Privacy Notice
We consider the protection of your privacy and your personal data to be of utmost importance and pay particular attention to it in all our business relationships. We respect the confidentiality of your personal data and always act in accordance with the applicable laws and regulations governing the protection of personal data, as well as the provisions of this Privacy Notice.
Accordingly, we hereby inform you that, in order to ensure comprehensive protection of personal data, we have aligned our business operations with all the requirements of 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, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter: “GDPR“), as well as the Croatian Act on the Implementation of the General Data Protection Regulation (Official Gazette No. 42/2018; hereinafter: the “Act“).
Please note that this Privacy Notice applies to you as a customer of BJELIN SPAČVA d.o.o., meaning that everything set out herein applies to the processing of your personal data as a customer of BJELIN SPAČVA d.o.o.
Accordingly, below you will find information on (i) who processes your personal data, (ii) the purposes for which your personal data are processed, (iii) whether we transfer your personal data to third parties and/or to other countries or international organisations, (iv) the period during which we process your personal data, and (v) your rights in relation to your personal data.
- Scope of this Privacy Notice
Following the introduction above, this Privacy Notice is intended to inform you, as our customer, how the seller, Drvna industrija BJELIN SPAČVA društvo s ograničenom odgovornošću za drvnu industriju, with its registered office at Duga 181, Vinkovci, OIB: 02046778584, registered in the Court Register of the Commercial Court in Osijek under registration number (MBS): 030014502 (hereinafter: “BJELIN SPAČVA d.o.o.“), processes your personal data.
In this regard, BJELIN SPAČVA d.o.o. acts as the Data Controller in relation to the personal data it processes.
Furthermore, as we are aware that the term processing of personal data may be somewhat confusing, the following table provides a brief explanation of what constitutes personal data and what constitutes the processing of such data.
| PERSONAL DATA | PROCESSING OF PERSONAL DATA |
| Any information relating to an identified or identifiable natural person (the “Data Subject“). An identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person. | Any operation or set of operations performed on personal data or on sets of personal data, whether by automated or non-automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. |
- Collection and Use of Personal Data
We collect your personal data directly from you within the framework of the business relationship established between you and us as a customer of our products. We collect your personal data (i) in order to fulfil our obligations arising from the sales contract for products from our range concluded with you, (ii) to enable us to comply with certain legal obligations imposed on us as the seller in relation to you as the consumer, and (iii) on the basis of certain legitimate interests of BJELIN SPAČVA d.o.o.
We process and use the personal data you have provided exclusively for specific purposes, which include in particular:
- – Taking steps at the customer’s request prior to the conclusion of a sales contract. The collection and processing of your personal data is necessary in order to take steps at your request prior to concluding a sales contract for products from our range, such as responding to your enquiries regarding our products, product specifications, service conditions and similar matters.
- – Performance of the sales contract. For the purpose of fulfilling our obligations as the seller under the sales contract concluded with our customers, we collect and process your personal data in order to process your orders, contact you where necessary regarding matters relevant to the performance of the contract, issue invoices, deliver the purchased goods, and, where applicable, issue the necessary documents and declarations in accordance with tax and/or customs regulations.
- – Maintenance of records required by law. Your personal data may form part of records that we are legally required to maintain, including accounting records in accordance with the Accounting Act, tax records, and records of customer complaints in accordance with consumer protection legislation.
- – Protection of security, property and health. BJELIN SPAČVA d.o.o. collects and processes your personal data through video surveillance systems installed for the purpose of protecting the security of the company, its employees, visitors and property. The collection and processing of personal data through video surveillance is governed by a separate internal policy adopted by BJELIN SPAČVA d.o.o.
- – Data cleansing and consolidation. From time to time, the personal data you have provided may be verified or consolidated with (i) data from our existing records (online and offline), (ii) data obtained from legal predecessors, or (iii) data obtained from other sources.
- Legal Basis for Processing Your Personal Data
In accordance with Article 6 of the General Data Protection Regulation (GDPR), every processing of personal data must have a valid legal basis. BJELIN SPAČVA d.o.o. processes your personal data on the basis of one or more of the following legal grounds, depending on the specific purpose of the processing:
- – Performance of a Contract (Article 6(1)(b) GDPR): processing is necessary for the performance of a sales contract to which you are a party, as well as for taking steps at your request prior to entering into such contract. This legal basis applies in particular to the processing of orders, delivery of goods, issuing invoices, and contacting you in connection with the performance of the contract.
- – Compliance with Legal Obligations (Article 6(1)(c) GDPR): processing is necessary for compliance with the legal obligations applicable to BJELIN SPAČVA d.o.o. as the Data Controller, arising from the Accounting Act, tax legislation, the Consumer Protection Act, and other applicable regulations.
- – Legitimate Interest (Article 6(1)(f) GDPR): processing is necessary for the purposes of the legitimate interests pursued by BJELIN SPAČVA d.o.o., for example, to protect property, ensure the safety of individuals, and carry out data cleansing and consolidation, provided that such interests are not overridden by your interests or fundamental rights and freedoms.
- – Consent (Article 6(1)(a) GDPR): where processing is not necessary for the performance of a contract, compliance with legal obligations, or the purposes of a legitimate interest, the processing is based on the consent you have previously given. You may withdraw your consent at any time, without affecting the lawfulness of processing carried out on the basis of your consent before its withdrawal.
- Transfer and Disclosure of Your Personal Data
As described in the previous section, depending on the type of process in which we process your personal data, certain data may be transferred to third parties. We will do so in order to comply with our legal obligations or to comply with applicable laws, regulations or orders issued by public authorities.
In addition, we may share your personal data with third parties with whom we cooperate in the course of providing our services. In doing so, we ensure that such parties are reliable, require them to comply with the same personal data protection standards that we apply ourselves, and prohibit them from using your personal data for any purpose other than those specified.
However, we do not transfer your personal data to other countries and/or international organisations.
- Data Retention Period
The retention period of your personal data primarily depends on the purpose for which they were collected, that is, the reason why we process your personal data. In this regard, we guarantee that we will not retain your personal data in a form that enables your identification for longer than is necessary to fulfil the purpose for which they were collected.
- Source of Your Personal Data
We collect your personal data primarily directly from you within the framework of the business relationship you have established with us as a customer of our products. This includes the personal data you provide to us:
- – when submitting enquiries and during sales negotiations,
- – when concluding and performing a sales contract,
- – through communication with us (by email, telephone or in person),
- – by visiting our business premises (where video surveillance is in operation in accordance with a separate internal policy).
In certain cases, your personal data may be collected from other sources, for example:
- – from our existing internal records (online and offline),
- – from the legal predecessors of BJELIN SPAČVA d.o.o.,
- – for the purpose of data verification and consolidation.
In all of the above cases, we process only those personal data that are necessary for the specific purpose of the processing, in accordance with the data minimisation principle set out in the GDPR.
- Automated Decision-Making and Profiling
In accordance with Article 22 of the General Data Protection Regulation (GDPR), we inform you that BJELIN SPAČVA d.o.o. does not make decisions based solely on automated processing, including profiling, which produce legal effects concerning you or similarly significantly affect you.
Any decisions that may have an impact on your business relationship with BJELIN SPAČVA d.o.o. are made with the appropriate involvement of our authorised employees.
- Right to Information, Right to Withdraw Consent and Right to Erasure of Your Personal Data
Below we set out the rights you are entitled to exercise in relation to the processing of your personal data as described above. In this regard, you have the following rights:
- – the right to request, in writing, information regarding your personal data that we process;
- – the right to have inaccurate personal data relating to you rectified;
- – the right to have personal data relating to you erased;
- – the right to restriction of processing where:
- – you contest the accuracy of the personal data relating to you;
- – you consider the processing of your personal data to be unlawful but oppose the erasure of the personal data;
- – you consider that BJELIN SPAČVA d.o.o., as the Data Controller, no longer requires your personal data, but you require them for the establishment, exercise or defence of legal claims;
- – the right to receive the personal data relating to you and to transmit those data to another Data Controller in a structured, commonly used and machine-readable format;
- – the right to object to the processing of your personal data;
- – the right to lodge a complaint with the authority responsible in the Republic of Croatia for personal data protection and supervision of personal data processing (the Croatian Personal Data Protection Agency).
Please direct any request for the exercise of the rights described above to the contact point specified in Section 10.
We also inform you that, where we process certain of your personal data on the basis of your consent (which will be the case where the processing of certain personal data is not necessary for the performance of the sales contract, compliance with the legal obligations of BJELIN SPAČVA d.o.o. as the Data Controller, or for the legitimate interests of BJELIN SPAČVA d.o.o.), you are entitled to withdraw your consent at any time by sending a notification to the email address specified in Section 10.
- Data Security
We also inform you that BJELIN SPAČVA d.o.o. is committed to implementing appropriate technical and organisational security measures to ensure the confidentiality and integrity of your personal data.
- Contact
For any questions regarding this Privacy Notice or the processing of your personal data, please contact us at gdpr@bjelin.hr.
