Privacy policy

Introductory provisions


DIALOG KOMUNIKACIJE d.o.o. takes care of your privacy.

These privacy rules apply to all individuals whose personal data is collected and processed in accordance with the requirements of the General Data Protection Regulation (EU) 2016/679 (hereinafter: the Regulation) and the applicable laws of the Republic of Croatia.

This Privacy Policy prescribes the types of personal data that DIALOG collects about individuals, how they use and transfer the collected data, and prescribes the rights that individuals have at their disposal regarding the use of their personal data.

This Privacy Policy also prescribes measures to be taken to protect the personal data of individuals, the period of retention of personal data and ways to exercise the rights of individuals regarding their personal data that are subject to processing.

It is also the responsibility of DIALOG to ensure that these Rules are available to all individuals whose personal data is collected by DIALOG prior to collection.

It is the responsibility of every employee of DIALOG, who collects personal data of individuals, to acquaint the individual with these Rules in order to ensure the lawful obtaining of consent for the collection and processing of personal data of individuals.


  1. Personal data

According to the definition given in the General Regulation on Personal Data Protection, personal data are “all data relating to an individual whose identity has been established or can be established (respondent); an identifiable individual is a person who can be identified directly or indirectly, in particular by means of identifiers such as name, identification number, location data, network identifier or by one or more factors specific to the physical, physiological, genetic, mental , economic, cultural or social identity of that individual. ”


  1. The data we collect

In order to be able to provide services we must collect certain personal information. We undertake to only collect data that is necessary to achieve the purpose and at the same time does not pose a threat to your privacy.

DIALOG collects your personal data such as name and surname, address of residence, e-mail address, telephone / mobile phone number, OIB (personal indetification number).

You are not obliged to provide us with your personal data, and if you choose not to provide us with your personal data, we may not be able to provide you with certain services or inform you about our activities.


  1. How we use the data we collect

The personal data we collect will be used for the following purposes:

  • providing our services
  • organization of Diablog
  • promotion of our services (newsletter)
  • to communicate with you about market surveys and researches and your participation in them
  • implementation of prize contests
  • managing, evaluating and improving our business (including developing new services, improving and innovating existing services, analyzing our services, managing our communications, performing data analysis and market researches, and performing accounting, auditing, and other internal functions)
  • to be able to respond to your requests and inquiries


In accordance with the Regulation and other legal regulations, DIALOG processes and collects personal data only if and to the extent that one of the following conditions is met:

– processing is necessary for the execution of the contract in which the respondent is a party or in order to take action at the request of the respondent before concluding the contract;

– processing is necessary in order to comply with the legal obligations of DIALOG, as the manager or executor of processing;

– processing is necessary for the needs of the legitimate interests of DIALOG as a processing manager or a third party (such as website management, data analysis and management, evaluation and business improvement).


In all other cases, when there is none of the above grounds for collecting personal data, DIALOG must obtain the consent of the respondents for the processing of personal data.

DIALOG may also use data obtained in other ways, for which it gives special notice at the time of collection. DIALOG may combine data it collects about individuals (for example through a website or from third parties) for the purposes described above.


  1. Consent to data processing

By accepting this Privacy Policy, you give us your consent for processing your personal data for specially defined purposes.

DIALOG needs your consent to process your personal data. Consent must be given explicitly. When we ask for your consent to the processing of special categories of personal data, you will be specifically informed of the purpose of the collection and the manner in which the special category of data is processed.

You may withdraw your consent at any time in accordance with the prescribed withdrawal procedure, provided that the withdrawal of consent does not affect the lawfulness of the processing based on the application prior to its withdrawal.


  1. Promotional prize contests

Our websites and the social networking sites we manage often contain information about the various games we organize. For those competitions and prize games to which we provide electronic access, we will use your personal data only for the purpose of realizing the prize contest (eg to get in touch with you in case of winning the prize game). We do not share this information with anyone outside of DIALOG except with clients for whom we organize games or to meet legal obligations.


  1. Protecting children’s personal data

DIALOG does not want and does not intend to collect personal data of persons under the age of 16, nor will it use them in any way, nor disclose them to third parties, except in the case of online prize games. If we learn that we have collected the personal information of a child under the age of 16, we will immediately delete all of the information listed from our records. If you believe that a child under the age of 16 has given us their personal contacts, please contact us as set out in this Privacy Policy.

Online contact information is used without the permission of parents or legal representatives only to respond directly to the child’s request and will not be used for any other purposes. In cases where children under the age of 16 are allowed to participate in prize games, we require the child to obtain prior permission to participate from their parents or legal representatives, and enter the e-mail address or telephone / mobile number of their parents or legal representatives. The parent or legal representative is authorized to deny the child permission to participate in prize games. If a child under the age of 16 wins the prize, the parents or legal representative will be notified by e-mail, telephone or in writing. The personal data of the child and the parent are deleted from our records if requested to do so by the parent or legal representative.

As a parent or legal representative, you always have the right to request access to all personal information about your child that we have received on one of our sites, you can request the deletion of data and / or prohibit us from future collection and use of information about your child.


  1. Data sharing

We do not disclose any personal information we receive about you, except as described in this Privacy Policy. We may share your personal information with our subsidiaries and affiliates within the meaning of the Companies Act and service providers, with whom DIALOG has entered into a service agreement for the purposes described in this Privacy Policy. Every third party is obliged to keep your data and use it only for the fulfillment of contractual obligations, acting on the orders of DIALOG or if it is necessary for the fulfillment of legal obligations.

For each transfer of your personal data to third parties, from the category of special data, your consent will be required, unless otherwise provided by law, ie. if there is a legal obligation to share data.

We may disclose your information if we have to comply with a legal obligation or if we are ordered to do so for legal purposes, to determine, exercise our legal rights, when we believe that disclosure of personal information is necessary or appropriate to prevent damage or financial loss, in case of sale or transfer of all or part of the business or assets (including status changes, deletions or liquidations of the company), and in other cases with your consent.


  1. Data transfer

We may transfer the personal information we collect about you to recipients (including our affiliates within the meaning of the Companies Act) to third countries only if:

– you have given your explicit consent to the transfer;

– the transfer is necessary for the execution of the contract concluded between the respondent and the controller or in order to take measures before signing the contract initiated by the respondent;

– the transfer is necessary for the conclusion or execution of a contract concluded between the controller and a third party, and is in the interest of the respondent;

– the transfer of personal data is obligatory or prescribed by law for the purpose of protecting an essential public interest or for the purpose of exercising or defending legal actions;

– the transfer of personal data is necessary to protect the vital interests of the respondents;

– work on the transfer of personal data to a third country for which the European Commission has assessed that it has appropriate data protection standards;

– the recipient provides a sufficient guarantee regarding the adequate protection of personal data.


  1. Data storage

We store the personal data we collect about you only to the extent necessary for the purposes for which they were collected, in accordance with the provisions of this Privacy Policy or longer if we have another legal basis for the storage of personal data.


  1. Rights of individuals

To update or correct your information, restrict the receipt of our notifications, or submit a request, please contact us as set forth in this Privacy Policy.


10.1. The right to access data

DIALOG will, at your request, confirm whether and what your data is being processed. You can request the following information:

– Purpose of processing and legal basis for data processing;

– If the processing is based on the legitimate interests of DIALOG or a third party, details of legitimate


– Categories of personal data that are collected, processed and stored;

– Recipients or categories of recipients to whom the data are disclosed or will be disclosed;

– If personal data is transferred to third countries or international organizations security information transmission of that data. The EU has authorized the transfer of personal data outside the European Economic Area areas based on the existence of minimum data protection standards. In case of data transfer in countries that are not on the list of safe countries, we will ensure the existence of certain measures to keep your data remains protected;

– The period of storage of your data;

– Details of your rights to correct, delete, restrict processing, or oppose processing data;

– About your right to withdraw your consent to the processing of your data at any time;

– How to file a complaint to the supervisory service;

– Whether it is a legal or contractual request for the collection of personal data or a request that is necessary for the conclusion of the contract, whether you are obliged to provide personal data and possible consequences for denial of personal data.

– The source of personal data if the data is not collected directly from you.

– Information and details on automated decision making, such as profiling and all key information on the logic used when creating the profile, as well as the meaning and expected consequences of such processing.

In order to establish the identity of the applicant, DIALOG accepts the following documents:

– Identity card (I.D.)

– passport

– other public document with a photograph


10.2. Right to correction

You have the right to request a correction of your data processed by DIALOG, if the stored data is inaccurate or incomplete.

10.3. Right to delete

If you prove that the reasons for which personal data are processed are no longer permissible, necessary or reasonable under certain circumstances, the relevant personal data will be deleted unless required otherwise by applicable law.

10.4. The right to limit processing

When certain conditions are used in the processing of your data, you have the right to restrict such data processing.

10.5. The right to transfer data

It is your right to transfer your data, which is processed by DIALOG, to someone else.

10.6. The right to object

You have the right to object to certain types of processing of your personal data (eg direct marketing)

10.7. The right to refuse automatic data processing, including profiling

It is your right to oppose the legal effects of the automatic processing of your personal data.

10.08. Rejecting a request for access or correction

In the event that DIALOG refuses to comply with your request for access or correction, you will be notified of the reasons for the refusal.

10.9. The right to lodge a complaint with the supervisory authority

In case you have any objections to the way your personal data is processed by DIALOG or to the way your complaint is processed, you can complain directly to the supervisory body (Personal Data Protection Agency).

11. How we protect personal information

We use organizational, technical and physical measures to protect the personal information we collect through a website that protects your personal information from accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

  1. Amendments to our Privacy Policy

This Privacy Policy may be amended or supplemented from time to time, without prior notice, in order to reflect changes in our business and practices.

  1. How to contact us

In order to update or correct your information or if you have any questions regarding this Privacy Policy or the service or your rights related to the protection of personal data, contact us by e-mail or by registered mail to Šoštarićeva 10, Zagreb.

  1. Ownership and approval of the document

The owner of this document is DIALOG. DIALOG will review this Policy in accordance with the requirements mentioned above. The current version of this document is available to all DIALOG employees at the company’s headquarters.


Marina Čulić Fischer, managing director