Privacy Policy
Last updated: January 15, 2024
Stormy Wheel d.o.o. ("we," "our," or "us") operates the website stormy-wheel.com and provides real estate services along the Croatian coast. This Privacy Policy describes how we collect, use, and share information about you when you interact with our website and services.
We believe in transparency about data practices. This policy aims to explain things clearly without excessive legal jargon while still covering the necessary legal bases.
Information We Collect
Information You Provide Directly
When you contact us, request information, or engage our services, you may provide:
- Contact details: name, email address, mailing address
- Communication content: messages you send us, notes from consultations
- Property preferences: budget range, location interests, property requirements
- Financial information: when necessary for transactions, such as proof of funds
- Identification documents: passport or ID copies required for property transactions under Croatian law
Information Collected Automatically
When you visit our website, we automatically collect certain technical information:
- Device and browser information: browser type, operating system, screen resolution
- Usage data: pages visited, time spent on site, referral sources
- IP address and approximate geographic location
- Cookies and similar tracking technologies (see our Cookie Policy for details)
How We Use Your Information
We use collected information for these purposes:
Providing Services
- Responding to your inquiries and communications
- Matching you with suitable properties based on your stated preferences
- Coordinating property viewings and consultations
- Facilitating property transactions and legal processes
- Providing post-purchase support and introductions
Improving Our Business
- Analyzing website usage to improve user experience
- Understanding market trends and client needs
- Training our team on client service
- Developing new services based on client feedback
Legal and Compliance
- Complying with Croatian real estate regulations
- Maintaining records as required by law
- Responding to legal requests from authorities
- Protecting our legal rights when necessary
Legal Basis for Processing
Under the General Data Protection Regulation (GDPR), we process your personal data based on:
- Contract performance: When processing is necessary to provide services you've requested
- Legitimate interests: When we have a valid business reason that doesn't override your privacy rights
- Legal obligations: When Croatian or EU law requires us to process certain data
- Consent: When you've given explicit permission, such as for marketing communications
Information Sharing
We share personal information only in these circumstances:
Service Providers
We work with third parties who assist our operations:
- Legal partners who handle property documentation
- Website hosting and technical service providers
- Analytics services that help us understand website usage
- Email service providers for communications
These providers are contractually bound to use data only for the services they provide to us.
Transaction Parties
During property transactions, we share relevant information with:
- Property sellers or their representatives
- Notaries handling transaction documents
- Land registry offices
- Banks involved in financing
Legal Requirements
We may disclose information when required by Croatian law, court orders, or valid governmental requests.
Data Retention
We retain personal information based on the type of data and our ongoing relationship:
- Inquiry data: Deleted after 24 months if no engagement follows
- Client records: Retained for 10 years after transaction completion, as required by Croatian regulations
- Website analytics: Aggregated and anonymized after 26 months
- Marketing consent records: Retained as long as consent remains valid, plus 3 years
Your Rights
Under GDPR, you have the following rights regarding your personal data:
- Access: Request a copy of data we hold about you
- Correction: Ask us to correct inaccurate information
- Deletion: Request deletion of your data (subject to legal retention requirements)
- Portability: Receive your data in a structured, machine-readable format
- Objection: Object to certain types of processing
- Restriction: Request limited processing in certain circumstances
- Withdraw consent: Withdraw previously given consent at any time
To exercise these rights, contact us at [email protected]. We respond to requests within 30 days.
International Transfers
Your data is primarily stored and processed within the European Union. When we use service providers outside the EU, we ensure appropriate safeguards through:
- EU-approved Standard Contractual Clauses
- Adequacy decisions by the European Commission
- Other legally recognized transfer mechanisms
Security Measures
We implement appropriate technical and organizational measures to protect your data:
- Encrypted connections (HTTPS) for all website traffic
- Secure storage systems with access controls
- Staff training on data protection
- Regular security assessments
- Incident response procedures
While we take reasonable precautions, no internet transmission is completely secure. We cannot guarantee absolute security of data transmitted to our website.
Children's Privacy
Our services are not directed at individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have inadvertently collected such information, please contact us immediately.
Changes to This Policy
We may update this Privacy Policy periodically. Significant changes will be communicated through website notices or direct email to active clients. The "Last updated" date indicates when the policy was most recently revised.
Contact Us
For privacy-related questions or to exercise your rights:
Data Controller: Stormy Wheel d.o.o.
Address: Ulica Varoška 18, 21000 Split, Croatia
Email: [email protected]
If you believe we have not adequately addressed your concerns, you have the right to lodge a complaint with the Croatian Personal Data Protection Agency (AZOP):
Agencija za zaštitu osobnih podataka
Selska cesta 136, 10000 Zagreb, Croatia
azop.hr