Privacy policy

Privacy policy

Mint Media Ltd.

MINT MEDIA Ltd. with registered office in Dubrovnik, on Liechtensteinov put 3, VAT number: 51576256404, represented by a member of the Management Board Barbara Lakić (hereinafter: The Company) is determined and committed to protecting your privacy and personal data during their processing. This Privacy policy explains the way how we collect and use your personal information for the purpose of fulfilling our legal obligations, establishing and exercising the rights and obligations arising from the contractual relationship; your rights and opportunities in this regard.

1. WHO IS RESPONSIBLE FOR THE SECURITY OF COLLECTED PERSONAL DATA

The Company is responsible for the security of the collected personal data.
Your data will be processed by the Company as the processing manager, and Ivan Ivušić as a person authorized for GDPR, based on the Decision on the appointment of the person responsible for GDPR from May 25th, 2018. In order to protect personal data, enable their processing and to exercise your rights as a respondent whose personal data are processed, personal data may be provided to natural and legal persons with whom we cooperate, based on our contractual or legal obligations (e.g. tax advisors, accounting service, law offices, public authorities).

2. WHAT PERSONAL DATA WE PROCESS

The personal information we process may include:

  • data for establishing and maintaining contact such as name, surname, residential address, residence, personal identification number, occupation - business function, postal address, business address, telephone number, fax number, mobile phone number, e-mail;
  • data relating to the issuance of invoices and payment processing, the implementation of legal obligations in relation to the prevention of money laundering and terrorist financing, such as bank account numbers, payment card details and other relevant information;
  • further business information that are necessary for the purpose of establishing a contractual relationship or that have been voluntarily provided to us, such as instructions, specific requirements and / or orders;
  • previously published information that we collect through publicly available registers and records;
  • details on mutual communication (such as written correspondence), as well as conducted conversations to the extent necessary for the exercise of rights and obligations under the contractual relationship.

3. HOW WE COLLECT PERSONAL DATA

We collect and process your personal information depending on the circumstances, including:

  • when and if the collection of personal data is necessary for the purpose of establishing a contractual relationship and exercising the rights and obligations arising from it;
  • when you contact us directly or through electronic communications and / or with our employees in the aim of establishing a business relationship or expressing interest for the purpose of establishing a business relationship;
  • when our employees contact you or a legal entity in which you are a shareholder, equity holder, holder of direct or indirect economic interest or perform an appropriate function including employment, with the aim of establishing a business relationship or expressing interest for business cooperation;
  • when you are in use of any of our services or applications, for the purpose of the functionality of those services and applications or to improve the functionality of those services and applications;
  • for the purpose of distributing promotional material and advertising our products and services;
  • in certain circumstances, we collect and process your personal data through third parties. For example, we may collect personal information from a legal entity with which you have a business relationship, from other legal entities with which your legal entity has a business relationship, and from other publicly available registers and records.

4. ARE YOU OBLIGED TO GIVE US YOUR PERSONAL DATA

In principle, you provide all personal data to us voluntarily. As a rule, there are no negative or harmful consequences if you decide not to provide us with your personal data. However, there are circumstances when the Company cannot undertake business activities, provide its service or use of the application, or take legal action without your personal data, for example when personal data are necessary for processing your orders, instructions, requests and requests, in order to establish a contractual relation. In these cases, the collection and processing of your personal data is a prerequisite for the provision of our services, unless there is some other legal basis for their collection such as legal or contractual basis.

5. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA

We process personal data exclusively for the following purposes (hereinafter: Permitted purposes):

  • for the purpose of establishing and exercising rights and fulfilling obligations from employment contract;
  • for the purpose of exercising the rights of workers prescribed by special laws;
  • for the purpose of exercising the rights of the Company as an employer in employment and in connection with employment;
  • for the purpose of protecting the safety and health of workers;
  • for the purpose of production and delivery of promotional material;
  • for the purpose of establishing a contractual relationship and exercising the rights and obligations arising from it;
  • for the purpose of managing and administering business processes related to the fulfillment of the contract and for the exercise of rights and obligations arising therefrom, including payment processing, bookkeeping purposes, auditing, collection of receivables and support services in connection therewith;
  • for the purpose of harmonizing and fulfilling our legal obligations, as well as obligations that may arise from the law of the European Union, as well as the rights of third countries to the applicable extent, to the extent and content in which these rights do not contradict the law of the Republic of Croatia;
  • for the purpose of analyzing and improving our services, applications and communication with you;
  • for the purpose of security protection and access control to our business premises, IT and communication system, online platforms, websites;
  • for the purpose of identifying the person authorized to represent our contractual partners, signing orders, accepting offers and concluding a contractual relationship with us;
  • for the purpose of respecting court decisions, decisions of public bodies, legal persons with public powers, exercising our rights and interests based on law;
  • for the purpose of keeping statistics records related to our business;
  • for marketing, publicity and propaganda purposes;
  • for any purpose deemed necessary for the accomplishment of any of the foregoing purposes.

For the purpose of communication regarding marketing services, providing that such an obligation is prescribed by law, we will only send you the information for which you have given your consent and only as long as you do not withdraw your consent. We will not use your personal information to take any other action or create a profile, except in the cases listed here.

Depending on the Permitted purpose on which we process your personal data, we may process your personal data on the following legal grounds:

  • if you have consented to the processing of your personal data for one or more Permitted purposes;
  • when data processing is necessary for the performance of a contract in which the data subject is a party, or in order to take action at the request of the data subject before the contract is signed;
  • when processing is necessary to comply with our legal obligations;
  • when processing is necessary to protect your key interests;
  • when processing is necessary for the purposes of our legitimate interests in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data. / EC ("GDPR").

6. WITH WHOM WE CAN SHARE YOUR PERSONAL DATA

We may share your personal information in the following circumstances.

If you are our business partner or user of our services or applications, we may share your personal information with external associates such as law firms, accounting services, tax advisors, credit bureaus and financial institutions, business entities with which cooperation is necessary to exercise rights and obligations from a mutual contractual relationship (e.g. printing services), debt collection agencies, public bodies and bodies with public authority, when this is necessary for the purpose of protection of contractual rights and / or claims, or when it is in the public interest or when it represents legal obligation.

We may share your personal information on a confidential basis with third parties for the purpose of obtaining your opinion regarding the quality of our products and services to help us improve the quality of our products and services.

We may share your personal data with third parties to whom we have transferred or assigned rights from the contractual relationship with you.

We are authorized to order third parties to process your personal data in our name and on our behalf and in accordance with our instructions as the controller, in which case we assume responsibility for the confidentiality and security of your personal data. In that case, the Company remains fully responsible to you for the security and confidentiality of personal data and will use all necessary measures required by applicable regulations to ensure the integrity and security of your personal data.

We may also use your personal information for statistical purposes to monitor visits to and use of our websites, services and applications with a view to developing our business and improving the quality of our websites, services and applications.

Finally, we may disclose your personal information to a third party only with your consent to do so, whether the consent is contained in a separate document or constitutes a separate clause in the contract, if it is a legal obligation or an obligation to act in accordance with a court or other public authorities.

7. PERSONAL DATA OF THIRD PARTIES YOU SUBMIT

If you provide us with the personal data of other natural persons (for example, one of your employees, a director or a person with whom you have a certain business relationship, or family), you must ensure and guarantee that you are authorized to disclose personal data, and that we may obtain, use and transmit them without obligation to take further action in accordance with the terms of the Privacy policy. You must ensure that another individual is aware of the disclosure of their personal information to us, that they have given consent to such disclosure, use and transfer of personal information and that they are fully aware of the content of the Privacy policy, including and not limited to our identity, contact data, purposes of personal data processing, rights in relation to access to personal data, modification of personal data, insight into collected personal data, deletion of personal data, transfer of personal data, right to objections in relation to personal data processing, as well as consequences in case of violation of our obligations in relation to the foregoing.

8. PERSONAL DATA PROTECTION

We will protect your personal data by applying appropriate technical and organizational security measures in accordance with internal regulations and procedures regarding the storage, access, disclosure and access to personal data. Personal data can be stored in paper form and in special electronic personal data protection systems.

9. PERSONAL DATA TRANSMISSION

If there is a need for the Company to transfer personal data to a third country or international organization, we will take all necessary measures to ensure that the level of protection of your personal data meets the requirements of the Regulation and other applicable regulations of the Republic of Croatia. We ensure this, inter alia, by applying standard contractual clauses issued by the European Commission (Commission Decision of 15 June 2001 on standard contractual clauses for the transfer of personal data to third countries, in accordance with Directive 95/46 / EC and Commission Decision of 27 December 2004 amending Decision 2001/497 / EC as regards the introduction of an alternative set of standard contractual clauses for the transfer of personal data to third countries). In the event of such a transfer, the recipients of personal data in a third country or international organization shall ensure the level of protection required by the Regulation. In case of transfer of personal data to third parties, the Company will ensure that the said persons provide the same level of protection as provided by the Company.

10. CHANGES TO PERSONAL DATA

If any personal information you provide to us changes (e.g. your e-mail, residential address, etc.) or you learn that we have incorrect personal data, please inform us by sending an e-mail to the following e-mail address info@mint-media.hr

The Company is not liable for any losses arising from inaccurate, untrue, defective or incomplete personal data provided to us.

11. HOW LONG DO WE KEEP PERSONAL DATA

Your personal data will be deleted when the reasonable need for their storage for Permitted purposes ceases, i.e. to the applicable extent when you withdraw your consent, provided that we are not legally obliged to keep personal data. In any case, we will keep your personal data as long as there is a need to keep them for the purpose of realizing the rights and obligations under the contract or business relationship, including the need to enforce the collection of the claim.

12. YOUR RIGHTS

Subjected to the conditions prescribed by the Regulation, i.e. the regulations of the Republic of Croatia, you have the right to withdraw consent (if the processing of personal data is based on consent and there is no other legal basis), the right to inspect the collected personal data, the right to request a copy, the right to request a change in the collected personal data, the right to delete personal data, the right to transfer the collected personal data, the right to object to the processing of personal data. If you opt for any of the above, please contact us by sending an email to the following email address: info@mint-media.hr. When sending, we may ask you to prove your identity by submitting a valid copy of your personal document from which your identity can be established in order to comply with applicable regulations and prevent unauthorized disclosure of personal information. We reserve the right to charge you additional fees if you abuse your right to access personal data, for example in the case of repeated requests or requests for additional copies of documents without a reasonable basis. We will consider all your requests and complaints we receive, and we will respond to them in a timely manner. If you are not satisfied with our answer, you can send your remark to the body responsible for personal data protection – the Agency for Personal Data Protection.

Contact details of the Agency for Personal Data Protection:

Martićeva street 14, HR – 10000 ZAGREB

Ph. 00385 (0)1 4609-000

Fax. 00385 (0)1 4609-099

E-mail: azop@azop.hr

Web: www.azop.hr

13. CHANGES TO THE PRIVACY POLICY

This Privacy policy is effective from May 25, 2018. We reserve the right to change it from time to time, which will correspond to the changed procedures and manner of processing personal data or changed legal circumstances. The changes will take effect on the day of publication.

14. HOW TO CONTACT US

We care about your opinion about our Privacy policy. You can contact us by sending an e-mail to the e-mail address: info@mint-media.hr or  in writing by sending a letter to the following business address within the Company’s registered office: Liechtensteinov put 3, Dubrovnik, for Ivan Ivušić.