EXPERIENCE d.o.o. Website to work properly, in order to be able to further improve the site, in order to improve your browsing experience, the site must save a small amount of information (Cookies) on your computer.

The cookie information is saved to your computer by the web site you visit. Cookies usually save your settings, web settings, such as your preferred language or address. Later, when you open the same web page again, the internet browser sends back the cookies that belong to that page. This allows the page to display information tailored to your needs.

Key cookies allow us to serve you with content and track traffic to our pages and apps, and the analytic cookies we use and third parties who process data for us for data analysis (e.g., Google Analytics) allow us to manage and improve the performance and design of our websites and applications, as well as tracking, reviewing, researching, and reporting.

Browsers and devices have tools that allow cookies to be disabled on web pages and apps. If you disable cookies, you may not be able to access all features of our services. We suggest that your key cookies stay active for a better user experience and help us improve and develop our products and services.

XIII. FINAL PROVISIONS

This Privacy Policy has been applied since 16.01.2020.

Any changes to the Privacy Policy will be posted on our website: https://hedonia.hr/