capturing moments

Privacy Policy

Thanks for your interest in my work and my photo services. Protection of your personal data is very important and high priority for CVIRN-PROMOCIJA d.o.o. The processing of personal data, such as the name, e-mail address, address or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR).

1. About the Privacy Policy

1.3. This is the privacy policy put into effect by CVIRN-PROMOCIJA d.o.o., Zagreb, Petra Zrinskog 10/A (hereinafter: “Company” or “Us”). In this respect, the Company has the position of a processing manager for your personal data.

1.2. This Privacy policy applies to our customers and those who use our services, as well as those interested in becoming that (hereinafter: “Clients” or “You”).

1.3. This Privacy policy details the way we handle the privacy and usage of your personal data. The Privacy policy applies only to natural persons and their personal information.

1.4. This version of the Privacy policy applies from May 25, 2018. The Privacy policy will be subject to regular audits, and each updated version will be placed on this website.

1.5. In case of any questions or requests regarding the handling or protection of your personal information, please contact us via e-mail, at:

2. Which personal data do we process?

2.1. We process only that personal data which you have provided us with, either during initial contact or in further communication (for example, during a phone call, through e-mail, etc.), or those that came from our business dealings.

2.2. We process the following personal data:

2.2.1. Your identification information – first and last name, address (street and house number, city, ZIP code, country)

2.2.2. Your contact information – cell phone and landline numbers, fax numbers, e-mail address, contact address (street and house number, city, ZIP code, country)

2.2.3. Additional information necessary for business purposes – company name, type of user (private or business); bank account information necessary for the realization of a business relationship.

3. Why do we process your personal data?

3.1. Your personal data is processed because you are our customer or use our services, or have expressed interested in becoming so.

3.2. Your personal data is processed for the following purposes:

3.2.1.Contract agreement and photo services
We process your personal data required to process, accept and complete your inquiry for our photo services.

3.2.2. Fulfilling our legal duties
We process your personal data in order to fulfill our duties – when and how the positive law regulations require us to do so. In that case, the basis for processing your personal data is the fulfillment of our legal duties.

3.2.3. Purchase and request information
We process your personal data to inform you about the status of your requests, service deliveries or the like, all with the goal of giving you complete information. In that case, the basis for processing your personal data is our legitimate interest.

3.2.4. Other cases
To protect our legitimate interests as a company (for example, when necessary for the purposes of conducting judicial, misdemeanor or other court proceedings or, where necessary, to ensure an adequate level of protection). In that case, the basis for processing your personal data is our legitimate interest.

4. Who has access to your personal data?

4.1. We regard your personal data as a business secret and protect them as such, in accordance with applicable legal regulations and best practices.

4.2. Third parties have the right to access and process your personal data only in the situations described below:

4.2.2. People we work with when we consider it necessary to protect certain legitimate interests. For example, tax advisers or other counselors. In that case, those persons will process your personal data exclusively for our purposes;

4.2.3. Competent bodies in the conduct of oversight over the legality of our business and conduct, as well as other legal persons when it is necessary for the performance of some of our statutory duties, such as an auditor. In that case, these legal persons process your personal information for the purpose assigned to them by law;

5. Is your personal data transferred to third countries?

Your personal data will not be disclosed to third countries (outside the European Union).

6. What is the timeline for storing your personal data?

6.1. For data where there is a legally defined deadline, your data will be store throughout that period and will be deleted after an additional period of one year.

6.2. Personal data which we process based on our legitimate interest are kept as long as there is legitimate interest, and is deleted in a period of 1 year from the end of our legitimate interest.

6.3. The personal data we process on the basis of your consent will be kept as long as we have your consent. In the event of withdrawal of consent, we will delete them as soon as possible.

7. Your rights

7.1. If you choose to exercise one or more of the rights listed below, the Company has the right to verify your identity, all for the purpose of protecting your personal information.

7.2. Your rights are made available to you free of charge. However, if your requests to access or transfer your personal data are frequent (for example, if your last request was less than 6 months ago) or excessive (for example, if you request all of your personal data in writing), we have the right to ask you to settle these costs yourself, before carrying out such actions.

7.3. Access to your personal data: you have the right to request confirmation on whether we process your personal data, as well as access to your personal data that we process. You can send your request via e-mail, at:

7.4. Correcting incorrect personal data: you have the request correction of your incorrect personal data, as well as the right to supplement your personal data that we process. You can send your request via e-mail, at:

7.6. The right to withdraw consent and the right to forget: You have the right to withdraw your consent for processing your personal data, as well the right to request that your personal data that we processed based on your consent is permanently deleted. You can send your request via e-mail, at:

7.7. Complaints against processing or handling your personal information: You have the right to object to the processing of your personal data as well as to our general manner of handling your personal information. Please send us your request via e-mail, at, with the subject title being “Objection against processing” and the body of the message being an explanation for the reason of the complaint, as well as your request.

7.8. Right to complain to the Personal Data Protection Agency as the Client: at any time, you have the right to complain to the Personal Data Agency (, regarding the processing and protection of your personal data.

8. Website information

8.1. This website contains information on products and services that CVIRN-PROMOCIJA d.o.o. offers. CVIRN-PROMOCIJA cannot be held responsible for any damages arising from the use of information from this web site for purposes beyond its intended purpose. CVIRN-PROMOCIJA obliges to apply maximum security measures to protect the interests of its customers to prevent any misuse of information.