Privacy Policy - Information on the Processing of Personal Data
1. Data controller
The Croatian Lifestyle Medicine Association (hereinafter: HUMŽiS / CROLMA), as data controller, uses this Privacy Policy to explain how personal data are processed and how it complies with its obligations under the General Data Protection Regulation (GDPR).
2. Types of personal data processed
We process your personal data, meaning information relating to an identified or identifiable person, in particular identifiers such as name, surname, academic title, OIB (Croatian personal identification number), date of birth, address, professional title, telephone number, email address, photograph and similar data, in the following situations:
when you use a registration form to participate in an event we organise;
when you complete a membership form;
when you complete an order form, purchase a product, order a service or take part in one of our events;
when you subscribe to our newsletter or news updates;
when you use our contact form;
when you contact us or connect with us through social media;
when we photograph or record events and activities that we organise.
Under the Croatian Associations Act, the Association is legally required to maintain a register of its members containing the following mandatory information: name, surname, OIB, date of birth and membership category. In addition to these data, we process members' contact details so that we can contact them about membership fees and Association activities.
We will not collect your personal data unless you provide them voluntarily. Certain personal data collected through information systems and software used to operate the website are an exception where transmission is necessary for the use of internet communication protocols, for example IP addresses during registration. The scope of such data will not exceed what is necessary for participation in the relevant activities.
3. Newsletter
We send our newsletter on the basis of consent to people who have subscribed to receive our news. On the basis of legitimate interest, we also send the newsletter to our members, customers and collaborators.
From the time they join the Association, each HUMŽiS / CROLMA member receives our newsletter at the contact address provided in their membership application. Every newsletter recipient can unsubscribe easily by sending an email to medicinazivotnogstila@crolma.net requesting that notifications stop and that they be unsubscribed. We retain unsubscribed email addresses for 5 years, corresponding to the general limitation period under Croatian law, on a suppression list on the basis of legitimate interest, in order to document the opt-out and prevent further messages from being sent to recipients who have unsubscribed. We collect statistical data about email opens and URL clicks in order to monitor and improve email delivery and analyse interest in particular content.
Data are retained until the person withdraws consent, until we receive information that the person no longer receives our emails at the relevant email address, or until the person objects to our contacting them on the basis of legitimate interest.
You have the right to withdraw your consent at any time without adverse consequences. Withdrawal of consent does not affect the lawfulness of processing carried out before the consent was withdrawn.
You have the right to object to our legitimate interest in contacting you for direct marketing purposes. If you do so, we will no longer contact you for that purpose.
4. Social media
We collect personal data concerning our contacts on social media platforms (Facebook, Instagram and LinkedIn), as well as information about reactions to our social media posts.
5. Purposes and legal bases for processing
The purposes for which we process your personal data include:
Taking steps at your request, for example responding to your questions and comments, fulfilling your requests, sending an application form or quotation, or receiving a quotation;
HUMŽiS / CROLMA activities and membership, including maintaining records in accordance with the Croatian Associations Act, such as name, surname, OIB, address, date of birth and membership category, and maintaining records of board members, meetings and general assemblies;
Performance of a contract to which you are a party or taking steps before entering into a contract, for example handling your registration for an event or advertisement, providing a service, or entering into a donation agreement;
Investigating suspected fraud, harassment, physical threats or other breaches of our Statute, laws, rules or regulations, or third-party rights, or investigating conduct that we consider or suspect to be inappropriate;
Compliance with legal obligations to which we are subject, for example disclosures required by law, regulation or court order, as well as obligations under the law and our Statute, such as measures to prevent conflicts of interest;
Photographing or recording participants at events we organise, on the basis of consent or legitimate interest, for the purpose of promoting the event;
For the purposes of or in connection with legal proceedings, including establishing, exercising or protecting legal rights;
Providing personal data for the purposes listed above is voluntary. However, refusal to provide such data may prevent HUMŽiS / CROLMA from entering into a contract with you, responding to your requests, providing services, receiving and processing your event registration, or complying with its legal obligations.
6. Recipients
Your personal data may be disclosed, where closely connected with the purposes described above, to:
entities required to fulfil orders or event registrations, deliver packages, send post or email, remove duplicate information from recipient lists, photograph events, process credit and debit card payments, or provide customer services, which usually process personal data on behalf of HUMŽiS / CROLMA as processors;
entities that maintain our information systems, acting as processors;
persons authorised by HUMŽiS / CROLMA to process personal data;
law enforcement bodies and public authorities where required by applicable law or in good faith;
HUMŽiS / CROLMA's legal and financial advisers where data need to be shared for legal, tax or audit procedures;
business partners for their own purposes only where an appropriate legal basis exists.
7. Data retention
HUMŽiS / CROLMA will process your personal data only for as long as necessary to achieve the purposes described in section 5. Where a retention period is prescribed by law, HUMŽiS / CROLMA will retain personal data for the period required or permitted by that law.
8. Your rights
Your rights include the following:
Right to erasure ("right to be forgotten") - you have the right to obtain the erasure of personal data concerning you, and we are required to erase personal data without undue delay where one of the following conditions applies:
a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
b) you withdraw the consent on which the processing is based and there is no other legal ground for the processing;
c) you object to the processing and the grounds supporting your right to erasure override HUMŽiS / CROLMA's legitimate interest in processing and/or retaining the personal data;
d) the personal data have been unlawfully processed;
e) the personal data must be erased in order to comply with a legal obligation.
Right of access - you have the right to obtain confirmation as to whether your personal data are being processed and, where they are, to obtain access to the personal data and information about the purposes of processing, categories of data, possible recipients to whom the personal data will be disclosed, and similar information.
Right to rectification - you have the right to obtain, without undue delay, the rectification of inaccurate personal data.
Right to object - you have the right, on grounds relating to your particular situation, to object to the processing of personal data.
Right to restriction of processing - you have the right to request restriction of processing where:
(a) you contest the accuracy of the personal data, for a period enabling us to verify their accuracy;
(b) the processing is unlawful and you oppose the erasure of the personal data and request restriction of their use instead;
(c) we no longer need the personal data for the purposes of processing, but you require them for the establishment, exercise or defence of legal claims; or
(d) you have objected to processing pending verification of whether our legitimate grounds override those of the data subject.
In addition, you have the right to lodge a complaint with the competent supervisory authority in the Republic of Croatia, the Croatian Personal Data Protection Agency.
9. Links to other websites
The Site may contain links to other websites that are not owned, operated or maintained by HUMŽiS / CROLMA. When you leave the Site, you should review the terms and privacy policies of each website you visit. You should also independently assess the authenticity of any website that appears or claims to be one of our websites, including websites linked through email. Unless stated otherwise, we do not control, recommend, endorse or have an affiliation with such websites or their content, products, services or privacy policies.
10. Security practices
The security of personal data is very important to us, and we have established appropriate physical, electronic and organisational procedures to protect the data we collect. Taking into account the state of the art, the costs of implementation, and the nature, scope, context and purposes of processing, as well as the varying likelihood and severity of risks to the rights and freedoms of natural persons, we will implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk. This includes protection against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed, and against unlawful processing.
11. Applicable law and jurisdiction
Croatian law governs all matters relating to this Privacy Policy. You agree that courts in the Republic of Croatia have exclusive territorial jurisdiction in proceedings relating to the Site and this Privacy Policy. We do not warrant or imply that the Site or its content and materials are suitable for use outside the Republic of Croatia. Information on the Site relating to any services or products applies only to the Republic of Croatia, and those products and services may not be available in all locations.
12. Changes and updates to this Privacy Policy
HUMŽiS / CROLMA reserves the right to amend or update this Privacy Policy. Please check this page from time to time for changes or updates. Any changes will be published here and will show the updated effective date on the first page of the Privacy Policy.
13. Use of the AI chat assistant
We use the Niro AI chat assistant on our website. Niro is provided by Upheave technologies d.o.o., which acts as a data processor on our behalf. In accordance with Article 50 of Regulation (EU) 2024/1689 (AI Act), we inform you that you are interacting with an AI system. You can contact us directly at any time at info@crolma.net.
When you use the chat, we process the messages you enter, basic technical data such as browser type, timestamps and session identifier, and any contact details you voluntarily provide. This processing is carried out for the purpose of providing information and user support, on the basis of our legitimate interest under Article 6(1)(f) GDPR.
Conversations are stored, and authorised staff and the service provider may review them for quality improvement and to respond to your enquiries. The data are not used to train AI models.
The AI assistant provides automated responses and the information it gives may be inaccurate or incomplete. The content is for information purposes only and does not constitute professional advice. Any binding information, including prices, availability and terms, is confirmed by our staff.
Please do not enter sensitive personal data into the chat, including financial information, OIB or information about third parties. For specific questions, contact us at info@crolma.net.
Additional information about data processing, subprocessors and transfers outside the EEA is available in the privacy technical specification (https://app.niro.hr/legal/privacy-specs) and terms of use (https://app.niro.hr/legal/terms).
14. Contact information
If you have any questions about this Privacy Policy, you can contact us by email at info@crolma.net.
