Firmus grupa d.o.o.
Emila Antića 53
51266 Selce
OIB: 65092215454

Introductory provisions
This Policy establishes a responsible and transparent framework for ensuring compliance with the General Regulation on Personal Data Protection. The policy applies to all organizational parts of “Firmus grupa doo” (hereinafter PROCESSING MANAGER) and to all employees, including part-time employees and temporary workers, as well as to all external collaborators acting on behalf of the processing manager.

Policy statement
The processing manager is dedicated to doing business in accordance with all laws, regulations and the highest standards of ethical business. This policy sets out the provisions of the expected behavior of employees of the data controller and its external collaborators who deal with the collection, use, storage, transmission, publication or destruction of any personal data belonging to employees, business partners of the data controller and other natural persons. The purpose of the policy is to standardize the protection of the rights and freedoms of the data subject by preserving the privacy of his personal data in all aspects of the controller’s operations that include personal data. This policy establishes that the PROCESSING MANAGER will not disclose personal data to a third party without authorization, nor act in a way that endangers them.

Principles of personal data processing
The controller shall adopt the following principles to be followed in the collection, use, retention, transfer and destruction of personal data:

LEGITIMACY, JUSTICE AND TRANSPARENCY
Personal data will be processed legitimately, fairly and transparently towards the respondents. This means that in all relevant situations, the data controller will inform the respondent about how they will process the data (transparency), and the processing will be carried out exclusively in accordance with what was said (fairness) and in accordance with the purpose prescribed in the applicable law on protection personal data (legitimacy).

LIMITATION OF PURPOSE
Personal data will be collected for clearly defined and legitimate purposes and will not be processed in any way inconsistent with those purposes. This means that the data controller must clearly state what the collected data will be used for and limit the processing of personal data to only those processes that are necessary to achieve these purposes.

DATA MINIMIZATION
The personal data collected will be relevant and limited to what is necessary to achieve the purpose of their processing. This means that the controller will not collect, process or store more personal data than is absolutely necessary.

ACCURACY OF DATA
The collected personal data will be accurate and up-to-date, which means that the controller will have developed procedures for detecting and resolving obsolete, inaccurate and unnecessary personal data.

CAUTION STORAGE
Personal data will not be kept in a form that allows the identification of respondents for longer than is necessary for the purpose of processing. This means that the data controller, wherever possible, will store personal data in a way that limits or prevents the identification of the respondent.

DATA SECURITY
Personal data will be processed and stored in a way that provides adequate protection against breaches such as unauthorized and unlawful processing and accidental loss, destruction or damage to data. The data controller will implement appropriate technological and organizational measures described in the Personal Data Security Policy to ensure the integrity and confidentiality of personal data at all times.

PRIVACY BUILT INTO SYSTEM DESIGN
When designing new and reviewing and expanding existing processing manager systems and processes, care will be taken to apply all of these principles to maximize the privacy of respondents.

Principles of personal data processing
All respondents whose data are collected and processed by the controller have the following rights:

RIGHT TO ACCESS INFORMATION
Each respondent has the right to a copy of the data that the processing manager has in his archive for the purpose of insight. In addition to the right to access their own data, the respondent also has the right to information about:

purpose of processing and legal basis for processing
legitimate interest, if the processing is based on it
types and categories of personal data collected
to third parties to whom the data are forwarded
data retention period
source of personal data, if not collected from respondents.

All information should be provided to the respondent in clear and simple language, to ensure understanding, and must be clearly indicated and visible so that the respondent does not overlook it. There is a possibility that providing the requested information to the respondent may reveal information about another person. In such cases, it is necessary to anonymize the data or completely withhold it in order to protect the rights of that person.

RIGHT TO CORRECT DATA
Every respondent has the right to correct inaccurate or incomplete data that the processing manager has in his archive.

THE RIGHT TO FORGET
Respondents may request that information about them be removed from the archives. The request will be taken into consideration and will be granted if it does not contradict the legal basis of personal data processing.

RIGHT TO LIMIT PROCESSING
Respondents have the right to limit the scope of processing, in cases where this is applicable.

RIGHT TO DATA TRANSMISSION
Respondents have the right to a copy of the data for transfer to another controller.

RIGHT TO OBJECT
Respondents have the right to object, especially in cases where the processing is based on the legitimate interest of the controller. Then it is necessary to review the purpose of the processing and establish its legal basis and, in cases where it is applicable, enable the subject to withdraw consent for data processing and/or stop processing his data.

RIGHT TO ASSESS
Respondents have the right to ask the supervisory authority to assess the violation of the provisions of the Regulation and the internal policies of the processing manager.

RIGHT TO OBJECT TO PROFILING
Respondents have the right to object to automatic profiling and other forms of automated decision making. In the event that the data controller rejects the request of the data subject, the reason for the rejection will be stated in the response, which the data subject can appeal to the competent authority for the protection of personal data (AZOP).

Legal basis
The legal bases for the collection and processing of personal data of respondents are the following:

LEGAL OBLIGATION
The laws governing the business of taxpayers prescribe data sets that are necessary for the execution of a legal obligation. For the collection and processing of data prescribed by law, the data controller will not ask for consent from the subject, but will only collect data prescribed by law and will not use it for other purposes. This especially applies to data collected on the basis of the following laws and regulations pertaining to them, among which we single out:

Accounting law
Accounting law
Value Added Tax Act
Income Tax Act
Labor Law
Rulebook on the content and manner of keeping records of workers

PERFORMANCE OF THE CONTRACTUAL OBLIGATION
The personal data necessary for the fulfillment of the contractual obligation will be collected by the controller without the consent of the respondent, to the minimum extent necessary for the performance of the obligation.

LEGITIMATE INTEREST
The controller will then publish a list of its legitimate interests on the basis of which it collects and processes personal data for the purpose of enabling and / or improving its services or products.

PROTECTION OF VITAL INTERESTS OF RESPONDENTS
The controller may collect and process personal data without the consent of the respondent if this is for the purpose of protecting his vital interests.

PUBLIC INTEREST OR EXECUTION OF THE OFFICIAL AUTHORITY OF THE PROCESSING MANAGER
In the case when the activity of the head of processing includes acting in the name of public interest or data processing is based on another type of official authority, it is not always necessary to inform the respondent about the collection of personal data.

CONSENT
In all other cases, the controller will seek the consent of the respondent for the collection and processing of personal data in which the purpose of the processing will be clearly stated. The subject can withdraw his consent at any time and thus his data must be automatically removed and the processing terminated. The processing manager will keep records of active and withdrawn consents for the purpose of ensuring the correctness of operations.

Legitimate interest
The processing manager announces the following legitimate interests:

PERSONAL DATA PROTECTION GDPR
Respondents have the right to object to the processing of personal data based on these legitimate interests.

Terms and definitions

GENERAL REGULATION ON THE PROTECTION OF PERSONAL DATA (GDPR)
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a regulation by which the European Parliament, the Council of the European Union and the European Commission intend to strengthen and unify the personal data protection processes of all individuals within the European Union (EU). The regulation also applies to the export of personal data outside the EU.

PROCESSING MANAGER
An entity that determines the purpose, conditions and manner of processing personal data.

PROCESSING PERFORMER
An entity that performs data processing on behalf of the controller.

PERSONAL DATA PROTECTION AGENCY
A state agency whose task is to protect data and privacy, monitor the processes of application of the Regulation, and actively implement the Regulation on the Protection of Personal Data within the European Union.

PERSONAL DATA PROTECTION OFFICER
A data protection expert who acts independently to ensure that the business entity operates in accordance with the policies and procedures set out in the Regulation.

EXAMINEE
A natural person whose personal data is processed by the controller or executor of data processing.

PERSONAL INFORMATION
Any information that is associated with a natural person, ie. to the respondent and which can be used to directly or indirectly identify a person.

PROCESSING OF PERSONAL DATA
Any activity carried out on personal data, automatic or not, which includes the collection, use, creation of records and the like.

PROFILING
Any automated data processing for the purpose of assessing, analyzing or predicting the behavior of respondents.

RIGHT OF ACCESS OF RESPONDENTS
Known as the ‘right of access’, it allows the respondent access to personal data concerning him / her which are in the possession of the controller.

Legislation
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals in connection with 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)

Law on the Implementation of the General Regulation on Data Protection.