(hereinafter: the Policy)
- PRIVACY POLICY AND ITS PURPOSE
The purpose of this Policy is to explain clearly and concisely how and for which purpose Apsolon processes your personal data located on or collected through the website www.apsolon.com.
Apsolon is aware that the protection of your personal data is important to you and therefore takes all reasonable technical and organizational measures aimed at their protection and processes it legally, fairly, and transparently.
In terms of processing your personal data, Apsolon is in the position of the controller – the one who determines the purposes and means of processing personal data.
In case you decide to apply for a job ad or student practice in Apsolon through the website www.apsolon.com (“Career” section of the website), Apsolon shall use TalentLyft (available through: www.talentlyft.com), talent acquisition software developed by AdoptoTech d.o.o. for services with its registered seat in Zagreb, Ljudevita Posavskog 34A, PIN: 57168930727. In this case AdoptoTech d.o.o. is in the position of the processor – the person who processes the personal data on behalf of and follows the instructions of the controller, all based on the agreement on the processing of personal data.
The term “personal data”, when used in this Policy, refers to all information about you that you give us (when, for example, you send us your CV or send a query using a contact form) including (but not limited to) the name, surname, e-mail address, contact number, name of your employer, IP address, etc.
We kindly ask that you get acquainted with this Policy and contact us if you have any questions using the following contact details:
Apsolon d.o.o.
Jurišićeva 3
10 000 Zagreb, Republic of Croatia
PIN: 88407675650
- DATA PROTECTION OFFICER
To protect the privacy of your personal data, Apsolon has appointed Zrinka Kolarić as a data protection officer – you can contact the officer by sending an e-mail message to: dpo@apsolon.com, in particular, if you consider that your personal data processed by Apsolon are incomplete, incorrect, or not up to date.
- PERSONAL DATA CATEGORIES, PURPOSE OF PROCESSING PERSONAL DATA AND LAWFUL BASIS FOR PROCESSING
Apsolon undertakes that your personal data shall be processed in accordance with the 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), Law regarding the implementation of the General Data Protection Regulation and all other relevant legislation.
Apsolon undertakes to retain all personal data to which it has the right and power of access as confidential and to use it exclusively for a specific (prescribed) purpose.
In case you visit and use the web page www.apsolon.com only for information purposes, e.g. if you do not contact Apsolon via the form on the page or otherwise do not provide it with your personal data, Apsolon will collect only personal data that your browser transfers to its server, which is technically necessary to show you our web site and guarantee stability and security.
In addition to the above mentioned, Apsolon collects, in particular, the following information:
| METHOD OF COLLECTION OF PERSONAL DATA | PURPOSE OF PROCESSING | LAWFUL BASIS FOR PROCESSING | PERSONAL DATA BEING COLECTED DIRECTLY FORM YOU |
| newsletter | to inform you about developments in the field of EU and financial consulting, regulatory reform, digital transformation, and other areas of Apsolon’s activities and to create a database of users for marketing purposes | consent (also in particular cases legitimate interests) | name, surname, e-mail address, name of the organization in which you are employed |
| contact form – via the section of the website called “Contact”, related to your inquiries about business cooperation, journalistic and other inquiries | to give you an answer to your inquiry | legitimate interests | name, surname, e-mail address, phone number |
| in case of downloading content through the section of the website called “Publications” | to enable you to download the requested content and to inform you about current events and news in areas of Apsolon’s activities | legitimate interests | name, surname, e-mail address, name of the organization in which you are employed |
| contact form via the section of the website called “Career”, related to your applications for a job or student internship at Apsolon | selection of potential job candidates and possible employment in Apsolon | processing is necessary in order to take steps at the request of the data subject prior to entering into a contract or consent (if your personal data is kept for future tenders) | name, surname, e-mail address, phone number, and other personal data you provide us with in your CV and (in particular, sex, date of birth, citizenship, photography, education level, occupation, previous work experience, professional training data) |
| automatically using cookies | to enable you to use the activities through the website www.apsolon.com and improve its work and your user experience | legitimate interests | IP address, language preferences |
Depending on the types of activities you perfrom on the website www.apsolon.com (e.g., browsing through the page, downloading content…), some of the requested personal data is determined as mandatory and some as voluntary. If you do not wish to provide mandatory data for activities that require them, you will not be allowed to participate in those activities.
- YOUR RIGHTS
| RIGHT | PURPOSE | HOW TO ACHIEVE IT |
the right of access | provide you with an insight into your personal data Apsolon possesses | you can request that Apsolon provides you with a copy of your personal data which it possesses. The copy needs to show: the categories of personal data concerned;the purpose of processing;in which way the data is being processed;to whom the data was forwarded;data retention period;data source in case data is indirectly collected. |
| the right to rectification | ensure that the personal data processed by Apsolon is accurate and up to date at all times | you can request that Apsolon corrects personal data concerning you if it is inaccurate or out of date |
| the right of erasure | ensure that personal data processed by Apsolon is appropriate, relevant, and necessary for the purposes for which they are processed | you can request that Apsolon deletes personal data concerning you – this right is not absolute and sometimes there are reasons based on legal provisions because of which a request to delete data cannot be complied with |
the right to restrict processing | temporary restriction of processing in cases where it is not clear whether and when personal data will have to be deleted | if you want to question the accuracy of your data processed by Apsolon, you have objected to the processing of your data on a basis that Apsolon considers legitimate or Apsolon no longer needs your personal data for processing purposes and you need it to establish, execute or process legal claims. you can request restriction of their processing |
| the right to data portability | provide you with a choice – this right allows you to choose and use those services which suit you best | if processing is based on your consent or is performed by automatic means, you have the right to request that we provide you with personal data that you have previously provided to us and transfer them to another controller without interference |
| the right to object | ensure you have better control over processing of your personal data | you have the right to object to processing of your personal data based on a legal basis that we consider legitimate |
All of the above-mentioned rights can be exercised by sending a request to the e-mail address dpo@apsolon.com indicating ‘protection of rights‘ in the subject of e-mail or by using the contact details of Apsolon indicated at the beginning of this Policy.
- HOW TO PROTECT YOUR RIGHTS?
| PROTECTION MECHANISM | HOW TO EXERCISE YOUR RIGHT? |
| right to lodge a complaint with a supervisory authority | in case: that you have failed to adequately protect your rights in contact with Apsolon;you suspect another violation of the GDPR; you can lodge a complaint (request for the determination of a violation of rights) to Croatian Personal Data Protection Agency (hereinafter: AZOP) |
| right to an effective judicial remedy against a supervisory authority | in case: that you are not satisfied with the decision already made by AZOP;that AZOP failed to resolve your complaint within the prescribed time limit;that AZOP failed to inform you about the progress or outcome of your complaint within the prescribed period; you can initiate an administrative dispute by filing a lawsuit with the competent administrative court |
| right to compensation | GDPR guarantees you the right to compensation for material and non-material damage caused by the breach of your personal data (contrary to the GDPR) – the procedure for the exercise of the right to compensation for damages is initiated by a lawsuit, and is conducted before municipal courts |
- DATA PROTECTION MEASURES
Apsolon keeps your personal data in a secure environment and takes (and periodically tests and upgrades) all reasonable administrative, technical, physical, organizational, and other security measures to protect it from unauthorized access, use, alteration, or destruction by any third party.
Apsolon provides access to your personal data only to those of its employees who need it in order to duly fulfill their obligations under the employment contract. All employees have signed adequate confidentiality agreements and Apsolon continuously educates them on the importance of maintaining the privacy and security of your personal data.
- RETENTION OF PERSONAL DATA
Apsolon shall not retain your personal data for longer than necessary to fulfill the purposes for which the data was processed. Apsolon can store certain personal data for a period of time prescribed by law or a regulation that obliges it to keep personal data.
In case you have given Apsolon consent, your personal data will be processed until that consent is withdrawn.
If judicial, administrative or other similar proceedings are instituted, personal data may be stored until the end of such proceedings, including a possible period for declaring legal remedies.
- COOKIES
In order to maintain the website www.apsolon.com, ensure its functionalities are on the expected level and improve your user experience Apsolon shall store small data files (known as “cookies”) on the device through which you browse the said page. This is a standard procedure used on most websites.
Cookies are small files which we store on your device when you visit our website so we can access them later. Cookies themselves do not contain or collect data, however, in combination with a web browser, they can help the website deliver a more personalized service to you.
You can find more information about cookies in our Cookie Policy.
- OTHER WEBSITES
This Policy only applies to processing personal data which Apsolon collects throught the website www.apsolon.com.
To the extent that you disclose your personal data to other parties through the website www.apsolon.com (e.g., by clicking on a link to any other website or site), different rules may apply to their use or processing of your personal data. Apsolon shall not be liable for any act or omission of third parties.
Apsolon uses a business profile using the services of Facebook, Instagram, YouTube, and LinkedIn, and you can read about their Privacy Policy, the way they use your personal data, and their data protection officers at:
| Privacy policy:https://www.facebook.com/policy.php Data protection officer:https://www.facebook.com/help/contact/540977946302970 | |
| Privacy policy:https://help.instagram.com/519522125107875 Data protection officer:https://www.facebook.com/help/contact/540977946302970 | |
| YouTube | Privacy policy:https://policies.google.com/privacy?hl=hr Data protection officer:https://support.google.com/policies/contact/general_privacy_form |
| Privacy policy:https://www.linkedin.com/legal/privacy-policy Data protection officer:https://www.linkedin.com/help/linkedin/ask/TSO-DPO |
- EXCHANGE OF PERSONAL DATA WITH THIRD PARTIES
Apsolon will not share your personal data with unauthorized persons, but it can make it available to its reliable partners (e.g., partners maintaining its IT system) and legal entities associated with Apsolon. In that case, Apsolon will enter into appropriate contracts with partners and oblige them to use personal data entrusted to them only according to the Apsolon’s instructions and for the purpose set by Apsolon.
In case of a legal obligation, Apsolon reserves the right to disclose your personal data if it is necessary to submit it to the competent authorities or law enforcement authorities.
Apsolon can, as a controller, transfer personal data outside the EU if it is necessary for the execution of contracts between Apsolon and data processor or Apsolon and other data controller or if the transfer is necessary to meet Apsolon’s legal obligations. In the last-mentioned case Apsolon can transfer personal data only to countries which provide an appropriate level of protection through standard contractual clauses or other adequate methods of transferring personal data to third countries provided for in GDPR.
- ENTRY INTO FORCE AND AMENDMENTS
Apsolon shall periodically update this Policy. The version currently published on the website www.apsolon.com is in force and valid.