The company Providens d.o.o. from Zagreb (hereinafter referred to as: Providens) is the controller processing the personal data and, within the meaning of General Data Protection Regulation (GDPR), shall define the purposes and methods of processing personal data within the scope of its business and legal operation.
Providens shall take special care that personal data is processed in accordance with the basic principles from Chapter II of the GDPR; above all that personal data are processed lawfully, fairly and in a transparent manner, and that they remain adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
In general, Providens shall not process personal data of persons under 18. By way of exception, in accordance with the provisions of Article 8 of GDPR personal data of a person aged 16 may be processed while in all other cases (of persons under 16), such processing is lawful only if express consent is given by the holder of parental responsibility over the child, which fact must be established in a clear and unequivocal manner in conformity with the provision of Article 8 paragraph 2 of the GDPR.
Providens shall not process personal data that disclose racial or ethnical origin, political opinions, religious or other beliefs, trade union membership, genetic or biometric data intended for unique identification of persons nor shall it process data on the sex life or sexual orientation of persons.
The Data Protection Officer is Sabina Tadić, employee of Providens Zagreb, firstname.lastname@example.org.
SECURITY OF PERSONAL DATA AND SYSTEM RELIABILITY
Providens shall implement appropriate technical and organizational measures for enabling efficient application of data protection principles, such as reducing data amounts and activating safeguards which ensure that by using an integrated approach processing includes only personal data that are necessary for the individual specific purpose. Special attention shall also be given to the issue of amounts of collected personal data, the extent of their processing, storage period and accessibility.
Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for rights and freedoms of persons posed by the processing, Providens shall, both at the time of the determination of the means for processing and at the time of the processing itself, implement appropriate technical and organizational measures in order to secure the appropriate level of security taking into account the possible risks. This is primarily achieved through continuous monitoring of stored personal data, processing only in the extent which is necessary for each specific purpose and storing personal data only if necessary to achieve the specific purpose of processing.
RIGHTS OF DATA SUBJECTS – PERSONS TO WHOM PERSONAL DATA RELATE
If at any given moment Providens wishes to collect personal data by any means it shall first notify the data user to whom those personal data relate and shall inform them of all the pertaining details and their rights.
The controller shall take appropriate measures to provide any required and prescribed information relating to processing to the data subject in a concise, transparent, intelligible and easily accessible form, using clear and plain language.
Right of access to data
The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning them are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations; where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; the right to lodge a complaint with a supervisory authority; where the personal data are not collected from the data subject, any available information as to their source; the existence of automated decision-making, including profiling and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. Where personal data are transferred to a third country or to an international organization, the data subject shall have the right to be informed of the appropriate safeguards. The controller shall provide a copy of the personal data undergoing processing. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
Right to rectification
The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject shall have the right to complete their incomplete personal data, including by means of providing a supplementary statement.
Right to be forgotten
The data subject shall have the right to obtain from the controller the erasure of personal data concerning them without undue delay and the controller shall have the obligation to erase personal data without undue delay if the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; the data subject withdraws consent on which the processing is based and where there is no other legal ground for the processing; the data subject objects to the processing in that sense; the personal data have been unlawfully processed; the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; the personal data have been collected in relation to the offer of information society services directly to a child. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
Right to restriction of processing
The data subject shall have the right to obtain from the controller restriction of processing if the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims; the data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject. Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State. A data subject who has obtained restriction of processing shall be informed by the controller before the restriction of processing is lifted.
Right to data portability
The data subject shall have the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, if the processing is based on consent or on a contract and the processing is carried out by automated means. In exercising their right to data portability, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
Right to object
The data subject shall have the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning them for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes. At the latest at the time of the first communication with the data subject, the right shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.
Right to object to profiling
The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them. This shall not apply if the decision is necessary for entering into, or performance of, a contract between the data subject and a data controller; is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or is based on the data subject’s explicit consent. The data controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and to contest the decision.
Additional measures for personal data protection used by Providens include encrypted website links and CAPTCHA verification for preventing unwanted spam mail and encrypted communication with the mail server.