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Privacy Policy

Privacy Policy

PRIVACY POLICY

THE APPLICATION

AMPnet IO d.o.o. established in Zagreb, Heinzelova ulica 62A, VAT no.: 57624879969 (hereinafter: Company) developed the application AMPnet Crowdinvesting (hereinafter: Application) that requires you to enter certain personal data. The Company is determined and committed to protecting your privacy and personal data during their processing. This Privacy Policy explains the manner in which we collect and use your personal data for the purpose of fulfilling our legal obligations and lists your rights and possibilities in this respect.

If you decide to use the Application, you are consenting to the collecting and using of the information related to this Privacy Policy. Personal data that we collect is used for providing and improving the application service. Your data will not be used or shared with others, except as described in this Policy Privacy for using the Application.

Terms used in this Privacy Policy have the same meaning as in the General Terms for using the Application, except if specified otherwise in this Privacy Policy.

I/ WHO IS THE RESPONSIBLE PERSON FOR THE SAFETY OF THE COLLECTED PERSONAL DATA

The Company is responsible for the safety of the collected personal data.

The Company will process your data in the capacity of the controller. For the purpose of protecting personal data, enabling the processing of data and exercising your rights as the data subject whose personal data is being processed, the personal data might be released to natural and legal persons that we collaborate with, based on our contractual or legal obligations (e.g. tax advisors, accounting service, attorneys, competent public authorities bodies).

II/ WHICH PERSONAL DATA DO WE PROCESS

The personal data we process might include:

  • data for establishing and keeping contact such as name and surname, address, seat of a legal person, place of residence, personal identification number, postal address, business address, fax number, mobile phone number, email address;
  • data referring to issuing of invoices and processing payment in the event of introducing payment for using the Application and conducting legal obligations related to the prevention of money laundering and terrorism financing, such as bank account numbers, payment cards data and other related information;
  • further business information that have been provided to us voluntarily, such as provided instructions, specific requests and/or orders;
  • previously published information that we collect using publicly available registers, records and logbooks;
  • details on mutual communication (written correspondence, etc.), as well as conversations conducted in the scope necessary for the improvement of the Application services as well as for resolving potential objections and complaints;
  • personal data retrieved during the usage of the Application service, that is during the monitoring of electronic devices, which personal data is strictly related to your user account or to the persons whose electronic devices you monitor.

III/ HOW WE COLLECT PERSONAL DATA

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

  • when and if the collection of personal data is necessary for the purpose of improving the Application service;
  • when you contact us using electronic means of communication with the aim of establishing business cooperation or expressing interest for the purpose of establishing business cooperation;
  • when you contact us using electronic means of communication with the aim of submitting an objection, complaint, suggestion, advice;
  • when you contact us using electronic means of communication with a request for help in using the Application services;
  • when our employees contact you with the aim of providing notifications concerning the Application services or changes in the General Terms of use or the Privacy Policy;
  • for the purpose of distributing promotion material and advertising our products and services;

IV/ LOG DATA

Every time you use the Application services, in the event of an error in the Application, using third parties we can collect data and information that is located on the electronic devices under the name Log Data. The Log Data may contain data such as the IP address, name of device, operative system version, Application configuration during the use of the Application, time and date of using the Application services and other statistical data.

V/ COOKIES

Cookies are files with a small amount of data that are usually used as anonymous unique identifiers. They are sent to your browser from the web-sites you visit and are stored in the internal memory of the device.

The Application does not use cookies by or in itself. However, the Application may use third-party codes and libraries that use cookies for collecting information and improving their services. You have the option to accept or reject these cookies and to be informed when a cookie is sent to your device. If you decide to reject our cookies, you might not be able to use some parts of the Application or you might not be able to use the Application service in full.

VI/ ARE YOU OBLIGED TO PROVIDE US WITH YOUR PERSONAL DATA

In general, you provide us with all your personal data voluntarily; there are generally no negative or detrimental consequences if you decide not to provide us with your personal data. However, if you do not consent to providing your personal data, you will not be able to use the Application services and there are circumstances when the Company cannot take certain actions without your personal data, for example when the personal data is needed for creating a user account in the Application, for proper monitoring of the use of electronic devices, processing your instructions, requests, advice, petitions and potential orders. In all of these events, the collecting and processing of your personal data is a prerequisite for providing our services, except in the event when there exists another legal basis for the collection of your personal data, such as a legal or contractual basis.

VII/ THE PURPOSES FOR WHICH WE PROCESS PERSONAL DATA

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

  • for the purpose of executing the Application services;
  • for the purpose of improving the Application services;
  • for the purpose of connecting Application users;
  • for the purpose of processing requests, objections, petitions, advice or orders of the Application users;
  • for the purpose of creating and delivering promotion material;
  • for the purpose of establishing a contractual relationship and exercising the rights and obligations thereof;
  • for the purpose of managing and administrating business processes related to the execution of the Application services;
  • for the purpose of complying with and fulfilling our legal obligations as well as the obligations that may arise from European Union law and third countries law in a measure that is applicable and which scope and content do not contradict Croatian law;
  • for the purpose of analysing and improving our services and communication with you;
  • for the purpose of protecting the security and managing access to websites and communication systems connected with the Application;
  • for the purpose of complying with court decisions and decisions made by public authorities and legal persons with public authority and exercising our rights and lawful interests;
  • for the purpose of keeping statistical records related to the operation of the Application;
  • for purposes of marketing, promotion and propaganda;
  • for any purpose considered necessary in relation to the fulfilment of some of the above listed purposes.

For the purposes of communication related to marketing services, provided that such an obligation is prescribed by law, we will be sending you only that information that you have consented to and only for as long as you do not withdraw your consent. We will not use your personal data for taking any other actions or creating profiles except in the cases listed here.

Depending on the Allowed Purpose for which we are processing your personal data, we can process your personal data based on the following legal grounds:

  • if you have given consent to the processing of your personal data for one or more Allowed Purposes;
  • the processing is necessary for improving the Application services which you use;
  • processing is necessary for compliance with our legal obligations;
  • processing is necessary in order to protect your vital interests;
  • processing is necessary for the purposes of our legitimate interests pursuant to the provisions of the Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter: GDPR).

VIII/ WITH WHOM CAN WE SHARE YOUR PERSONAL DATA

We can share your personal data in the following circumstances:

We can share your personal data with external associates such as business entities with whom a collaboration is necessary for exercising the Application services, maintaining the quality of the Application services, improving the Application user experience, public bodies and bodies with public authority, when it is necessary for the purpose of protecting the contractual rights and/or requests, or when it is in the public-legal interest, i.e. when such sharing represents a legal obligation.

We are also authorised to order third persons to process your personal data in our name and for our account and in accordance with our instructions as the controller, in which case we assume the responsibility for the secrecy and security of your personal data. In this case, the Company remains completely responsible towards you for the security and secrecy of the personal data and will utilize any means necessary as required by relevant regulations in order to ensure the integrity and safety of your personal data.

We can also use your personal data for statistical purposes in order to monitor the visits and usage of our websites, with the purpose of developing our activities and improving the quality of the Application.

In other cases, we may disclose your personal data to a third person only if you provide us with your consent for such act, independently of whether the consent is contained in the consent for using the Application or contained in a separate document, if required by law or if ordered by a court or other public body, i.e. a body with public authorities.

IX/ LINKS TO OTHER WEBSITES

The Application may contain links to other websites. If you click such a link, you will be redirected to a website connected with the link. Please note that we do not manage these external websites. Therefore, we recommend that you review the privacy policy of these websites. We have no control of and assume no responsibility for the contents, privacy policy or practices of any third-party websites or services.

X/ THIRD PERSONS PERSONAL DATA THAT YOU PROVIDE TO US

If you provide us with personal data of other natural persons (for example of the persons whose electronic devices you will be monitoring using the Application, some of your employees, directors or persons with whom you have a certain business relationship), you must ensure and you guarantee that you are authorised to disclose their personal data to us, that we can process this data and that we can, without the obligation to take further action, collect, use and transfer this data pursuant to the conditions laid out in the Privacy Policy.

You must especially ensure that the other natural person is acquainted with the disclosing of their personal data to us, that they have consented to such divulgence, usage and transfer of personal data, and that they are entirely familiar with the contents of the Privacy Policy, including but not limited to our identity, purpose of the Application, contact data, purposes for personal data processing, rights in relation to access to personal data, changes in personal data, insight into the collected personal data, deletion of personal data, transfer of personal data, right to submitting an objection in relation to the processing of personal data, as well as the consequences for violating our obligations in relation to the above stated.

XI/ PERSONAL DATA PROTECTION

We will protect your personal data by applying appropriate technical and organisational-security measures, pursuant to internal regulations and procedures in relation to the storing, access, disclosing and access to personal data, all regulated by statutory regulations of the Republic of Croatia and legal acts of the European Union. The personal data may be stored in paper form and/or be stored in special electronic systems for personal data protection.

XII/ TRANSFER AND ENCRYPTION OF PERSONAL DATA

If the need arises for the Company to divulge personal data to a third party or individuals for the following reasons:

  • in order to make the provision of the Application service easier,
  • in order to continue with the provision of the Application service in the name of the Company,
  • in order to fulfil the services connected with the Application services,
  • in order for you to help us in analysing the manner in which the Application is being used,
  • in order to comply with the requests or decisions of government bodies or with justified requests of public authorities,

we will take all necessary measures in order for the level of protection of your personal data to be compliant with the provisions of the Regulation and other relevant regulations of the Republic of Croatia. In the event of such a transfer, the recipient of the personal data ensures the level of protection as prescribed by the Regulation.

We would like to notify the users of the Application service that some third parties have access to your personal data. The reason for this is the performing of the tasks assigned to them in the name of the Company. However, they are obliged not to publish or use your personal data for any other purpose.

XIII/ CHANGES IN PERSONAL DATA

Should any personal data you have provided us change (e.g. your email address, living address, legal person seat, etc.) or if you learn that we are in possession of incorrect personal data, please enter the correct personal data in the Application by changing the user account in the Application, or notify us of this by sending an email to the following email address: [email protected]

The Company is not responsible for any losses that might arise from incorrect, untruthful, lacking or incomplete personal data that you have provided us.

XIV/ HOW LONG DO WE STORE THE PERSONAL DATA

Your personal data will be deleted when there is no longer any reasonable need for their storage for Allowed Purposes, i.e. in the measure in which this is applicable when you withdraw your consent, provided that we are not legally obligated to store the personal data. In any event, we will store your personal data for as long as there exists the need for their storage for the purpose of providing and improving the Application services.

XV/ YOUR RIGHTS

Pursuant to the conditions laid out in the Regulation, i.e. the regulations of the Republic of Croatia, you have the right to withdraw your consent (if the processing of personal data is based on the consent, and there is no other legal basis for the processing), the right of insight into the collected personal data, the right to request a change of the collected personal data, the right to delete the personal data, the right to transfer the collected personal data, the right to object to the processing of personal data. Should you decide for any of the above listed, kindly contact us by sending an email to the following email address: [email protected]

When sending the request, we might ask you to prove your identity by submitting a valid copy of a personal document from which your identity can be determined, with the aim of following the relevant regulations and preventing unauthorised disclosure of personal data. We reserve the right to charge you additional fees if you misuse your right to access to personal data, for example in the event of submitting repeated requests. We will consider all your requests and objections that we receive and answer them in a timely manner. If you are not satisfied with our reply, you can submit your objection to the body competent for the protection of personal data - the Croatian Personal Data Protection Agency.

Contact data of the Croatian Personal Data Protection Agency:

Selska cesta 136

HR - 10000 ZAGREB

Tel. 00385 (0)1 4609-000

Fax. 00385 (0)1 4609-099

Web: www.azop.hr

XVI/ LEGAL WAIVER

You, as the person responsible for the personal data we process in your name as the controller for the provision of the Application service, guarantee to us that you have all of the relevant informed consents, approvals and permissions from each person whose personal data might be processed during the use of the Application and that are submitted to us while using the Application. You agree that the Company is not responsible for all the requests, damages and losses you might have suffered in relation to or arising from the processing of your personal data and other personal data submitted to our systems while using the Application services.

XVII/ JURISDICTION

This Privacy Policy and all its amendments, potential disputes, disagreements, arguments, questions or requests arising from the interpretation, execution, breach, solving or nullity of this Privacy Policy or in relation to it, directly or indirectly, is subject to Croatian legislation and the law of the Republic of Croatia. Previously stated notwithstanding, the Company and the Application users will make every reasonable effort to attempt to resolve disputes amicably.

XVIII/ CHANGES IN THE PRIVACY POLICY

This Privacy Policy is effective as of 1 January 2021. We reserve the right to change it from time to time, with the changes reflecting the changes in the activities and the manner of processing personal data or the changes in the legal circumstances. The changes shall take effect with the day of their publication.

XIX/ HOW TO CONTACT US

We care about your opinion about our Policy Privacy. You can contact us by sending an email to the email address: [email protected] or in writing by sending a written document to the following office business address of the Company: Josipa Marohnića 3, 10000 Zagreb.

AMPnet IO d.o.o.

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