About Privacy Policy

In accordance with 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, and repealing Directive 95/46/EC (Official Journal of the European Union L 119, 4.5.2016, page 1, hereinafter: General Data Protection Regulation), which has been in full application since 25 May 2018 in the Republic of Croatia and all EU Member States, as well as the Law on the Implementation of the General Data Protection Regulation (Official Gazette No. 42/18, hereinafter: the Act), or in accordance with the legal framework for the protection of personal data in the Republic of Croatia and the European Union and the best European practice, REAL GRUPA Ltd., for marketing and trade, with its registered office in the Republic of Croatia, Ulica Ljudevita Posavskog 31, 10000 Zagreb, OIB: 57210097686 (hereinafter: REAL GRUPA), as the Data Controller of personal data of potential clients and website visitors, has created the Privacy Policy.

This Privacy Policy (“rules”) explain how REAL GRUPA collects, uses and manages your personal data contained on the website and made available to REAL GROUP using the website www.realgrupa.com.

The Privacy Policy applies to all services offered by REAL GRUPA, with the aim of the policy to inform our visitors, partners and users of our services (hereinafter: data subjects) in a clear and transparent manner about the processing of their personal data and their rights.

REAL GRUPA is committed to protecting and respecting your privacy. Please read this Policy carefully to understand why and how we collect your personal data and how it will be used. Regarding the personal data we collect, REAL GRUPA is the “data controller”, respectively the one who determines the needs for which and how personal data are processed.

REAL GRUPA, as a provider of website services, is committed to the protection of the privacy of personal data.

If you wish to contact us regarding this Policy or regarding your personal data, please use the following contact information:

REAL GRUPA d.o.o.
Ulica Ljudevita Posavskog 31
10 000 Zagreb
E-mail: gdpr@realgrupa.com

How and when do we collect your personal data?

We collect your personal data when it is necessary to meet your needs and requirements, to provide services or for the purposes of our business:

• when you contact us and ask for assistance or ask a question to exercise one of your rights guaranteed by applicable regulations, we process your contact data,
• when you contact us via social networks (Facebook and LinkedIn), we collect the data that you have left available to us when making an inquiry or request,
• when you send us any inquiry or inquiry related to our services through our contact information by e-mail, phone call, post or in any other way, we collect your e-mail address, name, surname, phone number, etc. for the purpose of responding to the inquiry. Also, we collect the topic of the inquiry as well as the content of it depends on what kind of inquiry it is,
• when you send us a request for data and services of REAL GRUPA, we will process your contacts and/or other data that you provide to us when sending an inquiry,
• when you contact us as partners or as interested legal entities in connection with our services, we collect your data such as name, surname, e-mail, telephone number, position in the company, occupation, account number, etc. Our partners can be natural persons, craftsmen, persons with whom contracts for work are concluded or legal entities that are represented or represented by natural persons (e.g. signatories of contracts, couriers, recipients of invoices, etc.). In contacts with interested legal entities, we also process data on natural persons who represent or represent these legal entities. Such processing is necessary for the performance of the contract, i.e. for the purpose of providing our service, which are or may be necessary actions/preliminary actions related to the conclusion of the contract,
• if you wish to send an open job application, we will process data such as your name, surname, age, title, occupation, work experience, contact phone number and other data contained in your application,
• when participating in prize games and competitions, we collect your data only if you decide to participate in them, and on that occasion, for the purpose of conducting the prize game or competition and awarding prizes, we process the data depending on the type of prize game or competition, and we will additionally inform you about this in the rules of the prize game or competition. The data that may be processed are, for example, name, surname, address for sending the prize, e-mail address, etc.
• during the video surveillance that we have introduced to ensure the safety of people and property, respecting to reduce the exposure of workers and visitors to the risk of robbery, burglary, violence, theft and similar events at work, in connection with work or the use of our services, we process your personal data on the basis of a legitimate interest, such as a recording of your image, manner of walking, physiognomy, etc.

We collect the above specific categories of your personal data:

• when the processing is necessary for the performance of a contract to which the data subject is a party, respectively to act at the request of the data subject prior to the conclusion of the contract
• to fulfil our obligations arising from the applicable regulations of the Republic of Croatia
• based on consent, which may be shown to you, for example, when you come to the website www.realgrupa.com via a pop-up window
• based on legitimate interest, for example in cases where cookies are necessary for the functioning of the www.realgrupa.com or when it comes to data collected through video surveillance systems.

In exceptional cases, we may also carry out processing to protect the vital interests of the data subject or another natural person, e.g. in the event of illness or injury, for which we may need to ask you for an identity document or health data that falls under a special category of personal data. This would also apply in emergency health situations, such as the state of epidemic, during which we would be obliged to process data based on the recommendations of the competent public authorities of the Republic of Croatia.

If the processing is based on your consent, you have the right to withdraw your consent at any time. The data controller should be notified of the withdrawal of consent by e-mail: gdpr@realgrupa.com or at the address Ulica Ljudevita Posavskog 31, 10 000 Zagreb, Croatia. Such withdrawal will not affect the lawfulness of processing based on consent prior to its withdrawal.

If the processing is based on a legitimate interest, we have procedures in place to assess that the processing is appropriate to business needs and that it is as intrusive as possible, i.e. we perform such processing only if the interests of the data subject do not override our legitimate interests. An example of such processing is the use of necessary cookies on our websites for the purpose of proper functioning of the website and video surveillance for the purpose of ensuring the safety of people and property. In these cases, the data subject always has the right to object to such processing.

Please pay attention to the mandatory scope of the data we ask you for, because in the event that you do not provide the requested information that is determined as mandatory in order to perform the requested or expected activity for you, unfortunately, you will not be allowed to participate in it, i.e. without the requested data, the activity will not be technically feasible.

What data do we collect directly from you and for what purpose?

Typical categories of data that we collect from service users are the following: first name, last name, e-mail address, phone number, position in society, occupation and other information you provide when you communicate with us by phone, e-mail and social networks.

We collect your personal data for the following purposes:

• performance of the service, fulfilment of the contract or other means of ensuring the provision of the requested service
• use of all services on the website www.realgrupa.com
• efficient response to your inquiry and processing of your requests
• statistical data processing
• improvement of the quality of content, functionality and services

What privacy rights do you have?

Please note that at any time you have the right to request the following from REAL GROUP:

To exercise any of the above rights, please use the contact details provided at the beginning of the Privacy Policy.

If you believe that your rights are not being respected, you have the right to file a complaint with the Personal Data Protection Agency (Ulica grada Vukovara 54, 10 000 Zagreb).

Special note:

When making an inquiry or request related to the exercise of the rights we have stated earlier, we may also ask you for additional identifiers in cases where we suspect your identity or if you do not have verified or confirmed data in our system through which, after you make an inquiry, we can undoubtedly determine that it is you before providing the data or a copy of the data. For your safety, we verify your identity because we do not want your data to fall into the hands of a third party without authorization.

The deadline for responding to your request (the so-called GDPR inquiry) is one month and it can be extended by sending an explanation of the extension of the deadline.

Where is your personal data stored?

We store the personal data we collect about you in a secure environment. Your personal data is protected from unauthorized access, disclosure, use, alteration, or destruction by any organization or individual.

The processed data is stored on our premises and secure IT systems, but sometimes we store the data on the servers of our trusted service providers located in the EU.

REAL GRUPA will ensure that personal data is kept in a secure place (which includes reasonable administrative, technical and physical protection to prevent unauthorized use, access, disclosure, copying or modification of personal data), which can only be accessed by authorized persons. All authorized persons sign the confidentiality statement.

The data collected for the purposes specified in this Policy will only be stored for as long as necessary to fulfil the stated purposes. Your personal data will not be stored in a form that allows you to be identified for longer than REAL GRUPA reasonably deems necessary to achieve the purpose for which it was collected or processed. REAL GRUPA will store certain personal data for a period prescribed by law or regulation that obliges REAL GRUPA to store data (more under “How long will REAL GRUPA keep your personal data? ̋).

In case you have given us consent (for example, you have selected a certain category of cookies to use), we will process your personal data until you withdraw your consent.

If you declare a well-founded objection to the processing of personal data based on a legitimate interest, we will not process your personal data in the future.

In addition to all the above, it is important to point out the following: if judicial, administrative or extrajudicial procedure have been initiated, personal data may be stored until the end of such proceedings, including a possible period for filing legal remedies.

Does REAL GRUPA exchange data with third parties?

Protecting your privacy is important to us, so we will never share your personal data with third parties except for the purposes described in this Policy. We will always inform you about the sharing and transfer of data.

REAL GRUPA cooperates with other companies. This means that we sometimes share your personal data, using secure IT systems. When we do so, the data is transferred to servers located in the EU or in a country that ensures an adequate level of protection in accordance with EU legislation.

In some cases, our partners who provide services on behalf of or for REAL GROUP may process your data outside the European Union or the European Economic Area. However, the contracts we conclude with such entities oblige them to handle your data with special security measures in accordance with the regulations in force in the member states of the European Union.

On 10 July 2023, the European Commission adopted a new adequacy decision under which personal data can be freely transferred from the European Union to companies in the US participating in the Data Privacy Framework.

The adequacy decision is based on Article 45 of the General Data Protection Regulation. The General Data Protection Regulation (GDPR) is a mechanism that ensures the secure and lawful transfer of data to third countries. Companies in the U.S. that wish to participate in the Data Protection Framework must undergo a self-certification process and enrol in the list of companies that have accessed the Data Privacy Framework.

Also, if our contract partner is based in the US, we will review existing contracts and check the security standards that our partner guarantees to ensure the protection of all our data subjects with the latest standards approved and suggested by the relevant institutions.

The purposes for which we share data with our trusted partners are, for example, accounting needs, fulfilment of contractual and legal obligations, etc. These service providers are obliged, under the relevant contracts, to use the data entrusted to them only in accordance with our guidelines and exclusively for the purposes strictly specified by us. We also oblige them to adequately protect your data and to treat it as a business secret.

We audit all our partners once a year to ensure that the protection of your personal data continues to be at the required level and that it complies with applicable regulations.

How long will REAL GRUPA keep your personal data?

REAL GRUPA will not retain your personal data for longer than the period for which the data is necessary to fulfil the purpose of their use, and for a maximum period of 5 years, except in exceptional cases or when a longer data retention period is prescribed by law.

Information on the use and duration of cookies on the REAL GRUPA website can website can be found in the Cookie Policy.

You can find out more about data retention periods by contacting our Data Protection Officer.

What will we use your information for?

We may use your personal data in several different ways, mainly to perform our legal, contractual, and other obligations to you, but sometimes also to improve your experience of using the website and for security reasons.

The purposes for which we use your data are described in this Policy, and if your data is processed for other purposes, you will be informed before such (new) processing is carried out.

Cookies

To maintain the website and ensure that its functionalities are at the expected level, REAL GRUPA uses a technology known as “cookies”.

Cookies are small files that we send to your computer and can access later. They can be temporary or permanent. Thanks to cookies, you can browse our site without difficulty. Cookies allow us to function securely on the website.

Read more about the cookies we use on the website www.realgrupa.com in the Cookie Policy.

Other websites

Other websites that can be accessed through the website www.realgrupa.com have their own confidentiality and data collection statements and the ways in which they are used and published.

REAL GRUPA is not responsible for the methods and conditions of operation of third parties.

REAL GRUPA collects and processes personal data through user interactions on social networks such as Facebook and LinkedIn.

REAL GRUPA, or the responsible persons appointed by REAL GRUPA, have access to messages and/or posts on the mentioned social network, however, personal data collected through them, especially those contained in messages, are not stored or further processed by REAL GRUPA except for the purposes specified in this Policy.

REAL GRUPA uses a business profile using Facebook and LinkedIn services, and you can view their Privacy Policy or confidentiality statements as well as the way they use your personal data at:

In case you have questions regarding the collection and processing of data by Facebook or LinkedIn or you want to exercise any of your rights guaranteed by the General Data Protection Regulation, please contact:

Entry into force and changes to the privacy policy

These Rules enter into force upon publication on the website.

REAL GRUPA reserves the right to amend the Privacy Policy and it will be published on the website.

Update and Publication Date: December 9, 2024.