1. Introduction

The company Indigo Blu j.d.o.o., established at Pristav 37, 52232 Kršan VAT No. 11172110574 (Indigo Blu in further text), in running its business needs to collect and use certain personal data.

This policy has been written and implemented to assure that Indigo Blu operates in accordance with its legal, organizational and technical obligations regarding the protection of personal data.

All Indigo Blu's employees are fully informed of the contents of this Policy. They assure its application when handling and processing personal data. The employees whose tasks include handling and processing personal data have been properly trained on their duties regarding protection of personal data.

This Policy applies to all personal data stored by Indigo Blu, relating to any natural person, regardless of her relation to the business, whether she is, she was or she might become a client, a supplier or a contact-person.

This Policy has been implemented to prevent potential damages to Indigo Blu and its employees and subjects as well as to assure that processing of personal data be fully aligned with the applicable laws and other regulations.

2. Definitions and Scope

‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an 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 natural person;

‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction as well as any application of logical, mathematical and other operations on such data.

Indigo Blu collects and processes personal data mostly for providing services within the scope of its business. That is why Indigo Blu needs to collect and process certain categories of data about persons whom it has contact with (subjects). Indigo Blu handles these personal information in appropriate manner, regardless of whether the data are obtained, recorded, stored and used in a paper copy, on a computer or any other media.

When giving her data to Indigo Blu, the subject consents that Indigo Blu process her personal data in accordance with the declared purpose. Subject’s data privacy is permanently protected. At any moment, subject can exercise her rights, as listed and explained below.

Indigo Blu gathers and processes subject's personal data in accordance with the Law on the Protection of Personal Data (OJ 103/03, 118/06, 41/08, 130/11, 106/12), other applicable Croatian regulations, the European Directive 95/46/EC and the General Data Protection Regulation (GDPR), (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016).

Indigo Blu stores the collected data appropriately and assures their confidentiality. Indigo Blu shall not forward collected data to third parties without a subject’s consent, except when it may be needed to fulfill Indigo Blu’s legal obligations, when it is necessary to fulfill tasks of public interests or when the subject herself has made these data publicly available and/or in other cases when it is imposed by applicable regulations.

Regarding her personal data processed by Indigo Blu, subjects have the following rights.

Rights of the data subject and explinations

Right to Information

At any moment, data subject have right to demand information whether her personal data are being processed and for what purposes, who is the data controller, the contact-data of the Data protection officer, which categories of personal data are being processed, who or what is the source of her personal data, who are receivers of her personal data and the right to information about her other rights listed in this Policy (right to access, right to rectification, right to deletion, right to restriction and other).

Right to Access

Every data subject has right to ask and obtain from Indigo Blu a confirmation if personal data related to her are being processed, obtain access to these data and to the information on: - the purposes of the processing; - the categories of personal data being processed; - the recipients or the categories of recipients to whom the personal data have been or will be disclosed; - where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from Indigo Blu rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; - the right to lodge a complaint with a supervisory authority; - where the personal data are not collected from the data subject, any available information as to their source; - existence of an automated decision-making, including profiling and its consequences.

Right to rectification

The data subject shall have the right to obtain from Indigo Blu without undue delay the rectification of inaccurate personal data concerning him or her. The data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to erasure / right to be forgotten

Data subject have the right to have his or her personal data erased and no longer processed where the personal data are no longer necessary in relation to the purposes for which they are collected or otherwise processed, where a data subject has withdrawn his or her consent and there is no other legal basis for processing of these data, if the data have been unlawfully processed, if the data need to be erased to comply with the applicable Union law or national regulation of the member state having jurisdiction over Indigo Blu, if the data have been collected in relation to the information society services.
This is not applied if the data processing is necessary (and to the necessary extent) in order to exercise the right of freedom of expression and information, for compliance with a legal obligation which requires processing by Union or Member State law to which the Indigo Blu is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in Indigo Blu, for reasons of public interest in the area of public health, for archiving purposes in the public interest, scientific or historical research purposes, for the establishment, exercise or defense of legal claims.

The right to lodge a complaint with a supervisory authority

The data subject has the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him including profiling where the processing of the personal data is necessary for the performance of a task carried out in the public interest or in the exercise of legitimate Indigo Blu's or third parties interest. Indigo Blu shall no longer process the personal data unless Indigo Blu demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Right to data portability

The data subject has the right to receive the personal data concerning him or her, which he or she has provided to Indigo Blu, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from Indigo Blu if data processing is based on his or her consent and the data are being automatically processed.
Where technically feasible and when it does not impair other people's rights and freedoms, the data subject has the right to have the personal data transmitted directly from Indigo Blu to another.

Rights pertaining to automated decision making and profiling

The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her except if it is necessary for entering into, or performance of, a contract between the data subject and Indigo Blu, when expressly authorized by Union or Member State law to which the Indigo Blu is subject or it is based on the subject’s express consent.

Right to consent withdrawal

The subject's consent is one of legal basis for processing the data concerning a data subject. The data subject has the right to withdraw his or her consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to restriction of processing

Data subject has the right to demand restriction of processing of his or her personal data if he or she contests the accuracy of the personal data, for a period enabling Indigo Blu to verify the accuracy of the personal data; if his or her data have been unlawfully processed and he or she does not demand deletion, but only restriction of processing; if Indigo Blu does not need his or her data any more, but it needs they exist to exercise or execute its legal claims. If he or she objected to processing of his or her personal data, the subject has the right to demand restriction of processing for the period needed to establish whether the Indigo Blu's legitimate grounds of the controller override his or her rights from his or her objection.

To exercise his or her rights, the data subject should contact the Data Protection Officer, by sending a written notice or a request to the Indigo Blu's Data Protection Officer, by e-mail, using the e-mail address he or she obtained from Indigo Blu, or by street mail to the address: Pristav 37, 52232 Kršan, i.e. to the physical address of Indigo Blu LLC under condition that I request the exercise of my rights by an e-mail to the above mentioned address or submitting a written personal notice personally announced before by phone to the number +385 95 805 8464, and identifying myself with a valid personal ID.

3. Data Protection Officer

Indigo Blu has designated its Data Protection Officer:

Aleksandra Đorđić
tel: +385 95 805 8464

All inquiries regarding the protection of personal data should be addressed to the Data Protection Officer.

4. Principles Relating to the Protection of Personal Data

Indigo Blu acknowledges the importance of lawful and proper handling of personal data, so it makes its best efforts to assure that personal data are treated lawfully and properly. With this in mind, Indigo Blu fully accepts and complies with the principles of Data Protection.

The general data protection principles require that data:

5. Indigo Blu’s Activities Regarding Data Processing

Indigo Blu can publish, on their web site, the contents of the cookies used to advertise and produce statistics of web traffic based on interests and information from the web page visitors from social networks. If a data subject uses a Indigo Blu’s social network or application content, a cookie from these sites or application could be stored on a subject’s device used to access the Indigo Blu’s web page. Visitors have right to disable the cookies. Web browsers are usually set so that they accept cookies by default, but the data subjects can easily change this setting in their browsers. If a data subject wants to limit or block all cookies including Indigo Blu 's web sites and applications (which can be prevent the use of some parts of these web sites) or other web sites or applications, the subject can do it in his or her web browser settings.

When the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, Indigo Blu shall communicate the personal data breach to the data subject without undue delay unless Indigo Blu has implemented appropriate technical and organizational protection measures, and those measures were applied to the personal data affected by the personal data breach, in particular those that render the personal data unintelligible to any person who is not authorized to access it, or unless Indigo Blu has taken subsequent measures which ensure that the high risk to the rights and freedoms of data subjects is no longer likely to materialize or if it would involve disproportionate effort. In this, latest case, Indigo Blu will use public communication or a similar measure to assure that the data subjects be informed in an equally efficient way.

6. Review and Verification

Indigo Blu reserves its right to update this Policy as deemed necessary to maintain the best practices and to assure its compliance to any changes or amendments regarding the protection of personal data.