Data protection policy
Purpose and scope of the Data Protection Policy
With this policy, the management of Energia naturalis d.o.o. (hereinafter referred to as: ENNA) undertakes to define the approach to personal data protection and privacy for all companies within the ENNA Group, assigns responsibilities, defines the rules for the handling of personal data and provides comprehensive support for the data management system in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and other applicable regulations on the protection of personal data and information security.
Through the implementation of this Privacy Policy as a common code of conduct within the Group, the ENNA Group supports and respects the privacy and protection of personal data in its business processes, relationships with employees, customers and business partners and ensures the highest level of information security.
This policy shall be applicable to the entire operations of the following ENNA Group companies:
ENERGIA NATURALIS d.o.o. for investments and management, Economic zone Vukovar 13, Vukovar, PIN: 65900776536;
ENNA NEXT d.o.o. for supplies and services, Economic zone Vukovar 13, Vukovar, PIN: 61700516273
ENNA LOGIC d.o.o. for transport and services, Economic zone Vukovar 13, Vukovar, PIN: 53488178655;
LOGIC FINANCIAL d.o.o. for investments and management, Economic zone Vukovar 13, Vukovar, PIN: 27354907951
ENNA TRANSPORT d.o.o. for freight transport, Economic zone Vukovar 13, Vukovar, PIN: 87583888894;
ENNA FRUIT d.o.o. for production and marketing, Radnička cesta 39, Zagreb, PIN: 35345009214;
ENNA AGRO d.o.o. for the production and marketing of agricultural products, Economic zone Vukovar 13, Vukovar, PIN: 22945077554
ENNA ESCO d.o.o. for consulting and services, Economic zone Vukovar 13, Vukovar, PIN: 77752255036
ENNA SOLAR d.o.o. for consulting and services, Economic zone Vukovar 13, Vukovar, PIN: 59149709878
ENNA GEO d.o.o. for services, Economic zone Vukovar 13, Vukovar, PIN: 93706478234
ECO RECYCLING PARK d.o.o. for services, Economic zone Vukovar 13, Vukovar, PIN: 53782715851
MOSLAVINA VOCA d.o.o. for production, trade and service Ulica Trnoščica 14, Dugo Selo, PIN: 20972056960
DESOL d.o.o. for production, trade and services, Economic zone Vukovar 13, Vukovar, PIN: 63483307101
GEO POWER BABINA GREDA d.o.o. for research, development, trade and services, Economic zone Vukovar 13, Vukovar, PIN: 95533888135
GEO POWER ZAGOCHA d.o.o. for electricity production and exploration of mineral raw materials, Economic zone Vukovar 13, Vukovar, PIN: 87576535731
The policy is available to all employees and other interested parties on the websites of the above-mentioned companies. Any future amendments to this Policy will be made known and published in a timely manner.
Responsibility for the implementation of the Policy
ENNA's Board of Directors shall provide support to ENNA Group companies, all sectors/organizational units and the Data Protection Officer in the implementation of this Policy by providing them with the necessary resources for the implementation of the principles of personal data processing and the application of technical and organizational measures for the protection of personal data.
At the level of the ENNA Group, a Privacy Group has been established, which consists of persons authorized for the implementation of this Policy:
Member of the Board of Directors, responsible for privacy and protection of personal data;
Designated Data Protection Officer;
Authorized person from the Information Technology department;
Authorized person in the field of legal affairs;
Authorized person from the HR department;
Authorized person from the Accounting department;
Authorized person from Marketing;
Authorized person from the Sales, supply and transport department.
All employees and third parties who process personal data as part of the business relationship are obliged to act in accordance with and in the manner set out in this Policy.
Principles relating to processing of personal data
ENNA Group has adopted and implements the following principles relating to the collection, processing and storing of personal data:
Lawfulness, fairness and transparency
Personal data is only processed when there is a relevant legal basis for this (e.g. contractual relationship, data subject's consent, legal obligation or legitimate interest of the ENNA Group).
During data collection and throughout the processing process, all relevant information about the processing of personal data and their rights is available to respondents and is provided in clear and simple language.
Purpose limitation
Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. ENNA Group provides transparent information on what the collected data is used for and limits the processing of personal data to what is necessary to achieve the purpose of processing.
Data minimisation
When collecting personal data, the ENNA Group limits itself only to data that is necessary, appropriate and relevant in relation to the purposes for which they are processed.
Storage limitation
Personal data must be kept in a form that makes it possible to identify data subjects for no longer than is necessary for the purposes of the processing. Upon completion of the processing purpose and legal requirements, ENNA Group will delete or anonymize personal data.
Accuracy
ENNA Group ensures that all personal data is accurate and up-to-date during the entire processing period. Inaccurate or incomplete data shall be updated or deleted in a timely manner if the accuracy of the data cannot be ensured.
Integrity and Confidentiality
ENNA Group shall implement appropriate technical and organizational measures to protect personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage to personal data.
The level of protection and the types of measures applied shall be based on an assessment of the risk of a particular processing operation to the rights and freedoms of the data subject.
Personal data protection by design and data protection by default
When designing new, and when changing or expanding existing systems and processes for processing personal data, ENNA Group applies this Policy, taking into account the latest achievements, the cost of implementation, and the nature, scope, context and purposes of processing, as well as risks to the rights and freedoms of individuals. resulting from data processing.
Reliability
Within the scope of the procedures for the processing of personal data, ENNA Group provides corresponding records and other evidence on the basis of which the reliability and compliance of the processing with the above-mentioned principles can be determined at any time.
Rights of data subjects
Depending on the legal basis and method of personal data processing, data subjects may exercise the following rights in relation to processing carried out by the ENNA Group:
The right of access to data and information about data processing, including a copy of personal data;
Right to rectification of data;
The right to erasure;
The right to restriction of processing;
The right to data portability:
The right to object (when the processing is based on the legitimate interest of the ENNA Group)
Rights related to automated decision-making including profiling.
Data subjects can exercise their rights by submitting a request electronically to dpo@enna.hr or to the registered business address of one of the ENNA Group companies
Regardless of the purpose and legal basis of the processing, all data subjects may always lodge a complaint with the supervisory authority: Croatian Personal Data Protection Agency, Selska cesta 136, 10 000 Zagreb, azop@azop.hr.
Date of the last amendment: September 24, 2024
Remark:
Detailed information on the processing of personal data in accordance with Article 13 of the General Data Protection Regulation are provided to data subjects at the time of collection of their personal data, and are available on the websites of companies withing the ENNA Group and in other documents accessible to data subjects in a timely manner (contracts, general terms and conditions, etc.).