Updated 17 May, 2024
1. Introduction
This website (coreneo.agency) is owned and operated by Jezgra Neo j.d.o.o. (trading as CoreNeo). Velimira Škorpika 7a, 22000 Šibenik, Croatia (“CoreNeo”, “we”, “our”, or “us”). This Privacy Policy outlines how we collect, what information we gather, and the reasons for collecting it, how we use it, the duration of storage, and the measures we have in place to protect your privacy. As the data controller, we are responsible for your personal data, including the processing activities conducted by our subcontractors under our instructions.
We maintain the confidentiality of your personal data. If you have any questions regarding how we handle personal data, please contact us. The primary contact for privacy matters at our organization is the Data Protection Officer, who can be reached via email at gdpr@coreneo.agency.
You have the right to file a complaint with the Croatian Personal Data Protection Agency (AZOP), the supervisory authority for data protection issues in Croatia (https://azop.hr/).
This Privacy Policy should be read in conjunction with our Cookies Policy.
We reserve the right to amend this Privacy Policy, along with other related GDPR documents, in compliance with the European Union’s General Data Protection Regulation (Regulation 2016/679) and Croatian GDPR laws (NN 42/2018).
2. How We Collect Your Personal Data
Personal data encompasses any information that can identify you, either directly or indirectly, through various identifiers or unique characteristics specific to you.
We collect only the information that is necessary, relevant, and sufficient for the purposes you provide it for. This Privacy Policy applies to personal data we receive through:
- Our website: https://coreneo.agency/
- Our contact channels: When you provide personal information via our “Contact Us” form on our website, or through email and/or phone.
- Applying for a position: When you send us an application for employment when applying for a position at our company.
We may collect your personal data in the following ways:
- Directly from you: When you interact with us directly, correspond with us, or submit information via email, phone, or social media.
- Automatically: When you access and browse our website, we collect information about your usage and activity using technologies such as cookies and other tracking technologies.
- Public sources: Information that is publicly available.
Our website may contain links to third-party websites, plug-ins, and applications. Following these links or enabling these connections may allow third parties to collect or process your data. Please note that we do not control these third-party websites and are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.
3. Personal Data We Collect
CoreNeo processes personal data for the following groups:
Website Visitors
- Geo-location, IP address, and cookies (For more details, please see our Cookie Policy).
Job Candidates
- Data collected through job applications or unsolicited applications, including:
- Personal Information: Name, address, email, phone number.
- Professional Data: Information from cover letters and CVs/resumes (such as education, training, and previous employment details).
Potential Clients
- Name, email, and/or phone number.
Newsletter Subscribers
- Email address and cookies.
4. Data Retention
We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Specific retention periods are determined based on the nature of the data and the purposes for processing it.
Our data retention periods are as follows:
- Website Visitors: 26 months
- Job Candidates: 5 years
- Clients: 5 years
- Newsletter Subscriptions: 4 years
5. Goals of and Legal Basis for Processing
We process your personal data based on one or more legal grounds.
Depending on the data collected, we process personal data for the following purposes:
- To comply with legal obligations
- To provide and perform our services
- To provide you with the necessary information
- For marketing purposes or to send you information about our services via newsletter
- To enhance practicality and efficiency using cookies
- To process job applications
All personal data collection is based on one of the following:
- Consent of the individual sharing the data
- Performance of a contract to which the individual is a party
- Compliance with a legal obligation
- Legitimate interests of CoreNeo or a third party
- Vital interests of the individual or another person, or the public interest
We will not use your data for any purpose or on any basis other than those listed above. If we need to process personal data for other reasons, we will explicitly seek your permission.
We also collect information you provide when you cooperate with us or use our services, which is necessary for contract execution. This includes data necessary for delivering contracted services, issuing invoices, proving authority to enter into a contract, and data collected during communication with us (e.g., contact information). We process this data for the duration of our contractual relationship.
6. Social Media
All personal data collected through CoreNeo’s social media platforms, as defined by the GDPR, is processed in accordance with this Privacy Policy and in compliance with legal requirements.
CoreNeo is present on the following social media platforms, each with its own privacy policy linked below:
7. Provision to Third Parties
We currently do not share personal data with third parties for their direct marketing purposes. Regarding the quality of our services, we may engage third-party contractors and suppliers. These entities serve as processors or sub processors for data protection purposes, processing personal data strictly as directed by us. If these parties access or handle personal data, we establish a Data Processing Agreement (DPA) with them, ensuring that they only process your personal data for the specified purposes.
For internet analytics, spam protection, and newsletter services, we utilize Google Analytics, reCAPTCHA by Google, and Mailchimp. You can find their privacy policies linked here.
We commit to processing and storing personal data exclusively within the European Union, unless otherwise agreed upon in writing. However, exceptions apply when tracking website interactions. When using Google Analytics, Mailchimp and other services, your data may be stored outside the EU, subject to the respective privacy policies and terms of service. We encourage you to review their privacy policies through the provided links.
In the course of processing activities outlined in this Policy, your data may be transferred to countries outside the EU and the European Economic Area (EEA). These countries, including the US, may have different data protection laws from those of your country. In such cases, we implement appropriate safeguards to protect your personal data in accordance with GDPR Articles 45 and 46. These safeguards may involve adhering to the European Commission’s standard contractual clauses for personal data transfers or relying on other legal frameworks.
8. Security
We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, use, or disclosure. These measures include encryption, access controls, and regular security assessments.
9. Automated Decision Making
We do not engage in automated decision-making processes that produce legal effects concerning you or similarly significantly affect you.
10. Your Rights
Under GDPR, you have the following rights concerning your personal data:
The right to access: You can request copies of your personal data.
The right to rectification: You can request correction of inaccurate or incomplete data.
The right to erasure: You can request the deletion of your personal data under certain conditions.
The right to restrict processing: You can request the restriction of processing under certain conditions.
The right to data portability: You can request the transfer of your data to another organization or directly to you under certain conditions.
The right to object: You can object to processing your personal data under certain conditions.
To exercise your rights, please contact us at:
Jezgra Neo d.o.o.
Velimira Škorpika 7a
22000 Šibenik, Croatia
Email: gdpr@coreneo.agency
We will respond to your request within the timeframe required by law.