ETF Airways d.o.o., Ulica Javora 2, 10255 Stupnički Obrež, Hrvatska, OIB: 40026370127, represented by the CEO Stjepan Bedic, as (hereinafter) Processing Manager, pursuant to Art. 29 para. 1 of the Ordinance on the processing and protection of personal data of 25 May 2018 in connection with the provisions of the General Regulation on Data Protection (EU) 2016/679 and the Act Implementing the General Regulation on Data Protection (OG 42/18) ), adopts in written and electronic form the following:

DECISION

Article 1.

Pursuant to Art. 29 paragraph 1 of the Ordinance on data protection of 25 May 2018 (hereinafter: the Ordinance) in connection with the provisions of the General Regulation on Personal Data Protection (EU) 2016/679 (hereinafter: the Regulation) and the Act on the implementation of the General Regulation on Data Protection (OG 42/18) (hereinafter: the Act on the Implementation of the Regulation), the Head of Processing prescribes the Rules of Personal Data Protection Policy (hereinafter: Privacy Policy).

Article 2

PRIVACY POLICY

Purpose of the Privacy Policy:

The Privacy Policy of ETF Airways d.o.o., Ulica Javora 2, 10255 Stupnički Obrež, Hrvatska (hereinafter: ETF Airways d.o.o.) protects the privacy of its clients, employees, employee candidates, business partners and external associates and expresses concern for their personal data. The privacy policy of ETF Airways d.o.o. undertakes to process personal data exclusively in accordance with the principles of the Decree, the Law on the Implementation of the Decree and the Ordinance.

Personal information:

According to the Regulation, personal data are all data relating to an individual whose identity has been established or can be established (“respondent”), and an individual or respondent as the Regulation calls him, whose identity can be established is a person who can be identified directly or indirectly .

Processing:

According to the Regulation, processing means any operation or set of operations carried out on personal data or on sets of personal data, whether automated or non-automated, such as collecting, recording, organizing, structuring, storing, adapting or modifying, locating, inspecting, using , detection by transfer, dissemination or otherwise making available, harmonization or combination, restriction, deletion or destruction.

Data collection:

ETF Airways d.o.o., collects exclusively personal data that the client, employee, candidate for employee and business partner as well as external associate enters independently.

Data is collected through available forms, contacts (e-mail, phone or in person) or prescribed web forms.

Data collection is necessary for the provision of services and placement of products from the registered activity of ETF Airways d.o.o. collection, invoicing and delivery of purchased goods and services or fulfillment of guarantees that follow as a result of the business relationship, and they are collected based on terms of use.

By creating a business relationship, the following personal information about you and your travel arrangements that we collect, use, disclose and store may be collected:

• Name and surname,
• Address, place, postal code,
• Phone number,
• Email address (e-mail),
• Mr / Miss / mrs,
• Date of birth,
• Passport number, ie the number of the personal document necessary for proving personal identity,
• Citizenship,
• Credit card information (always anonymous ‘xxxx xxxx xxxx 1234’),
• IP addresses
• Name and surname of the person for the alternative delivery address, postal code, address and city for delivery to the alternative address and contact telephone number at the alternative delivery address,
• Name and surname of the alternative person in charge of downloading the service or product, e-mail address

The information collected during the business relationship with ETF Airways d.o.o., is used in the following ways:

• We use the name, surname, e-mail address to identify the user
• We use the e-mail address to contact you in case of sending an offer, invoice, notice of business relationship
• Name, surname, e-mail address, telephone number, postal code, place, address, and at your request the name and surname, address and telephone number for the alternative delivery address we use for possible delivery of products and services, including delivery of services and products to the specified address
• Name, surname, e-mail address, telephone number are used to manage possible disagreements regarding the business relationship

Due to a better user experience and better support, all collected data will be stored for one year from your last business relationship with our company. After this period, your user data will be deleted. Except legally necessary.

Purpose and insight:

Personal data is used exclusively for the aforementioned purposes, and will be available to external executors in the processing process.

We might share personal information with technical service providers that provide and maintain our recording system. Hosting is provided by Plus Hosting, Croatia (www.plus.hr). In addition, based on the legal obligations prescribed by special legal regulations, personal data will be made available to representatives of the competent legal authorities.

Web cookies:

Some of our outsourcers use standard web cookies on their websites. These are small pieces of code that your browser automatically executes, and are needed to adequately display the content of the pages on all devices, and without them the use of the pages would not be possible. The information thus collected is information about your browser and is used to remember your location on the pages in case the session is interrupted, to track user movements to improve the functionality of the pages and to improve your user experience.

The cookie that tracks your session remains active for 45 minutes or until the internet browser is turned off.

Cookies set in this way are used to improve your user experience and which allow you to adjust the display settings on the online store page remain active for 12 months or until deleted from the browser.

In addition to these standard cookies, we also use Google Analytics, Google AdWords cookies that track your behavior on the site. These cookies store information about the ways in which visitors use the website, including the number of pages displayed, where visitors come from and the number of visits, all to simplify the use of the website for you. More information about them can be found at:

http://www.google.com/analytics/learn/privacy.html

Please note – web cookies can be deleted using your browser settings, and instructions on how to remove them can be found using the ‘Help’ feature in your browser or on the browser manufacturer’s website.

More information on what cookies are, what they are for and how to remove them from the most common browsers can be found at http://www.aboutcookies.org.uk/

Storage and protection:

Personal data will be stored and processed within the legal deadline.

ETF Airways d.o.o., implements adequate data protection safeguards, but cannot guarantee the protection of any information during transmission to or from the Website, and cannot be held liable for the actions of any third party that receives such information.

ETF Airways d.o.o., will endeavour to do its best to protect your personal information and once we receive it through strict procedures and security features we strive to prevent unauthorised access to the information. As the transfer of data via the Internet is not completely secure, we cannot guarantee the security of the data sent to our site. You make each transfer as such at your own risk.

Please note that no website is 100% secure, we strive to fully protect your information, but we cannot guarantee complete security. In addition, no computer is 100% safe from hacking or unwanted downloads, and we recommend that you use all available measures to secure your own computer and browser.

Respondents’ rights:

Respondents have the right to information, access to personal data, correction of personal data, their deletion (“right to forget”), the right to limit the processing of personal data, the right to portability of personal data, the right to object to the processing of personal data and withdrawal of consent.

In order to exercise your right to information, correction of incorrect data or their deletion, please contact us by e-mail: passengers@etfairways.com . Your request will be resolved as soon as possible.

The respondents exercise these rights through a request submitted to the processing manager in writing or by e-mail.

The Head of Processing is obliged to decide on the Request of the respondent within one month from the day of receipt of the Request.

In the event that the respondent is not satisfied with the response of the controller or the controller does not act on the Respondent’s Request, the Respondent may file a complaint with the Personal Data Protection Agency. (hereinafter: AZOP).

Correction

In order to change any information, contact us by the same e-mail and we will make the necessary changes.

Deletion

In order to request the deletion of your personal data, please contact us by e-mail: passengers@etfairways.com . Please note that although you have requested deletion, we will only delete data that we do not have to keep under contractual and legal obligation. Your request will be resolved as soon as possible.

Export data in standard format

At the request of the respondents, ETF Airways d.o.o. will deliver all your personal data to the client as soon as possible, and you can request such export by e-mail: passengers@etfairways.com

Withdrawal of consent

If you have given us consent (permission) to use any private data during your business relationship, you can always withdraw it by e-mail at: passengers@etfairways.com

Resolving misunderstandings or additional issues

To resolve possible misunderstandings or ask additional questions, please use e-mail: passengers@etfairways.com

Data privacy:

ETF Airways d.o.o., guarantees complete privacy of data that may have been obtained during the business process of the services it performs. All possibly available data will be stored on secure storage systems, in a secured and technically protected area. They will be kept only during the necessary business process and will be permanently securely deleted upon completion.

All data processing will be done only with the consent (permission) of the owner (bearer) of the same. We guarantee that we will not provide the data to “third” parties (except for any legal obligation: court decision, etc.). All data will be stored at the location of our headquarters.

Contact:

For all additional questions you can contact us at:

ETF Airways d.o.o.
Ulica Javora 2,
10255 Stupnički Obrež, Hrvatska

(+385) 99 737 0016
info@etfairways.com

Article 3

This Decision shall enter into force on the day of its adoption.
Stupnički Obrež, January 1st, 2021.