INFORMATION ON THE PROCESSING AND PROTECTION OF PERSONAL DATA - ALPHA LUXE GROUP

INFORMATION ON THE PROCESSING AND PROTECTION OF PERSONAL DATA

ALPHA LUXE GROUP d.o.o. (from now on: ALPHA LUXE) provides its clients with transparent information about the protection and processing of personal data it collects from clients that are required for the execution of a real estate brokerage service.

ALPHA LUXE, as Head of Personal Data Processing, protects your privacy and processes only personal information that is necessary for the purpose for which it was collected. ALPHA LUXE keeps records of the processing of personal data in electronic and hard copy form. It contains at least the following information: name and contact information of the processing manager, processing purposes, description of the categories of respondents and types of personal data, categories of recipients to whom the personal data have been disclosed or will be disclosed, envisaged deadlines for deleting different categories of data (if possible), general description of technical and organizational security measures, client/respondent rights.

It is of utmost importance to us that the client's personal information is adequately protected. When processing personal data, ALPHA LUXE ensures that it is processed solely under applicable laws and regulations. In the processing of personal data, ALPHA LUXE will act transparently and will only process it if it has a clear purpose and while in the interest of the clients, and will use the measures available to protect the client's personal information.

The term data processing means storing, recording, organizing, accessing and transmitting personal data to ALPHA LUXE for the duration of the business relationship, but also after the termination of the business relationship with the client, during the period in which ALPHA LUXE is obliged to keep original documentation.

I. NAME AND CONTACT INFORMATION OF THE PROCESSING LEADER

The head of personal data processing is:
ALPHA LUXE GROUP d.o.o., Mate Vlašića 17, 52440 Poreč
Tel: 0038552204933
Mob: 00385953631892
E-mail: info@alphaluxegroup.com
The processing of the personal data of the clients is carried out by the staff of ALPHA LUXE.

II. PURPOSE OF TREATMENT AND LEGAL BASIS FOR TREATMENT

The purpose of collecting and processing personal information is necessary for the realization of the service you have requested. All personal data that ALPHA LUXE has learned about you by providing you with the service is protected and will not be accessed for processing your information unless it is necessary for the realization of the service you have requested, if it is not legally required, or if there is no legitimate interest in doing so.

We also collect and process your personal information because it is necessary for us to comply with our obligations based on strict regulations in force in the Republic of Croatia, such as the Real Estate Brokerage and Obligations Act and other relevant laws of the Republic of Croatia in our business.

With your consent, we process personal information for telephone surveys of your satisfaction with the services provided, sending marketing materials, market segmentation, sending promotional materials and promotions and discounts, and other purposes for which your consent is required.

When providing advertising services to your business entity/product/event, etc. by ALPHA LUXE, through the Istraplakati.hr website, we collect and process information when respondents give their consent to receive our newsletters and other commercial information; when they browse our websites when they offer us their products or services when they give their consent to receive our newsletters and additional business information; when they want to apply for a job at ALPHA LUXE and when they want to ask a question or file a complaint.

Legitimate interest:
The processing of your information based on our legitimate interests is subject to special rules that allow you to object to such processing at any time, based on your particular situation. The legitimate interests on which ALPHA LUXE will process your personal information are: contacting clients to send special offers or marketing material, conducting video surveillance of ALPHA LUXE business facilities and identifying and registering visitors for the protection of persons and property, and compliance with anti-money laundering regulations of the Republic of Croatia.

III. SOURCE OF PERSONAL DATA

We process personal data required for the purposes set out in point II, which we have received from the Respondent, from the competent institutions, publicly available sources, and which the Respondent reports to us under the provisions of the Regulation. We collect and process personal information reasonably, lawfully and transparently and care for its accuracy, completeness, timeliness and security.

IV. DESCRIPTION OF CATEGORIES OF RESPONDENTS AND CATEGORIES OF PERSONAL DATA

The categories of respondents ALPHA LUXE collects personal information from are all clients who wish to establish a business relationship for services for which the company is legally registered, e.g. real estate brokerage, real estate valuation, consulting, advertising and marketing, etc. How if ALPHA LUXE could establish a business relationship with you and provide you with a quality service, you must share your personal information with us. Without consent to collect the following personal information, we will not be able to provide our services.

The categories of personal information we collect and process to fulfil a purpose are as follows:
- - name and surname,
- address,
- OIB,
- telephone/mobile number and e-mail address,
- possibly other personal data for which there is an obligation to collect under the Law on Real Estate Brokerage and the Law on Prevention of Money Laundering and Financing of Terrorism.
- Information necessary for the conclusion and eventual realization of the contract consuming the real estate brokerage contract,
- and, if you consent to it by signing the contract or otherwise appropriately making a video of your property to sell according to your order/instructions
- transaction and payment information: transaction details, bank account information;
- job application information: CV, cover letter, job interview notes;
- any other information that the respondent gives us, directly and willingly, while using our websites, services, and when entering into any agreement with ALPHA LUXE.

Your personal information is collected and recorded in (alternatively, depending on the service you require from ALPHA LUXE):
- brokerage contract,
- a field form listing the details of the property you are selling or your wishes and needs when buying,
- when providing advertising services (leasing of advertising space - Posters) by ALPHA LUXE, personal information is entered into offers/accounts/contracts that we enter into with clients, and (applies to everyone, if applicable) in the newsletter database.

In addition to the personal information you provide us, we also collect publicly available real estate data from publicly available registers (e-cadastre and e-land registers) that may contain your personal information if you are the owner of the property or the personal information of another property owner.

ALPHA LUXE, when collecting personal data, is guided by the principle of obtaining the minimum required amount of personal data for a particular purpose, and collecting and processing personal data to contract service and establish a contractual relationship and fulfilling a contractual obligation. The amount of information we will need to receive depends on the service or product requested (e.g. brokerage, purchase, lease, lease, business and technical cooperation agreements, etc.).

If you provide information about personal information other than your own, please inform the person whose personal information you have provided to us.

The business premises of the ALPHA LUXE GROUP headquarters and the exterior surface of the ALPHA LUXE headquarters are under video surveillance, which is clearly, transparently and unequivocally made visible to clients/respondents. Video surveillance of business premises is necessary and legitimate for the protection of property and persons. Only responsible person ALPHA LUXE has the right to access the data, under the provisions of the Regulation.

V. CATEGORIES OF RECIPIENTS TO WHICH PERSONAL DATA IS DETECTED OR WILL BE DETECTED

Personal information is available to ALPHA LUXE staff; ALPHA enters into business cooperation agreements with other real estate agents (other real estate agents and natural persons - real estate agents) to provide you with the best possible service and find the best possible service for your solution. In this case, we may pass on your personal information to an external associate (law firm or other legal entity of another profession (geodetic/architectural offices), for drafting purchase or other contracts, or for regulating the legal status of real estate, is included in the ALPHA LUXE furthermore, and in the part of providing advertising services (Posters), may provide access to your personal information to its partners, who act as processing agents. These third-party service providers will only operate on the instructions of ALPHA LUXE. They will only have access to your personal information to fulfil the purposes for which personal information is collected and subject to the same privacy and privacy rules as ALPHA LUXE. ALPHA LUXE is required to obtain your consent before forwarding your personal information to partners for direct marketing purposes.

VI. DEADLINES FOR DELETING DIFFERENT DATA CATEGORIES, IF POSSIBLE

We keep your personal information for 10 + 1 years, based on legal requirements (such as the Anti-Money Laundering and Terrorist Financing Act) or our legitimate interest in resolving potential complaints or disputes.

Exceptionally, in the case of video surveillance of the premises of the ALPHA LUXE GROUP headquarters, the data shall be retained for a maximum of 6 months after which it shall be erased, unless another law prescribes a more extended period of retention or if the evidence is in court, administrative, arbitration or other equivalent proceedings.

In terms of the provision of marketing and advertising services and the area of employment, in determining the appropriate retention period for personal information, ALPHA LUXE draws in particular on the following criteria:
• information about your application, payment and use of our services is kept for the entire period of your application / contractual relationship and under the applicable limitation periods
• the commercial relationship management information with our service providers and partners is kept for the entire contractual period and under the applicable statute of limitations periods;
• if you agree to receive marketing materials, ALPHA LUXE will retain your personal information until you indicate that you no longer wish to receive such communications or otherwise for the period specified by applicable laws;
• when your personal information is collected as part of requests/queries related to IT services and applications, ALPHA LUXE will store your data for the period necessary to process such requests or queries
• job application information may be kept for up to 2 (two) years from the date of the last contact with the applicant unless the applicant agrees to a more extended period; in that case, the data may be archived under the applicable statute of limitations.

VII. GENERAL DESCRIPTION OF TECHNICAL AND ORGANIZATIONAL SAFETY MEASURES

ALPHA LUXE's business in the processing and protection of personal data is in line with the legal regulations governing the processing of personal data. We take technical and organizational measures, in the domain of our capabilities, to protect your personal information. Internal servers are password-protected, and each employee has only the information they need to do the job. If necessary, employees are educated on company premises and/or specialized training on measures and importance of personal data protection of respondents.

VIII. WHAT ARE YOUR RIGHTS

The protection of personal data entails significant client rights, such as:
right of access - you have the right to contact us at any time to confirm that your data is being processed and, if that data is being processed, requesting access to your data and information to which you have a right regarding the protection of personal data. ALPHA LUXE provides you with a copy of the personal data being processed, and for any additional copies you request, we may charge you a reasonable fee based on administrative costs.
the right to rectify - if we process your incorrect data, you can at any time ask us to correct them, and if they are incomplete, you have the right to supplement them;
right to delete - - you have the right to ask us to delete personal data relating to you if we have illegally processed them or if personal data are no longer necessary for processing, etc. Please note that there are reasons to prevent immediate deletion, for example, to make, enforce, or defend legal claims, and we will inform you in detail of each application;
right to a restriction of processing - you can ask us to limit the processing of your data:
- if you dispute the accuracy of personal information during a period that allows us to verify the accuracy of that information,
- if the processing is illegal, but you oppose deletion and instead seek a restriction on the use of that information,
- if we no longer need the data for processing purposes but request it for making, meeting and defending legal claims,
- if you objected to the processing;
right to data portability - you have the right to receive the data that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transfer this information to another processing manager if the processing is based on consent or contract and is carried out by automated means;
right of objection - you may object to the processing of your data at any time if the processing is based on our legitimate interests, including the creation of a profile or if we process your data for direct marketing purposes;
right of complaint - - if you believe that by processing your data, we have breached Regulation (EU) 2016/679 of the European Parliament and the Council or other regulations regarding the protection of personal data. You are certainly entitled to complain about a national or EU supervisory authority;
Right to Withdrawal - When processing is based on consent, you have the right to withdraw the consent at any time without prejudice to the lawfulness of the consent-based processing before it is removed. You can do the same in the same way you gave permission.
right to compensation - if you have suffered (none) material damage as a result of a violation of the relevant legal provisions, you are entitled to benefit from the processing agent or us for the loss suffered;

In case you wish to exercise any of the above rights and all the prerequisites are fulfilled, you must send a request for the exercise of rights in writing to the address below or at the premises of the headquarters.

Contact informations:
ALPHA LUXE GROUP d.o.o.
Mate Vlasic 17
52440 Poreč
+385 95 363 1892

If your requests are manifestly ill-founded or excessive, mainly due to their repeated repetition, we may charge an administrative fee or refuse to act on the application. Business ALPHA LUXE GROUP d.o.o. in the processing and protection of personal data is harmonized with the legal regulations governing the processing of personal data. If you believe that your right to protection of personal data has been violated, you can file a complaint with the Personal Data Protection Agency (AZOP) at azop@azop.hr. We, as processing managers, have the right to disable the deletion of your data, to refuse to limit the purpose or to prevent the transfer of data to third parties if we are unable to fulfil the service you have requested us to do or if a particular law requires the keeping of specific personal data and we are obliged to keep it.