This Personal Data Protection Policy (the “Policy”) applies to the personal data processing performed by the company Arivera Fruit d.o.o., Ulica Trnoščica 14, 10370, Dugo Selo (hereinafter referred to as Arivera Fruit), as data controller for the personal data of:
· Arivera Fruit employees
· Arivera Fruit employment candidates
· Members of the Arivera Fruit governance bodies
· Arivera Fruit business partners and suppliers
· Reporters of irregularities at Arivera Fruit (whistleblowers).
1. Purpose and Scope of the Personal Data Protection Policy
In its operations, as well as in its relationship with employees, clients and business partners, Arivera Fruit shall promote and respect the privacy and protection of personal data, making sure to provide the highest level of information security in accordance with the General Data Protection Regulation EU 2016/679 (GDPR) and other applicable regulations from the area of personal data protection and information security.
The purpose of this Policy is to make sure that the personal data processed by Arivera Fruit are appropriately kept and protected, that such personal data are only retained for as long as necessary and that data that are no longer required are safely erased or destroyed.
Arivera Fruit shall provide support in implementing this Policy to all divisions / organisational units and to the data protection officer by securing the resources required to implement the personal data processing principles and to apply the technical and organisational personal data protection measures.
All employees and third parties that process personal data as part of the business cooperation are obligated to act in accordance with and as stipulated by this Policy.
2. Personal Data Processing Principles
Arivera Fruit has adopted and implemented the following principles in collecting, processing and storing personal data:
Lawfulness, integrity and transparency
Personal data shall only be processed when there are appropriate legal grounds to do so (e.g. contractual relationship, consent of the data subject, legal obligation or legitimate interest of Arivera Fruit).
Throughout the entire process of collecting and processing personal data, the data subjects shall have access to any important information regarding the personal data processing and their rights, provided in a clear and simple language.
Purpose limitation
Personal data shall be collected for clearly defined legitimate processing purposes and shall not be processed for purposes other than the originally defined purpose. Arivera Fruit shall transparently state the reasons for which the collected data will be used and limit the personal data processing to processes that are necessary to achieve the intended purpose.
Data quantity reduction
When collecting personal data, Arivera Fruit shall restrict itself to only what is necessary, appropriate and relevant to achieving the personal data processing purpose.
Retention restriction
Personal data shall be retained in a form that enables the identification of data subjects for not longer than necessary to achieve the purpose of processing. Once the purpose of processing has been achieved and the legal conditions are met, Arivera Fruit shall erase or anonymise the personal data.
Accuracy
Arivera Fruit shall secure the accuracy of personal data and keep them up to date for the entire processing period. Inaccurate or incomplete data shall be updated or erased in a timely manner if it is not possible to provide for data accuracy.
Integrity and confidentiality
Arivera Fruit shall undertake appropriate technical and organisational measures to protect the personal data, including protection from unauthorised or unlawful personal data processing, accidental loss, destruction or damage.
The level of protection and the type of measures applied shall be based on the assessment of risk from the respective processing to the data subject’s rights and freedoms.
Technical and integrated personal data protection
When designing new and amending or extending existing personal data processing systems and procedures, Arivera Fruit shall apply this Policy, while taking into account the most recent achievements, the costs of implementation, the nature, scope, context and purpose of processing, as well as the risks arising from the data processing to the rights and freedoms of individuals.
Reliability
When processing personal data, Arivera Fruit shall secure appropriate records and other evidence that can be used at any time to establish the reliability and compliance of the processing with the aforementioned principles.
3. Data Subjects’ Rights
Depending on the legal grounds and the way of personal data processing, the data subjects can exercise the following rights with respect to the processing performed by Arivera Fruit:
Data subjects can exercise their rights by sending a request via email with the title (subject) “For the Personal Data Protection Officer“:
Regardless of the purpose and legal grounds of the processing, all data subjects can always lodge a complaint with the supervisory authority: Personal Data Protection Agency (Agencija za zaštitu osobnim podataka), Zagreb, azop@azop.hr.
Any future amendments to this Policy shall be timely announced and published.
Date of last amendment: 31.1.2025.
Note:
Pursuant to Article 13 of the General Data Protection Regulation, detailed information on personal data processing shall be provided to data subjects at the time of collecting their personal data, as well as in other documents made available to the data subjects in a timely manner (contracts, general terms and conditions etc.)
