Privacy and Personal Data Protection Policy

This information is provided, by Articles 13 and 14 of EU Regulation 679/2016 (hereinafter, "Regulation"), for users (hereinafter: "Users" or "User") of the site in the desktop and mobile versions and applications Nekretnine.hr, (hereinafter: "Site and App ") owned by Immobiliare.it S.p.A., and whose management and marketing in Croatia has been assigned to Indomio d.o.o., owner of the processing of personal data (hereinafter, "Owner") and is intended to describe the methods of management of the Site and App regarding the processing of personal data, as well as to allow the Users of the Site and App to know the purposes and methods of processing of personal data by the Owner in the event of their conferment.

As specified in General Terms and Conditions the services offered by the Holder are aimed at people older than 18 years. Should Holder become aware of the data processing of people under 18 years without a valid parental or legal guardian consent, he reserves the right to unilaterally interrupt the use of the service offered as well as to cancel the acquired data.

Terms that are not defined in this personal data protection disclosure have the same meaning as described in General Terms and Conditions.

Users who publish real estate ads undertake to comply with the General Conditions and Terms of Service, also with regard to the protection of personal data. Users assume responsibility for any communication and publication of third-party data, guaranteeing that they have full right to communicate them. The Owner is free from any liability towards third parties, deriving from the illegitimate use of their data.

Applicable principles to the Personal Data Treatment  Back to top

The Holder, pursuant to and for the purposes of the Regulation, informs that the aforementioned legislation provides for the protection of individuals with regard to the personal data processing, and that this treatment will be based on the principles of correctness, lawfulness, transparency and protection of the confidentiality and fundamental rights.

Type of users  Back to top

In relation to the use of the Site and App, the following types of Users are distinguished:

Simple Users can access some services (e.g. search for properties) anonymously, while for other services (such as posting a listing or receiving updates automatically) it is necessary to register before using.

Professional Users, after signing a Service Contract, have access to certain services intended for them.

Purpose, legal basis of the Treatment and Optional Submittal  Back to top

The personal data provided by Users through the use of the Site and App, will be processed with their consent, for the purposes described below:

  1. Service supply for Simple Users:
    1. In order to provide certain services such as saving listings, saving a search and receiving information on new listings automatically, the User must register through the Site and App. The data necessary for the Registration are limited to the provision of:
      • Name
      • Surname
      • Email address
      • Phone number
    2. The User, by accessing his personal section present on the Site and App (hereinafter "User Profile"), may provide additional personal data as additional information (eg date of birth, gender, residence) that will be collected by the Holder if provided.
  2. Supply of services of Contact Advertisers and Research Forwarding:
    1. To enable Advertisers to provide the User with the information they require regarding the properties, the Advertisers Contact service allows the User to forward its personal data to real estate agencies, construction companies, other companies and real estate professionals and private users who advertise real estate listings.
    2. In order to simplify Users in their real estate search, the Search Forwarding service allows to forward the searches made by the User to real estate agencies and other competent companies and professionals in the search area.
  3. Information, promotional and profiling activities:

    In order to allow the User to get sector information such as news and curiosities, as well as advertising information, the User can join the information, promotional and profiling Activities service to receive informational, promotional and marketing communications on the basis, in some cases, of the activity done on the Site and App.

    It is possible to cancel anytime the registration to the aforementioned communications, by deselecting the following items, present on the Profile page of each Simple User:

    • "I would like to receive information and promotional notices"
    • "I would like to receive the Nekretnine.hr News newsletter"

    The Holder will thus be able to make activities of analysis on the interests, habits and choices of Users, also in order to be able to send them customized promotional material on the services offered.

  4. Service provision for Professional Users:

    In order to allow professional operators to qualify themselves as Professional Users, subject to the stipulation of a Services Contract with the Holder, it is necessary for the operator to provide the personal data indicated below, to be contacted in order to know the services dedicated to professionals:

    • Name
    • Surname
    • Company name
    • Municipality
    • Email address
    • Phone number

    The processing of data for the purposes mentioned in the points A to E finds its legal basis in the art. 6 (a) of the Regulation ([…] the interested party has given consent to the processing of its personal data for one or more specific purposes).

    In the case mentioned in the letter A (II), the non-conferral will not compromise the supply of the service provided for therein.

    In particular, in the hypothesis of the letter A (I) the failure to provide the data necessary for the registration of the User, will determine the impossibility to provide the services mentioned in the subsequent letters B, C and D.

Methods of Processing and Storage of Personal Data  Back to top

The Holder ensures that personal data are processed in full compliance with the Regulation, using manual, IT or telematic systems. Processing can also be carried out using automated tools to store, manage and transmit the data.
The data collected and processed will be protected with physical and logical methods in order to minimize the risks of unauthorized access, diffusion, loss and destruction of data, pursuant to art. 25 and 32 of the Regulation.

The processing of data will last no longer than is necessary to meet the purposes for which they've been collected, such as the storage of search criteria, notification, publication of listings and contact of professional operators.

According to the art. 7 paragraph 3 of the Regulation, the interested party has the right to obtain at any time the revocation of the consent to the processing. To request the deletion of its personal data, the interested party can send a request to the email address korisnici@nekretnine.hr

If no deletion request is received by the Holder, the personal data will be stored for a period not exceeding 10 (ten) years, with effect from the date of the last access to the Site and/or App by the User.

Recipients of Personal Data  Back to top

The personal data collected may be processed by subjects or categories of subjects acting as data processing Managers pursuant to art. 28 of the Regulation or that are authorized to process the data pursuant to art. 29 of the Regulation.

Furthermore, for some services, the data may be communicated to companies that collaborate or use the services of the Holder (for example individual proponents for information about properties; banks or credit intermediaries for the provision of mortgages and loans and other financial services related to the sale of a property), with the sole intention of providing the services requested by the User. In these cases the companies are autonomous holders, therefore the Holder is not responsible for the processing of the data by them. Furthermore, the Holder is not responsible for the contents and compliance with the legislation on personal data protection by sites not managed by the Holder.

Apart from the aforementioned hypotheses, personal data will not be communicated except to subjects, entities and Authorities to whom communication is obligatory pursuant to laws or regulations.

Transfer of Data to a Third Country or to an International Organization  Back to top

The personal data collected through the Site and App, may be transferred outside the national territory, only and exclusively for the execution of the services requested through the Site and App and in compliance with the specific provisions of the Regulation.

Some personal data may be shared with recipients located outside the European Economic Area. The Holder ensures that the processing of personal data by these recipients takes place in compliance with the Regulation.

Browsing Data Collection  Back to top

The IT systems and the technical and software procedures underlying the operation of the Site and App acquire, during their normal exercise, some personal data whose transmission is implicit in the access and operation mechanisms and protocols in use on Internet.

Every time the User connects to the Site and App and every time he recalls or requests a content, the access data are stored in our systems, in the form of tabular or linear data files.

This category of data includes, for example, IP addresses, domain names of computers used by users who connect to the Site and App, the request by the User's browser, in the form of URI (Uniform Resource Identifier) notation addresses, the date and time of the request to the server, the method used in submitting the request to the server, the amount of data transmitted, the numeric code indicating the status of the response given by the server and other parameters relating to the operating system and to the IT environment of the User.

This data may be used by the Holder for the sole purpose of obtaining anonymous statistical information regarding the use of the Site and App in order to identify the Users' favorite pages and therefore provide more adequate contents and to check the correct functioning. Upon request of the Authority, the data could be used to determine responsibility in case of hypothetical computer crimes against the Site and App or its Users.

Information about Cookies, Search Engines and Position Data  Back to top

Cookies are aimed at speeding up the analysis of Internet traffic, making easier for Users to access the services offered by the Site and App and providing useful and relevant advertising to visitors. With the use of cookies, no personal data are transmitted or acquired and no user tracking systems are used. If the User do not want the information provided by him to be collected through the use of cookies, he can implement a simple procedure present in his browser that allows to refuse the function of cookies.

The information relating to the real estate proposals entered on the Site and App will be visible in the searches done in the internal search engine and could be made available to third party search engines as Site and App allow the indexing of their contents by third-party engines.

In the event that the listing page has already been removed from Site and App, it is possible that the cache copy remains in the search results for a few days. The search results are not managed by Site and App, but the user can report the removal of the page and request the update of the cache copy directly to the search engine.

When using the Site and App with the active position detection function, the Site and App may collect and process information on the User's current position. This data are processed anonymously, in a format that does not allow to identify the User personally, and are used only to facilitate the use of some Site and App Location-based functions. Location services can be activated or deactivated by the User at any time by accessing the settings of your device.

For more information, please read the page Use of Cookies.

Rights of the data subject  Back to top

In particular, in the hypothesis of the letter A (I) the failure to provide the data necessary for the registration of the User, will determine the impossibility to provide the services mentioned in the subsequent letters B, C and D.

  1. confirmation of the existence or not of personal data concerning him, even if not yet recorded, in a concise, transparent, intelligible and easily accessible form, with simple and clear language;
  2. the indication:
    1. of the origin of the personal data;
    2. of the purposes and methods of treatment;
    3. of the legitimate interests pursued by the Holder or third parties;
    4. of any recipients or categories of recipients of the personal data;
    5. any intention of the holder to transfer personal data to a third country or an international organization;
    6. of the period of storage of personal data;
    7. of the logic applied, as well as the importance and the expected consequences of this treatment for the person concerned, in the case of processing carried out with the aid of electronic tools in the context of an automatic process of collection and/or profiling;
    8. of the identification data concerning the Holder, Data Supervisors, any designated Representative and the Data Protection Officer (so called DPO);
    9. the subjects and categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or appointees;
  3. the possibility of proposing a complaint to a supervisory Authority;
  4. the updating, rectification or, when interested, integration of the data;
  5. the deletion, transformation into anonymous form or blocking of data processed in violation of the law, including those whose storage is not necessary in relation to the purposes for which the data have been collected or subsequently processed;
  6. the limitation to the processing;
  7. the portability of personal data concerning him to another Data Holder;
  8. revocation of the processing;
  9. the attestation that the operations mentioned in the letters a) and b) have been brought to the attention, even with regard to their content, of those to whom the data have been communicated or diffused, except in the case where such fulfillment proves impossible or involves a manifestly disproportionate use of resources with respect to the protected right;
  10. the opposition, in whole or in part, for legitimate reasons, to the processing of the personal data concerning him, even if pertinent to the purpose of the collection.

Data Treatment Holder and Data Protection Officer  Back to top

To exercise the rights in the previous point, the concerned person may at any time contact the Holder and/or the Data Protection Officer for any communications regarding the processing of his Personal Data, or to know the updated list of any Data Processors appointed by the Company, by sending notice to the following contacts:

The Data Controller:
Indomio d.o.o.
Ulica grada Vukovara 284, Zagreb
info@nekretnine.hr

Processing of personal data of job applicants  Back to top

The Data Controller ensures that the personal data of candidates participating in the selection process is processed in accordance with the provisions of the General Data Protection Regulation (GDPR), the GDPR Implementing Act, and other applicable data protection regulations. If you would like to join our team, please read the following information.

1. Who collects and processes your personal data?

The personal data you provide us during the recruitment process are collected and processed by the data controller: Indomio doo, Ulica grada Vukovara 284, Zagreb info@nekretnine.hr.

2. Legal basis for the processing of personal data and purposes for which personal data are used

We process your personal data for recruitment purposes, as part of your job application or a speculative application for a specific position.

  • If you have applied for a published vacancy: We process your personal data for the purpose of verifying whether you meet the requirements for the position and making a hiring decision.
    • The legal basis for this processing is the performance of a contract to which you are party or the implementation of pre-contractual measures taken at your request. The processing of your personal data is necessary for the performance of the aforementioned procedure.
    • In the event that an employment contract is not stipulated with you, your personal data will be retained for 1 (one) month from the end of the competition, after which they will be permanently deleted.
  • Exceptionally, if you wish us to retain your personal data for a longer period, your personal data will be processed based on your consent. In this case, your personal data will be retained for a period of 12 (twelve) months from the date of consent, unless consent is withdrawn before the expiration of that period.
  • If you have applied for an open position: We process your personal data to assess your qualifications for a potential vacancy, for future recruitment purposes, and to make hiring decisions. The legal basis for this processing is your consent. The processing of your personal data is necessary to achieve the stated purpose. Personal data is retained for 12 (twelve) months from the date of consent, unless consent is revoked before the expiration of that period.

3. What personal data are processed?

The personal data we process includes:

  • identification data (e.g. name and surname, date of birth)
  • Contact information (e.g., email address, phone number, LinkedIn profile, if you have made it available)
  • information contained in your resume (e.g., education level, work experience, licenses and certifications, and other information you have listed on your resume)
  • photos of candidates who voluntarily send them as part of their CV

4. Who has access to your personal data?

Your personal data may be accessed by our employees who conduct the recruitment process, as well as by other individuals or categories of recipients pursuant to Article 28 of the General Data Protection Regulation (GDPR). Your personal data may also be accessed by authorized individuals and employees of the affiliated company LEAD GENERATION INFORMATICS AND INTERNET SERVICES SOCIETE ANONYME, which is the founding company of the data controller.

5. Where your personal data will be processed and transferred to third countries

Your personal data will be processed within the European Economic Area (EEA).

If it becomes necessary to transfer your personal data outside this area, personal data will be transferred to recipients in third countries only if the European Commission issues an adequacy decision establishing that the country in question ensures an adequate level of protection for personal data in accordance with the General Data Protection Regulation (GDPR), or if appropriate safeguards, such as standard contractual clauses, are provided.

6. Duration of storage of personal data

In accordance with the principle of storage limitation, your personal data will be retained only for the time necessary to achieve the purposes for which they were processed. The retention period for your personal data depends on the purpose for which they were collected and the duration of the individual selection process for the specific position for which you applied, or until you withdraw your consent, if the processing is based on your consent. Without prejudice to the foregoing, your personal data will not be retained for a period longer than that indicated in point 2.

Exceptionally, longer retention periods may be established if the personal data is necessary for the establishment, exercise or defense of legal claims or due to the existence of statutory retention obligations, in accordance with the provisions of the General Regulation and other relevant regulations.

7. Obligation to provide data

The personal information you provide us when submitting an application, CV, or unsolicited job application is necessary for us to assess whether you meet the requirements for the position you are applying for.

If you refuse to provide the personal data required for employment in a specific position or fail to provide such data to the extent necessary to assess your suitability for the position, we will not be able to consider your application and/or open an application process and, consequently, we will not be able to enter into a contract with you.

8. Your rights as a data subject

Regarding the processing of your personal data, you have the following rights:

  • right of access to personal data
  • the right to rectify inaccurate personal data and to complete incomplete data
  • the right to erasure of personal data ("right to be forgotten")
  • the right to limit the processing of personal data
  • right to object to the processing of personal data
  • right to portability of personal data
  • the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal (where the processing is based on this legal basis).
  • the right to lodge a complaint with the supervisory authority, the Agency for Personal Data Protection (AZOP), if you believe that the processing of your data violates the provisions of the General Regulation and the rules on personal data protection (www.azop.hr)

To exercise all other rights relating to the processing of personal data, you can contact the Data Controller using the contact details provided in point 1.

9. Automated decision-making/Profiling

During the recruitment process, we may perform a certain form of profiling of candidates to assess their skills and suitability for a specific job position. This profiling does not constitute automated decision-making within the meaning of Article 22, paragraphs 1 and 4, of the General Data Protection Regulation and does not produce legal effects that significantly affect you without human intervention.

Profiling is based on the information provided in the job application, CV, spontaneous applications, or during a job interview and is used exclusively for the candidate selection process.

Changes  Back to top

This Policy may be subject to amendments. Whenever substantial changes to the use of the data relating to the User should be made by Nekretnine.hr, the latter will notify the User by publishing them with the utmost clarity on its pages.

Date of last update:
4 November 2024