PRIVACY POLICY

1. Introduction

Proficio d.d. with headquarters in Zagreb, Ilica 1A, OIB: 39508009387, (hereinafter: Proficio) is a trading company registered in the court register of the Commercial Court in Zagreb for services.

Proficio is primarily engaged in catering and real estate. In its operations, Proficio must collect and process certain data about individuals and is therefore the manager of personal data processing.

In some cases, Proficio is also the data processor, but only in the case when the data processing managers are trading companies from the Proficio group of entrepreneurs. In the aforementioned case, there is an interest in the transfer of personal data within the group of entrepreneurs for internal administrative purposes, among others for the processing of personal data of clients or employees.

The purpose of this policy is to ensure that Proficio provides all necessary information regarding the protection of personal data of individuals whose personal data it processes.

All Proficio employees are fully aware of the content of this policy and ensure its application when processing personal data. Employees whose tasks include the handling of personal data are adequately educated regarding their tasks in relation to the protection of personal data.

This policy applies to all personal data processed by Proficio in relation to any person, regardless of whether they were, currently are or will be an employee, guest, client, supplier or contact of Proficio. This policy does not apply to anonymous data. Anonymous data is data that has been modified in such a way that it cannot be linked to a specific natural person or cannot be linked without a disproportionate effort, and therefore, in accordance with current regulations, it is not considered personal data.

This policy was created with the aim of improving the services of Proficio to its users, protecting users in terms of the confidentiality of their personal data when providing Proficio services, and preventing the occurrence of potential damage to Proficio and its employees and users as respondents, and to ensure that processing of personal data by Proficio in full accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and on the repeal of Directive 95/ 46/EC (General Data Protection Regulation) (GDPR) and other applicable regulations. The personal data processed by Proficio in its operations are not shared with unauthorized persons, offered, sold or transferred outside the Republic of Croatia.

2. Definition and application:

Personal data is considered to be all data relating to an individual whose identity has been determined or can be determined, that is, an individual (respondent) who can be identified directly or indirectly, especially with the help of identifiers such as name, identification number, location data, network identifier or with the help of one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

The processing of personal data means any procedure or set of procedures performed on personal data or on sets of personal data, either by automated or non-automated means such as collection, recording, organization, structuring, storage, adaptation or modification, withdrawal, retrieval, inspection , use or use, disclosure by transmission, dissemination, publication or otherwise making available, matching or combining, restriction, deletion or destruction and the implementation of logical, mathematical and other operations with this data.

Categories of personal data that Proficio processes in its operations are name and surname, address, social security number, year of birth, e-mail address and other personal data for certain categories of respondents.

Proficio collects and processes personal data primarily to provide services to the respondent in its business or to fulfill legal obligations. The legal basis for the processing of personal data is the contractual relationship between Proficio and the respondent, the legal obligation of Proficio or the consent of the respondent. Proficio handles this personal data adequately and in accordance with regulations, regardless of how this data was collected, recorded, stored and used - on paper, computer or other media. Proficio processes personal data that it receives from respondents, but also from third parties with information or at the request of the respondent. Proficio sometimes collects data from publicly available sources such as, for example, data from publicly published registers, public telephone directory, publicly available services or commercial services. Proficio does not forward the said personal data to third countries or to humanitarian organizations.

Proficio, in order to protect people and property, collects certain data through video surveillance in its facilities, i.e. the external surfaces of the facilities, whereby respondents are clearly warned by posted video surveillance signs when entering the recording perimeter. Only the person in charge of Proficia and the person authorized by the person in charge have access to the said data, subject to all the conditions prescribed by the Law on the Implementation of the General Regulation on Data Protection (Official Gazette 42/18).

When the respondent sends electronic mail (e-mail) to Proficio with personal data with which it is possible to identify him, by means of an e-mail message with a question or comment or by filling out the contact form at www.proficio.hr, www.pinebeach.hr or www. angelodoro.com, Proficio uses this data to fulfill the requests or queries of respondents regarding the provision of Proficio services. In the event that the respondent does not want to provide his/her personal data necessary for the provision of these services, compliance with the respondent's request or response to the respondent's inquiry, Proficio will not be able to process such a request or inquiry or provide the service.

Proficio processes certain personal data of respondents for marketing purposes (name and surname, address, e-mail address) in order to deliver information about promotions, benefits and actions of Proficio services, but only based on the consent of the respondents. Proficio allows each respondent to withdraw their consent for such data processing once given, in accordance with the respondent's rules stated below.

At the moment of submitting the data of the respondent to Proficio, the respondent consents to Proficio processing his personal data, in accordance with the indicated purpose and for a certain period of time.
The protection of the privacy of personal data of the respondent is permanent, and at any time the respondent can exercise his rights, which are listed and explained below.

Proficio permanently stores the personal data of employees from the employment relationship and in connection with the employment relationship. Personal data from accounting or bookkeeping documents (for example invoices to customers or guests, but also received invoices from suppliers) is kept by Proficio for at least 11 years in accordance with accounting regulations. Personal data of guests necessary for the provision of accommodation services is kept by Proficio for at least two years after the end of the calendar year in which they were entered in the Guest Book or Tourist List, in accordance with regulations on the content and manner of keeping the Guest Book or Tourist List. Contact data of respondents for the provision of marketing services (newsletter) is processed by Proficio up to the withdrawal of consent on the basis of which it processes them.

Proficio can, in order to carry out its business process, entrust certain data processing tasks to data processors, but only to those who comply with technical, logical and organizational personal data protection measures provided by Proficio.

Proficio stores the collected personal data in an appropriate manner and ensures their confidentiality. Proficio will not forward the collected data to third parties without the permission of the respondent, except in cases where this is necessary to fulfill Proficio's legal obligations (for example to the Tax Administration, the Croatian Pension Insurance Institute, the Ministry of Tourism and other competent authorities) or contractual obligations to which the respondent is a party. , in cases where it is necessary for the fulfillment of tasks that are carried out in the public interest or in cases where the respondent himself has published this information, as well as in other cases determined by the competent regulation.

The respondent has the following rights with regard to personal data processed for him by Proficio:

RIGHTS OF RESPONDENTS (EXPLANATION)

The right to information

The subject has the right to request notification from Proficio at any time as to whether his personal data is being processed and for what purpose, who is the data controller, the contact details of the data protection officer, which categories of personal data are being processed, for what period they are being processed or stored, who is the source for obtaining his personal data, who are all the recipients of his personal data, as well as the right to be notified of his other rights specified in this policy (right of access, right of correction, right of deletion, right to limit processing and others).

Right of Access

The respondent has the right to obtain confirmation from Profic whether personal data relating to him/her are being processed, and then to obtain access to such data and information about:
- processing purposes,
- categories of personal data that are processed;
- recipients or categories of recipients to whom the data has been disclosed or will be disclosed;
- if possible, about the period for which the data is stored, that is, about the criteria by which it is possible to determine that period;
- to request from Proficio the correction or deletion of personal data or the restriction of the processing of personal data relating to the respondent or the right to object to such processing;
- the right to submit a complaint to the supervisory body;
- if personal data is not collected from the respondent, any available information about its source;
- the existence of automated decision-making, which includes the creation of profiles, with consequences.

Right to rectification

The respondent has the right to obtain from Proficio the correction of inaccurate personal data relating to him without undue delay. The respondent has the right to supplement incomplete personal data, including by providing an additional statement.

Right to erasure / right to be forgotten

The respondent has the right to request that Proficio delete personal data relating to him without delay if the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, if the respondent withdraws the consent on which the processing is based and there is no other legal basis of processing, if the data subject files an objection to the processing, if personal data has been unlawfully processed, if personal data must be deleted in order to comply with a legal obligation under Union law or the law of a member state to which Proficio is subject, if personal data has been collected in connection with the offer of information society services to a child.

The above does not apply if processing is necessary (and to the extent necessary) for the exercise of the right to freedom of expression and information, for compliance with a legal obligation that requires processing under Union law or the law of a member state to which Proficio is subject, or for the performance of a task in the public interest or when exercising official authority, due to public interest in the field of public health, for the purposes of archiving in the public interest, for the purposes of scientific or historical research, for the purpose of establishing, realizing or defending legal claims.

The right to object

The respondent has the right, based on his special situation, at any time to object to the processing of personal data relating to him, including the creation of a profile, in cases where the processing is necessary for the performance of a task in the public interest or in the exercise of official authority, i.e. if the processing is necessary for the needs of the legitimate interests of Profic or a third party. Proficio may no longer process personal data unless Proficio proves that there are compelling legitimate reasons for processing that go beyond the interests, rights and freedoms of the data subject or to establish, exercise or defend legal claims.

If personal data is processed for the purposes of direct marketing, the data subject has the right at any time to object to the processing of personal data relating to him for the purposes of such marketing, which includes creating a profile to the extent related to such direct marketing.

The right to data portability

The respondent has the right to receive the personal data relating to him, which he has provided to Proficio in a structured, commonly used and machine format, and has the right, without interference from Proficio, to transfer this data to another controller if the processing is based on his consent and if processing is carried out in an automated way.

The data subject has the right to a direct transfer from Profic to another data controller if this is technically feasible, and this right must not negatively affect the rights and freedoms of others.

Rights related to automatic decision-making and profiling

The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects that relate to him or similarly significantly affect him, unless that decision is necessary for the conclusion or execution contract between the data subject and Proficio, if it is permitted by Union law or the law of a Member State to which Proficio is subject or based on the express consent of the data subject.

Right to withdraw consent

The consent of the respondent is one of the legal bases for the processing of data relating to the respondent. The subject has the right to withdraw the consent he has given at any time. The withdrawal of consent does not affect the legality of data processing that was carried out before the withdrawal of consent.

The right to an effective legal remedy (complaint and objection)

Without prejudice to other administrative or judicial remedies, each data subject has the right to submit a complaint to the supervisory authority regarding the processing of his personal data. Every respondent has the right to an effective legal remedy against a legally binding decision of a supervisory body that applies to him. The supervisory authority is the Personal Data Protection Agency.

The right to restrict processing

The respondent has the right to request a limitation of the processing of his personal data: if he disputes the accuracy of his personal data - for the period necessary for Proficio to verify that accuracy, if the processing of his personal data is illegal and does not request deletion but only limitation of processing, if Proficio no longer needs his personal data, but their existence is necessary for the fulfillment of his legal requirements, if he has objected to the processing, he has the right to request a limitation of the processing for the period until it is determined whether Profic's legitimate reasons for the processing exceed his reasons from the objection.

In order to exercise their rights, the subject should contact the personal data protection officer at Profic by sending a written notice or request to the personal data protection officer, by e-mail to the e-mail address below or by ground mail to the address: Zagreb, Ilica 1A, with adequate identification with the code that the respondent received from Proficio when booking or receiving an offer for Proficio catering services. The respondent can also exercise his rights by delivering a personal statement directly to the Proficio business premises, with prior notice to the phone number +385 (0)1 4886 100 and identification with a valid personal document. Proficio reserves the right to set additional requirements regarding the identification of the person seeking to exercise their rights, all in order to prevent or disable the abuse of the rights of the respondent regarding the protection of his personal data.

3. Personal data protection officer:

Proficio has appointed a personal data protection officer, and each respondent has the right to contact him regarding the protection of his personal data via:
phone number: +38523250961
e-mail address: newsletter@pinebeach.hr

4. Personal data protection principles:

Proficio believes that the legal and proper treatment of personal data is very important and therefore ensures that personal data is treated legally and correctly. For this purpose, Proficio fully supports and complies with the Data Protection Principles.

Data protection principles require that personal data:
- they must be processed fairly and legally and, in particular, they must not be processed if the conditions specified by the regulations are not met;
- they are collected only for one or more specific and legal purposes and may not be further processed in any way that would be incompatible with these purposes;
- the processing must be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed, and the data must be accurate and up-to-date;
- may not be retained longer than necessary for the applicable purpose;
- must be processed in accordance with the rights of the data subjects in accordance with the applicable regulations:
- appropriate technical and organizational measures must be taken against unauthorized or illegal processing of personal data and against accidental loss, destruction or damage of personal data;
- may not be transferred to a country or territory outside the EU, unless that country or territory ensures an adequate level of protection of the data subject's rights and freedoms in relation to the processing of personal data.

5. Activities of Profic regarding data processing:

Proficio undertakes the following:
- fully respects the conditions of fair collection and processing of personal data;
- fulfills the obligation to specify the purpose for which personal data is processed;
- collects and processes adequate personal data and only to the extent that it is necessary to fulfill operational needs or in accordance with all legal requirements;
- submits all necessary data to the Personal Data Protection Agency at its request;
- carries out a strict check on the length of storage of personal data;
- ensures that the rights of the person whose data is processed can be fully exercised in accordance with the protection of personal data;
- takes appropriate technical and organizational security measures to protect personal data;
- ensures that personal data is not transferred abroad without insurance protection;
- treats all persons fairly and fairly, regardless of their age, religion, disability, gender, sexual orientation or ethnicity, when dealing with their requests for information;
- establishes clear procedures for responding to requests for information.

6. Use of cookies

In order for the websites of Proficia d.d. work properly and in order to improve them in order to improve your browsing experience, it is necessary to save a minimum amount of information (cookies) on the computer of the visitor to the website. More than 90% of internet sites use the practice of cookies, and according to the rules of the European Union, they are obliged to request the user's consent. By using the Internet pages of Proficia d.d. the visitor agrees to the use of cookies, by blocking which the visitor can still view the page, but some of its features will not be functional.

What is a cookie?
A cookie is information saved on your personal computer at the time of browsing the website you visited. Cookies enable easier use since they save the settings for the website (language or address) of the website visitor and reactivate them when the website is restarted. In this way, the information is adapted to the needs and usual ways of using the site visitors.

From simple information about settings, cookies can store a large amount of personal information (name, e-mail address) to which site visitors must fully provide access. If the visitor of the Internet pages has not enabled them, cookies cannot access the files on their computer. The activities of saving and sending cookies are not visible to site visitors, however, they can choose the option of approving/rejecting requests to save cookies, deleting saved cookies and other activities related to the use of cookies in the settings of the selected Internet browser.

How to disable cookies?
By turning off cookies, they are not allowed to be stored on the site visitor's computer. Cookie settings can be configured and changed in the selected Internet browser. In order for site visitors to see the settings, they should select the browser they are using (Chrome, Firefox, Internet Explorer 9, Internet Explorer 7 and 8, and Opera or Safari (pages in English)). If site visitors disable cookies, they will not be able to use certain functionalities of the website.

What are temporary cookies?
Temporary cookies, or session cookies, are removed from the site visitor's personal computer at the moment of closing the internet browser in which they viewed the website. With the help of these cookies, the pages store temporary data.

What are persistent cookies?
Permanent, or saved, cookies remain on the site visitor's personal computer even after closing the internet browser. With the help of these cookies, websites store data to facilitate their use. For example, Internet pages that require the entry of a username and password will "remember" the entry of the visitor to the page, which will appear on each new visit. Persistent cookies will remain recorded on your computer for days, months or years.

What are first-party cookies?
First-party cookies come from the website that visitors browse, and can be temporary or permanent. In this way, websites store data that will make it easier for site visitors to use each time they visit that website.

What are third-party cookies?
Third-party cookies are placed on a site visitor's computer from other websites that are located on the website they are viewing. These are, for example, pop-up ads, and cookies have the role of tracking websites for advertising purposes.

Does this website use cookies?
Yes, this website uses cookies to provide visitors with a simpler and better user experience.

What cookies does this website use?
Temporary cookies (Session cookies) – these are cookies that will be automatically deleted when closing the Internet browser in which visitors to the site are working. Persistent cookies – these are cookies that will remain "recorded" in the Internet browser of the site visitors until they expire or until they manually delete them. The collected information is anonymous and does not include personal data of site visitors.

Are there any third-party cookies on the website?
There are several external services that store limited cookies, which are not set by the Proficio website. Limited cookies are used for the smooth use of features that provide users with easy access to content.

The pages on which this policy is published enable:
Attendance measurement
The site uses Google Analytics - a service for measuring traffic. If visitors want to disable the saving of cookies by the service, they should prohibit them at the following link: Google Analytics - https://tools.google.com/dlpage/gaoptout

Additional information about turning off cookies
There are several websites to disable the storage of cookies for different services. More information can be found at the following links:
http://www.allaboutcookies.org/
http://www.youronlinechoices.eu/

7. Review and verification:

Proficio has the right to update this policy if necessary to reflect best practice and to ensure compliance with any changes or modifications regarding the protection of personal data.
In Zagreb on May 23, 2018. years

Proficio d.d.
Chairman of the Board Gavin Michael Susman