The confidentiality clause in the Internet business became a standard a long time ago, and is respected by serious companies. Adria Luxury Boats is completely up-to-date with trends in this matter and is able to provide customers with data privacy in complete security.

Adria Luxury Boats d.o.o. (Further in the text referred to as “the Company”) carries out personal data protection measures in accordance with the General Data Protection (GDPR) statutory and regulatory obligations.

Processing Manager: Adria Luxury Boats d.o.o., Liburnijska ulica 7a, 51414 Ičići

Adria Luxury Boats d.o.o. has appointed the Personal Data Protection Officer.

Regarding all matters pertaining to the processing of your personal data and the fulfilment of rights provided by the General Data Protection Regulation, you may contact the Personal Data Protection Officer in any of the following ways:

in writing to: Adria Luxury Boats d.o.o., Liburnijska ulica 7a, 51414 Ičići, for Data Protection Officer

by e-mail to: info@alb.hr

We are fully committed to ensuring continuous and effective policy-making, and we also expect our employees and business partners to do so.

This policy defines the expected behavior of the Company, its permanent, temporary and part-time employees as well as business partners and third parties in relation to the collection, use, storage, transmission, disclosure or destruction of personal data processed in the business processes of the Company.

PERSONAL DATA PROTECTION RULES

These rules are relate to the privacy practices of the Company used in contracting and providing services to its customers. This privacy policy has been defined to clarify the purpose and manner of use of personal data, the category of personal information we collect, the time period in which we process them, and to acquaint you with all of informations regarding the processing of your data.

THE DATA WE COLLECT

During various forms of interaction with the Company (the use of the web site owned by the Company, sending of inquiries / requests by e-mail, mail) we collect personal data which implies but are not limited to the following:

•           Name and surname

•           E-mail address

During various forms of interaction, the Company may also collect information that does not fall into a group of personal data, which includes, but is not limited to, the following:

• Data about the device through which you are connecting to the Internet

• The type and version of the Internet browser you are using

• The ways of using the Company’s Web site

LEGAL BASES FOR PERSONAL DATA PROCESSING

We process and use personal data only for the purposes for which they were collected. Processing of personal data is permitted only to the extent that at least one of the following is met:

• Processing is necessary to comply with the Company’s legal obligations – which implies but does not limit the processing of data for the purpose of issuing invoices, for the purpose of resolving complaints based on applicable regulations (Consumer Protection Act)

• Processing is necessary for the implementation of a contract where the user is a customer or in order to take action upon request by the user before concluding the contract

• Processing is necessary for the legitimate business interests of the Company or a third party, unless when there is a greater interest or the fundamental right of users who require the protection of personal data – for example, data processing for marketing purposes, when we inform our customers about special offers or call to the event for which we think customers might be interested

• On the basis of the information about the extent of processing, there is an explicit consent by the user

USE OF DATA

The Company uses personal data for the following purposes:

• Provision of services in accordance with contractual obligations – The Company may use personal data during the provision of contracted services and to provide various forms of communication during the process of realization of cooperation

• Marketing and Sales Activities – The Company may use personal information to inform about new benefits, items, discounts, or similar activities

• Employee Protection – The Company may disclose personal information of individuals if it believes it is necessary or appropriate to protect the health and safety of employees, visitors, property and / or user or clients

• Legal obligations of reporting and data processing

DATA COLLECTING METHODS

Personal data is collected in one of the following ways:

• Directly from the individual – the information provided for the purpose of concluding or fulfillment of the contract, by sending a inquiry via contact form on the Company’s web site, by creating a user account on the Company’s website, coming to the Company’s premises, by telephone conversation.

• Indirectly – information that is publicly available on non-Company websites (eg. social networks, open forums), data obtained by using cookies, links, and similar technologies

USERS REQUIREMENTS

The Company ensures the realisation of user rights in relation to:

• Access to information;

• Objection to processing;

• Limitation of processing;

• Data transfer;

• Correction of data;

• Deleting data

The Applicant submits a written or oral request. If an individual submits an application pertaining to any of the above-mentioned rights, the Company will consider any such request in accordance with all applicable laws and regulations on data protection. The Company reserves the right to charge the costs for processing user request in exceptional cases where the requests are unreasonable.

Users have the right to be informed on the basis of the submitted application and after successful verification of their identity on the following:

• The purpose of processing personal data;

• Source of personal data, if it is not provided by the user;

• Personal data category;

• recipients or categories of recipients to whom personal data had been or may be transferred together with the location of those recipients;

• The anticipated period of storage of personal data or explanation for determining the storage period;

• Use of any automated decision-making, including profiling

All requests for access or correction of personal data must be addressed to the Personal Data Protection Officer, who will record any request upon receipt. The response to each request is submitted within 30 days of the receipt of the written request of the user.

PERSONAL DATA PROCESSING BASED ON USER CONSENT

In certain cases, the Company may seek the consent of the users for the processing of personal data for a particular purpose.

When personal data processing is based on a consent, the user can, at any time, withdraw the consent, but this will not affect the legitimacy of the processing before consent was withdrawn.

DATA KEEPING

The Company will not retain personal data for longer than is necessary in the relation of the purposes for which it was originally collected.

Company will keep your Personal Information as long as they are required to provide products or services; as long as it is necessary in accordance with these Privacy Policy Rules or the time of collection; as long as necessary because of our legal obligations, resolving disputes and enforcing our contracts; or to the extent permitted by the law.

When the retention period expires, the Company will delete personal information in a manner that ensures that they can not be reconstructed or read.

DATA PROTECTION

The Company carries out physical, technical and organizational measures that guarantee the security of personal data (for example, prevention of loss or damage, unauthorized modifications, unauthorized access or processing and other threats to which personal data may be exposed by human activity or physical / natural environment).

The security measures being implemented aim to:

• Prevent unauthorized persons from gaining access to a data processing system that processes personal data;

• Prevent persons who have the right to use the data processing system to access personal data that is beyond their needs and authority;

• Ensure that personal data during electronic transmission or during transmission can not be read, copied, modified or removed without permission;

• Ensure the availability of system records for the purpose of determining who has been entered, altered or removed personal data from the data processing system;

• Ensure that, when processing is carried out by the Personal Data Protection Executive, the data can only be processed in accordance with the instructions of the Personal Data Protection Officer;

• Ensure that personal data is protected against unwanted destruction or loss;

• Ensure that personal data collected for different purposes can be processed separately;

• Ensure that personal data is not kept longer than necessary.

REQUESTS BY THE JUDICIAL AUTHORITIES

Under certain circumstances, it is permissible to share personal information without the user’s knowledge or consent. when disclosure of personal data is required in any of the following purposes:

• Preventing or detecting crimes.

• Arrest or prosecution of the offender.

• Estimate or collection of taxes or fees.

• By court order or by any law

HANDLING OF COMPLAINTS

In the case of complaints regarding compliance with these and other privacy-related rules, please contact us at info@alb.hr. In case of a complaint, we will investigate the whole situation regarding the use and disclosure of personal data in accordance with these policies and we will try to resolve them as soon as possible.

CHILDREN PERSONAL DATA PROTECTION

We are well aware that children deserve special protection in every way, including in terms of personal data protection, since they may be less aware of the risks and possible consequences of disclosing their data.

Pursuant to Article 19, paragraph 1 of the Law on Implementation of the General Data Protection Regulation (NN 42/2018), as regards the protection of personal data, children are considered all persons under the age of 16 and Company does not seek or collect personal data of or on children without the consent of the holder of parental responsibility.

Therefore, the Company will make every reasonable effort to ensure that the data received from the children are processed only with the consent of the holder of parental responsibility.

If the Company finds that the personal data of the children are sent, but without the valid consent of the holder of parental responsibility, the Company will, to a reasonable extent, endeavor to do the following:

• delete these personal data from files as soon as possible; and

• ensure, in the case that deletion is not possible, that such personal information is not used for any purpose;

• and will not, in any case, give it to any third party.

WHERE WILL YOUR PERSONAL DATA BE PROCESSED

We handle your data within the European Economic Area. In the event of a need for the transfer of personal data beyond that area, such transfer will only take place if the European Commission has confirmed that a third country meets a certain level of data protection or if there are adequate safeguards in accordance with applicable law (eg. binding corporate rules, clause).

THE RIGHT OF COMPLAINT SUBMISSION TO SUPERVISORY BODIES

At any time, you may file a complaint about processing of your personal data if you believe that when processing your data we violated the Croatian or European regulations on data protection to the Supervisory Authority – the Personal Data Protection Agency, Martićeva 14, Zagreb, azop@azop.hr

PRIVACY POLICY ON THE WEB

The Company acknowledges and appreciates your right to data confidentiality and undertakes to preserve the security of the data collected through the Company’s Web site.

Your personal data is collected and used only on the basis of the information you have voluntarily provided to the Company, either by using an Internet site or by filling out a contact form (when filling out a contact form, personal information such as your name and surname and e-mail address).

Collected personal data is kept in electronic form and all appropriate technical and organizational measures are applied to prevent personal data violations. Received emails with your personal information will be used by the Company only for the purpose of meeting your requirements.

For site management and statistical purposes, we collect information through standard Web logs. These Web logs contain the IP address from which you connect to the alb.hr site, the date and time you access the site, search terms, and the pages you visited. We make periodic checks of the types of browsers/operating systems used and of the pages from which you direct-link to our site. We create summary statistics from the Web logs in order to measure the number of visitors to know better our visitor’s interests and to help make the site more useful.

WHO ELSE HAS ACCESS TO YOUR PERSONAL DATA?

We do not share your personal information with strangers. Personal data about you is in some cases provided to our trusted partners to provide you the services or improve your user experience. Your data is shared with:

Our Data Processing Partners:

• Google Analytics

Our business partners:

• /

Related Third Parties:

• /

We only work with data processing partners who are able to provide an adequate level of protection for your personal information. We disclose your personal information to third parties or public officials when we are legally required to do so. We may disclose your personal information to third parties only if you have consented yourself or if there is another legal basis for this.

COOKIES

Cookies allow collecting of the statistical information about the user’s behavior on the web pages (eg. in which parts of the Internet page the users stay the longest and the shortest), which Internet browser is used (eg. Internet Explorer, Opera, Safari, Google Chrome , Firefox) and so on.

A cookie is a small packet of data sent from a server to a user’s computer, and serves as an anonymous identifier. The purpose of the cookie is to improve user experience while using the web site. Cookies on the Company’s web pages are anonymous and are not used to access user data or to track user activity after leaving the web site.

What are Temporary Cookies?

Temporary cookies are removed from your computer when you close your browser. With them, websites store temporary data.

What are permanent cookies?

Permanent or saved cookies remain on your computer after you close the Internet browser. With them, websites store information such as login name and password, so you do not have to sign in for each visit to a particular website.

We use cookies for the following purposes:

• Required cookies (Required) – these cookies are required to use some of the important features on our web site. These cookies do not collect any personal information.

• Functional Cookies (For Settings) – these cookies allow functionality that makes our service simpler and allows us to provide more personalized features for you. For example, website might remember your name and e-mail in contact forms so that you do not have to enter this information again.

• Google Analytics cookies – these cookies are used to track usage and performance of our sites and services

We use Google Analytics to measure traffic on our website. Google has its own Privacy Policy that you can view here. If you want to exclude Google Analytics tracking, visit the Google Analytics opt-out page.

The Company monitors statistical visits of its sites solely to obtain the necessary information on the attractiveness and success of their sites.

The owners of Internet browsers inform you about how to manage cookies. Read more on those links:

• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari (Desktop)
• Safari (Mobile)
• Android Browser
• Opera
• Opera Mobile

For the remaining Internet browsers, please consult with the relevant documentation provided by the respective Company who is the owner of Internet browser.

SAFETY

The Company takes all security measures to protect the user’s data during data entry, data transfer, data processing, and data storage. Access to data is limited only to those employees who are required to do business that require particular data.

Personal data given to the Company when completing a contact form will be kept during the existence of the Website. All information provided to the Company by filling in the contact form on the Website will be destroyed at the latest when Company stop to existence.

Users at any time have the right to request information about which of their personal data are being processed by the Company, or towhich of their personal data needs be changed or deleted, by submitting a request to the Personal Data Protection Officer.

DISCLOSURE

Except for authorized law enforcement investigations, no attempt is made to identify individual users or usage patterns. We do not give, share, sell or transfer any personal information to a third party.

INTRUSION DETECTION

In the event of authorized law enforcement investigations, and pursuant to any required legal process, information from our available sources may be used to help identify an individual.

COPYRIGHT

Adria Luxury Boats materials published on the internet are protected by copyright law. Apart from fair dealing for the purposes of private study, research, criticism or review, no part may be reproduced or reused for any commercial purposes whatsoever.

TERMS OF USE

The materials on this site are provided “as is” and without warranties of any kind either express or implied. To the fullest extent permissible pursuant to applicable law, we disclaim all warranties, express or implied, including, but not limited to, implied warranties of merchantability and fitness for a particular purpose. We do not warrant that the functions contained in the materials on the site will be error free. We do not warrant or make any representations regarding the use or the results of the use of the materials and information on the site in terms of their reliability, correctness, accuracy or otherwise. alb.hr is not in any form responsible for any damages caused in relation to the use of alb.hr services.

We explicitly disclaim any responsibility for the accuracy, content, or availability of information found on sites that link to or from the Site. We cannot ensure that you will be satisfied with any products or services that you purchase from a third-party site that links to or from the Site or third party content on our sites.

Please exercise discretion while browsing the Internet using this site (alb.hr). You should be aware that when you are on the alb.hr site, you could be directed to other sites that are beyond our control. We are not responsible for content of other web sites.

We make no representation that materials on the Site are appropriate or available for use in any particular location. Those who choose to access the Site do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable.

These Terms are effective until terminated by either party. You may terminate these terms at any time by discontinuing use of the Site and destroying all materials obtained from the Sites and all related documentation and all copies, whether made under the terms of these terms or otherwise. These terms will terminate immediately without notice from us if in our sole discretion you fail to comply with any term or provision of these terms.

CONTACT INFORMATION

Adria Luxury Boats d.o.o.

Liburnijska ulica 7a

51414 Ičići

e-mail: info@alb.hr

UPDATING OF PRIVACY POLICY

Privacy Policy is regularly reviewed and verified by the Company. The current version is always available on our website www.alb.hr and if any major changes affect your rights and freedoms, we will notify you directly.

We reserve the right to make changes to these Privacy Policy.

The last change was made on June 30, 2018.