Personal Data Protection Policy at Dogma nekretnine d.o.o.
DOGMA NEKRETNINE, d.o.o. (hereinafter: DOGMA NEKRETNINE or just DOGMA) is very serious about protecting your personal data and implements all necessary technical and organisational measures in accordance with the best practice and obligations stipulated by the Croatian laws and the General Data Protection Regulation (EC 2016/679) – GDPR.
Dogma’s information system is protected in accordance with the practices and standards. The logical and physical access to system components is managed in accordance with applicable standards, and users are regularly trained and informed about the importance of information security and data protection.
The specific purpose and methods of processing your personal data largely depend on the type of business relationship based on which we collect your data. In our business we are guided by the basic principles of personal data protection, which means that we process data legally, transparently, and fairly, the processing is limited only to the purpose for which the data were collected, and only the data necessary for that purpose are processed. We keep your personal data only to the extent necessary for achieving the purpose of the processing, except when we are bound by certain regulations to store personal data longer or when required so by our legitimate interests (for example, for making, implementing, or protecting a legal claims). The accuracy, reliability, confidentiality, and integrity of your personal data are also principles we follow when processing. Access to your personal data is granted only to authorised persons of Dogma nekretnine and partners who provide us with business support (data processors).
Several different departments have been engaged within our company to comply with the above regulatory requirements, ensuring a multidisciplinary approach to preserving and protecting the privacy of our customers, business partners, job candidates, and other persons whose data we collect in our business. We thus regularly train our employees and we contract adequate protection measures with the partners providing us with business support.
Data controller is DOGMA NEKRETNINE d.o.o., with its registered office in Rijeka, Fiorella la Guardia 6, PIN /OIB/: 00335331932.
Please send your inquiries to:
Address: Fiorello la Guardia 6, 51000 Rijeka, e-mail address: firstname.lastname@example.org
Purpose and legal grounds for personal data processing
Dogma nekretnine d.o.o. as the data controller protects your privacy and processes only the personal data that are essential to it and that have been collected as part of its business activities, whether the data were provided by you or a third party, or from publicly available sources, for the following purposes:
- Fulfilment of contractual obligations – when processing is necessary to fulfil the contract that you are a party to or to take action at your request prior to concluding the contract
- Satisfaction of legitimate interests – when necessary, we also process personal data outside of the specific contractual relationship to satisfy our legitimate interests. For example, such legitimate interests may include the following:
- Conducting legal proceedings and keeping records of them
- Discovering perpetrators of criminal offences and preventing frauds
- Protection of persons and property
- Fulfilment of your requests so that you could help us develop, deliver, and improve our services or for our internal needs, such as audit, data analysis and research for the purpose of improving our products, services and communication with our users
- Answering your inquiries and comments
- Necessary compliance with legal obligations – considering its diverse business activities, Dogma is obligated to comply with numerous legal obligations. For example, we are obligated to act in accordance with the Money Laundering and Terrorism Financing Prevention Act, the Real Estate Brokerage Act, etc.
- Personal data processing for a special service or several special purposes described by consent, only after we receive your consent for the processing of your personal data for a particular purpose. Your consent is in accordance with the relevant provisions of the Regulation, it is unconditional, and given freely. You reserve the right to withdraw your consent at any time.
If we process your personal data for the purposes not described herein or outside the purpose for which you have given your consent, before such processing we will provide you with the information about this other purpose and all relevant information about the processing.
Which personal data do we collect and how do we get them?
We primarily process the personal data collected within the scope of the business relationship, such as the name, surname, PIN /OIB/, address, real property data, etc. However, if necessary for the performance of our business activities and regardless of the specific contractual or business relationship, we also collect data from public sources (court register, land register, Financial Agency – FINA) or they are legitimately disclosed to us by other companies of Dogma Group, other contractual partners or third parties.
Are you obligated to share your personal data with us?
You are not obligated to do so. However, keep in mind that, in some cases of failing to provide the required data, Dogma nekretnine d.o.o. will not be able to enter into a contractual relationship with you, i.e. meet its legal and contractual obligations. For example, without your identification, we will not be able to meet the obligations for which the relevant law requires clear identification of the principal.
Data storage period
Dogma nekretnine d.o.o. will store your personal data only as long as necessary for performing its contractual or legal obligation or satisfying a legitimate interest, except in case of personal data processing based on your consent, when processing ceases at the moment when you withdraw your consent. You can withdraw your consent at any time by sending a request to:
– the e-mail address email@example.com
We would like to note that withdrawing the consent does not affect the legality of the data processing based on the consent prior to its withdrawal.
If your personal data will no longer be necessary for fulfilling the above purpose, they will be destroyed, except in cases when further storing is required by law.
Who is the recipient of your personal data?
Dogma nekretnine d.o.o. undertakes to keep your personal data and will not disclose them, i.e. make them available, to third parties without your express consent, except:
- To service providers we hire as data processors for tasks related to the fulfilment of the contract to which you are a party (e.g. Dogma upravljanje d.o.o., Dogma Kapital d.o.o., law firm, relevant services for utilities transfer)
- To the competent authorities for the purpose of performing tasks in their competence (e.g. Tax Administration, Ministry of the Interior)
- When the data are requested by the court or the competent state attorney’s office, i.e. other authorities in equivalent legal proceedings
- When Dogma nekretnine d.o.o. is legally obligated to disclose these data.
What are your rights regarding personal data processing?
Depending on the legal ground for the processing, you may have the following rights:
- Right to request access to personal data relating to you, which means that you have the right to be informed about the scope of collected data, purpose of the processing, category of personal data that is being processed, recipients to whom the data is delivered, and the period of storage
- Right to request an amendment to inaccurate or incomplete personal data, in which case we are obligated to act in accordance with your request without unnecessary delay
- Right to object to the processing of personal data in case they are processed based on Dogma’s legitimate interests or for direct marketing purposes
- Right to request deletion of data in cases when the purpose of the processing has been fulfilled, when you have withdrawn your consent as the only basis for the processing, when your privacy protection interest outweighs Dogma’s legitimate interest in the processing, when you object to the processing for direct marketing purposes, when it is required for purposes of compliance with legal requirements to which Dogma is subject, and in case of any illegal processing. The right to deletion is not an absolute right and does not apply, for example, in cases when processing is necessary to exercise the right to the freedom of information and expression, compliance with legal requirements to which Dogma nekretnine d.o.o. is subject, establishment, realisation, or defence of legal requests, etc.
- Right to restrict data processing, for example, when you are disputing the data accuracy, until the accuracy is verified
- Right to transfer the data to another data controller if the processing is based on consent or performance of a contract to which you are a party, i.e. if the processing is carried out automatically and it would be technically feasible
- Right to lodge an objection to the national supervisory authority, i.e. the Croatian Personal Data Protection Agency.
Requesting access to personal data pertaining to you or requesting the correction of your personal data
If you want access to your personal data or if you believe that irregularities have occurred in the processing of personal data, please contact the above address or e-mail address.
Lodging an objection to personal data processing
If you believe that Dogma nekretnine d.o.o. has no legal grounds for processing your personal data, you can lodge an objection to the above address or e-mail address at any time.
In that case, we will no longer process your personal data and we will not be able to provide our services to you or be in a business relationship with you.
General Terms and Conditions
General Terms and Conditions of Brokerage
Pursuant to the Real Estate Brokerage Act of 10 October 2007, DOGMA nekretnine d.o.o. Rijeka, Fiorella La Guardia 6, as the broker, hereby adopts the following General Terms and Conditions of Brokerage.
Description of the broker’s individual activities
- The broker shall act with the care of a prudent businessman in terms of the endeavours to find a person who would negotiate on the conclusion of a purchase and sale or other agreement aimed at transferring and acquiring ownership rights, which realises the interest of the principal, and to bring such person into contact with the principal.
- In addition to the obligation to find a person or the opportunity for entering into an agreement, the broker, with the cooperation and informing of the principal, undertakes to mediate in negotiations, endeavour to accomplish an agreement between the parties and have them enter into an agreement to mutual satisfaction, inform the principal (seller/buyer) about the circumstances relevant for the conclusion of the deal, provide legal support during the preparation of individual acts, and, upon the conclusion of the agreement, submit the necessary documentation to the competent land register department of the Municipal Court for the purpose of registering the ownership right.
- The basic obligation of the principal (seller/buyer) is to pay the contracted fee to the broker for the broker’s individual activities described in Article 1 of the General Terms and Conditions of Brokerage.
- The obligation to pay the brokerage commission is regulated by the Brokerage Agreement concluded with each principal (seller/buyer) individually, and which also regulates the amount of the brokerage fee.
- The fee for the brokerage service is charged as a percentage of the total achieved amount of the purchase price, and the amount may never exceed a total of 6% + VAT of the purchase price.
- The broker regulates the brokerage commission by the Decision on pricing method, which is based on the price list published by the Croatian Chamber of Economy – Trade Sector.
Material costs not included in the fee
- The agreed and paid brokerage fee does not include the costs of settling court fees for the entry, reservation and notification, notary fees for the certification of signatures on documents, settlement of fees for obtaining the title deed, copies of the cadastral plan, identification, transfer of mortgage to change the mortgage debtor, certificates and other documents regarding the concluded legal transaction which realises the interest of the principal (seller/buyer), and it is exclusively the principal’s obligation.
- Material costs that normally constitute court fees for the actions described in paragraph 1 of this Article shall be charged in accordance with the applicable Court Fees Act and other acts regulating the said payment of the costs in question or the principal (seller/buyer) shall pay the court fees independently and deliver proof to the broker so that it could be enclosed with the proposals/requests that require the settlement of due court fees.
Cancellation of the brokerage order
- The principal (seller/buyer) may cancel the brokerage order provided that the revocation is not contrary to the principle of good faith. The procedure of order cancelling cannot be time-barred, i.e. with the intention of depriving or knowingly damaging the broker regarding the right to a fee.
- The cancellation of the brokerage order shall be specified in the Brokerage Agreement.
- The Agency as a broker has at least one employed person, an agent or director of the company, who is professionally qualified for real estate brokerage and has passed the professional examination referred to in Article 30 of the Real Estate Brokerage Act.
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