Privacy policy

1. Introduction

Dolphin Ltd. with headquarters in Zagreb, Dvorničićeva 22, OIB: 31062429092, (hereinafter: Dolphin), in its business must collect and use certain data about individuals.

The purpose of this policy is to ensure that Dolphin fully complies with legal, organizational and technical obligations with regard to personal data protection.

All Dolphin employees are fully familiar with the content of this policy and ensure its implementation when handling personal data or processing personal data. Employees whose tasks also include handling personal data are adequately educated regarding their tasks in relation to personal data protection.

This policy applies to all personal data held by Dolphin in relation to any person, regardless of whether it was, currently is or will be a client, supplier or contact.

This policy is designed with the aim to improve Dolphin's services towards its users, to protect users in terms of confidentiality of their personal data in providing Dolphin's services and to prevent potential damage to Dolphin and its employees and users as respondents and to ensure that the processing of personal data by Dolphin is fully in accordance with the law and other applicable regulations. Personal data that Dolphin Ltd. processes in its business are not shared with unauthorized persons, are not offered or sold.
 

2. Definition and application

Personal data are all data related to an individual whose identity is determined or can be determined, i.e. an individual 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 characteristic of the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

The processing of personal data includes any operation or set of operations performed on personal data or sets of personal data, either by automated or non-automated means such as collection, recording, organization, structuring, storage, adaptation or modification, withdrawal, finding, inspection, use or utilization, disclosure by transmission, dissemination, publication or making available in any other way, alignment or combination, limitation, deletion or destruction and the performance of logical, mathematical and other operations with these data.

Dolphin collects and processes personal data primarily for the purpose of providing services in its business. Therefore, Dolphin needs to collect and process certain types of data about individuals who come into contact with Dolphin (respondents). Dolphin treats these personal information adequately and in accordance with regulations, regardless of how these data were collected, recorded, stored and used – on paper, computer or on other media.

At the moment of providing the respondents' data to Dolphin, the respondent agrees that Dolphin processes his personal data, in accordance with the indicated purpose. The protection of the privacy of personal data of respondents is permanent, and at any time the respondent can use his rights which are listed and explained below.

Dolphin processes personal data of respondents in accordance with the Personal Data Protection Act (NN 103/03, 118/06, 41/08, 130/11, 106/12), other Croatian regulations, Directive 95/46/EC and the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016).

The data collected by Dolphin are stored in an appropriate manner and their confidentiality is ensured. Dolphin will not forward the collected data to third parties without the permission of the respondent, except in cases where it is necessary to fulfill legal and statutory obligations or contractual obligations of Dolphin, in cases where it is necessary for the fulfillment of tasks performed in the public interest or in cases where the respondent himself has published these data, as well as in other cases determined by the competent regulation.

The respondent, in respect of personal data processed by Dolphin for him, has the following rights:

Right to be informed

The respondent has the right at any time to ask for information whether his personal data are being processed and for what purpose, who is the controller, contact details of the data protection officer, which categories of personal data are being processed, for which period they are being processed or stored, who is the source of obtaining his personal data, who are all recipients of his personal data, as well as the right to be informed about his other rights listed in this policy (right to access, right to rectification, right to erasure, right to restrict processing and others).
 

Right to access

The respondent has the right to obtain from Dolphin a confirmation whether personal data concerning him are being processed, then to get access to these data and information about:

• the purpose of processing,
• the categories of personal data being processed;
• recipients or categories of recipients to whom the data have been disclosed or will be disclosed;
• if possible, about the period for which the data are stored or about the criteria by which it is possible to determine that period;
• to ask Dolphin for rectification or erasure of personal data or restriction of processing of personal data concerning the respondent or rights to object to such processing;
• the right to lodge a complaint with a supervisory authority;
• if personal data are not collected from the respondent, any available information about their source;
• the existence of automated decision-making, including profiling, with consequences.

Right to rectification

The respondent has the right without unnecessary delay to obtain from Dolphin the rectification of inaccurate personal data concerning him. The respondent has the right to complete incomplete personal data, among other things by giving an additional statement.
 

Right to erasure / right to be forgotten

The respondent has the right to have Dolphin erase personal data concerning 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 for processing, if the respondent objects to the processing, if the personal data have been unlawfully processed, if the personal data must be erased for compliance with a legal obligation in Union law or member state law to which Dolphin is subject, if the personal data were collected in relation to the offer of information society services to a child.

This does not apply if processing is necessary (and to the extent it is necessary) for the purpose of exercising the right to freedom of expression and information, to comply with a legal obligation requiring processing in Union law or member state law to which Dolphin is subject, or for the performance of a task in the public interest or in the exercise of official authority vested in Dolphin, for reasons of public interest in the public health area, for the purpose of archiving in the public interest, for the purpose of scientific or historical research, for establishing, exercising or defending legal claims.
 

Right to lodge a complaint with a supervisory authority

The respondent has the right on the basis of his specific situation to object at any time to the processing of personal data concerning him, including profiling, in cases where processing is necessary for the performance of a task in the public interest or in the exercise of official authority vested in Dolphin or if processing is necessary for the purposes of legitimate interests of Dolphin or a third party. Dolphin may no longer process personal data unless Dolphin demonstrates compelling legitimate grounds for processing which override the interests, rights and freedoms of the respondent or for establishing, exercising or defending legal claims.

If personal data are processed for the purposes of direct marketing, the respondent at any time has the right to object to the processing of personal data concerning him for such marketing, which includes profiling to the extent that it is related to such direct marketing.
 

Right to data portability

The respondent has the right to receive personal data concerning him, which he has provided to Dolphin, in a structured, commonly used and machine-readable format, and has the right to transmit those data to another controller without hindrance from Dolphin, if the processing is based on his consent and if the processing is carried out by automated means.

The respondent has the right to direct transmission from Dolphin to another controller, if technically feasible, and this right should not adversely affect the rights and freedoms of others.
 

Rights related to automated decision-making and profiling

The respondent has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or similarly significantly affects him, except if that decision is necessary for entering into, or performance of, a contract between the respondent and Dolphin, if permitted by Union law or the law of the member state to which Dolphin is subject or based on the express consent of the respondent.
 

Right to withdraw consent

The respondent's consent is one of the legal bases for processing data related to the respondent. The respondent has the right at any time to withdraw the consent he has given. Withdrawal of consent does not affect the legality of the data processing done before the withdrawal of consent.
 

Right to restrict processing

The respondent has to request a restriction of processing of his personal data: if he disputes the accuracy of his personal data - for the period necessary for Dolphin to verify that accuracy, if the processing of his personal data is unlawful but he does not request erasure but only limitation of processing, if Dolphin no longer needs his personal data, but their existence is necessary for the realization of his legal claims, if he has lodged an objection to the processing he has the right to request a restriction of processing for the period until determining whether legitimate reasons for processing by Dolphin outweigh his reasons for