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Privacy Policy

Notes on Data Processing

Automated Data Processing (Log Files, etc.)

Our site can be visited without actively providing personal details of the users. However, with every calling up of the website we automatically save access data (server log files) such as the name of the Internet service provider, the operating system used, the website from which the user visits us, the date and duration of the visit or the name of the requested file and, for security reasons (e.g. to detect attacks of our website) the IP address of the end device used for a period of seven days. These data are exclusively evaluated to improve our service and do not allow any conclusions on the person of the user. These data are not merged with other data sources. Art. 6 para. 1 lit. f) GDPR is the legal foundation of the data processing. We process and use the data for the following purposes: 1. Provision of the website, 2. Improvement of our websites, and 3. Prevention and detection of errors/malfunctions and misusage of the website. The processing is made to pursue justified interests in ensuring the functionality and the faultless and secure operation of the website and to adapt this website to the requirements of the users.

 

Use of Cookies (General, Function, Opt-Out Links, etc.)

In order to make the visit to our website attractive and to allow the usage of certain functions we use so-called cookies on our website. The use of cookies serves our justified interest to make the visit to our website as pleasant as possible and is based on art. 6 para. 1 lit. f) GDPR. Cookies are a standard Internet technology for the storage and retrieval of login and other usage information for all website users. Cookies are small text files stored on the end device. They allow us to save user settings so that our website can be displayed in a format customized to the user device. Some of the cookies used by us are deleted again after the browser session, i.e. after the browser has been closed (so-called session cookies). Other cookies remain on the end device of the user and allow us or our partner companies to recognize the browser during the next visit (so-called permanent cookies).

The browser can be set in such a way as to inform the user on the setting of cookies so that they can decide individually about their acceptance or generally exclude the acceptance of cookies for certain cases or in general. Furthermore, the cookies can be deleted in retrospect to remove data that the website has deposited on the computer of the user. The deactivation of the cookies (so-called opt out) may result in a few constraints of the website functionality.

Categories of Users Concerned:
Website visitors, users of online services

Opt Out:
Internet Explorer: https://support.microsoft.com/de-de/help/17442
Firefox: https://support.mozilla.org/de/kb/wie-verhindere-ich-dass-websites-mich-verfolgen
Google Chrome: https://support.google.com/chrome/answer/95647?hl=de
Safari: https://support.apple.com/de-de/HT201265

Legal Foundations:
Acceptance (art. 6 para. 1 lit. a) GDPR); justified interests (art. 6 para. 1 lit. f) DSGVO)
In each case the legal foundation is explicitly named with the respective tool.

Justified Interests:
Storage of opt-in preferences, presentation of website, assurance of website functionality, preservation of user status for complete web presence, recognition for next website visitor, user-friendly online offer, assurance of chat function.

 

Content Management System

Web-based application with data transfer to CMS providers via installed plugins
We use a content management system (CMS) to edit, organize and display digital content on our website. The application is used web-based on the provider's servers. With the help of the CMS, our website can be created, edited and managed and equipped with the necessary functions (e.g. forms, blogs, images and other digital content). In addition, the website designed by the CMS helps our website to be found more easily by users on the search engine results page (SERP). By supporting an integrated firewall within the CMS, we ensure that our website is protected from external attacks and thus prevent misuse of the website. In addition, we ensure that the CMS is regularly updated and patched to guarantee the security of our website, which is based on the CMS. 

Data categories: 
Usage data (e.g. websites visited, access time), meta and communication data (e.g. device information)

Purposes of processing: 
Creating, editing and managing page content, storing and archiving data, creating landing pages, website security

Legal basis: 
legitimate interest (Art. 6 para. 1 lit. f) GDPR)

Legitimate interests: 
protection against spambots

TYPO3
Recipient: TYPO3 Association, Gewerbestrasse 10, CH-4450 Sissach, Switzerland
Privacy policy: typo3.org/privacy-policy

 

Online Marketing

In order to continuously increase our reach and popularity of our online offer we process personal data within the framework of online marketing, in particular with respect to potential interests and measuring the effectiveness of our marketing measures. In order to measure the effectiveness of our marketing measures and recognition of potential interests, information relevant for this purpose is saved in cookies or similar processes are used. The data saved in the cookies may include viewed contents, visited websites, settings and used functions and systems. As a rule, no clear data of the users are processed for the purposes described. The data are modified in such a way that the actual identity of the users is neither known to us nor to the provider of the tool used. The data modified hereby are often saved in user profiles. In case the user profiles are saved the data can be read out, complemented and complemented on the server of the online marketing provider when visiting other online offers using the same online marketing process. We can determine the success of our advertisements based on summarized data which are made accessible to us by the provider of the online marketing process (so-called conversion measurement). Within the framework of these conversion measurements, we can track if a marketing measure has led the visitor of our online offer to a purchase decision. This evaluation serves the analysis of the success of our online marketing.

Categories of Persons Concerned:
Website visitors, users of online services, interested parties, communication partners, business and contractual partners

Categories Data:
User data (e.g. visited websites, interest in contents, access times), meta and communication data (e.g. device information, IP addresses), location data, contact data, content data (e.g. text details, photos, videos)

Purposes of Processing:
Marketing (in part interest-based and behaviour-related), conversion measurement, target group formation, click-tracking, development of marketing strategies and increase of campaign efficiency)

Legal Foundations:
Acceptance (art. 6 para. 1 lit. a) GDPR); justified interests (art. 6 para. 1 lit. f) DSGVO)

Justified Interests:
Optimization and further development of website, profit increase, winning and retention of customers

 

Plug-Ins and Integrated Contents of Third Parties

We have integrated functions and contents procured from third-party providers. In this way, videos, representations, buttons or contributions (subsequently called contents) can be integrated. To allow the visitors of our online offer to see contents the respective third-party provider processes, among other information, the IP address of the user so that the contents can be transferred to the browser and presented. Without this processing procedure it is not possible to present third-party contents. Sometimes further information is collected by so-called pixel tags or web beacons providing the third-party provider with information on the use of the content or the visitor traffic on our online offer, technical information on the browser or the operating system of the user, the time of visit or referring websites. The data collected in this way are stored in cookies on the end device of the user. In order to protect the personal data of the visitors of our online offer we have taken certain security precautions to prevent the automatic transfer of these data. These data are only transmitted when you use the buttons resp. the third-party contents.

Categories of Persons Concerned: 
Users of the plug-in or integrated third-party contents

Categories Data: 
Usage data (e.g. used websites, interests, access time), meta and communication data (e.g. device information, IP address), contact data (e.g. e-mail address, phone number), master data (e.g. name, address)

Purposes of Processing:
Design of our online offer, increase of reach of advertisements in social media, sharing of contributions and contents, interest and behaviour-based marketing, cross-device tracking

Legal Foundations:
Acceptance (art. 6 para. 1 lit. a) GDPR)

Vimeo
Service used: Vimeo Inc, 555 West 18th Street New York, New York 10011, USA
Data protection: https://vimeo.com/privacy
Opt-out link: https://vimeo.com/cookie_policy
Legal basis: Consent (Art. 6 para. 1 lit. a) GDPR)

 

Contacting

With our online offer we provide the opportunity to contact us directly or obtain information on different contacting options. If a contact is established, we process the data of the enquiring person in the scope required for answering resp. processing the enquiry. Depending on the channel used for contacting us the data processed may vary. 

Categories of Persons Concerned:
Enquiring persons

Categories Data:
Master data (e.g. name, address), contact data (e.g. e-mail address, phone number), content data (e.g. text details, photos, videos), usage data (e.g. interests, access times), meta and communication data (e.g. device information, IP address)

Purposes of Processing:
Processing of enquiries

Legal Foundations:
Acceptance (art. 6 para. 1 lit. a) GDPR), fulfilment or initiation of contract (art. 6 para. 1 lit. b) GDPR)

 

Data Transfer

We transfer the personal data of the visitors of our online offer for internal purposes (e.g. for internal administration or to the HR department to comply with legal or contractual obligations). The internal data transfer resp. revealing of the data is only made in the required scope and in compliance with the applicable privacy regulations. For the execution of contracts resp. the fulfilment of a legal obligation it may be required to transfer personal data. If the data internally required are not provided it may happen that the contract with the person concerned cannot be closed. We transfer data to countries outside the EEA (so-called third countries). This is made for the purposes listed above. The transfer is only made to fulfil our contractual and legal obligations or based on an acceptance previously granted by the person concerned. Furthermore, this transfer is made in compliance with the applicable privacy regulations, in particular under consideration of art. 44 ff. GDPR, e.g. based on adequacy decisions adopted by the European Commission or other suitable guarantees (e.g. standard privacy clauses, etc.).

 

Storage Period

We generally save the data of visitors of our online offer as long as this is required to render our service or insofar as this has been provided by the European regulator and legislator or another legislator in laws and regulations we are subject to. In all other cases, we delete the personal data upon accomplishment of the purpose, with the exception of such data that we have to store further to fulfil legal obligations (e.g. we are obliged to keep documents such as contracts and invoices for a certain period in accordance with tax and commercial laws).

 

Automated Decision Finding

We renounce automated decision finding or profiling, acc. art. 22 GDPR.

 

Legal Foundations

Relevant legal foundations primarily arise from the GDPR. These are supplemented by national laws of the member states and may be applicable together with or supplementary to the GDPR.

Acceptance:
Art. 6 para. 1 lit. a) GDPR serves as the legal foundation of processing procedures for which we have sought acceptance for a particular processing purpose.

Fulfilment of Contract:
Art. 6 para. 1 lit. b) GDPR serves as the legal foundation of processings that is required for the fulfilment of a contract the contracting party of which is the person concerned or for the execution of pre-contractual measures taken at the request of the person concerned.

Legal Obligation:
Art. 6 para. 1 lit. c) GDPR serves as the legal foundation of processings that is required for the fulfilment of a legal obligation.

Vital Interests:
Art. 6 para. 1 lit. d) GDPR serves as the legal foundation if the processing is required to protect vital interests of the person concerned or of another natural person.

Public Interest:
Art. 6 para. 1 lit. e) GDPR serves as the legal foundation of processings that are required for the accomplishment of a task that is in the public interest or in execution of public authority which has been transferred to the person responsible.

Justified Interest:
Art. 6 para. 1 lit. f) GDPR serves as the legal foundation of processings that are required for the protection of the justified interests of the person responsible or a third party unless the interests or fundamental rights and liberties of the person concerned that require the protection of personal data prevail, in particular if the person concerned is a child.

 

Rights of Persons Concerned

Right of Information:
Acc. art. 15 GDPR persons concerned have the right to demand confirmation if we process data related to them. They can demand information on these data and on the further information stated in art. 15, para. 1 GDPR as well as a copy of their data.

Right of Correction:
Acc. art 16 GDPR persons concerned have the right to demand the correction or completion of the data related to them and processed by us.

Right of Deletion:
Acc. art. 17 GDPR persons concerned have the right to demand the immediate deletion of the data related to them. Alternatively, acc. art. 18 GDPR they can demand to restrict the processing of their data.

Right of Data Transfer:
Acc. art. 18 GDPR persons concerned have the right to demand the provision of the data they have made available to us and their transfer to another person responsible.

Right of Complaint:
Furthermore, persons concerned have the right to complain with the supervisory authority responsible as provided by art. 77 GDPR.

Right of Objection:
Insofar as personal data based on justified interests acc. art. 6 para. 1 p.1 lit f) GDPR are processed persons concerned have the right to object acc. art. 21 GDPR against the processing of their personal data insofar as there are reasons arising from their peculiar situation or if the objection is directed against direct advertising. In the latter case persons concerned have a general right of objection that is implemented by us without stating a particular situation.

 

Revocation

Some data processing procedures are only possible with the explicit consent of the persons concerned. You have the opportunity to revoke a consent already granted at any time. For this purpose, an informal message resp. e-mail to us (fill in mail-contact) is sufficient. The righteousness of the data processing performed up to the revocation remains unaffected by the revocation.

 

External Links

On our website you find links to online offers of other providers. Herewith we point out to the fact that we have no influence on the content of the linked online offers and the compliance with privacy regulations by their providers.

 

Modifications

We reserve the right to adapt these privacy notices at any time in case of modifications of our online offer and in accordance with the applicable privacy regulations to ensure that they comply with the legal requirements.

Responsible Body and Data Protection Officer

PropSAS
Poslovna zona Lonići
23 205 Bibinje
Croatia

+385 (99) 3329479
info@propsas.hr

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