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Privacy policy

Hrvatske Autoceste d.o.o. (hereinafter: HAC), as the manager of the personal data processing, protects the privacy of responders and processes only personal data that is required for the purpose for which it has been collected.

1. Basic information about the manager of the personal data processing

Hrvatske Autoceste d.o.o., for operation, construction and maintenance of motorways, Zagreb, Širolina 4, OIB : 57500462912, phone: 01/4694 444, sluzbenikzazop@hac.hr

2. Purposes and legal bases of the personal data processing

HAC processes personal data in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data and on the repeal of Directive 95/46/EC (hereinafter: General Regulation).

Any processing of personal data is conducted based on an appropriate legal basis as described below.

2.1. Taking pre-contractual actions at the request of the responder and executing the contract in which the responder is a party in the sense of Clause 6, Paragraph 1, Point (b) of the General Regulation

For the purposes of executing and fulfilling contracts related to electronic toll collection (ENC) services, HAC collects and processes the following data directly from the user: name and surname, OIB, address, telephone number, e-mail address, copy of traffic license and anonymized credit card number when it is required for the performance of the contracted service.

Rights and obligations from contractual relations related to the use of motorways and toll collection are regulated in detail in the General Terms and Conditions of the Use of the Motorway and Toll Collection.

By using motorways, other data necessary for the provision of the service are automatically generated and collected, including information about the entry and exit toll plazas, date, time of entry and exit from the motorway, vehicle category, image and video records at the toll plazas, which, depending on the conditions of recording, angle and resolution of the camera, may include the license plate of the vehicle and the image of the driver and other passengers.

The aforementioned data is collected regardless of the method of toll collection, and refers to all users who pay tolls with an ENC device, but also by other methods of collection.

HAC also collects personal data when contacting users at points of sale or through customer service (by post, e-mail, telephone) for the purpose of resolving inquiries or complaints related to the use of the service.
In addition to the data of users who are natural persons, for the stated purposes HAC also collects personal data of natural persons who are authorized to represent and communicate on behalf of legal entities who are users of HAC services.
Rights and obligations from contractual relationships related to the use of the HAC ENC and Live TrafficHR applications are regulated in detail by the general conditions for the use of the respective applications, which are available to users within the application itself.

If the responder refuses to provide the specified necessary data, HAC will refuse to provide the service.

2.2. Fulfillment of HAC's legal obligations as a data controller, in the sense of Clause 6, Paragraph 1, Point (c) of the General Regulation

Based on the Roads Act, HAC is obliged to:

- organize the toll collection system and establish mutual interoperability with the electronic toll collection systems of other motorway operators;

- monitor and analyze the state of traffic safety on public roads;

- initiate procedures for the expropriation of real estate for the purposes of public road construction.

In the event of a traffic accident, vehicle breakdown, fire intervention and similar extraordinary events on the motorway, HAC workers prepare written documents (report, record, work diary of the patrol service, order to remove the vehicle) which, depending on the type of extraordinary event in question, may contain personal data of event participants or vehicle owners, namely: first and last name, OIB, identity card or passport number, address, vehicle registration number, insurance policy number and photos taken at the event location.

• In accordance with the Accounting Act, HAC is obliged to compile and keep accounting documents.

In this context, all data necessary for calculating the price and billing the service are considered accounting documents, and refer to information on the vehicle category, entry and exit toll plazas, date, time of entry and exit of the vehicle from the motorway, on the basis of which price is calculated for the use of the service, i.e. individual sections of the motorway.

• In accordance with the Act on the right to access to information, HAC is obliged to act on requests for exercising the right to access information. For these purposes, information about the request issuer is collected, which is necessary to provide the requested information and to keep records of the received requests.

• Pursuant to the Consumer Protection Act, HAC is obliged to enable its consumers (service users) to submit a written complaint either in its business premises, via post or electronic mail, and to keep a written record of complaints.

2.3. Processing required for the performance of a task of public interest or official authority, in the sense of Clause 6, paragraph 1, point (e)

• Based on the public task arising from the Roads Act, HAC informs the public about the condition and throughput of roads, extraordinary events and meteorological conditions important for safe traffic.

Video surveillance footage on certain parts of the motorway (e.g. toll plazas, sections of the motorway, tunnels and interchanges, etc.) and other relevant data collected from the competent HAC services are used for the aforementioned purposes.

2.4. The processing is necessary for the purposes of the legitimate interests of the controller or a third party, in the sense of Clause 6, paragraph 1, point (f) of the General Regulation

Based on legitimate interest, for the purpose of protecting people and property, HAC keeps records of parties' arrivals in official premises, and a video surveillance system has been installed at the entrance/exit from official premises, parking lots and other key locations.
The processing of personal data of users is also carried out for the purpose of ensuring the security of the service, preventing and detecting misuse and other harmful actions committed on the motorway to the detriment of HAC, other users and persons, as well as for the purpose of market research and analysis.
Telephone conversations between users and HAC workers are recorded and used for the purpose of improving the service and quality of work of HAC workers and resolving user objections and complaints. Before the start of the conversation, the user is informed that the conversation will be recorded.

2.5. Processing is based on the consent in the sense of Clause 6. paragraph 1, point (a) of the General Regulation

When users make inquiries, they do so freely and voluntarily, therefore HAC's processing of personal data carried out for the purpose of responding to such inquiries is based on the consent of the responders. Objections, complaints and other inquiries strictly related to the use of the service are processed on the basis of other legal grounds.

3. Processing of personal data through video surveillance

Video surveillance has been installed on motorways, interchanges, tunnels, toll plazas and other infrastructure owned or controlled by HAC.

Video surveillance of public areas is carried out by HAC as a legal entity with public powers, in accordance with the Act on the Implementation of the General Regulation on Data Protection.

In the framework of execution of its public tasks arising from the Roads Act, HAC uses the video surveillance system for the following purposes:

traffic control and management;
ensuring a high level of traffic safety on the motorway through timely detection of potential dangers and extraordinary events and timely intervention of internal and external emergency services;
informing the public about the state and throughput of motorways, extraordinary events and meteorological conditions on motorways;

On the basis of legitimate interest, HAC uses the video surveillance system for the following purposes:

identifying irregularities in the use of motorways and collection of unpaid tolls;
protection of the safety of workers, visitors, service users, business partners and other persons who, for any reason, find themselves in the premises under the control of HAC;
protection of structures, devices, equipment, installations and other property of HAC;
determination of possible liability for damage committed by HAC towards third parties and third parties towards HAC.

Personal data collected by video surveillance is stored depending on the capacity of the video surveillance system itself, and for a maximum of 6 months, except in cases where longer storage is prescribed by law or is evidence in court or other equivalent proceedings (more information in point 8. Data retention period).

Note: Considering the purpose of video surveillance and the resolution of the cameras in certain locations, video surveillance recordings are not clear and precise enough to use them to directly or indirectly determine the identity of an individual.

4. Use of cookies

On its websites ( www.hac.hr and www.prodaja.hac.hr ) HAC use necessary cookies (eng. cookies) that enable the correct operation of the website and optional cookies that are used to analyze website traffic, as well as marketing and other cookies. Such optional cookies are used by HAC exclusively based on the user's consent. More detailed information about cookies is available in Cookie Settings.

5. Security of personal data

HAC takes technical and organizational measures to protect personal data, which ensures the integrity, availability and confidentiality of personal data, while applying the principles of data protection processing in terms of reducing the amount of data, scope of processing and storage period.

HAC regularly reviews the adequacy of such measures and continuously improves them, depending on the circumstances of the processing and the risks to the rights and freedom of the data subject.

6. Source of personal data

HAC primarily collects personal data directly from responders, in connection with the provision of motorway use services and toll payments, or when users contact them with a request or inquiry.

Exceptionally, HAC collects personal data of responders from third parties, for example the Ministry of the Interior or the Center for Vehicles of Croatia, when it is necessary to identify the toll payer.

7. Recipients of personal data

In certain business processes, for example for processing payment transactions, IT support and IT-communication services, HAC uses the services of reliable partners (processors).

Processors, when necessary, process personal data while ensuring appropriate technical and organizational measures for the protection of personal data. Special contracts on the processing of personal data have been concluded with all executors, which regulate the executor's obligations regarding the protection and handling of personal data.

In certain circumstances, HAC has a legal obligation to disclose personal data to the police, judicial authorities or other competent authorities for the purposes of performing tasks within their jurisdiction, based on special regulations.

HAC does not forward personal data to recipients outside the European Union.

8. Personal data retention period

Personal data is collected, stored and processed as long as it is necessary to fulfill the purpose for which it was collected.

Data on the use of ENC devices are stored for the duration of the contractual relationship and after the termination of the contractual relationship if there is a legal obligation or legitimate interest of HAC, such as the collection of claims against the user, in which case the data is stored for 5 years from the termination of the contract in accordance with the general limitation period, i.e. until the final conclusion of the court proceedings.

Data on financial transactions constitute an accounting document and are kept for at least 11 years in line with the Accounting Act (the data required for calculating the price and charging the service is considered an accounting document, and refers to information on the vehicle category, entry and exit toll plazas, date, the time of entry and exit of the vehicle from the motorway based on which the price for using the service, i.e. individual sections of the motorway, is calculated.)

Recordings of calls to customer support are kept for 3 months.

Personal data collected by video surveillance are stored depending on the capacities of the video surveillance system, and for a maximum of 6 months, except in cases where longer storage is prescribed by law or they are evidence in the court or other equivalent proceedings.

Video surveillance recordings at toll plazas Lipovac, Zagreb East, Sveta Helena, Goričan, Bregana and Dugopolje are kept for up to 90 days.

Video surveillance footage at other toll plazas are kept for up to 30 days.

Video surveillance footage of tunnels, interchanges, road structures and parts of open sections of motorways are kept for 7 to 10 days, depending on the storage capacity. Except for recordings of events that affected the management and safe flow of traffic which are kept for a maximum of 6 months.

Personal data for which the storage periods are not defined by a special regulation are stored in accordance with the Rulebook on the preservation of archival and public documentary materials adopted by HAC as an obligation to apply the Act on Archival Materials and Archives.

9. Rights of responders

Depending on the legal basis and method of personal data processing, responders may exercise the following rights:

Right to information about processing and access and copy of data;
The right to correct incorrect and/or supplement incomplete data;
The right to delete data (if there is no longer a legal basis for further processing or storage);
Right to restriction of processing (if applicable);
The right to object to processing based on HAC's legitimate interest;
The right to withdraw previously given consent for data processing (if applicable).

HAC will take appropriate actions to undoubtedly establish the identity of the responder who requests the fulfillment of one of the aforementioned rights. In this procedure, HAC will only request the necessary data from the responders, which it already has at its disposal as a data controller.

10. The right to complain to the supervisory body

Every responder has the right to submit a complaint to the competent supervisory body, Croatian Data Protection Agency with the seat at:

Selska cesta 136, 10000 Zagreb, azop@azop.hr

11. Contact of the data protection officer

HAC has appointed a personal data protection officer.

Responders can direct all requests, inquiries or complaints to the contact officer:

Hrvatske Autoceste d.o.o.

Širolina 4, 10000 Zagreb

sluzbenikzazop@hac.hr

This privacy policy was last updated on ___ September 2024