Privacy Policy

1. Introduction

This is the General Privacy Policy (hereinafter: the “Privacy Policy”) adopted by DECODE HQ d.o.o., Zagreb, Radnička cesta 47, OIB (Personal Identification Number): 20903022276 (hereinafter: the “Controller”), a company engaged in software development.

The purpose of this Privacy Policy is to clearly and thoroughly inform service users, business partners, as well as all other persons who come into contact with the Controller, prior to the commencement of data processing, of all facts relating to the processing of their personal data, their rights and the available legal remedies relating to the data processing procedure.

2. Contact details of the data controller

DECODE HQ d.o.o.
Radnička cesta 47
10 000 Zagreb, Croatia

Email: gdpr@decode.agency
Phone: +385 97 658 9455

www.decode.agency

DECODE is incorporated and registered with the Commercial Court of Zagreb in the Republic of Croatia.

Court reg. no: 080802501

PIN: 20903022276
VAT no: HR20903022276
GIRO account IBAN: HR1623400091110532862
SWIFT: PBZGHR2X

3. Definitions

Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Controller: a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law. For the purposes of this Privacy Policy, unless expressly stated otherwise, the controller is the Controller as defined above.

Processor: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. This Privacy Policy will clearly indicate the circumstances in which the company defined as the Controller acts in the capacity of a Processor.

Data subject: a natural person, an individual whose personal data is processed by a personal data processing operation, regardless of his or her origin, age or nationality.

Third party: a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

Personal data: any information relating to an identified or identifiable natural person (“data subject”). This is data that directly or indirectly identifies an individual, such as name and surname, age, biometric and other health and financial data, data on education, ethnic and religious affiliation (so-called special categories of personal data), but may also include various other data such as identification numbers, location data, online identifiers, or factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the data subject.

4. Applicable legal provisions

• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation; hereinafter: the “GDPR”).
• Act on the Implementation of the General Data Protection Regulation (Official Gazette 42/18)
• Other applicable sources depending on the specific situation in terms of compliance with the legal obligations of the controller, all as set out in this Privacy Policy (Art. 6(1)(c) GDPR)

5. What personal data we process and for what purposes

5. 1

If you are our supplier / business partner, we will request the following data from you (or we will obtain/verify them in the relevant public register):

• name and surname of the legal representative (e.g. director of the company or holder of a sole proprietorship/family farm/other comparable activity)
• your OIB (Personal Identification Number), registered office address (which may coincide with your address of residence/domicile) and IBAN if you are operating in the form of a sole proprietorship/family farm/self-employed activity or other comparable form which is equated with a natural person
• your signature
• contact details such as e-mail address and mobile phone number

Such processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (Art. 6(1)(b) GDPR). Without this data, the performance of the agreed engagement is not possible.

In order to comply with legal obligations (e.g. keeping records of invoices with the tax authorities), certain documents (e.g. invoices) containing your personal data will be forwarded to our accounting service provider.

Depending on the circumstances, if it is necessary for the protection of our legal or financial interests, we may share the aforementioned data with providers of legal advisory services (law firms), auditors, tax advisors and similar bodies, all subject to confidentiality obligations or the existence of a duty to preserve professional secrecy.

Data collected in this manner is not transferred to third countries.

All data that forms part of accounting records (e.g. invoices) is retained for 11 years (Art. 10(2) of the Accounting Act). Other data is retained for as long as necessary for the statute of limitations period for damages to expire (5 years from the occurrence of the damage).

5.2.

If you are an employee of our business partner, we will request the following data from you (or we will obtain/verify them in the relevant public register):

• name and surname
• contact details such as e-mail address and mobile phone number
• We need this data in order to facilitate cooperation through easier and faster communication. Such processing is based on our legitimate interest (Art. 6(1)(f) GDPR), for which a corresponding proportionality assessment has been carried out.
• Depending on the circumstances, if it is necessary for the protection of our legal or financial interests, we may share the aforementioned data with providers of legal advisory services (law firms), auditors, tax advisors and similar bodies, all subject to confidentiality obligations or the existence of a duty to preserve professional secrecy.
• Data collected in this manner is not transferred to third countries.

We retain this data until the expiry of the business cooperation with our partner (and your employer), or for a shorter period if your employment with your employer ceases. Exceptionally, it is possible that we may retain documentation (e.g. correspondence) containing your data (e.g. e-mail correspondence) for a longer period, but no later than 5 years from the cessation of cooperation with your employer, if this is necessary for the possibility of initiating judicial or similar proceedings.

5.3.

If you visit our website, www.decode.agency, certain data will be processed:

• through the use of cookies. You can find out more about the use of cookies in our Cookie Policy. The remainder of the text under this Section 5.4. relates to the following processing:
• by completing the contact form (which you can use to either send us a message or schedule a 30-minute online introductory meeting), in which case we will request your name and surname, your business e-mail address, telephone number and LinkedIn profile information, as well as a description of the project/enquiry, so that we know who is contacting us and how to respond to your message.

We also offer the option of subscribing to our newsletter.

Purpose of processing: Legitimate interest of the Controller (Art. 6(1)(f) GDPR).

Recipients of data: Depending on the circumstances, if it is necessary for the protection of our legal or financial interests, we may share the aforementioned data with providers of legal advisory services (law firms), auditors, tax advisors and similar bodies, all subject to confidentiality obligations or the existence of a duty to preserve professional secrecy. We are also required to share this data upon request with public authorities (e.g. the police).

Transfer to a third country: Data collected in this manner is not transferred to third countries.

Data retention period: Data is retained for one year from the receipt of the message; and for longer if judicial or similar proceedings have been initiated in relation to the message.

5.3.

If you contact us as a candidate for a employee position, we will need to process certain personal data:

• name and surname
• date of birth
• address of residence/domicile
• contact details (mobile phone number and e-mail address)
• data on education or other qualifications necessary for the specific position
• data from your curriculum vitae and/or cover letter
• data about your website or profile on platforms (LinkedIn, blogs, GitHub, etc.)

Purpose of processing: Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (Art. 6(1)(b) GDPR). This data is necessary for us to be able to assess whether you meet the required criteria for the position.

Recipients of data: We collect this data through the BambooHR portal (a company which, as a processor, provides recruitment services and with which we have concluded an appropriate data protection agreement, and the servers on which the data is stored are located within the EU). Furthermore, if you are a candidate for a position that involves working with a specific client, it is possible that the client may wish you to also undergo their recruitment process, in which case you will be invited to forward the data to the said client as well.

Transfer to a third country: Data collected in this manner is not transferred to third countries.

Data retention period: We retain this data for as long as the recruitment process for the specific position lasts. After that, the data is erased if an employment relationship has not been established.

5.3.

If you are our employee, you will receive a detailed notice regarding the processing of personal data.

6. Data protection

The Controller is committed to protecting the personal data of its clients, partners and employees, and in order to ensure such protection, takes appropriate technical and organisational measures and, as necessary:

• ensures the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
• implements the timely restoration of the availability of and access to personal data in the event of a physical or technical incident;
• regularly tests, assesses and evaluates the effectiveness of technical and organisational measures for ensuring the security of data processing.

All organisational and technical measures are described in our internal documentation, which is regularly updated, and all our staff have been made aware of the rules contained therein.

Every employee of the Controller is obliged to maintain data confidentiality.

The Controller takes all necessary measures to ensure that data is processed in a secure manner and is responsible for the protection of personal data and the prevention of its loss and misuse, and ensures that no unauthorised person can access, disclose, transfer, alter or erase the data being processed.

7. Data transfers

The Controller does not sell or rent personal data to third parties. However, there are certain circumstances (as set out in the above descriptions of individual personal data processing operations) in which we may share personal data without further notification to the data subject:

• With public authorities and regulatory bodies if required by legal obligations.
• With other recipients with a legal basis, such as courts, for the purpose of fulfilling the legal obligation of cooperation and provision of data.
• With providers of legal advisory services, human resources services in recruitment procedures, auditors, tax advisors and similar bodies, all subject to confidentiality obligations or the existence of a duty to preserve professional secrecy.

8. Legal basis for data processing

The Controller (as set out in the above descriptions of individual personal data processing operations) shall process data on the basis of the following legal bases:

• On the basis of the consent of the data subject which has been given for the processing of his or her personal data for one or more specific purposes (hereinafter: consent), based on Art. 6(1)(a) GDPR.
• On the basis of a contractual obligation where processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (hereinafter: performance of a contract), based on Art. 6(1)(b) GDPR.
• Where processing is necessary for compliance with a legal obligation to which the controller is subject, based on Art. 6(1)(c) GDPR.
• Where processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, based on Art. 6(1)(f) GDPR.

9. Data subject rights

We respect the rights and freedoms of data subjects. Under the GDPR, all data subjects in the process of personal data processing have the following rights:

9.1. Right to information (right of access): The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing, the categories of personal data concerned, the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations, where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period, the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing, the right to lodge a complaint with a supervisory authority, where the personal data are not collected from the data subject, any available information as to their source, the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject (* Art. 15 GDPR).

Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards.

The Controller shall provide a copy of the personal data undergoing processing. For any additional copies requested by the data subject, the Controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.

9.2. Right to rectification: The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

9.3. Right to erasure (‘right to be forgotten’): The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies: 

(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; 

(b) the data subject withdraws consent on which the processing is based; 

(c) the data subject objects to the processing and there are no overriding legitimate grounds for the processing, or the data subject objects to processing carried out for the purposes of direct marketing; (d) the personal data have been unlawfully processed; 

(e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; 

(f) the personal data have been collected in relation to the offer of information society services to a child.

9.4. Right to restriction of processing: The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies: where the data subject contests the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the personal data; where the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; where the controller no longer needs the personal data for the purposes of processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; where the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.

9.5. Right to data portability: The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent or on a contract and where the processing is carried out by automated means.

9.6. Right to withdraw consent: Where the processing of data is based on the consent of the data subject, the data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

9.7. Right to object: The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

9.8. Lodging objections/complaints

All objections and complaints, as well as requests for the exercise of the above-mentioned rights, may be submitted at any time using the following contact information:

• by e-mail: to the e-mail address gdpr@decode.agency
• in writing: DECODE HQ d.o.o., Zagreb, Radnička cesta 47, with the notation “personal data protection”

The Controller shall commence an investigation of the objection when the objection is submitted to the above-mentioned addresses. We shall respond to your enquiries/objections without undue delay and in any event within one month of receipt of the request. That period may be extended by a further two months where necessary, taking into account the complexity and number of the requests. You shall be informed of any such extension within one month of receipt of the request, together with the reasons for the delay.

Where the requests of the data subject are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the requested action; or refuse to act on the request.

Every data subject shall have the right to lodge a complaint with a supervisory authority if he or she considers that the processing of personal data relating to him or her infringes the GDPR. Such complaints may be submitted to the following addresses of the Croatian Personal Data Protection Agency (Agencija za zaštitu osobnih podataka):

• In person (by making an oral statement on the record)
• In writing to the address: Agencija za zaštitu osobnih podataka, Ulica Metela Ožegovića 16, 10 000 Zagreb
• By completing the online form available on the Agency’s website
• By sending an e-mail to: azop@azop.hr
• By sending a fax to the number: 01/ 46-090-99

No appeal is permitted against the decisions of the Croatian Personal Data Protection Agency, however an administrative dispute may be initiated before the competent administrative court by filing a lawsuit.

10. Amendment of the privacy policy

We reserve the right to amend the contents of this Privacy Policy. This Privacy Policy shall enter into force on the date of publication on our website. The last update was made on 25 November 2025.