How we process your personal data?

PRIVACY POLICY

Avant Car (hereinafter referred to as Avant Car or data controller) is aware of the importance of your privacy, which is why we are committed to protecting the confidentiality of personal data of our customers. We assure you that your personal data, captured on our webpages or through doing business with you, will be collected, processed, protected and stored in compliance with the applicable legislation.

The purpose of this document is to inform you of our Privacy Policy and the possibilities you have in choosing the method of how your data are collected and used.

This Privacy Policy is available at the bottom of each Avant car webpage (https://avant2go.hr and https://www.avantcar.hr and their subpages) and in each Avant car mobile applications.

1. DATA CONTROLLER

The controller of your data is Avant Car d.o.o., Savska Opatovina 36, 10000 Zagreb, email address gdpr@avantcar.hr, and phone number 01 6251 227.

2. DATA PROTECTION OFFICER

Our data protection officer can be reached at the email address: gdpr@avantcar.hr, through which you can address your questions, requests and comments, related to processsing of your personal data. Strict confidentiality shall apply to all topics and contents.

2. PURPOSES OF DATA PROCESSING

We process your personal data in cases where: you visit one of our websites, contact us via an online form or other means of communication, sign up for electronic newsletters, wish to use or are a user of one of our services (Avant2Go, Avant2Go Delivery, Rent-a -car, Fleet management, Charge by Avant car), participate in our online surveys or marketing campaigns, participate in our prize games or apply for a job with us on your own initiative.

In the rest of the chapter, we provide you with more information related to processing.

3.1. VISIT OF THE WEBSITE OR MOBILE APPLICATION

We record every visit to one of our websites in order to detect errors and monitor attacks. The data we process and store for a short time are: your IP address, the URL address of the website from which you accessed our website, browser settings and information about the operating system of your computer or mobile device, the content you access on the Avant car website or mobile application, the date of access and the duration of the visit to the Avant car website or application. If our system determines that you are not carrying out any activities that would endanger the operation of our website / application, the data is automatically deleted. In the event that our system determines that you are carrying out activities that are clearly illegal or aimed at disabling the functioning of the website / application, your IP address is stored permanently and our system places it on the black list of IP addresses ("black list"), disabling your further use of the website / application.

Legal basis for the processing of personal data: our own legitimate interest (Article 6/1(f) of the General Regulation on the Protection of Personal Data), which is in monitoring and analyzing the operation of online and mobile applications, technical maintenance and development of Avant car websites and services, ensuring the operation of information systems, network and information security (prevention of events, illegal or malicious actions that threaten the accessibility, authenticity, integrity and confidentiality of stored or transferred personal data and the security of related IT services), prevention of unauthorized access to information systems and responding to computer security threats and incidents.

Retention period: until the end of the session at the latest (general rule) or permanently (for cases of attempted abuse).

Individual rights: objection, access to data, correction, restriction of processing. If you believe that we are not exercising your rights adequately, you can file a complaint with the Croatian national supervisory authority for the protection of personal data. You can read more about your rights in the chapter Your rights.

3.2. SUBSCRIBE TO THE SENDING OF ELECTRONIC NEWSLETTERS

You can subscribe to receive up-to-date notifications and information about our promotions and news on our website or by replying to a received email. We will process your (identification and contact) personal data, namely name, surname and e-mail address for the purpose of direct marketing or for sending periodic notifications of new products from our offer. The legal basis for the processing of your data is your personal consent according to point 6/1(a) GDPR. We will keep personal data until you revoke your consent. In addition to revoking consent, you can also exercise the right to access personal data, correct or restrict processing, or object to the processing of personal data at any time. If you believe that we are not exercising your rights adequately, you can file a complaint with the Croatian national supervisory authority for the protection of personal data. You can read more about your rights in the chapter Your rights.

3.3. COMMUNICATING WITH US

If you contact us via the online form, the customer support center or by other means (in writing by (electronic) mail or by telephone), we will process your (identification and contact) personal data, namely name, surname, e-mail address and / or telephone number for the purpose of communicating with you (preparing an answer to your question), which is necessary for the implementation of measures before the conclusion of a contract according to point 6/1(b) GDPR or represents our legitimate interest according to point 6/1(f) GDPR, which is in managing relations with existing customers, providing information and assistance to existing customers, ensuring or improving the quality of selected services, informing about services or products. We will keep your personal data until the end of the communication, while you may, at any time before that, ask us to delete your personal data. At any time, you can also exercise the right to access personal data, correct or limit processing, or object to processing. If you believe that we are not exercising your rights adequately, you can file a complaint with the Croatian national supervisory authority for the protection of personal data. You can read more about your rights in the chapter Your rights.

If, on the basis of demand, you decide to enter into a contract with us, we will process your data in the manner and within the framework of the provision of services from the individual program, as stated in points 3.4. – 3.8.

3.4. USE OF CAR SHARING SYSTEM AND »AVANT2GO« APPLICATION

Access to the »Avant2Go« services is possible only after completing the registration process in the »Avant2Go« system via the »Avant2Go« mobile application and activating the user account.

As part of the »Avant2Go« service, we process the following personal data of the user - a natural person:

- In the registration process and for the purposes of implementing measures to conclude a contract: gender, first and last name, date of birth, residential address (address, postal code, city, country), telephone number, email address, citizenship; credit card data: type, last 4 digits and date of validity, electronic version of the credit card (in case of concluding a distance contract and if the »Avant2Go« mobile application allows this); driver's license information (scan or picture, country of issue, date of validity, document number) and tax number.

- After the conclusion of the contract and for the purposes of implementing the contract, we additionally process: access to the personal document of the user and the payer and / or proof of the address of residence (each only in case of impossibility of clear identification of the person); number and date of conclusion of the contract; data on previous services, purchase history, completed financial transactions, payment method (credit card, personal payment, package), balance in the wallet (credit), balance of benefits, information about the recommender (recommend the Program and get the benefit); call history and call recordings, e-mail correspondence with the client; location data: GPS location of the vehicle (limited to the moment when the data is checked), events related to vehicle rental (unlock time, lock time, rental location, return location, driving time, kilometers traveled); data on offenses committed with »Avant2Go« vehicles, data on damage events in which an »Avant2Go« vehicle is involved.

In the case of concluding a contract with a member - a legal entity, we process the following personal data:

- In the registration process and for the purposes of implementing measures to conclude a contract: name and surname of the responsible person; contact details of the contract administrator (name and surname, telephone number, e-mail address).

- After the conclusion of the contract, we additionally process: data about the user: gender, first and last name, date of birth, residential address (address, postal code, city, country), telephone number, email address, citizenship, data on the user's driver's license (country of issue, date of validity, document number); data on previous services, driving history, call history and call recordings, e-mail correspondence with the customer; location data: GPS location of the vehicle (limited to the moment when the data is checked), events related to vehicle rental (unlock time, lock time, rental location, return location, driving time, kilometers traveled); data on offenses committed with »Avant2Go« vehicles, data on damage events in which an »Avant2Go« vehicle is involved.

Legal basis for the processing of personal data: for the provision of services, this is the performance of a contract according to point 6 /1(b) GDPR; for all cases of GPS tracking of »Avant2Go« vehicles and the collection of location and rental data, the legal basis is the performance of a contract according to point 6/1 (b) GDPR or our legitimate interest according to point 6/1(f) GDPR, which is in: improving, the development and upgrading of the »Avant2Go« service and the general protection of the operator's assets or property; for the provision of direct marketing services, the legal basis is consent according to point 6/1(a) GDPR or our legitimate interest according to point 6/1(f) GDPR (if we send advertising messages to existing customers who have been informed of this possibility in advance), which is in the management of customer relations and monitoring customer satisfaction (e.g. providing information regarding the concluded contract and for the purposes of providing discounts and benefits, rewarding customer loyalty, informing about prize games, etc.); for the case of sending data to external users listed in point 4.1. the legal basis is the execution of a contract according to point 6/1(b) GDPR or the fulfillment of our legal obligation according to point 6/1(c) GDPR.

Retention period: the entire duration of the contractual relationship on the basis of which you use the services and 5 (five) years after the termination of the contract (general statutory limitation period for compensation claims). Data processed for the realization of the contract, for which a different storage period is prescribed by law (e.g. accounting and tax data), are kept for 10 (ten) years after the termination of the validity of the contract.

Individual rights: access to data, rectification, limitation of processing, portability, and in cases of processing for direct marketing purposes, also the right to object. If you believe that we are not exercising your rights in relation to the processing of your personal data adequately, you can file a complaint with the Croatian national supervisory authority for the protection of personal data. You can read more about your rights and the possibility of appeal in the chapter Your rights.

3.5. USE OF THE RENT-A-CAR SERVICE

Access to Rent-a-car services is possible on the basis of concluding a contract with us after completing the vehicle reservation process through any of our reservation channels (website, mobile application »Avant2Go«, telephone reservation, e-mail reservation, personal (»walk- and«) reservation, reservation through the distribution systems of any intermediary (»broker«) with whom we have a contractual relationship; rental through contractual partners to whom we provide assistance services (i.e. replacement vehicle rental services).

As part of the rent-a-car service, we process the following personal data:

- for the purposes of implementing measures before concluding a rental agreement: first and last name, date of birth, residential address, telephone number, email address, driver's license information (scan, country of issue, date of validity, driver's license number), credit card information (name holder, credit card number, validity date, CVC code) or about another means of payment.

- after concluding the rental agreement, we additionally process: data on previous services - purchases; contract information (contract number and date); information on offenses committed with the rented vehicle; data on damage events in which the rented vehicle is involved; payment method information (credit card, cash, e-invoice or invoice); e-correspondence with the client.

Legal basis for the processing of personal data: for the provision of the rent-a-car service, this is the performance of the contract according to point 6/1(b) of the GDPR; for the performance of direct marketing services, the legal basis is your consent according to point 6/1(a) GDPR or our legitimate interest according to point 6/1(f) GDPR (when we send advertising messages to existing customers who have been informed of this possibility in advance), which is in the management of customer relations and the monitoring of customer satisfaction (e.g. providing information regarding the concluded contract and for the purposes of providing discounts and benefits, rewarding customer loyalty, informing about prize games, etc.); for the case of sending data to external users listed in point 4.1. the legal basis is the execution of a contract according to point 6/1(f) GDPR or the fulfillment of our legal obligation according to point 6/1(c) GDPR.

Retention period: the entire duration of the contractual relationship on the basis of which you use the services and 10 (ten) years after the termination of the contract.

Individual rights: access to data, rectification, restriction of processing, portability, and in cases of processing for direct marketing purposes, also the right to withdraw consent and the right to object. If you believe that we are not exercising your rights in relation to the processing of your personal data adequately, you can file a complaint with the Croatian national supervisory authority for the protection of personal data. You can read more about your rights and the possibility of appeal in the chapter Your rights.

3.6. USE OF THE FMG ("FLEET MANAGEMENT") SERVICE

Access to FMG services is possible based on the conclusion of the FMG contract and completion of the vehicle rental process.

As part of the FMG service, we process the following personal data:

- before concluding the contract: information about the driver of the client (company): first and last name, address of permanent residence, tax number, personal registration number, telephone number, email address; driver's license (scan, validity date, driver's license number); data on the additional driver (usually a family member): first and last name, driver's license (view, date of validity, number); if the customer is a legal entity, also the data of the administrator of the contract: first and last name, telephone number, e-mail address and the first and last name of the legal representative of the customer.

- after the conclusion of the contract, for the purposes of contract implementation, we additionally process: contract number and date; information on offenses committed with the rented vehicle; data on damage cases; payment method information (credit card, cash; e-invoice or invoice); e-mail correspondence with the client; information about the buyer of the vehicle (if the vehicle is sold to a natural person or s.p.): first and last name, address of permanent residence, personal registration number (tax number in the case of s.p.).

Legal basis for the processing of personal data: for the provision of FMG services, this is the performance of a contract according to point 6/1(b) of the GDPR; for the performance of direct marketing services, the legal basis is your consent according to point 6/1(a) GDPR or our legitimate interest according to point 6/1(f) GDPR (if we send advertising messages to existing customers who have been informed of this possibility in advance), which is in the management of customer relations and the monitoring of customer satisfaction (e.g. providing information regarding the concluded contract and for the purposes of providing discounts and benefits, rewarding customer loyalty, informing about prize games, etc.); for the case of sending data to external users listed in point 4.1., the legal basis is our legitimate interest according to point 6/1(f) GDPR or the fulfillment of our legal obligation according to point 6/1(c) GDPR.

Retention period: the entire duration of the contractual relationship on the basis of which you use the services and 10 (ten) years after the termination of the contract.

The rights of individuals: access to data, correction, restriction of processing, transferability, in cases of processing for the needs of direct marketing, also the right to object and, in the case of processing based on consent, also the withdrawal of consent. If you believe that we are not exercising your rights in relation to the processing of your personal data adequately, you can file a complaint with the Croatian national supervisory authority for the protection of personal data. You can read more about your rights and the possibility of appeal in the chapter Your rights.

3.7. USE OF THE CHARGE BY AVANT CAR SERVICE

As part of the Charge by Avant car service, we process the following personal data:

- name, surname and e-mail address, and after the conclusion of the contract, also the identification number assigned to the customer and data on previous services - purchases.

Legal basis for the processing of personal data: for the provision of Charge by Avant car services, the legal basis is the performance of the contract according to point 6/1(b) of the GDPR; for the performance of direct marketing services, the legal basis is your consent according to point 6/1(a) GDPR or our legitimate interest according to point 6/1(f) GDPR (if we send advertising messages to existing customers who have been informed of this possibility in advance), which is in the management of customer relations and monitoring of customer satisfaction (e.g. providing information regarding the concluded contract, etc.); for the case of sending data to external users listed in point 4.1. the legal basis is our legitimate interest according to point 6/1(f) GDPR or the fulfillment of our legal obligation according to point 6/1(c) GDPR.

The rights of individuals: access to data, correction, limitation of processing, portability, in cases of processing for direct marketing purposes, also the right to object and, in the case of processing based on consent, also the withdrawal of consent. If you believe that we are not adequately exercising your rights in relation to the processing of your personal data, you can file a complaint with the Croatian national supervisory authority for the protection of personal data. You can read more about your rights and the possibility of appeal in the chapter Your rights.

3.8. PARTICIPATION IN OUR ONLINE SURVEYS AND MARKETING PROMOTIONS

In the case of your decision to participate in our online surveys and marketing campaigns, we collect and process the personal data that you provide us voluntarily and only for the purpose of providing our services, for the needs of our internal administration and the management of our business.

The legal basis for the processing of your data is your personal consent according to point 6/1(a) GDPR. We will keep personal data until you revoke your consent. In addition to revoking consent, you can also exercise the right to access personal data, correct or limit processing, or object to processing at any time. If you believe that we are not exercising your rights properly, you can file a complaint with the Croatian national supervisory authority for data protection. You can read more about your rights in the chapter Your rights.

3.9. PURCHASE OF A VOUCHER

If you decide to purchase a voucher, we process your personal data necessary to carry out the purchase transaction (depending on the method of purchasing the voucher, this data can be: first and last name, e-mail address, telephone number, last 4 digits of the credit card). The legal basis for the processing of personal data is the execution of a sales contract according to point 6/1(b) of the GDPR. We will store your data in accordance with legal requirements in the accounting and tax fields (10 years). If you are the recipient of a voucher, we process your first and last name. The legal basis for the processing is our legitimate interest according to point 6/1 (f) GDPR, which is in enabling the acquisition of benefits.

Your data rights are data access, rectification, restriction of processing and the right to portability. If you believe that we are not exercising your rights in relation to the processing of your personal data adequately, you can file a complaint with the Croatian national supervisory authority for the protection of personal data. You can read more about your rights and the possibility of appeal in the chapter Your rights.

3.10. PARTICIPATION IN OUR SWEEPSTAKES

If you decide to participate in our raffle, we will process your data to the extent necessary to carry out the individual raffle. More detailed information regarding the personal data that you must provide to us in order to participate in the prize draw and our obligations and your rights in relation to processing are provided in the conditions of participation in the prize draw. If we organize a prize game with our partners, this is also stated in the general conditions of the individual prize game, where it is also stated whether the partner receives your data, to what extent and for what purpose.

The legal basis for the processing of your personal data is our legitimate interest in connection with the implementation of the prize draw according to point 6/1(f) GDPR. If you are the recipient of the prize, the legal basis for processing your data is the performance of the contract according to point 6/1(b) of the GDPR and the fulfillment of our tax obligations according to point 6/1(c) of the GDPR. We will keep your personal data for the duration of the prize draw, and if you are a prize winner, for 5 (five) years from the end of the draw. Data for which a different storage period is prescribed by law (e.g. accounting and tax data) is kept for 10 (ten) years from the end of the contractual relationship or the implementation of the prize draw. You can exercise your rights to access, correction, restrictions, data portability at any time. If you believe that we are not exercising your rights properly, you can file a complaint with the Croatian national supervisory authority for data protection. You can read more about your rights in the chapter Your rights.

3.11. SENDING REQUESTS TO WORK WITH US

If you send us a spontaneous job application to our contact information, we undertake to process your personal data solely for the purpose of carrying out procedures for selecting potential candidates for jobs, contacting about (non)selection, invitations to a possible interview, possible preparation of a draft contract on employment and for the protection of our rights in the event of a dispute due to alleged discrimination and related procedures in conducting the selection process. The processing of this data is necessary for the implementation of measures before the conclusion of a possible contract with you according to point 6/1(b) of the GDPR.

If the selection process is not carried out, we will immediately delete your data or anonymize it accordingly. If we assess that your application may be of interest for possible future job advertisment or some other job and we would like to keep it for a longer period of time, we will inform you beforehand and ask for your express written consent and keep your data for up to 2 (two) years or until your withdrawal of consent. If we carry out a selection procedure for the position you have applied for, we will keep your application for the entire duration of the employment procedure and for another 30 (thirty) days after you receive notification of (non)selection, or in the event of a possible complaint and the expected filing of a legal remedy against the selection procedure for at least 5 (five) years, or for the time until the final conclusion of any legal proceedings.

At any time, you can exercise your rights to access, correct, limit, transfer data. If you think that we are not exercising your rights properly, you can file a complaint with the Information Commissioner of the Republic of Croatia. You can read more about your rights in the chapter Your rights.

4. DISCLOSURE OF PERSONAL INFORMATION TO EXTERNAL PARTIES

4.1. DISCLOSURE OF PERSONAL INFORMATION TO EXTERNAL USERS

We reserve the right to access and disclose personal data in order to fulfill and ensure compliance with the law, comply with legal requirements, use data in legal proceedings or protect the rights and property of Avant car or our customers. For these needs, on the basis of and in accordance with the procedures provided for by law, taking into account the relevant provisions of the legislation in the field of personal data protection, we can forward your personal data to: the insurance company, the Croatian Insurance Association (resolving damage cases), the city police (road and traffic violations), DARS (in case of traffic offences), the police or the state prosecutor's office (in case of misdemeanours, criminal offences), the court (in case of legal proceedings), the law firm (which, as an authorized representative of e.g. the owner of the parking area, requests the transmission of information about the driver or in case of administrative or court procedures), detectives and enforcers, bankruptcy trustees, public authorities of foreign countries, external auditors, external IT service providers, leasing companies, e-identity providers, tax authority, as well as supervisory authorities, in the performance of their duties (inspectors, agencies, offices).

4.2. DISCLOSURE OF PERSONAL DATA OR DATA PROCESSORS

When cooperating with other companies (contractual data processors), which carry out special services for Avant Car, Avant Car enables them to access those data which are indispensable for their work. These providers are contractually bound to safeguard the privacy of these data and may use them solely to carry out their work. The above-mentioned contractual data processors safeguard the transferred data; they do not store them, and they process them exclusively on our behalf and within the limits of our authorisation. The contractual data processors are entitled to use the transferred data solely within the scope of performing their work.

Within the framework of legislative powers, your personal data can be disclosed to the following data users:

• accounting services, law firms and other providers of legal and management consulting services;

• providers of files and data carrier erasure services;

• providers of informational technology services within the framework of servicing and maintenance;

• payment service providers;

• an administrator or a webmaster;

• cloud computing services providers and email services providers;

• providers of the customer relationship management systems;

• contractual partners when conducting a marketing campaign, prize game or event;

• to the service provider of the call center for customer assistance.

4.3. DATA DISCLOSURE TO AVANT CAR GROUP COMPANIES

If you use the services of affiliated companies of the Avant car group, your personal data will be forwarded to such companies to the extent necessary and for the purpose of carrying out the contractual relationship with this company, as well as for the purpose of your identification and to verify whether you meet all the conditions for using the services of this company and whether you have settled all your obligations towards all companies of the Avant car group.

4.4. EXPORT OF DATA TO THIRD COUNTRIES

Apart from the stated, your personal data may in specific cases be transfered to other third countries or international organisations, whereupon the transfer shall take place in accordance with legal basis for such a transfer, as regulated by the GDPR and valid Croatian legislation. Such possible basis are as follows:

• a decision of the European Commission on establishment of adequate level of personal data protection;

• adoption of appropriate safeguards (approved binding corporate rules; standard contractual clauses on data protection; entry into an appropriate contract on processing of personal data; or other appropriate safeguards as envisaged by the GDPR);

• derogations in specific situations, envisaged by the GDPR.

5. PROTECTION OF PERSONAL DATA

We are committed to protecting all personal data that you provide to us.

We prevent unauthorized access to them, their use and disclosure with a number of different security technologies and procedures.

If necessary, SSL-encryption is used on our websites to increase the security of the transfer of sensitive data. Within the company, data is stored in permanently controlled computer systems with limited access in controlled places.

After the termination of the need for data management, i.e. after fulfilling the purpose for which the data was collected, the data is immediately anonymized or irretrievably and permanently deleted.

In the event that our website contains links to other websites that are not in any way related to us, we do not assume any responsibility for the protection of your data on these websites.

6. FREEDOM OF CHOICE

You control the data you provide to us. If you decide not to provide us with certain data, then you will not be able to access certain sites or functions on our websites; nor will we be able to answer your inquiry or contact you in such cases. If you want to become a user of one of our services, providing the information we ask you for before or upon entering into a contractual relationship, as well as during its duration (especially in the case of data changes), is your contractual obligation and we cannot enter into a contractual relationship with you or you ( further) to provide services, whereby we may also be entitled to withdraw from the contract for the stated reason and in accordance with the contract.

If your personal data changes (postal code, e-mail address, address, telephone number, etc.), please notify us of the changes to the e-mail address: gdpr@avantcar.hr.

7. YOUR RIGHTS

The data controller assures you a consistent implementation of all your incidental rights in connection with your personal data processing on the basis of applicable legal regulations.

As a data subject you shall have the following rights:

Right to withdrawal of consent: If, as a data subject, you have given your consent to the processing of your personal data (for one or several purposes), you shall have the right to withdraw the consent. The withdrawal of consent has no impact on the legality of data processing having been carried out prior and up to its withdrawal.

You can withdraw, free of charge, your consent at any time by sending a written statement to the data controller’s email address gdpr@avantcar.hr. Neither legal consequences nor sanctions ensue from the withdrawal of the consent.

Right to access personal data: As a data subject you shall have the right to get a confirmation from the data controller whether your personal data are processed or not. If they are, you shall have the right to access your personal data (i.e. including copying them) and be given the information concerning your personal data processing (e.g. the purpose of processing, type of data, users your personal data have been or will be transferred to, anticipated data retention period, technical and organisational measures on data protection, existence of automated decision making, including profiling etc.).

Right to rectification: As a data subject, you shall have the right to obtain without undue delay the rectification of the inaccurate and complementing of the incomplete personal data. To this end, you shall have the right to submit to us a complementary statement with updated personal data.

Right to erasure (i.e. right to be forgotten): You shall have the right to obtain from the data controller to take steps without undue delay to erase your personal data if one of the reasons given in Article 17 of the General Data Protection Regulation exists (e.g. if the data are no longer required to serve the purpose they have been collected for or processed in some other way; if you have withdrawn your consent and there is no other legal grounds for the data processing; if you contest the data processing and there are no overriding legitimate interests for the data processing; if the data have been processed unlawfully etc.).

Right to restriction of processing: The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

- the accuracy of personal date is contested by the data subject, for a period the controller can verify the accuracy of the personal data;

- the processing is unlawful and the data subject objects to erasure of the personal data and requests the restriction of their use instead;

- the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;

- the data subject has contested the processing pending the verification whether the legitimate grounds of the controller override those of the data subject.

Right to data portability: As a data subject you shall have the right to receive the personal data in a commonly used and machine-readable format and have the right to transmit those data to another controller, when the processing is based on consent or on a contract or is carried out by automated means.

Right to object: If data processing is based on our legitimate interests, you shall have the right, according to the reasons concerning your particular position, to object to the processing of your personal data at any time. In such case, we will continue processing your personal data provided that we prove the existence of compelling legitimate grounds for processing them which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

Where your personal data are processed for direct marketing purposes, you shall have the right to object at any time, free of charge and without giving any reasons, by sending us a message to our email address gdpr@avantcar.hr you object to your personal data being processed for direct marketing purposes, we will immediately stop processing them for these purposes.

Furthermore, we will, upon your request, provide you in compliance with applicable law other information concerning your personal data which we process.

Right to lodge a complaint: If you believe that infringements of personal data protection legislation have occurred during the processing of your personal data, you shall have the right to lodge a complaint with the Information Commissioner of the Republic of Croatia, Selska cesta 136, 10000 Zagreb, Croatia, phone number 00 385 (0)1 4609-000, email address: azop@azop.hr.

7. CHANGES TO THE PRIVACY POLICY

This Privacy Policy was last updated in July 2023. We can update this Privacy Policy in compliance with respective applicable law, due to modifications to our services and on the basis of users’ feedback. All modifications of this Privacy Policy will be posted on this website / application, including the date of the latest update. In case of substantial modifications, we will inform you thereof in a conspicuous manner or through a direct message.

7. YOUR QUESTIONS AND SUGGESTIONS

Should you have any questions, reservations or suggestions concerning our collecting, using and disclosing of your personal data, you are kindly asked to submit them to us via the online contact form or contact our data protection officer at the email address: gdpr@avantcar.hr.