Napa Estate d.o.o. with headquarters in Poreč-Parenzo, Špadići 66 C, PIN (OIB): 87306381742 (“Napa Estate” or “we” or “us”) hereby notifies you in accordance with Articles 12, 13 and 14 of the General Data Protection Regulation (“GDPR”) on the information who is the data controller (responsible person for processing personal data), who are the recipients of data (persons authorised to receive the data in accordance with the contract and the legal provisions), which personal data ought to be processed, for what purposes, how long we store the data and what are your rights as the data subject.
Types of processed personal data
Napa Estate collects and processes personal data about you – information that can directly or indirectly identify you, especially with identifiers such as name, surname, academic title, title, PIN (OIB), birth date, address, phone, email, company where you are employed, location information, IP address (“Personal Data”), in the following cases:
- when you are our client,
- when you send us an inquiry regarding our services,
- when we process data in accordance with our legal obligations (Real Estate Brokerage Act, Anti Money Laundering and Terrorism Financing Act, Accounting Act, tax laws),
- when you contact us via the contact form or via e-mail,
- when we process your job application,
- when you visit our website and use the specific functionalities of our website.
Napa Estate will not collect Personal Data unless you voluntarily provide it to us, except for certain Personal Data collected through the information systems and programs used for the operation of our website, whose transmission is necessary for the use of internet communication protocols and will not require more information than necessary for performing certain activity.
Purposes of data processing
We process personal data for the following purposes:
- the (technical) maintenance, analytics, and improvement of our website,
- when we maintain contact with you over the telephone, post, or e-mail regarding our services (e.g. to create our offer),
- management of our customer base,
- the regular business operations,
- sending newsletter via e-mail,
- fulfiling our legal obligations.
Lawfulness of processing
Personal Data may be processed only if there is a legal ground for doing so. Pursuant to the GDPR we process personal data on the following legal grounds:
- Consent: If you are not our client, you can give consent for receiving our newsletter.
- Contracts/precontractual agreements: when you, as a client, require services from us and it is necessary for us to process your Personal Data to be able to provide you the requested services.
- Legal obligation: if we receive a legitimate claim to provide Personal Data to a competent authority. We are also legally obliged to keep personal data in our financial records for a certain period of time, in accordance with tax and accounting legislation.
- Legitimate interest: if you have been a client in the past or we have sent you an offer, we will retain your contact details 11 years after the last instance of our contact to be able to contact you in the future for possible follow-up projects/offers.
Recipients of Personal Data
We make use of services of suppliers in the field of ICT technologies and accountants, who are contractually bound to perform all necessary measures to ensure that Personal Data will remain confidential and secure. These data processors may only process Personal Data on our behalf and under our supervision, only for purposes we determine and under strict confidentiality. For data that our data processors transfer outside of the European Union to provide information services we use appropriate safeguards for transferring Personal Data.
Your Personal Data may be disclosed, in close connection with the above purposes to:
- entities that need to send mail or email, remove recurring information from the list of recipients of services, analyse data and provide support, provide user services, and which typically handle Personal Data on behalf of Napa Estate as processing executives, such as a cloud provider;
- entities that maintain our IT systems;
- entities providing us with accounting services that are subject to the appropriate contractual obligation of confidentiality;
- persons authorised by Napa Estate for the processing of Personal Data, subject to the corresponding legal obligation of confidentiality (employees of Napa Estate);
- Napa Estate associates, who are subject to the appropriate contractual obligation of confidentiality;
- competent authorities and public authorities when required by applicable law or in good faith (for example, to comply with the provisions of the law or legal proceedings in relation to Napa Estate for the purpose of protecting and defending the rights or property of Napa Estate or, in urgent circumstances, the security of Napa Estate Clients or the public);
- business partners for their needs, only in accordance with appropriate legal grounds.
Cookies are small files that are stored on your computer, which tell us which parts of our site the users visited. Cookies also provide us insight into user behaviour, in order to improve communication on the website. There are three categories of cookies:
First category – STRICTLY NECESSARY COOKIES
These cookies are the key to enabling browsing our websites and using their features. Without these cookies the use of our website is not possible.
Second category – FEASIBLE COOKIES
These cookies collect information on how you use our website – e.g. which sub-sites you visit the most. These data can be used to optimize our web-places and to make them easier to navigate. These cookies do not collect data based on which you may be identified. All data collected by these cookies are gathered and the collected data is anonymous.
Third category – FUNCTIONALITY COOKIES
These cookies allow web-places to remember your selections while browsing. For example, we may store your geographic location in the cookie in order to take care of showing you our web-place localized for your area. It is possible that we will remember personal settings such as text size, fonts and other adaptable website elements. The data that these cookies collect will not personally identify you and cannot track your activity while browsing on web-places outside this site.
Cookies that are not strictly necessary are activated only after the consent of the visitor. If the visitor of our website accepts these cookies, Google Analytics analyses (with an anonymizing function) are activated. We collect log information and information on the number of visitors on certain parts of our website. Google analyses the usage of the site, and cookies allow analysing visits by assigning a unique, randomly generated ID to your device by which your device is identified when visiting the site later.
The duration of the cookie is 2 (two) years. If you are visiting our site for the first time, a notification asking you to give us the consent to use Google Analytics will be displayed. If you give your consent, we will store the cookie on your computer and that notification will not appear until the expiration of the cookie. After the expiration of the cookie or if you actively delete the cookie beforehand, the notification will reappear during your next visit to our site and the invitation to give the consent will reappear.
You can withdraw your consent for cookies at any time by clicking on the following link: Click here to delete
Napa Estate processes Personal Data of the candidates who apply to our job contests and keeps them to the final completion of the job contest. After completing the job contest, Napa Estate keeps Personal Data of the selected candidates with whom we enter into the Employment Agreement and Personal Data of the candidates who gave us the consent to remain in our database for up to 2 (two) years after the application for the job contest. Only authorized persons within Napa Estate have access to candidates’ Personal Data, and they process and analyse applications for the purpose of contacting the candidate and possible recruitment.
If you gave your consent, we will send you our newsletter with real estate that we offer, according to your preferences. Personal Data which you gave us to register for the newsletter will be used only for that purpose. If you don’t want to receive our newsletter anymore, you can withdraw your consent at any time by clicking the ‘unsubscribe’ link at the bottom of the newsletter e-mail. If you unsubscribe, we will stop processing the Personal Data we collected for the purpose of sending our newsletter. The collected Personal Data will only be stored in the period during which you receive the newsletter until you withdraw your consent.
Napa Estate has access to Personal Data on its contacts on social networks that are published, such as name and surname, employer’s company, likes, comments, connection requests, messages and memberships in certain groups. Napa Estate uses social networks to respond to potential inquiries and to inform members of the social network about the news in its work.
Business relationships with clients
Napa Estate Clients are the persons with whom we have entered into an agreement on providing real estate brokerage services in relation to representation and professional advice (“Client” or “Clients”).
We keep the data for 10 (ten) years from the termination of the business cooperation and the transaction execution, after which the Personal Data is deleted, and the documentation is destroyed in accordance with the regulations governing the protection of Personal Data. If a certain Client wishes that the documentation is kept longer than the stated deadline, Napa Estate should be notified of it.
Napa Estate complies with the provisions of the applicable anti-money laundering laws in the Republic of Croatia. In order to comply with all statutory provisions, we are authorised to request additional evidence of Client’s identity in accordance with the applicable regulations. Napa Estate is obliged to inform the competent authorities about all potential cases of money laundering and is not obligated to compensate the Client for any damages arising as a result of the fulfilment of legal obligations.
Napa Estate, within its obligations under the Prevention of Money Laundering and Terrorism Financing Act (making a risk assessment of money laundering and terrorism financing, conducting due diligence measures of the Client and other), collects personal information of the persons with whom it establishes a business cooperation or carries out the transaction. The data refers to first and last name, a copy of the ID card, residence, date of birth, identification number and nationality if the person is a natural person, and name, headquarters, identification number, legal form, and name and surname, identification number, address, e-mail, and telephone number of the legal representative if the person is a legal entity, while for all Clients we collect data such as purpose and nature of the business relationship, the Client’s business, sources of funds that are the subject of the business relationship and the time of establishing the business relationship.
Transfer of Personal Data to third countries
Napa Estate might transfer Personal Data to data processors in third countries. If a data processor is located in the USA, we will only use services of data processors who have accessed the Privacy Shield Agreement between the EU and the US, thus ensuring adequate protection of Personal Data. Relevant contractual clauses regarding protection of Personal Data are concluded with the processors.
Napa Estate will process your Personal Data only for the time necessary to achieve the purposes described in this Policy.
In addition to the foregoing, Napa Estate will keep your Personal Data as required or permitted in accordance with applicable laws (e.g. at least 11 years, according to the Accounting Act, we shall keep documents based on which the data are entered into the accounting books and 5 or 10 years in accordance with the Anti Money Laundering and Terrorism Financing Act).
Napa Estate informs you that, in accordance with and to the extent permitted by applicable laws, you have the right to request from Napa Estate access and correction or deletion of Personal Data, or processing limitations related to your Personal Data, as well as to object to processing activities and to file a complaint with the competent authority (in the Republic of Croatia to Personal Data Protection Agency). You also have the right to know the recipients or categories of recipients to which your Personal Data was or will be disclosed, especially to recipients in third countries.
Security of processing
The security of your Personal Data is of paramount importance, so we have set up the appropriate physical, electronic, and control procedures, as well as technical and organisational measures to protect the data we collect.
Changes and updates of the Policy
Napa Estate reserves the right to amend or update this Policy at any time and without prior notice. Please check from time to time any changes or updates to our policies that will be posted here with updated effective date on the first page of the Policy if any changes or updates are made.
If you have any questions or comments regarding this Policy, you can contact us through our online form available at https://hedonistrian.com/contact/, by e-mail: email@example.com, or by phone +385955243399 and +385913002030.
Your Napa Estate team