Pursuant to the General Data Protection Regulation, the company Inkop International d.o.o. (hereinafter the Company) provides basic information on processing your personal data in this Privacy Policy. We therefore kindly ask that you carefully read the text below and contact us in case of any doubts or the need for additional information relating to processing your personal data.

Data Protection Officer

The Company appointed a Data Protection Officer, whom you can contact if you have any questions pertaining to processing personal data concerning you and the fulfillment of your data protection rights.

• E-mail: info@inkop.hr

The purpose of collecting personal data and the legal basis for the processing thereof

The purpose and method of personal data processing can be established by the Company or any of the Company’s partners, with whom the Company concluded an agreement on personal data processing, but they may also do it jointly. Should the Company independently establish the purpose and means for personal data processing, it shall be the controller. Should the Company establish the purpose and means for personal data processing together with one or more partners as the controller(s), they shall jointly perform the duties of the controller. Should the Company process personal data on behalf of the controller, the Company shall be the processor and process personal data in accordance with the requirements of the controller. In that case, the controller shall define which personal data shall be collected from the data subjects by the Company as the processor and to which extent.

They shall be notified thereof at the moment their personal data are collected. The basic purpose of personal data collection is to present and offer, as well as carry out other preparatory activities that precede a loan agreement or carry out activities upon your request prior to the conclusion of the loan agreement or legal obligations of the Company (especially those relating to the prevention of money laundering and terrorism financing). Your personal data are required for establishing a business relationship for the purpose of selling and delivering goods. Should we need specific personal data essential for providing the requested service, we shall notify you in a timely manner and in an appropriate way. While you are browsing the Company’s website, the Company does not collect your personal data such as name, surname, address, phone number, e-mail address, etc.

Your personal data remain secret when visiting the Company’s website unless you wish to voluntarily disclose them. At some places of the Company’s website (“contact”, “inquiry”, “questionnaire”, “order”, etc.), we do collect your personal data (name, surname, address, phone number, e-mail address, etc.), which you give us by filling out the relevant form on the website. The aforementioned data shall be used for the purpose of contacting you, answering your inquiries, offering you information upon your request, and recording the users of the website. These are necessary for us to answer to your request, offer you services and sell goods to you. By entering your personal data in the appropriate forms on the Company’s website, you give consent and confirm that the said data were given to the Company voluntarily and agree to their use for the purpose as indicated. The Company shall process personal data concerning you for the purpose of fulfilling its legal obligation, such as (but not limited to) obligations prescribed by the Anti Money Laundering and Terrorist Financing Law and international tax regulations (FATCA, CRS, etc.), i.e., those prescribed by the Consumer Credit Act, the Act on Consumer Housing Loans, and the regulations adopted pursuant to these acts. Should you refuse to give us such information, we shall not be able to deliver the goods to you.

The legal basis for the aforementioned personal data processing is Article 6 paragraph 1 items (b) and (c) of the General Data Protection Regulation (processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; processing is necessary for compliance with a legal obligation to which the controller is subject). The Company pursues a legitimate interest for processing personal data required for preventing fraud, and the legal basis thereof is Article 6 paragraph 1 item (f) of the General Data Protection Regulation (processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child). Should there be no aforementioned purpose and basis for processing personal data concerning you, your personal data shall only be processed, if you gave a written consent therefore. The legal basis therefore is Article 6 paragraph 1 item (a) of the General Data Protection Regulation (the data subject has given consent to the processing of his or her personal data for one or more specific purposes).

Recipients or categories of recipients of personal data

Personal data concerning you that we process as the processor shall be provided to the controller (credit institution), in accordance with the purpose of personal data processing defined by the controller and the rules of the controller. That includes personal data we collect for the purpose of fulfilling legal obligations prescribed by the Anti Money Laundering and Terrorist Financing Law and international tax regulations (FATCA, CRS, etc.). Personal data concerning you may be disclosed to other recipients so we could fulfill our legal obligations, i.e., upon a governmental authority’s request (such as the Croatian Personal Data Protection Agency, Anti-Money Laundering and Terrorist Financing Office, Financial Inspectorate, Ministry of Finance of the Republic of Croatia, Tax Administration, State’s Attorney Office of the Republic of Croatia (DORH), etc.) Your personal data may also be disclosed to courts, notaries public, lawyers, auditors, court expert witnesses and other persons, should that be required for the establishment, exercise or defense of legal claims, be it in court or administrative proceedings, or any other out of court proceedings.

Marketing

Upon your consent, we shall process your personal data for marketing purposes to notify you about offers, products and services of the Company and its partners. Data that we process for such purposes include: name and surname, address (street, house number, entrance, apartment, postal code, city, country), telephone number, e-mail address, mobile phone number (if applicable), date of birth. Consent also means that your personal data may be processed by one or more partners of the Company and that the Company’s partner may contact you directly. Should you refuse to give your consent or revoke it, your personal data shall not be used for marketing purposes. The legal basis therefore is Article 6 paragraph 1 item (a) of the General Data Protection Regulation (the data subject has given consent to the processing of his or her personal data for one or more specific purposes).

Information about the intention of transfer of personal data to a third country or an international organization and the existence of an adequacy decision

The Company does not intend to transfer your personal data to a third country or an international organization, except in cases in which a legal obligation therefore exists.

Storage period of personal data and criteria for defining that period

Your personal data shall be stored for as long as it is necessary for the fulfillment of the purpose of their processing, whereby the criterion for defining that period is the purpose of their collection, the statutory limitation period of the claim, or a specific provision of another act that binds us to store your personal data for a specific period of time.

Your rights pertaining to personal data

In order to ensure fair and transparent processing of your personal data, we refer you to your rights:

• Right of access – You have the right to contact us at any time and access information whether your personal data are being processed and, if they are, to which extent, request access to personal data and information you are entitled to in relation to personal data protection. The company shall ensure a copy of the processed personal data for you, and we may charge a reasonable fee based on administrative expenses for all additional copies you might ask for. Should you submit your request electronically, we shall provide you with information in the usual electronic form, unless you specify otherwise;
• Right to rectification – Should we process your personal data that are inaccurate, you can obtain form us the rectification thereof at any time. Should your personal data be incomplete, you shall have the right to have them completed;
• Right to erasure – You shall have the right to obtain from us the erasure of personal data concerning you if your personal data have been unlawfully processed or if they are no longer necessary in relation to the purposes for which they were collected or otherwise processed, etc. We kindly ask that you bear in mind that there are reasons which prevent instant deletion, such as the establishment, exercise or defense of legal claims, and we shall notify you thereof in detail in relation to each request;
• Right to restriction of processing – You shall have the right to obtain from us restriction of processing: if the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data; if the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; if we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims; if you objected to processing;
• Right to data portability – You shall have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller, if the processing is based on consent or on a contract and is carried out by automated means;
• Right to object – You shall have the right to object at any time to processing of personal data concerning you, should it be based on our compelling legitimate grounds, or if we process personal data concerning you for direct marketing purposes;
• Right to lodge a complaint – Should you think that we violated the General Data Protection Regulation or any other regulations relating to personal data protection by processing your personal data, we kindly ask that you contact our Data Protection Officer (the contact details are given at the beginning of this Privacy Policy) so we could resolve any issues;
• Right to withdraw consent – Where processing is based on consent, you shall have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. You can withdraw your consent by notifying the Company thereof in writing: by e-mail or mail sent to the Company’s address (the Company’s contact details are given at the beginning of this Privacy Policy) or you can notify the Data Protection Officer (the contact details are given at the beginning of this Privacy Policy) thereof in writing.
• Right to compensation – Should you have suffered material or non-material damage as a result of an infringement of relevant statutory provisions, you shall have the right to receive compensation from the Company or the Company if it is the processor.

We shall reply to your claim within an appropriate time limit, but no later than a month after the date of receipt of the claim, if a longer period is not requested therefore, in which case it cannot exceed 2 months.

Notes

This document about procedures involving personal data is regularly updated, and its latest version is always available on the Company’s website. This Privacy Policy shall apply as of 1 April 2020.

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