1. GENERAL PROVISIONS 

Artistic organization Zagreb Film Festival, Vukovarska Street 35a, Zagreb, VAT: 85305939367, as the data controller, in its business activities undertakes to safeguard the privacy and personal data in accordance with the General Data Protection Regulation (EU) 2016/679 – GDPR, as well as other regulations which regulate the protection of personal data.  

This Privacy Policy (hereinafter: “Policy”) applies to every person whose personal data is processed during their use of the Website or while ordering products and services through the Website. The provisions about using the Website are listed in our Terms of Service. The shortened names of the entities contained in this Policy refer to the same entities as in our Terms of Service.  

This Policy is intended to provide clear information about the processing and protection of personal data and to enable straightforward control and management of personal data. The subject of this Policy is the handling of personal data of Users during their visits and use of the Website www.croatian.film. We reserve the right to unilaterally change this Policy at any moment. The valid version of this Policy is always available on the Website. By using the Website and agreeing to the Terms of Use, you also consent to this Policy.

2. LEGAL BASIS AND PURPOSE OF DATA PROCESSING 

ZFF processes personal data of Users in the capacity of the other contracting party or Website visitor in the following instances:  

- contacting the Users via e-mail or phone number provided on the Website. In such instances, we use the User’s e-mail with the purpose of informing them on the products and services offered on the Website. The legal basis for personal data processing is undertaking the action requested by the User prior to finalizing the agreement. Other personal data which the User provides in this way, such as their name, surname or phone number, will not be processed if it is not necessary for this purpose;      

- subscription of Users to our newsletter. In such instances, we occasionally use the User’s e-mail to inform them about special offers and news about products and services available on the Website. The legal basis for personal data processing is consent given by ticking the appropriate box;  

- interaction with Users on social media (Facebook, Instagram, etc.). In these instances, we have access to data such as the User’s name and surname and personal information given in their reactions, comments, messages, etc. We use social media in order to answer to the Users’ queries and in order to inform them about the latest changes in our work. Depending on the purpose for data processing, the basis for processing is undertaking an action requested by the User prior to finalizing the agreement or a User’s consent;  

- the online ordering of charge-based services is described in detail in the Terms of Service. If a User wishes to use charge-based service on the Website, they must register their user account and sign into the system by entering their e-mail address, name and surname. If the User decides to watch certain charge-based content, they click on the icon VIMEO. Subsequently, the procedure of placing an order continues on the VIMEO platform. Given that the User pays for the agreed service on the VIMEO platform, online payment by card or PayPal account, further personal data of the User is processed in accordance with relevant rules of the VIMEO platform and other service providers – ZFF does not process the Users’ personal data in this segment. The basis for data processing is the execution of the agreement in which the User is a contracting party.

- in instances when it is possible to watch films on the Website free of charge, ZFF does not process the Users’ personal data.  

ZFF will remove personal data once the basis for the processing ceases to exist.  

3. TRANSFER AND PERIOD OF RETENTION OF PERSONAL DATA

In providing the Services through the Website, we use third party service providers, namely, the VIMEO platform for providing the service of viewing films, and the online financial transaction or payment via PayPal account service providers. ZFF does not transfer your data to said parties, but rather, in instances of watching charge-based content, the User independently enters into a relationship with these parties in the process of ordering the services on the Website. 

We transfer personal data to third parties only when this is necessary for the fulfilment of duties stated in the agreement or if ZFF is legally obligated to do so. ZFF may transfer the Users’ personal data to third parties in accordance with contractual obligations towards ZFF’s co-contacting parties if ZFF has a legitimate interest, which relates, for example, to expert associates, accounting, IT service providers, lawyers and currier services. ZFF may transfer personal data to supervising authorities, courts or state agencies when such data transfer is stipulated under the law. If allowed, ZFF shall then make every reasonable effort to notify the User of such data transfer prior to the fact. The collected personal data shall not be available to third parties for the purpose of offering goods and services of third parties, unless the User provides consent for this.       

The collected personal data is stored for as long as there is legal basis for processing a certain category of personal data, for example, until the withdrawal of consent. Personal data is erased entirely from all systems of storage no later than 30 days from the day of the termination of the basis for processing and storage, or later, if the obligation of storing said data is stipulated by special regulations.

4. COOKIES

The Website uses cookies as described in the separate regulations on cookie use which is available on the Website. 

5. SECURITY

We use technical and organizational security measures to ensure the protection of your personal data. Our security measures are continuously updated in line with technological developments.

6. USERS' RIGHTS

We enable Users to manage their personal data easily and transparently by exercising the following rights:  

- the right to withdraw their consent in writing by sending an e-mail with the subject “Withdrawal of Consent” clearly stating which consent is being withdrawn. The consent for receiving the newsletter can also be withdrawn by canceling the newsletter, at the bottom of each issue;  

- the right to receive information on which personal data of Users we process and access to personal data we process by sending an e-mail with the subject “Access to Information”; 

- the right to request that we correct or supplement personal data if they are incorrect or incomplete;

- the right to request personal data being erased if it is no longer necessary for the purpose for which we process it; 

- the right to request access to their personal data in a structured, customarily used and machine-readable format, and the right to request direct transfer of this data to another data controller, if applicable and technically feasible;  

- the right to limit further processing, if applicable;  

- the right to lodge a complaint about personal data processing, if applicable, and the right to complain to the Personal Data Protection Agency as the supervising body. We kindly ask all Users that, before contacting the Agency, they first contact us because we want to resolve in good faith any issues related to personal data protection, while respecting the rights of the Users to the utmost degree.   

You may exercise your rights by sending us an email at: info@croatian.film, or sending a letter to the address indicated in this Policy and stating the right you wish to exercise.