Privacy Policy

Trading company [2FC j.d.o.o. Fijanova ulica 4, Zagreb OIB:23869841386] as the Data Controller in accordance with the principle of transparency and the provisions of the General Regulation on the Protection of Personal Data (GDPR) makes the following:

RULES ON THE PROTECTION OF PERSONAL DATA

1. Introduction

The protection of personal data of users of the 2fcagency.com site is a special interest of 2FC Real Estate Agency. The purpose of the privacy policy is to explain in a clear and simple way what personal data we collect, how long we collect it, why we collect it, who has access to your data, what rights you have and how you can use it. When we collect your personal information or when you share it with us, we use it in accordance with this Policy. You will be informed about possible amendments to the Rules in a timely manner, including through publication on the 2FC Real Estate Agency website.
Please read these Rules carefully and if you have any questions or concerns regarding personal data, please contact us at [email protected].

2. What is personal data?

If you are interested in the exact legal definition of personal data, click on “Who wants to know more.. We have simplified it, so we define personal data as information that can be used to identify you directly (e.g. name and surname) or indirectly (e.g. through a pseudonym ).

3. How do we collect personal data?

We collect data directly from you (e.g. when you are our client, when you request an offer from us, when you contact us by phone and/or when you visit us at our branches), automatically (via our websites), if or from a third party (from publicly available sources such as open databases or other publicly owned data).
Important! Our website is not intended for persons under the age of 16. We advise all parents and guardians to teach their children how to handle personal data safely and responsibly on the Internet.
This Privacy Policy primarily applies to the personal information we collect when you visit this Website. Read about other processing of personal data in II. Part, point 6 of these Privacy Policy.
When you visit our website, we process your personal data:

For the purpose of communication with you
If you send us an e-mail or a message via our contact form, we collect your personal data, namely: (name and surname, e-mail address, content of your inquiry). Personal data will be used only in order to be able to respond to your inquiry, i.e. in order to be able to provide information or an answer in connection with which you have shown interest. The legal basis for processing personal data is our legitimate interest.

Direct marketing (via newsletter)
If you sign up for the newsletter, we process your personal data (name and surname, email address) so that we can send them to you regularly via email. The legal basis for processing personal data in this case is your consent. At any time, you can withdraw your consent and unsubscribe from the marketing mailing list via the link available in every e-mail marketing message.

Protecting our websites from cyber attacks and other threats

Legal basis: Legitimate interest – increasing the security of 2fcagency and preventing fraud
Category of personal data: Technical data (IP address, operating system data, information about visiting our websites) Please note that the provision of data is voluntary, but the refusal to provide certain personal data may result in the inability to provide our service and/or respond to your inquiries.

4. Links to Third Party Sites

If you visit other websites via links contained on our website, please note that these websites have their own privacy policies and that we are not responsible or liable for them.

5. Online Search

Our website uses the so-called cookies and similar technologies. The purpose of cookies is to ensure the correct operation of the website, to improve our service to make it as efficient as possible. Cookies are small text files that can be stored on your computer and are used by your web browser. Information collected by cookies and similar technologies may contain data about your application, application details, location, IP address, browser information, device information, duration of visits, ads you search, pages you have visited, etc. Most of the cookies we use are so-called “session cookies” that are deleted when an individual browser session ends. There are some permanent cookies with which we can recognize you as a visitor. It is your right to turn off cookies in the settings of your Internet browser.
(links for individual browsers can be found below in the text) https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=en
https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
https://support.apple.com/en-gb/safari
Read more about cookies and their various variants in the Cookie policy

II. part – data processing of our clients and/or potential clients. If you liked our offer and decided to enter into a business relationship with us and/or expressed interest in business cooperation, we may process your personal data for the following purposes:

Purpose of data collection: Fulfillment of contractual obligations
Legal basis: Processing is necessary for the execution of Contracts to which you are a party
Category of personal data: Name and surname, financial data, contractual data
(b)
Purpose of data collection: Communication with you, which includes processing for the purposes of:
2. Suggesting products/services that we believe you are interested in
3. Sending an offer
4. Sending/delivering notifications sent by us during the duration of the Agreement
5. Responding to your complaints arising from the business relationship with us
Legal basis: Processing is necessary for the execution of contracts in which you are a party, i.e. for taking preliminary actions necessary for concluding a contract;
1./2./5. Legitimate interest
3. processing is necessary in order to take actions at the request of the respondent before concluding the contract
4. processing is necessary for the execution of the Agreement to which you are a party
Category of personal data:
2. Data on previous purchases, Contact data
3. and 4. Contact information
(c)
Purpose of data collection: debt collection
Legal basis: legitimate interest
Category of personal data: first and last name, contact data, financial data
(d)
Purpose of data collection: Protection of our property and ensuring the safety of property and third parties
Legal basis: Legitimate interest
Category of personal data: Data collected by video surveillance
(f)
(Mr)
Purpose of data collection: Compliance with our legal obligations
Legal basis: Processing is necessary to comply with the legal obligations of the controller;
Category of personal data: Name and surname, Financial data, Data on the concluded contract
(h)
Purpose of data collection: Analysis of the performance and organization of our business, including processing for the purpose of creating reports and management analysis. we also process your personal data for the purposes of internal management, conducting business audits, implementing business controls.
Legal basis: Legitimate interest
Category of personal data: Name and surname, Information about your transactions, Information about the concluded contract

6. Analytics and advertising tools

Google Tag Manager
We use Google Tag Manager. The service provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Tag Manager is a tool we use to integrate tracking or statistical tools and other technologies on our website. Google Tag Manager itself does not create user profiles, does not store cookies and does not perform any independent analysis. It is used exclusively to manage and display the tools integrated through it. However, Google Tag Manager records your IP address, which may be transmitted to Google’s parent company in the United States.

Google Tag Manager is used based on Art. 6. paragraph 1. (f) GDPR. The website operator has a legitimate interest in the quick and easy integration and management of the various tools on its website. If appropriate consent is requested, the processing takes place exclusively on the basis of Art. 6, paragraph 1 (a) of the GDPR and Article 25, paragraph 1 of the TTDSG, if the consent includes the storage of cookies or access to information on the user’s device (e.g. device fingerprint) in the sense of the TTDSG. Consent can be revoked at any time.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US that aims to ensure compliance with European data protection standards when processing data in the US. Every DPF-certified company is committed to complying with these data protection standards. Additional information can be obtained from the provider at the following link: [https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt000000001L5AAI&status=Active](https://www. dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt000000001L5AAI&status=Active)
Google Analytics
This website uses functions of the web analytics service Google Analytics. The service provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior of website visitors. The website operator receives various usage data, such as the number of page views, length of stay, operating systems used and the origin of the user. This data is assigned to the corresponding user device. There is no user ID assignment.

In addition, Google Analytics allows us to record your mouse movements, scrolling and clicks. Also, Google Analytics uses different models to supplement the collected data and uses machine learning technologies in data analysis.

Google Analytics uses technologies that enable user recognition for the purpose of analyzing user behavior (eg cookies or device fingerprint). The information collected by Google about the use of this website is usually transferred to a Google server in the USA and stored there.

The use of this service is based on your consent in accordance with Art. 6. paragraph 1. (a) GDPR and Art. 25, paragraph 1 of the TTDSG. Consent can be revoked at any time.

The transfer of data to the USA is based on the standard contractual clauses of the European Commission. Details can be found here: [https://privacy.google.com/businesses/controllerterms/mccs/](https://privacy.google.com/businesses/controllerterms/mccs/).

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US that aims to ensure compliance with European data protection standards when processing data in the US. Every DPF-certified company is committed to complying with these data protection standards. Additional information can be obtained from the provider at the following link: [https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt000000001L5AAI&status=Active](https://www. dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt000000001L5AAI&status=Active)

IP Anonymization
Google Analytics IP anonymization is activated. This means that your IP address will be shortened by Google within the member states of the European Union or in other contracting states of the Agreement on the European Economic Area before it is transferred to the USA. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, create reports on website activity and provide other services related to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be combined with other Google data.

Browser plugin
You can prevent Google from collecting and processing your data by downloading and installing the browser plug-in available at the following link: [https://tools.google.com/dlpage/gaoptout?hl=hr](https://tools.google.com/ dlpage/gaoptout?hl=hr).

For more information about how Google Analytics processes user data, see Google’s privacy policy: [https://support.google.com/analytics/answer/6004245?hl=hr](https://support.google.com/analytics /answer/6004245?hl=hr).

7. With whom do we share your personal data?

Depending on the purpose for which it is collected, we may share your data with third parties who help us provide digital and e-commerce services, advertising agencies, marketing, digital advertising and social media advertising, third parties necessary for product delivery, e.g. mail / delivery services, third parties who help us provide technical support, payment service providers, legal representatives and the like. We may also disclose personal data as part of a business transaction, such as a merger or sale of assets, and to competent state and public authorities.

8. How long do we store your personal data?

We store and process your personal data only as long as necessary for execution
certain legal purposes, unless the applicable regulations provide for a longer period of time for a particular purpose
storage or in other Criteria for determining the storage period of personal data include the following:
For what purpose do we collect personal data?
What is the legal basis for processing personal data?
How long is personal data needed to fulfill a specific legitimate purpose?
Are we subject to a legal obligation to keep personal data? (In this case, we keep the data for a period specified by law)

9. Security and storage of personal data

We process personal data within the European Economic Area. We take all necessary organizational and technical measures to ensure that your personal data is safe and protected from loss, destruction, alteration, forgery, manipulation and/or unauthorized access. We undertake to notify you and the competent authority in the event of a breach of your personal data. We take measures to ensure that the data we collect and process are in accordance with the provisions of these Rules and the requirements of the law. If we share personal data with third parties, we use appropriate legal and technical mechanisms to protect your personal data from infringement.

10. Your rights

10.1. The right to withdraw the given consent

When the processing of personal data is based on your consent, you have the right to withdraw the given consent at any time. Withdrawal of consent does not affect the legality of processing based on the consent given before its withdrawal. He can with permission withdraw through this e-mail address [email protected] or by writing to the address of the headquarters of 2fcagency.

10.2. The right of access to personal data

You have the right to request confirmation of whether we are processing your data and, if yes, to obtain access to the same and information about the purpose of processing, categories of personal data, recipients or categories of recipients, about the expected period in which the data will be stored or about the criteria used to determine that period, the existence of rights, the existence of automated decision-making.
You can submit a request for access to data via this e-mail address [email protected] or by writing to the address of the headquarters of 2fcagency. In order to process your request, we have the right to request verification of your identity.

10.3. The right to correct incorrect or incomplete data and the right to erasure

If your data is incorrect and/or out of date, you have the right to ask us to correct the data. You can submit a correction request via this e-mail [email protected]. In certain cases, you have the right to request the deletion of your data, i.e. you have the so-called the right to be forgotten. Please note that the right to be forgotten is not an absolute right. In other words, we have the right to reject your request for data deletion, if we have a legitimate interest and/or legal duty and/or right to keep certain data. You can submit a deletion request via this e-mail address [email protected]. In order to process your request, we have the right to request verification of your identity.

10.4. The right to object to processing based on the Controller’s legitimate interests

You can object to data processing at any time and when data processing is based on legitimate interests. After an objection has been lodged, we may no longer process personal data unless we prove that there are compelling legitimate reasons for processing that go beyond your interests, rights and freedoms, or the data is processed for the purpose of establishing, exercising or defending legal claims. In order to process your request, we have the right to request verification of your identity.

10.5. The right to information and data portability

We are obliged to process your personal data transparently and clearly, and you have the right to receive easily understandable information about how we use your data. For this purpose, we have published these Rules, and in order to explain to you in the simplest and most transparent way what data we collect and why. Please note that for any additional questions and/or clarifications regarding the protection of your personal data, you can contact us via e-mail [email protected]. You also have the right to transfer data from our database to another Controller. This right only applies to data that you have provided to us based on a contract or consent and if the processing is carried out by automated means. In order to process your request, we have the right to request verification of your identity.

10.6. The right to complain to the competent authority

Your basic right is to file a complaint with the supervisory authority, i.e. the Agency for the Protection of Personal Data, Selska 136, Zagreb, if you believe that your personal data has been breached.

10.7. Right of limitation

It is your right to request that the processing of your data be restricted if:

you dispute the accuracy of personal data for the period during which the Data Controller is enabled to check the accuracy of personal data,
if we no longer need the personal data, but you require it in order to establish, exercise or defend legal rights,
if you have filed an objection to processing based on legitimate interests, in the period in which confirmation is expected whether the legitimate interests of the controller exceed your rights and
if the processing is illegal, but you object to the deletion of the data and request a restriction.
In order to process your request, we may ask you to verify your identity.

11. Conclusion

In no case will we misuse your personal data
When processing, we act in accordance with the law and the General Regulation on the Protection of Personal Data
We process data only for a specific and lawful purpose
We respect your rights

If you have questions about how we handle your personal data or would like to exercise your rights described in point 6 of these Rules, please contact us at [email protected] or by writing to the address of the 2FC Real Estate Agency  headquarters.

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