Remington Real Estate
en

Privacy Policy

The company REMINGTON REALTY d.o.o. values protecting the security and privacy of your personal data. Through this Privacy Policy, we aim to provide relevant information regarding the processing of your personal data, the methods by which we collect and process personal data, the purposes for which we use it, how long we retain it, whom your data is shared with, and how you can exercise your rights. Please read this Privacy Policy carefully, as it contains data processing rules and simultaneously serves as the Ordinance on the Processing and Protection of Personal Data. If you have any questions, feel free to contact us via the email address office@remingtonchristiesre.hr, and we will gladly answer all your inquiries.

  1. GENERAL INFORMATION

REMINGTON REALTY d.o.o. collects and processes your personal data both within the scope of its regular business operations (which includes, but is not limited to, real estate brokerage) and information about your activities on the Website. Within this scope, we act as the Data Controller, and it is important to us to protect the security and privacy of your personal data. We ensure that data is processed in accordance with the relevant legal regulations, particularly Regulation (EU) 2016/679 of the European Parliament and of 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, as well as the Act on the Implementation of the General Data Protection Regulation (Official Gazette No. 42/18).

  1. DEFINITIONS

The terms used in this Privacy Policy have the same meaning as the terms defined in the Regulation. Gender-specific terms used in this Privacy Policy are applied neutrally and refer equally to both female and male genders.

Data Controller – the legal entity that determines the purposes and means of processing personal data is REMINGTON REALTY d.o.o., with its registered seat in Opatija, Maršala Tita 81/1, PIN (OIB): 37143277687, registered in the court register of the Commercial Court in Rijeka under registration number (MBS) 040407074, represented by director Ivan Kovačić, Bregi, Zvančići 54K, PIN (OIB): 06154233722;

Joint Controllers – two or more controllers who jointly determine the purposes and means of data processing;

Data Processor - a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the Data Controller REMINGTON REALTY d.o.o. The Data Processor processes personal data on behalf of and according to the instructions of the Data Controller, such as accounting service providers, information and communication service providers, other persons for the execution of brokerage contracts, and similar.

Personal Data – any information relating to an identified or identifiable natural person based on one or more specific characteristics. In this Privacy Policy, "personal data" refers to information you provide about yourself, including (but not limited to) first name, last name, contact details, address, IP address, location data, online identifier, data collected via cookies and other similar technologies, and data provided within the framework of executing a brokerage contract or other services you requested from us;

Policy – this Privacy Policy, which contains information on the processing of personal data and the use of cookies and similar tracking technologies on the Website.

Regulation – Regulation (EU) 2016/679 of the European Parliament and of 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 (General Data Protection Regulation - GDPR).

Website – the website maintained by the Data Controller, on the domain [https://www.remingtonchristiesre.hr/hr/], accessible via web browsers.

Data Subject/User – a natural person, i.e., an individual whose identity is identified or can be identified. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name and surname, personal identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that individual, as well as any natural person visiting the Website or using one or more services or functions described in the Policy.

Device – means the electronic device through which the User accesses the Website.

  1. PRINCIPLES OF PERSONAL DATA PROCESSING

When processing personal data, the Data Controller is obliged to adhere to the principles specified by the Regulation. Consequently, only processing carried out in accordance with the principles set forth in this Article, which comply with the principles of the Regulation, can be considered lawful.

The Data Controller processes personal data respecting the following principles:

  1. Lawfulness, fairness, and transparency

The Data Controller processes data in accordance with all applicable legal provisions, protecting all necessary rights of the data subject. The Data Controller will provide the data subject with any further information necessary to ensure fair and transparent processing, taking into account the specific circumstances and context of the personal data processing.

  1. Purpose limitation

The Data Controller collects data for specified, explicit, and legitimate purposes and may not further process it in a manner incompatible with those purposes. However, further processing for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes is permitted.

  1. Data minimization

The Data Controller processes only data that is adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.

  1. Accuracy

Data must be accurate and kept up to date. The Data Controller is obliged to take every reasonable step to ensure that personal data that is inaccurate is erased or rectified without delay.

  1. Storage limitation

Data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed. Longer storage periods are possible only if the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to the implementation of appropriate technical and organizational measures required by the Regulation.

  1. Integrity and confidentiality

The Data Controller is obliged to process data in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.

  1. CATEGORIES OF DATA SUBJECTS

The Data Controller processes the personal data of Data Subjects, including contracting parties, ordering clients as buyers/lessees/tenants, ordering clients as sellers/lessors/landlords based on brokerage contracts, business partners, legal representatives and/or employees of legal entities that are our business partners, third parties such as proxies and representatives of parties, and visitors to the Website.

  1. CATEGORIES OF DATA

The Data Controller processes different categories of personal data depending on the category of the Data Subject and the purposes of processing, primarily processing:

5.1. Identification and contact data, such as:

  • First and last name/title, company name;
  • Personal identification number (OIB)/company registration number;
  • Date of birth;
  • Telephone number;
  • Email address;
  • Address of permanent residence, temporary residence, home address, or registered seat;
  • IP address or other identifiers and data collected via cookies or other similar technologies; data left by users when visiting social media profiles (including comments, "likes", online identifiers, etc.);
  • Document title, document number, photograph, and other data contained in identification documents (such as identity cards, passports, driver's licenses, and other documents for client identification purposes).

5.2. Accounting data, such as:

  • Bank name;
  • IBAN;
  • Other financial and banking data necessary for transaction execution.

5.3. Data related to employment and the realization of labor law status;

5.4. Data required for the performance of agreed services, such as:

  • Photographs and videos (such as photographs and videos of real estate, locations, etc.);
  • Other data collected on the basis of contractual relationships.

The Data Controller does not process special categories of personal data, i.e., data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, nor genetic data, biometric data processed for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person's sex life or sexual orientation.

  1. LEGAL BASIS AND PURPOSE FOR COLLECTING AND PROCESSING PERSONAL DATA

We collect personal data through our regular business operations as well as through our website to properly perform our services and ensure the smooth functioning of the Website. Your data is collected, for example, when concluding a brokerage contract, visiting our Website, submitting your information via designated forms, signing up for our newsletter, sending inquiries through the contact form, reserving a property, using web cookies, and through public profiles on social portals such as Facebook, Instagram, and LinkedIn. In connection with this, data left by visitors to these profiles (including comments, likes, online identifiers) is processed, alongside other situations required to conduct regular business operations, perform requested services, or fulfill obligations based on contractual relationships.

In the case of data collection through social networks, in addition to the Data Controller REMINGTON REALTY d.o.o., the operator of the relevant social network platform (e.g., Facebook, Instagram, LinkedIn, etc.) is an independent Data Controller. The social network operator, as an independent Data Controller, also processes personal data under the terms and conditions accepted by users when registering on the respective social network. Information about data processing by individual social network platform operators is available on their respective websites.

Regarding data processing for the purpose of website analytics, promotion, marketing, and advertising, REMINGTON REALTY d.o.o. and the social network operator providing the analytical data service are considered joint controllers. The website analytics service provider provides aggregate statistical data generated from specific events recorded on the social network operator's servers when users interact with the pages and content linked to them.

We collect and process the personal data of Data Subjects based on one of the following legal bases set forth in Article 6, Paragraph 1 of the Regulation:

  1. Compliance with the legal obligations of the Data Controller. In this case, processing is necessary due to applicable legal regulations, such as the Real Estate Brokerage Act and other regulations in tax, commercial, and criminal law, regulations on the prevention of money laundering, and other fields, including the execution of supervision by competent state bodies and in the event of a legal obligation to deliver data;
  2. Processing is necessary for the performance of a contract to which the Data Subject is a party or to take steps at the request of the Data Subject prior to entering into a contract;
  3. Consent of the data subject to the processing of their personal data for one or more specific purposes;
  4. When processing is necessary to take actions at the request of the data subject;
  5. Legitimate interest of the Data Controller or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, especially if the data subject is a child—for instance, conducting business operations and managing client relations, informing about services, marketing, and similar.

We process the personal data of Data Subjects collected on one of the above-mentioned legal bases for the following purposes:

  1. Performing our professional activities, i.e., providing agreed services and fulfilling contractual obligations;
  2. Facilitating mutual business communication;
  3. Identifying and processing inquiries submitted via forms;
  4. Resolving complaints;
  5. Analytical and statistical purposes;
  6. Technical and administrative purposes to ensure IT system security and system management;
  7. Promotional, marketing, and advertising purposes, including in particular the development and improvement of our services and other marketing activities (see more under point 7);
  8. Organizing and managing our business, executing business processes, exercising rights and obligations from concluded contracts, issuing invoices and processing invoice payments, internal analysis, record-keeping, and reporting, preventing, managing, and resolving disputes, storage, and similar business purposes;
  9. Fulfilling the legal obligations of the Data Controller regarding our professional activity and other statutory obligations for which data processing is required;
  10. Protecting persons and property, including the protection of health, safety, and integrity.


  1. MARKETING

Processing for marketing purposes is carried out based on your consent. You may withdraw your consent at any time by clicking the link provided in every such email received or via the email address office@remingtonchristiesre.hr. Data processing for marketing purposes may include the following activities:

  1. Displaying marketing content corresponding to your interests. In this case, we process your personal data, including data collected via cookies and other similar technologies regarding advertising and delivering ads tailored to your preferences. Personal data processing then also includes profiling, whereby customized advertisements are displayed based on your personal data, enabling a better adaptation of the displayed content to your individual preferences; and
  2. Conducting direct marketing activities (sending commercial information electronically via newsletter, SMS, or telephone).


8. OBLIGATION TO PROVIDE DATA

The processing of most Personal Data is prescribed by applicable legal regulations in commercial law, regulations governing real estate brokerage, money laundering prevention regulations, accounting, tax law, etc., and is therefore mandatory. If you do not provide us with such mandatory Personal Data, we will not be able to provide the requested service, establish another business (contractual) relationship, or remain in a business (contractual) relationship.

Providing certain types of Personal Data of the Data Subject for specific Purposes may be voluntary based on free and informed Consent, which the Data Subject can withdraw at any time; i.e., failure to provide such Personal Data would have no adverse consequences for the Data Subject.

  1. HOW LONG WE RETAIN YOUR DATA

We process and store your personal data within the periods prescribed by applicable laws, such as the Anti-Money Laundering and Terrorist Financing Act or laws in the fields of accounting, taxes, labor relations, and similar. For example, under the Anti-Money Laundering and Terrorist Financing Act, we must retain the data, information, and documentation collected on the basis of that Act for 10 years following the termination of the business relationship.

If the retention periods for personal data are not determined by law, we store personal data until the purpose for which the data was collected and processed is achieved. We will process and store your personal data collected on the basis of consent until the deadline specified when giving consent or until the moment consent is withdrawn.

  1. YOUR RIGHTS REGARDING THE PROCESSING OF YOUR PERSONAL DATA

In connection with the processing of your personal data, you have all the rights guaranteed by relevant regulations:

  1. Right of access – you may request confirmation from the Data Controller at any time as to whether personal data is being processed, and if so, obtain access to that data as well as information about the processing, the category of data concerned, the recipients or entities to whom data is disclosed, the planned date of erasure, and you also have the right to request a copy of the personal data undergoing processing;
  2. Right to rectification – the Data Controller is obliged to eliminate any potential irregularities or errors in the processed personal data and to update and supplement them if they are outdated or incomplete. Therefore, if you notice the processing of inaccurate or incomplete data or wish to modify it, you have the right to request rectification or supplementation;
  3. Right to erasure ("right to be forgotten") – you have the right to request the erasure of data if you believe that your personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; if your data has been unlawfully processed; or in the event of withdrawal of consent and filing an objection;
  4. Right to restriction of processing – in the event of such a request, the Data Controller ceases to perform operations on your personal data—except for operations to which you have given consent and data storage, in line with adopted retention rules—or until the reasons for restricting data processing cease (e.g., if a decision is issued by a supervisory authority allowing further data processing);
  5. Right to data portability - If processing is based on your consent and carried out by automated means, you have the right to receive the personal data concerning you which you provided to us. You also have the right to have that data transmitted directly to another controller, where technically feasible;
  6. Right to object - at any time, on grounds relating to your particular situation, you may object to the processing of your personal data for marketing purposes or purposes carried out based on the legitimate interest of the Data Controller;
  7. Right to withdraw consent - if data is processed based on your consent, you have the right to withdraw it at any time;
  8. Right to lodge a complaint - if you believe that the processing of personal data violates the provisions of the Regulation or other regulations on personal data protection, you have the right to lodge a complaint with the competent supervisory authority, the Croatian Personal Data Protection Agency (AZOP), with its seat at: Martićeva ulica 14, 10000 Zagreb, Croatia, web: http://azop.hr/, tel.: +385 1 4609 000.

SUBMITTING REQUESTS RELATED TO EXERCISING RIGHTS

If you have any questions regarding the processing of your personal data or wish to exercise your rights, please contact the email address office@remingtonchristiesre.hr, our registered office address, or use the contact form.

Remington Realty d.o.o. will do everything possible to respond to your request as quickly as possible, and no later than 30 days from the day the request is received. If for any reason we are unable to respond to your request within 30 days, we will notify you of the extension. If the request was sent to us electronically, we will respond in the same form, unless you request a response in a different format.

We store data about the submitted request and the person who submitted it to ensure the ability to prove compliance and to establish, defend, or claim any potential demands of the data subject in question.

  1. INFORMATION ON THE USE OF COOKIES

This Website uses cookies to improve user experience, ensure Website functionality, and for security purposes. Cookies are pieces of information stored on your computer, mobile phone, or tablet, which can be delivered directly by the website you visit (first-party cookies) or in cooperation with and for the needs of the website by a third party (third-party cookies). Using cookies, we collect certain personal data such as your device identifier, the type of internet browser you use, the IP address from which you access the Website, your language selection, the fact that you viewed the cookie notice, and similar. Cookies can contain a wide range of information, including elements of personal information. Such information can only be stored if you enable it. You can change cookie settings in your internet browser at any time; however, disabling/blocking cookies can significantly affect the functionality of the Website and consequently your user experience.

This Website uses cookies that are technically necessary for communication between the user's terminal equipment and the website they visit or to provide a service on the website at the user's request (technical cookies). Consent is not required for these cookies under Directive 2009/136/EC and the Electronic Communications Act (Official Gazette No. 76/22). Technical cookies (as mandatory or necessary cookies) are set in response to actions made by you which amount to a request for services (such as setting cookie preferences, logging in, or filling in forms, etc.). You can set your browser to block or alert you about these cookies, but some parts of the site will not work in that case.

For more information about exactly which cookies we use, see our Cookie Settings/Cookie Policy below:

Cookie Settings / Cookie Policy

This Website uses cookies to improve user experience, ensure Website functionality, and for security purposes. Cookies are pieces of information stored on your computer, mobile phone, or tablet, which can be delivered directly by the website you visit (first-party cookies) or in cooperation with and for the needs of the website by a third party (third-party cookies). Using cookies, we collect certain personal data such as your device identifier, the type of internet browser you use, the IP address from which you access the Website, your language selection, the fact that you viewed the cookie notice, and similar. Cookies can contain a wide range of information, including elements of personal information. Such information can only be stored if you enable it. You can change cookie settings in your internet browser at any time; however, disabling/blocking cookies can significantly affect the functionality of the Website and consequently your user experience.

This Website uses cookies that are technically necessary for communication between the user's terminal equipment and the website they visit or to provide a service on the website at the user's request. Consent is not required for these cookies under Directive 2009/136/EC and the Electronic Communications Act (Official Gazette No. 76/22). Technical cookies (as mandatory or necessary cookies) are set in response to actions made by you which amount to a request for services (such as setting cookie preferences, logging in, or filling in forms, etc.). You can set your browser to block or alert you about these cookies, but some parts of the site will not work in that case.

TYPES OF COOKIES:

Cookies by duration

This Website uses temporary and persistent cookies.

  • Temporary cookies (session cookies) expire and are automatically deleted when you close your internet browser. These cookies are mandatory for the proper operation of certain applications or functionalities on this Website. We use them to store temporary data, such as the last few pages you opened, etc.
  • Persistent or stored cookies remain saved on your computer's hard drive even after closing the internet browser. We use them to store basic information such as login username and password, language settings, and cookie settings. Persistent cookies remain in the browser until they expire or are manually deleted.

Cookies by source

This Website uses both first-party and third-party cookies.

  • First-party cookies come from the website that the user is viewing and can be persistent or temporary. Websites use these cookies to store information that will be used again the next time the user visits the site.
  • Third-party cookies originate from other, partner websites that the user is viewing. Third parties can thus collect data about users across different websites and use it for marketing and/or analytical purposes.

Cookies by function

  • Technical cookies – mandatory cookies

(always active) – necessary for the functioning of the Website and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not work. These cookies do not store any personally identifiable information.

  • Functional cookies

(optional) – enable the website to provide enhanced functionality and personalization.

  • Statistical cookies

(optional) – allow us to count visits and traffic sources so we can measure and improve the performance of our site.

  • Cookies used for analytical and marketing purposes

(optional) - serve the purpose of advertising, tracking user habits, and monitoring the effectiveness of specific solutions on the Website. These optional cookies include:

Google Analytics cookies that enable traffic analysis. The service provider is Google LLC, which means that information generated by these cookies about your use of the Website, including your IP address, is transmitted to a Google LLC server and stored there.

Google Ads cookies to record and realize visits to the Website for advertising purposes. By visiting the Website, your browser saves cookies that allow it to recognize you as a visitor when you visit websites that are part of the Google Advertising Network.

The Website also uses social media cookies that allow the user to share certain content through their own social media accounts. Data collected through these cookies is used exclusively for analytical and marketing purposes based on your consent, which you can withdraw at any time in the designated manner.


Additional information on configuring browser cookie settings can be found at the following links:

• Learn more about private browsing modes and cookie settings in Firefox here

• Read about incognito mode and cookie settings in Google Chrome here

• Read about the "InPrivate" mode and cookie settings in Internet Explorer here


  1. SHARING/TRANSFERRING YOUR PERSONAL DATA

We may share your personal data with entities with whom we cooperate in implementing the services we provide. For the purpose of fulfilling the contractual and legal obligations of the Data Controller, achieving a legitimate interest, and executing contracts and requested services, your data may be forwarded to the following categories of recipients, i.e., Data Controllers and Processors listed herein. Thus, data may be shared with business-related entities of the Data Controller, such as affiliates and business partners, service providers, and third parties entitled to collect and process data based on legal obligations, such as public authorities, courts and other judicial bodies, administrative bodies, agencies, inspections, and similar. Data may also be forwarded to our Data Processors who process personal data on behalf of the Data Controller, such as accounting service providers, information and communication service providers, and similar.

The data we share with affiliates, business partners, and service providers is shared to the extent necessary to provide our services, primarily for the execution of brokerage contracts. Our business partners process personal data as Data Controllers within the scope of services they provide to us or that we provide to them, or with whom we do business in some other way.

Although the Data Controller's head office is in Croatia, our business partners and service providers are also located outside of Croatia; therefore, in specific cases, and for the purpose of providing our services, particularly executing brokerage contracts, it is possible to transfer your personal data outside of Croatia. In this case, we ensure compliance with the rules prescribed by the Regulation and undertake necessary protective measures in line with regulations applicable in the European Union. In the event that some recipients are located in so-called third countries, i.e., countries outside the European Economic Area, we will require them to ensure an appropriate level of protection through measures provided for by the Regulation.

  1. HOW DO WE PROTECT YOUR DATA?

The Data Controller implements appropriate technical, personnel, and organizational measures to ensure the effective application of data protection principles, protecting collected data from accidental loss or destruction, unauthorized access or alteration, as well as unauthorized disclosure of or access to your personal data. These measures are reviewed and updated as necessary.

  1. CHANGES TO THE PRIVACY POLICY

We regularly review and update this Policy to harmonize its provisions with legal regulations and European Union rules, and we reserve the right to change the Policy if modifications prove necessary. Users will be notified of any changes and amendments to the Policy by the publication of the amended and updated Policy on the Website.

The Privacy Policy was last updated on March 8, 2023.

The Privacy Policy has been in force since September 1, 2020.