This Statement on the Protection of Personal Data that applies to M123 UPRAVLJANJE d.o.o., Zagreb, Radnička cesta 50, OIB 24735765698 takes effect on May 25, 2018. M123 UPRAVLJANJE d.o.o. shall treat your personal data in compliance with Regulation (EU) 2016/679 of the European Parliament on the protection of natural persons with regard to the processing of personal data and to the free movement of such data, as well as to the provisions of national laws that regulate personal data protection, implementing appropriate technical and security measures to protect personal data from unauthorized access, misuse, disclosure, loss or destruction.

1. Basic Data

This Statement indicates the types of data we collect, the manner in which these data are being processed, and the purpose to which they are used, as well as the rights regarding your personal data.

Data Controller: M123 UPRAVLJANJE d.o.o.

Data Protection Officer may be contacted via: e-mail

Contact form:

Contact e-mail address:

Should we use the external providers’ services for processing of your personal data, this shall refer to personal data processing upon request, whereby we also assume liability for the protection of your personal data.

2. Personal Data Categories That We Process

We process and use the personal data that refer to:

  • employees; employees' children and spouse,
  • outworkers,
  • corporate businesses,
  • contractual customers.

Within the scope of this business relationship you are obliged to make available personal data that are exigent for establishment and realization of this relationship, as well as for fulfilment of related contractual obligations; or again the data that we may have a legal obligation to collect. Without these data we shall be forced to decline conclusion of contract or execution of the order, as well as to suspend its implementation and terminate the existing contract. You are not obliged to give your consent to processing of data which are not relevant or prescribed by law in performance of a contract.

3. Legal Basis and the Purposes of Processing Personal Data

We process data based on:

  1. Legal obligations. We process your personal data in compliance with the rules in force, as well as for the purpose of notifying and reporting that we are under an obligation to perform, conforming to the said rules in force.
  2. Contract execution – we process personal data for the purpose of contract execution and fulfilment of the contractual obligations that were agreed upon.
  3. The consents you gave us for the purpose of your personal data processing.
  4. Legitimate interests.

4. Period of Data Storage

Personal data are retained, archived and extracted for the time period which is in compliance with legal and other regulations or decisions or with General Data Protection Regulation of the data processor. On principle, we delete your personal data upon expiry of all legal obligations regarding the keeping of personal data.

5. Consent Management

You can withdraw your contact consent at any time. Likewise, you can lodge a complaint to our processing of your personal data at any time. Alteration of consent can be executed through written application form addressed to: M123 upravljanje d.o.o., Zagreb, Radnička cesta 50 or via e-mail address:

If you revoke the given consent, it shall no longer be used for the above-mentioned purposes.

Should you again wish to give your consent, please feel free to do it at any moment.

In case we process your personal data which do not require your consent but are vital for either concluding a contract with us or for fulfilment of the concluded contract, or again for the purposes of our legal obligations, and you do not submit these data, we shall not be able to fulfil our contractual obligations towards you nor to conclude a contract with you.

Withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

6. User Rights

  1. Right of Access to information, including the information on personal data processing, that is, the subject's right to know whether their personal data are being processed by the controller or not.
  2. Right to Rectification: If we process your personal data that are incomplete or inaccurate, you can request that we correct or complete the data at any time.
  3. Right to Erasure: You may obtain erasure of your personal data if we have processed them unlawfully or if the processing presents disproportionate infringement of your protected interests. Please bear in mind that there are reasons which render momentary erasure impossible, e.g. statutory requirements for archiving.
  4. Right to Restriction of Processing: You may obtain restriction of processing your data from the controller if one of the following applies: • if you contest the accuracy of the personal data for a period enabling us to verify the accuracy of these data • if the processing is unlawful, but you decline the erasure, and instead request restricted use of data; • if we no longer need your personal data for the intended purposes, but you need them for the purpose of exercising legal claims, or • if you have lodged a complaint concerning the processing of these data.
  5. Right to Data Portability: You can request that we send you the data you have entrusted us with for archiving purposes in a structured, commonly used and machine-readable format: • if we process these data based on consent you gave us and are free to revoke, or the data based on the purpose of our contract fulfilment, and • if the processing is carried out by automated means.
  6. Right to object: If we distribute your data to the end of performing tasks of public interest, or of the tasks performed by public bodies, or in the processing of these data we claim our legitimate interests, you may file a complaint against such data processing should protection of your data be in your interest.
  7. Right to Object to Competent Authority: If you consider that the processing of your personal data infringes the Croatian or European directives on data protection, please contact us, we shall readily clear out any issues. You have the absolute right to lodge a complaint with Croatian Personal Data Protection Agency or, in case of change of regulations that are now in effect, to some other body taking over the Agency's competence and, as of May 25, 2018, to the supervisory authority within European Union, too.
  8. Exercising Rights: If you wish to exercise any of the above specified rights, contact us using our contact information in point 1 of this Statement.
  9. Identity Verification: In case of doubt we can request additional information for the purpose of your identity verification. This serves to protect your rights and your private domain.
  10. Misuse of Rights: Should you use some of the specified rights too often and with manifest intention of misuse, we may charge administrative fee or refuse to process your request.

7. Transfer of Personal Data to Third Countries

Transfer of personal data to third countries (the countries outside European Union) is done only:

  • in case of legal obligation,
  • if the subject has given an explicit consent to data transfer.

8. Data Transfer to Third Parties

We assume an obligation to keep your personal data, and not to reveal nor make accessible these data to third parties, except in the following cases:

  • if you, expressly in written form, give consent that some of the confidential data be communicated for a specific purpose or to a specific person,
  • upon written request of the court or public notary, if the data are required in performing the tasks conferred to them by the law (e.g. implementation of enforcement, insolvency, succession or property dispute proceedings),
  • if the data are required by the Ministry of the Interior or by a competent state attorney’s office for the purposes of performing tasks within their competence,
  • if the data are required for use by the court, attorneys or public notaries for the proceedings they are involved in, in which case the data are to be submitted in written form,
  • if the data are required by the Social Welfare Centre, in the framework of their statutory powers,
  • if the data are required by the Ministry of Finance, as well as Tax and Custom authorities, Pension Insurance Institute and Health Insurance Fund, for the proceedings within framework of their competence,
  • if we are under an obligation to send data to the Ministry of the Sea, Transport and Infrastructure,
  • if the data are required for implementation of contractual obligations towards you, as well as for implementation of our legal regulation,
  • in other cases that are prescribed by law.

9. Technical and Organizational Measures

We have taken all the technical and organizational measures in order to protect your data from loss, alteration, or access by a third party, and you are welcome to contact us should you have any questions; we shall readily and as soon as possible respond to your requests, inquiries or uncertainties, and assist you in exercising your rights.

Any kind of alteration regarding our policy of personal data protection shall be published in the Statement on the personal data protection on our webpages, of which publication you shall be duly notified.

10. Personal Data on Website

We collect only the personal data which the visitors of our official webpage voluntarily make available by way of requesting contact, applying for a job, using call-back service, and filling the complaint form. These personal data are used in a confidential manner and strictly for specific purpose.

These personal data shall not be transferred to third parties, except in case of legal obligation or a request from an official body, at which time the data can be proceeded to the competent authority. Access to webpages is subject to a protocolized approach, whereby technical data such as visiting rate of our page, the data on the operational system used in this process, the screen resolution, the time of visit and the size of transferred data are recorded.

For the purposes of enhancing your experience, the webpages can contain “cookies”, which are downloaded on the webpage visitor’s computer. “Cookies” may also be prevented from being placed which, however, entails a limited website offer, too. “Cookies” enable storing of website visitors’ distinctive preferences, as well as optimizing the technical processes and continual improvement of our offer.