Effective date: May 1, 2019
- Data controller
The Croatian Gas Association with its headquarters in Zagreb, OIB: 07359925707 (“CGA”) and the Croatian Gas Centre Ltd. OIB: 93249648961 (“CGC”) (together “CGA and CGC”, “we” or “us”) respect your privacy and undertake to protect it during and after your visit to this website, its associated mobile website and any micro website (which may be administered on behalf of CGA and CGC by a third party that usually operates as a processor) and which can be accessed through this website (hereinafter: “Website” and “Websites”). Accordingly, CGA and CGC operate as the joint controllers. CGA and CGC together formulate this privacy policy (“Privacy Policy”) and define the purpose and means of processing. CGA and CGC have mutually agreed on their responsibilities for respecting the obligations from the General Data Protection Regulation (Regulation) with regard to the lawfulness and security of processing and realization of the respondent’s rights.
This Privacy policy provides insight into our procedures regarding the processing of your personal data.
- Types of personal data that are processed
CGA and CGC collect and process your personal data (e.g. information by which your identity is established or can be established, in particular by using identifiers such as name, surname, academic title, OIB, date of birth, address, title, telephone, e-mail, photo, location information, IP address and so on, in cases such as when:
- You complete a registration form for participation at a particular event that we organize,
- You complete a membership form for CGA,
- You complete an order form, buy our product, order a service or participate in our event
- You download an e-conference-proceedings,
- You register for our newsletter/news updates,
- You use the contact form on our Website,
- You provide comments or ask questions,
- You seek information or use other features or function of the Website,
- You contact us or connect with us through social media
- We take photographs of the events/record the events and activities we organize,
- We contact you with regards to our products, services or events,
- We process your job application
CGA and CGC will not collect your personal data if you do not provide it voluntarily. This excludes certain personal data collected by information systems and programs used for operating the Website, the transmission of which is necessary for using Internet communication protocols (e.g., IP addresses when executing an order or applications) and will not require more information than is needed to participate in certain activities. If you do not want to provide us with your personal data (besides personal data relating to the use of internet communication protocols that are usually collected when visiting the Website) you may still access our Website, but you may not be able to participate in certain events, properly register, activate or use a specific service, complete an order form or get information about a particular event, apply for a job or contact us.
- Cookies – Google Analytics and Google Tag Manager
This Website utilises Google Analytics and Google Tag Manager, web analysis activities from Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”) that uses so-called cookies, i.e., small files stored on your computer. These files help us recognize certain preferences of our visitors while browsing the web and designing our websites accordingly. Mostly we use temporary cookies (session cookies). They are automatically deleted at the end of your visit. However, we also use permanent cookies. They serve to improve user guidance according to your preferences. You can set your browser to notify you about setting cookies to make your cookies usage more transparent. In principle, in your browser settings you can also refuse to accept cookies.Google uses cookies to analyse the use of the Website. Cookies enable that by assigning a unique randomly generated ID to your device according to which your device is identified when visiting the Website later. Cookies are provided by Google and their storage time is 24 months. If you visit this Website for the first time, a notice will be displayed on the webpage requesting that you provide a consent to the use of cookies. If you provide your consent, we will store the cookie on your computer and the notice will not reappear during the storage time of the cookie. After the expiration of the cookie storage time, or if the cookie is deleted beforehand, the notice will reappear on your next visit to the Website and the invitation to resubmit your consent will appear again. The information that a cookie collects regarding your use of the Website is mostly sent to a European Google server (or to a European Economic Area Member State) for anonymizing your IP address in order to exclude referring to a person. Only after the IP address is anonymized, the shortened IP address is transferred to the Google server in the US where it is stored. Only in exceptional cases a full IP address is sent to the Google server in the US and is shortened there. This website uses Google Analytics with an extension for collecting IP addresses anonymously (the so-called IP masking).The information that Google collects regarding your use of the Website (e.g., your entry URL, the pages you visited on our Website, the web browser you are using, your language preferences, the operating system you are using, the resolution of your display etc.) are stored and analysed on the Google server in the US and become available to us in an anonymous form. Data on the usage is not associated with your full IP address. We have activated on this Website Google’s IP anonymisation function so that the last 8 digits (type Ipv4) or the last 80 bits (type Ipv6) of your IP address are deleted.
Google has been certified in connection with the EU-US Privacy Shield so that data processing by Google in the United States is subject to an appropriate level of personal data protection. For more information about Google Analytics, please refer to Google Analytics Terms of Use, the Google Analytics Data Privacy and Security as well as Google’s Privacy Statement.
You may withdraw your consent for web analysis at any time by clicking the following button: Reject
- Direct marketing – newsletter, offers and news on our products and services
CGA and CGC send via newsletters information about the International Scientific and Professional Meeting of Gas Professionals, general offers for active participation at the Meeting (through exhibition units, lectures, sponsorships, advertising and other forms),information about the program of the Meeting, way of registration and all other announcements in relation to meetings that include links to the conference and exhibition Website; activities and work of CGA and CGC and the organizing of sessions of CGA’s general assembly and the Gas Day, round tables, conferences, exhibitions, seminars and similar events on gas and energy issues; new editions of brochures, technical regulations, manuals, new editions of the PLIN/GAS magazine (issued by CGA), notices of the issuing of authorisation for testing the correct function and non-leakage of gas installations, news concerning the gas sector, energy and environmental legislation, notices of tenders for drawing financial resources from EU funds and other sources; other types of news, including marketing materials, which may be of interest to gas and energy experts and other sectors that have an interest in the gas and energy industry.
The Newsletter is sent on the basis of consent or a legitimate interest approximately twice a month, and the frequency of sending increases by approaching a particular event or other activity organised by the CGA and CGC, and also in the case of news relevant to the gas and energy industry.
Recipients of Newsletters may easily and quickly unsubscribe with a single click on the unsubscribe link found in each newsletter.
Gorila IT d.o.o. acts as the processor for sending the Newsletters, while CGA and CGC collect statistics related to the opening of e-mails and URL clicks in order to monitor and improve the sending of emails and analyse interest in specific content.
Data is stored until a person withdraws their consent, until we receive the information that a particular person no longer receives our e-mails at a specific e-mail address or until they object to us contacting them based on a legitimate interest.
We also contact CGA members and energy sector experts whose contact information is publicly available to inform them about our products, services and events, and we contact our current customers by e-mail based on a legitimate interest in order to be informed about our latest events and products.
You have the right to withdraw your consent at any time without any negative consequences. Withdrawing the consent does not affect the lawfulness of processing until the moment of the consent withdrawal.
You have the right to object to our legitimate interest in contacting you for direct marketing purposes and we will no longer contact you for this purpose.
Our system for sending our Newsletter is incorporated into Amazon Simple Email Service which uses Amazon Mail Servers; Amazon is registered as a part of the EU-US Privacy Shield Agreement and is obligated to provide adequate personal data protection.
- Social media
CGA and CGC collect personal data on their contacts from social media (Twitter, LinkedIn) and contact them through e-mails and messages.
- Purposes, legal basis for processing and possible consequences of refusing to provide your personal data
When you provide your personal data, we will limit their processing for the purpose for which they have been collected in accordance with the terms of the Privacy Policy. The purposes for which we process your personal data include:
- Taking steps at your request before concluding a contract (e.g., answering your questions and comments, filling out your requests, submitting an application form or offer, receiving an offer, communicating with you about your Website activities, processing the application for an open job position or the job application);
- Execution of a contract to which you are a party or fulfilling pre-contractual obligations (e.g. acting in accordance to your application for a particular event or advertisement, providing access to specific areas and features on the Website, providing specific services);
- Investigating suspicion of fraud, harassment, physical threats, or other violations of any laws, rules or regulations, Website rules or the rights of third parties; or investigating any kind of behaviour which we believe or suspect is inappropriate;
- Compliance with the legal obligation to which CGA and CGC are subject (e.g., disclosures prescribed by law, regulation or a court order);
- For the purposes of legal proceedings or in connection with them: the realization or protection of legal rights;
- Submitting ads or direct sales materials or conducting market research, performing data analytics or performing commercial communications via electronic tools (SMS, e-mail, social media), regardless of whether automated (calls without an operator) or not, appropriate legal grounds, based on the legitimate interests or given consent of respondents;
- Photographing/recording participants at events organised by CGA and CGC, based on the consent or legitimate interest of participants, for the purpose of promoting events.
Providing personal data for the above purposes of A to E is voluntary, but any refusal to provide such data may prevent CGA and CGC from making a contract with you, responding to your requests, providing you with services, receiving and processing your application for a certain event and complying with the legal obligations that CGA and CGC are subject to.
Providing personal data for purposes described in points F and G is also voluntary; refusing to provide personal data or objections to processing personal data based on the appropriate grounds related to your specific situation may prevent CGA and CGC from sending adverts or direct sales materials or conducting market research, data analytics, publishing your photo or commercial communications. We may still contact you for administrative purposes, such as confirmation of an application, confirmation of an order, or processing your further requests.
In case you have given a consent for certain processing activities, in any case you may withdraw your consent (e.g. if you do not want to receive our Newsletter, click on the unsubscribe link). In that case, we will no longer process personal data, for whose processing you gave us your consent, so you may no longer have access to some benefits. However, in some cases of withdrawing the consent, we may keep and store your personal data so we can retain the ability to prove your process of your consent withdrawal and our actions in accordance with this request. The data storage time for this purpose is 5 years from the moment of filing a request for withdrawal. Consent withdrawal will not affect the lawfulness of processing prior to its consent withdrawal.
- Recipients
While strictly connected to the above-mentioned purposes, your personal data may be disclosed to:
- Subjects necessary for execution of orders, registering for events, delivering packages, sending postal mail and e-mails, removing redundant information from a list of recipients receiving payment services, analysing of data and providing marketing support, taking photographs of events, credit and debit card payment processing and the provision of customer services, who typically process personal data on behalf of CGA and CGC as processors;
- Subjects that maintain our IT systems (data processors),
- People authorised by CGA and CGC for processing Personal Data, subject to the appropriate legal obligation of confidentiality (employees of CGA and CGC);
- Bodies of CGA, subject to the appropriate contractual obligation of confidentiality;
- Law enforcement departments and public authorities when required by governing law or in good faith (e.g., to comply with the provisions of laws or comply with legal proceedings in relation to CGA and CGC, protect and defend the rights or property of CGA and CGC and the Website, or in urgent circumstances, to protect the personal safety of CGA and CGC service users, their Websites or the public);
- Legal and financial counsellors of CGA and CGC in the event of the need to forward data for legal, tax and auditors proceedings,
- Business partners for their requirements but only in accordance with the appropriate legal basis.
- Retention of data
CGA and CGC will process your personal data only as long as necessary to achieve the purposes described in Section 6 when the storage time is determined by law, CGA and CGC will retain your personal data for as long as this law determines it, i.e. allows it. In that way, for example, business associates’ data and marketing data are kept for at least 11 years from the last day of the business year in which business cooperation ceased, and for a maximum of 25 years based on the legitimate interests of CGA and CGC in contacting their associates. As mentioned above, cookies are stored for 2 years. Regarding the purposes described in sections 4.F and 4.G, your personal data will be processed until you exercise your right to object or until you withdraw your consent for the processing of your personal data, or until we receive information that you no longer receive our e-mails.
- Your rights
We process respondents’ personal data, while respecting their rights determined by the Regulation.
Your rights are as follows:
The Right to Delete (“Right to Forget”) – you have the right to obtain deletion of your personal data and we are obligated to delete personal data without unnecessary delay if one of the following conditions is met:
- Personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed,
- You have withdrawn your consent on which the processing is based and there is no other legal basis pro processing,
- You have filed a complaint against the processing and the legitimate reasons for the realization of the right to delete carry more weight than the legitimate interests of CGA and CGC in processing and/or storing personal data,
- Personal data have been unlawfully processed
- Personal data must be deleted in order to comply with the legal obligations.
The Right to Access Data – you have the right to receive confirmation of whether your personal data are being processed and, if they are, you have the right to access personal data, the purpose of processing, categories of data, potential recipients to whom personal data will be disclosed, and so on.
The Right to Correct – you have the right to obtain the correction of the incorrect personal data related to it without unnecessary delay
The Right to Object – based on your special situation you have the right to file a complaint about the processing of personal data at any time
The Right to Restrict Processing – you have the right to ask for restriction of processing if:
- You dispute the accuracy of personal data, for a period that allows us to verify the accuracy of personal data
- Processing is illegal and you are against deletion of personal data and instead, you are asking for restriction of their use
- If we no longer need personal data after processing, but you demand them for setting up, exercising or defending legal requirements or
- If you filed a complaint on the processing, expecting confirmation whether our legitimate reasons carry more weight than the respondents’ reasons.
In addition, you have the right to file a complaint with the competent supervisory body (in the Republic of Croatia, the Croatian Personal Data Protection Agency) and to be notified about the recipients or categories of recipients to whom your personal data was or will be disclosed, especially recipients in third countries.
- Links to other websites
The Website may contain links to other websites that are not owned, managed, or maintained by CGA and CGC. When you leave the Website, you should notice and read the conditions and the privacy policy of each website you visit. Furthermore, you should independently assess the authenticity of any Website that appears or claims to be one of our Websites (including those associated with e-mail). Regardless of all links that may exist on the Website, unless otherwise stated, we do not control, do not recommend or support, and are not affiliated with or subject to these websites or their content, products, services or privacy policies. Downloading materials from certain websites may result in violation of intellectual property rights or infecting your computer system with viruses.
- Security practices
Security of your personal data is exceptionally important to us, therefore we have set up the appropriate physical, electronic, and management procedures to protect the data we collect. Taking into account the condition of the technology, costs of the implementation and its nature, scope, context and purpose of the processing, as well as the different probabilities and severity of the risks for the rights and freedom of natural persons, we will take care of the implementation of the appropriate technical and organization measures to ensure a level of security equivalent to the level of risk, such as accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to personal data that are transmitted, stored or otherwise processed by such unlawful processing.
However, due to the open nature of the Internet, we cannot guarantee that communication between you and us or the information stored on the Website or on our servers will be completely safe from unauthorised access by third parties. To the greatest extent permitted by governing law, we waiver all responsibility and all liability for any damages that you may incur due to loss, unauthorised access, misuse or alteration of any information you submit to the Website.
- Governing law/jurisdiction
All questions relating to the Website and this Privacy Policy are governed by the Croatian law. You agree that in relation to the procedure related to the Website and Privacy Policy are only the courts with territorial jurisdiction in the Republic of Croatia. We do not warrant nor imply that the Website or content/materials on the Website are suitable for use outside the Republic of Croatia. Information provided on the Website regarding any service or product is only applicable to the Republic of Croatia and these services and products may not be available in all locations. If you are outside the Republic of Croatia, you are solely responsible for compliance with all governing local laws.
- Transfer of property
In the course of our business, we may sell or buy assets. If another subject acquires the majority membership in CGA and CGC, the personal data of the users of the Website we have collected may be transferred to that subject. Moreover, if any bankruptcy or restructuring process is initiated against us, such data may be considered our property and may be sold or transferred to third parties.
- Severability
If any provision of this Privacy Policy is considered invalid, unlawful or unenforceable for any reason by any law or public policy, the provision shall not apply to the extent to which it is invalid or unenforceable and the other provisions shall continue to apply with full legal effect.
- Changes and updates to our Privacy Policy
CGA and CGC reserve the right to modify or update this Privacy Policy at any time and without prior notice. Please check from time to time for any changes or updates to our Privacy Policy, which will be published here and show on the first page of the Privacy Policy the date of coming into force if any changes or updates are made.
- Contact information
If you have any questions or comments regarding the Website or the Privacy Policy, you can contact us via our online form at https://hsup.hr/en/contact/ or by email at zoran.dojcinovic@hsup.hr, or telephone 01/6189 -590/592.