PERSONAL DATA PROTECTION POLICY FOR WHOLESALE CUSTOMERS OF INA PETROLEUM PRODUCTS AND CUSTOMERS WHO PURCHASE EURO FUEL OIL EXTRA LIGHT, EURODIESEL BLUE AND LPG IN CONTAINERS FOR HOUSEHOLDS IN DOMESTIC MARKET (hereinafter: Policy)

INA-Industrija nafte, d.d. Zagreb, Av. V. Holjevca 10 (hereinafter: INA) as the personal data controller protects the privacy of their customers-natural persons, including the privacy of persons performing self-employment economic activity or trade, who purchase petroleum products or rent LPG containers, as well as natural persons employed by the customer (hereinafter: Customer/Customers), and processes only those personal data necessary for the realization of business cooperation with the Customer, i.e. conclusion of a contract, its execution and INA sales activities related therewith.In this regard, for the purpose of risk control for financial securityof their claims, INA may process personal data as part of monitoring credit standing and liquidity as well as monitoring other Customer changes in the Court Register, the Official Gazette of the Republic of Croatia,e-Bulletin Board, Fina, Tax Administration and other official sources and in the procedures of collection and redemption of claims.

In addition, based on legitimate interest, INA may use personal data for market research, i.e. for the collection of data and information necessary for planning, organization and control of the business process, as well as for the purposes of marketing activities of INA related to their products and services that the Customer might be interested in considering the business relationship with INA.
INA collects and processes the following personal data:name and surname of the Customer, PIN, address, phone number, mobile phone number, e-mail, number of the GP/GPR card for sale of blue diesel, name and surname of contact person.

INA processes personal data in a fair, lawful and transparent manner and takes care of their accuracy, completeness, up-to-dateness and security.Access to personal data is restricted to authorized persons who are directly related to the activities of realizing a business relationship with the Customer.Employees and contractual partners of INA are obliged to safeguard the confidentiality of personal data and a significant amount of effort is continuously put in employee training on the importance of safeguarding personal data privacy and security.

Providing the aforementioned personal data is a necessary condition for the realization of business cooperation with the Customer and in cases when the required data are denied, INA shall not be able to establish a business relationship with the Customer or deliver their products.
For the purpose of performing the foregoing objectives, INA has the right to process the aforementioned data, which includes the right of INA to collect, record, organize, structure, store, adapt or alter, retrieve, consult, use, disclose by transmission, disseminate or otherwise make available, align or combine, restrict, erase or destroy the data.

INA shall keep the data relating to the business relationship with the Customer for the duration and after the termination of the business relationship as long as there is a statutory obligation or justified interest of INA to keep the business documentation.In order to clarify, such interest exists, for example, in the case of Customer's complaint to the service and/or product, or in the event of any court or other proceedings that INA initiates to protect their legal interests.

INA undertakes to keep the personal data and shall not disclose or make them available to third parties, except:
-to accounting service providers for the purpose of calculating services, issuing invoices and keeping accounting records,
-to service providers of transport for petroleum products,
-to competent authorities for the purpose of performing the tasks within their competence,
-when these data are required by the court or the competent state attorney's office or other authorities in equivalent legal proceedings, and the disclosure of such data is requested in written form,
-when INA is obliged to submit these data according to the law, i.e. for the purpose of establishing, defending or exercising their legal rights,
-to their providers of information on the credit standing and monitoring of Customers-natural persons performing self-employment economic activity or trade, with the purpose of developing and improving INA sales policies,
-to market research agencies as their service providers when personal data is used for the purpose of market research,
-to companies for the collection and redemption of uncollectible receivables in the event of interest of INA in engaging such companies in order to reduce the burden of such receivables on their business.
When INA processes personal data, the Customer is entitled, in accordance with the terms of the applicable regulations governing the protection of personal data:
-to request access to personal data related to them, correction or deletion of personal data, restricted processing or object to the processing of such data and the right to transferability of data,
-if they believe that there has been an irregularity in processing of personal data, to contact the Personal Data Protection Officer at the contacts below:

Address:INA-Industrija nafte, d.d., Av. V. Holjevca 10, 10020 Zagreb
E-mail: szop@ina.hr

-to file a complaint with the national supervisory body, i.e. the Croatian Personal Data Protection Agency (CPDPA).
INA reserves the right to modify the subject Policy at any time and for any reason. Apart from the valid Policy published on the website www.ina.hr, the Customer shall also be notified of any change of the Policy on this website.INA may also remind about the Policy by e-mail and/or by mail to the address of the Customer.
 
 
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