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GDPR Privacy Policy for Personal Data Protection EU Project

1. Introduction
Tempo Ltd., based in Labin, Titov trg 7, VAT ID: 48743301312 (hereinafter TEMPO), in its business operations must collect and use certain information about individuals.

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

All TEMPO employees are fully familiar with this policy and ensure its application when handling or processing personal data. Employees whose duties include handling personal data are adequately trained regarding their responsibilities in data protection.

This policy applies to all personal data held by TEMPO concerning any individual, whether they were, are, or will be a client, supplier, or contact.

This policy aims to prevent potential harm to TEMPO, its employees, and data subjects and to ensure that TEMPO’s processing of personal data is fully compliant with laws and regulations.

2. Definition and Application
Personal data refers to any information related to an identified or identifiable individual, i.e., an individual who can be directly or indirectly identified, particularly by reference to identifiers such as name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that individual.

Processing personal data means any operation or set of operations performed on personal data or sets of personal data, whether automated or not, such as collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, dissemination or otherwise making available, aligning or combining, restricting, erasing, or destroying, and performing logical, mathematical, and other operations on that data.

TEMPO collects and processes personal data primarily to provide services in its business. Therefore, TEMPO needs to collect and process certain types of information about individuals who come into contact with TEMPO (data subjects). TEMPO treats this personal information appropriately, regardless of how the data was collected, recorded, stored, and used – on paper or other material.

When providing data to TEMPO, the data subject agrees that TEMPO may process their personal data for the specified purpose. The protection of data subject privacy is permanent, and the data subject can exercise their rights at any time, as outlined and explained below.

TEMPO collects and processes data subjects’ personal data 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 Council of 27 April 2016).

TEMPO stores collected data appropriately and ensures its confidentiality. TEMPO will not forward collected data to third parties without the data subject’s permission, except when necessary to fulfill TEMPO’s legal obligations, to fulfill tasks carried out in the public interest, or when the data subject has publicly disclosed the data, or in other cases prescribed by relevant regulations.

The data subject, regarding their personal data processed by TEMPO, has the following rights:

  • Right to Information
    The data subject has the right to request information at any time regarding whether their personal data is being processed and for what purpose, who the data controller is, the contact details of the data protection officer, the categories of personal data being processed, the storage period or criteria to determine this period, the source of their personal data, and the recipients of their personal data, as well as the right to information about other rights outlined in this policy (right of access, right to rectification, right to erasure, right to restriction of processing, etc.).
  • Right of Access
    The data subject has the right to obtain from TEMPO confirmation as to whether or not personal data concerning them is being processed, as well as access to this data and information regarding:
    • The purpose of processing;
    • The categories of personal data being processed;
    • The recipients or categories of recipients to whom the data has been or will be disclosed;
    • The storage period or the criteria for determining that period, if possible;
    • The right to request the correction or deletion of personal data or the restriction of processing of personal data concerning the data subject, or the right to object to such processing;
    • The right to lodge a complaint with a supervisory authority;
    • The existence of automated decision-making, including profiling, and any consequences.
  • Right to Rectification
    The data subject has the right to obtain from TEMPO, without undue delay, the correction of inaccurate personal data concerning them. The data subject also has the right to complete incomplete personal data, including providing an additional statement.
  • Right to Erasure / Right to be Forgotten
    The data subject has the right to have TEMPO delete personal data concerning them without undue delay if the personal data is no longer necessary for the purposes for which it was collected or otherwise processed, if the data subject withdraws consent on which the processing is based and there is no other legal basis for the processing, if the data subject objects to the processing, if the personal data has been unlawfully processed, if the personal data must be erased to comply with a legal obligation under Union or Member State law to which TEMPO is subject, or if the personal data was collected in connection with the offering of information society services to a child.
    This does not apply if processing is necessary (and to the extent necessary) for exercising the right to freedom of expression and information, for compliance with a legal obligation requiring processing under Union or Member State law to which TEMPO is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in TEMPO, for public interest purposes in the area of public health, for archiving purposes in the public interest, for scientific or historical research, or for establishing, exercising, or defending legal claims.
  • Right to Lodge a Complaint with a Supervisory Authority
    The data subject has the right to object at any time to the processing of personal data concerning them, including profiling, if the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in TEMPO or if the processing is necessary for the purposes of TEMPO’s legitimate interests or those of a third party. TEMPO may no longer process personal data unless it demonstrates compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject or for establishing, exercising, or defending legal claims.
    If personal data is processed for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data concerning them for such marketing, including profiling to the extent related to such direct marketing.
  • Right to Data Portability
    The data subject has the right to receive personal data concerning them, which they have provided to TEMPO, in a structured, commonly used, and machine-readable format, and the right to transfer that data to another data controller without hindrance from TEMPO, if the processing is based on their consent and if the processing is carried out by automated means.
    The data subject has the right to direct transfer from TEMPO to another data controller, where technically feasible, and this right must not adversely affect the rights and freedoms of others.
  • Rights Related to Automated Decision-Making and Profiling
    The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them unless that decision is necessary for entering into or performing a contract between the data subject and TEMPO, is permitted by Union or Member State law to which TEMPO is subject, or is based on the data subject’s explicit consent.
  • Right to Withdraw Consent
    The data subject’s consent is one of the legal grounds for processing data concerning the data subject. The data subject has the right to withdraw the consent they have given at any time. Withdrawal of consent does not affect the legality of data processing conducted before the consent withdrawal.
  • Right to Restrict Processing
    The data subject has the right to request the restriction of processing of their personal data if they dispute the accuracy of their personal data – for a period necessary for TEMPO to verify that accuracy, if the processing of their personal data is unlawful and they do not seek deletion but only restriction of processing, if TEMPO no longer needs their personal data but the data subject needs it for establishing, exercising, or defending legal claims, if they have objected to the processing and have the right to request restriction for the period until it is determined whether TEMPO’s legitimate grounds for processing override their objection.

To exercise their rights, the data subject should contact the data protection officer by sending a written notice or request to the data protection officer at TEMPO, via email using their provided email address, or by regular mail to: Titov trg 7, 52220 Labin, or by delivering a personal statement directly at TEMPO’s business premises with prior notification at +385 52 824 051, along with valid identification.

3. Data Protection Officer:
TEMPO has appointed a Data Protection Officer:

Anton Vlačić
Email: anton.vlacic@tempo-biz.eu

All inquiries regarding data protection should be directed to the Data Protection Officer.

4. Principles of Personal Data Protection

TEMPO considers the lawful and proper handling of personal data to be of great importance and ensures that personal data is processed lawfully and correctly. For this purpose, TEMPO fully supports and adheres to the Principles of Data Protection.

The Principles of Data Protection require that personal data:

  • must be processed fairly and lawfully, and in particular, must not be processed unless the conditions specified by regulations are met;
  • must be collected only for one or more specific and lawful purposes and must not be further processed in any manner incompatible with those purposes;
  • must be adequate, relevant, and not excessive in relation to the purpose or purposes for which they are processed, and must be accurate and up-to-date;
  • must not be retained for longer than is necessary for the applicable purpose;
  • must be processed in accordance with the rights of data subjects as specified by applicable regulations;
  • appropriate technical and organizational measures must be taken against unauthorized or unlawful processing of personal data and against accidental loss, destruction, or damage to personal data;
  • must not be transferred to a country or territory outside the EU unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

 

5. TEMPO’s Data Processing Activities

TEMPO undertakes the following:

  • fully respects the conditions for fair collection and processing of personal data;
  • fulfills its obligation to specify the purpose for which personal data is processed;
  • collects and processes adequate personal data only to the extent necessary to meet operational needs or comply with legal requirements;
  • provides all necessary information to the Personal Data Protection Agency;
  • strictly monitors the retention period of personal data;
  • ensures that the rights of individuals whose data is processed can be fully exercised in accordance with personal data protection;
  • takes appropriate technical and organizational security measures to protect personal data;
  • ensures that personal data is not transferred abroad without appropriate safeguards;
  • treats all individuals fairly and equitably, regardless of their age, religion, disability, gender, sexual orientation, or ethnicity, when responding to their information requests;
  • establishes clear procedures for responding to requests for information.

TEMPO may publish content related to cookies for advertising and traffic statistics on its website, based on the interests and information of visitors to TEMPO’s website from social networks. If a data subject uses content on TEMPO’s social networks or applications, a cookie from those networks and applications may be stored on the data subject’s device used to access TEMPO’s website. Visitors have the right to disable cookies. Web browsers are usually set to accept cookies by default, but data subjects can easily adjust this by changing their browser settings. If a data subject wishes to restrict or block all cookies, including those related to TEMPO’s websites/applications (which may prevent the use of certain parts of the website), or other websites/applications, this can be done in the browser settings.

In the event of a personal data breach likely to result in a high risk to the rights and freedoms of data subjects, TEMPO will notify the data subject of the breach without undue delay, unless TEMPO has implemented appropriate technical and organizational protection measures and these measures have been applied to the personal data affected by the breach, particularly those rendering the data unintelligible to any unauthorized person, or if TEMPO has taken subsequent measures ensuring that the high risk to data subjects’ rights and freedoms is no longer likely, or if notification would require a disproportionate effort, in which case TEMPO will use public communication or a similar measure to inform data subjects effectively.

6. Review and Audit

TEMPO reserves the right to update this policy as needed to reflect best practices and to ensure compliance with any changes or amendments to personal data protection regulations.