PRIVACY POLICY - RULES ON PERSONAL DATA PROTECTION

(hereinafter: "Rules")

Date of entry into force: 25.05.2019.

For personal data processing, within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016. on the protection of individuals with regard to the processing of personal data and the free movement of such data (hereinafter: the "General Regulation") and other regulations of the Republic of Croatia and the EU Member States governing the protection of personal data, the following processing manager holds the responsibility:

Zoran Matočec, Personal Data Protection Officer

Aktivplan 3D d.o.o., Mlinovi 78, 10000 Zagreb. 

If you have any questions about processing your personal information or your rights (see chapter 17), please contact us either via the Contact menu on the Web Site you visited or write to us (by registered post) to the following address: Aktiv Plan 3D d.o.o., Aleja seljačke bune 38, 10000 Zagreb, to the data privacy officer, or to e-mail adress: sailing@scan2sail.com

Aktivplan 3D d.o.o. is a limited liability company headquartered in Zagreb, providing booking services in yacht charteringing via digital channels. 

These Rules apply to the Web Site of Aktivplan 3D d.o.o. (hereinafter referred to as the "Web Site") and explain how the company works with your personal information (as defined below) from online sources and communications (via the Web Site, Emails and using other on-line tools).

These Rules do NOT apply to personal data collected in an off-line environment (except in the case of linking personal data collected in the on-line and off-line environment, see below in Chapter 9); as well as on the websites of third parties not controlled by Aktiv Plan 3D d.o.o. (if these web sites are accessible through the Web Site link to which these Rules apply).

These Rules and Terms of Use on the Web Site govern your access to and use of the Web Site.

1. What is "personal information"? 

"Personal Information" means any information that reveals the identity of a Web Site User, or may be used to identify a Web Site user, and is provided and / or collected from the online sources and communication of Aktivplan 3D d.o.o.: through the Web Site, by e-mail and by using other on-line tools.

• Personal information is, for example, your name and surname, address, e-mail address, phone number or other information that can be used to identify your identity. 
To protect your privacy, you can use the Web Site without giving any personal information.

2. Legal basis for the processing of personal data

We process personal data only when there is a valid legal basis for such processing, namely:
• with your previously obtained processing consent for a particular purpose (Article 6.1, item (a) of the General Regulation);
• if the processing is necessary for undertaking pre-contractual transactions, concluding and executing contracts with you (Article 6.1, item (b) of the General Regulation);
• If processing is necessary because of our obligation to comply with legal or statutory obligations (Article 6.1 (c) of the General Regulation);
• If processing is necessary to protect your key interests (or interests of another person) (Article 6.1, item (d) of the General Regulation);
• If processing is necessary for our legitimate interests (or legitimate interests of third parties), unless your interests, fundamental rights and freedoms are stronger than our legitimate interests (Article 6.1, paragraph (f) of the General Regulation). Our legitimate interest is considered to be the performance of all activities in the domain of regular business of Aktivplan 3D d.o.o.

3. The purpose of data processing

Providing personal data via the Web Site may be necessary for various purposes, for example:
• To answer your questions or requests,
• For information on our activities or services (e.g. by sending newsletters, promotional and non-promotional notices and announcements, invitations etc.),
• For the sake of understanding your interests and needs and ensuring effective customer support,
• Perform statistical analysis of your activity data while using the Web Site,
• if applicable, in order to execute your inquiries and / or contracts with Aktivplan 3D d.o.o.

Without your personal information, some of the foregoing purposes will not be possible.
Denial of third parties for the purposes of direct marketing: Your personal data will not be sold or transmitted to third parties for the purposes of direct marketing without prior notice to you and without your express consent to the described use of the data.
Send a message to a friend or colleague: On some of our web pages that can be accessed through the Web Site to which this Policy applies, users are offered a link option or message to a friend or colleague which then refers them to the Web Site. The emails of your friends that you specify on this occasion will be used for the purpose of sending notice to the person concerned, on your behalf and this information will not be used for any other purpose by Aktiv Plan 3D d.o.o. 

Google Analytics: The Web Site to which this Policy applies may use Google Analytics - the analysis service provided by Google Inc. (hereinafter referred to as "Google"). Google Analytics uses "cookies" - small text files that are automatically placed on a user's computer hard disk - for the purpose of analyzing user behaviour. Data collected through "cookies" about the use of a website (including the user's IP address) is transmitted and stored by Google to servers located in the United States. Google will use the collected data to evaluate the use of the Site, compile site activity reports for the needs of the site operator, and provide other services related to the use of the website and, in general, the use of the Internet. Google may also transfer this information to third parties when it is legally prescribed or when the third parties concerned process data on Google's behalf. Google will not associate the user's IP address with any other data Google collects. You can oppose the use of "cookies" by selecting the appropriate settings on your browser (note that this may affect the full functionality of this Web Site).

4. Methods of collecting personal data

We collect personal information online in, in general, two (2) ways:

1. Immediately from the Web Site User, voluntarily provided by the user, by means of those types of personal data that are identifiable to the user and which are requested in the appropriate forms or fields foreseen for this purpose on the Web Site.

Collective data. In certain cases, we remove the data that allows us to identify the user, and we keep this information in aggregate form. This data can be combined with other data for the purpose of creating anonymous, unified statistical data (e.g. number of visitors, source domains of a particular Internet Service Provider) collected for the purpose of evaluating and improving the Web Site and our services.

2. Automatic collection of certain types of data by Aktivplan 3D d.o.o. or third parties, our subcontractors that are generated whenever users visit the Web Site and when exchanging e-mails. Technologies that can be used are, for example, server logs / IP addresses, cookies, Web Beacon, and third-party application management and content management tools. For more information on automated data collection and technologies, please refer to chapter 6. 

5. Your choice

You have several options available by deciding on how to use the Web Site:
• You may use the Web Site if you choose not to provide your personal information by not entering it in the provided templates or fields on the Web Site, when you do not want to use the available individualized service. 
• You may decide that you will provide your personal information, in which case you have the rights listed below in chapter 17. 
• Certain parts of the Web Site may require your consent for a particular purpose of using the personal information you are free to give or deny. If you are granted access to special services or communications, such as receiving e-newsletters, you will be able to withdraw your consent at any time and unsubscribe from the list of recipients, according to the instructions that will be contained in each communication. In the latter case, we will endeavor to act promptly in accordance with your request, so that we may request additional information from the user before processing the request. 
• If you want to prevent anonymous recognition of your activities on the Web Site by using cookies, you can set your browser to reject all cookies or warn you that the cookie was sent (for details, please see chapters 6 and 7 below).

6. Automatic data collection

  • When you visit the Web Site, the server log records various information, such as your browser type, operating system, IP address, URL (web address) that you you visited before and after the Web Site visit, the search engines that led you to the Web Site and the ads you viewed as links that you used on the Web Site.
  • Relative data are collected automatically without your active participation in the delivery of such data.
  • The above data can be collected by various technologies. Your web browser also automatically transfers to the Web Site some of this information, such as the URL of the website you have just visited and the version information of the browser that your computer uses.
  • Web beacons, cookies, and other technologies for tracking and analyzing user behavior patterns do not generate automatic personal information that identifies the user. Only if the user voluntarily provides personal identification data - for example, by registering to or sending e-mails - the automated tracking technology may also be used to gain further information about using Web Sites and / or interactive e-mails to improve user experience.
  • Generally, automated data collection technologies make it easier to use the Web Site and Aktivplan 3D d.o.o. can provide a better service, customize its Web Site to user preferences, collect statistics, analyze trends, and otherwise edit and improve content on the Web Site. 
  • Some Web Site features may not be available without using the automatic data collection technology.

Server logs / IP addresses: An IP address is the number that is assigned to the computer whenever you access the Internet. Identification of personal computers on the Internet is done through IP addresses that allow computers and servers to recognize and communicate with each other. Aktivplan 3D d.o.o. collects IP addresses for administrative management of the system and for statistical analysis and monitoring of Web site functions.
Web beacon: On the Web Site or in Emails, Aktivplan 3D d.o.o. can use Internet technology called Web beacon (also known as "action tag") or "pure GIF techology". Web beacon is a tool used in website performance analysis for example, by measuring the number of site visitors or the number of visitors who visited certain key settings on the Web Site.

7. Using Cookies

• Cookie is a file that your server sends to your computer whenever you access the Web Site,

• This file is automatically saved to your computer's disk and uniquely recognizes visitors on the page,

• Cookies allow us to store data on the server to improve your user experience, for the purpose of analyzing the use of the Web Site and monitoring its functionality.

• Most Internet browsers are set to receive cookies, so you can also control cookies independently by setting your browser by rejecting all cookies or notifying you when a cookie is sent. However, we turn your attention to the fact that certain parts of the Web Site may not function properly if blocking cookies is blocked.

8. Security

Aktivplan 3D d.o.o. uses technological and security measures, rules, and other procedures to protect your personal information from unauthorized access, misuse, disclosure, loss or destruction.

To protect the confidentiality of your personal information, we use industry-standard security measures, such as firewalls or password protection. However, the confidentiality of personal data transmitted over the Internet can not be guaranteed. So we warn you that you always be careful when transferring your personal information to the Internet. In accordance with the stated when you provide personal information to the Web Site, you must assess the benefits and risks yourself.

Each user is solely responsible for the appropriate security and protection of the computer that uses malicious software such as trojans, computer viruses, and worms. You are aware that without adequate security measures (for example, secure Internet browser configuration, updated antivirus programs, personal firewall programs, avoiding the use of programs from suspicious sources) there is a risk that the data and passwords you use to prevent access to personal information may be detected by unauthorized third parties. 

9. Linking personal information you provide via Web Site to other personal information

• Aktivplan 3D d.o.o. can link and merge your personal information with the purpose of improving the quality of the Web Site and its services, enhancing our marketing and research activities as well as improving other business activities.
• Aktivplan 3D d.o.o. can link personal information you have provided online with your personal information collected off-line,
• Aktivplan 3D d.o.o. may link personal information you have provided to it directly with your personal information contained in third-party records.

10. Sharing and transferring personal data

10.1. Within Aktivplan 3D d.o.o.

Limited number of our employees may have the right to access your personal information. Our employees are trained on the importance of data privacy and on the ways of proper and safe handling and user data management.

10.2. Out of Aktivplan 3D d.o.o.

We may exchange your personal information with the following recipients:
• suppliers of services for Aktivplan 3D d.o.o. who perform the tasks necessary for the technological development and maintenance of the Web Site, providing customer support, sending promotional and non-promotional communications about our services etc. Aktivplan 3D d.o.o. maintains control of the use of this information and obliges suppliers to maintain confidentiality and act in accordance with applicable personal data protection laws and our special rules on processing of personal data; 
• potential acquirers in connection with the sale, transfer or other acquisition of a Web Site related business through which personal data is collected;
• competent state bodies and courts, based on their legitimate orders and whenever required by compulsory regulations;
• third parties participating in the process of implementing our corporate audits, testing and responding to any complaints or security threats.

10.3. Transfer data to other countries

• Some personal data may be stored or processed on computers in countries outside the European Economic Area (EGP), including in the United States, which do not offer the same level of protection required by the EGP.
• In Aktivplan 3D d.o.o. any international transfers of personal data will be made only with the application of appropriate safeguards (for example, using standard contractual clauses approved in the European Union, engaging US executives with a "Privacy Policy" certificate, etc.) for the purpose of ensuring that the executor (s) in such states ensure the level of protection of personal data in accordance with the standards applicable in EGP and in Croatia. If you want to know more about the circumstances surrounding the disclosure of your EGP data (if any) or if you want to obtain a copy of the protection measures, contact our Personal Data Protection Officer (details below).

11. Links to other web sites

The Web Site to which this Policy applies may contain links to other websites that may provide useful information to Web Site users. These Rules do not apply to these web sites and Aktivplan 3D d.o.o. does not respond to the privacy policy contained in these sites or to the content of these web sites, so we recommend that you review the privacy policies that apply to those sites. 

12. Protection of juvenile delinquency

The Web Site to which this Policy applies is intended for adults. We do not collect knowingly personal information about minors (defined as persons under the age of 18) without the prior, verifiable consent of her / his legal representative. The Appellate Legal Representative has the right, at his own request, to review the information provided by a minor and / or request the deletion of such information.

13. Notification to users of business or professional Web Site parts
If you are our business partner or if you provide us with your professional data through the Web Site, the information you provide us can be used to answer your questions and maintain business relationships (with you or any legal entities that you may represent). We may also exchange such personal information with third parties acting on your orders.

14. Additional Information on Personal Data Protection

If the Web Site contains certain provisions relating to the protection of personal data other than those contained in these Rules, the relevant additional provisions will be displayed on the page on which your personal information is collected.

15. Rules Update

• Aktiv Plan 3D d.o.o. reserves the right to occasional changes to these Rules without prior notice, with the purpose of monitoring technological progress and when changes are made to legislative or regulatory changes as well as for compliance with good business practices.
• We will notify you about any such changes by entering the date of the latest amendment to the Rules at the beginning of the Rules.


16. Maintenance Period

Your personal information will be kept as long as necessary to meet the purpose for which they are collected or in accordance with all statutory deadlines and requirements.

17. Your rights

With the use of restrictions that may be based on applicable laws, you always have the following rights:
• the right of rectification or the right to erase all your incorrect or incomplete personal data;
• the right to submit at any time the request for exclusion from the mailing list of the recipient of any promotional material. This will be listed at the bottom of every e-mail you receive from us;
• the right to receive information on the processing of your personal data, including the right to access personal data provided to Aktivplan 3D d.o.o .;
• In some cases, the right to object to the processing of your personal data for justified reasons;
• The right not to be affected by decisions based solely on automated data processing with the purpose of assessing certain personal aspects related to you, such as behavioral analytical data. In the section of  Cookie Policy, you can read more information about exercising that right if cookies are indicated;
• If personal data processing is based on your privacy or processing is necessary for the performance of the contract, you are entitled to transfer these personal data to another person or, if technically feasible for us, to another company;
• the right to file a complaint with the national data protection supervisory body; and
• the right to withdraw a person to process your personal information without any consequences.

All your questions and requirements regarding the exercise of these rights are to be sent via the Contact menu on the Web Site you visited or by submitting an application to our personal data protection officer to the contact provided at the top of these Rules.