We will always keep your data safe. This policy explains what information we collect about you and how we use it.

This digital application software is owned and operated by IDENTITY.

This Privacy Policy was published on December 18, 2023. Therefore, the policy comes into force for all our customers, users and visitors from 18.12.2023.

IDENTITY complies with the Data Protection Laws 1988-2018. The policy complies with the General Data Protection Regulation (GDPR) (EU) 2016/679 ("GDPR") and also complies with the Data Protection Act 2018. Therefore, we process your data securely and transparently.

In most cases, IDENTITY is the Data Processor, acting according to the instructions of Users who have created their accounts and profiles, locations that we display in the context of Events where Users can find other Users, and start a conversation with them on our platform.

The User and Events will generally be identified as the Data Controller for the purposes of the GDPR, which determines the purpose of the data and the manner in which it is processed.

Our GDPR privacy notice describes the type of personal data we collect and store about you, whether you are a customer, user or visitor. This includes user contact information including name, email address, postal address and contact number, and event information including location, name, start and end times, description and event radius.

Our privacy notice also explains how we use this information, how long the information is kept and any other relevant information about your information.

Definitions

The following definitions apply to our privacy policy:

"Application"

is a dating platform - a digital software service for connecting users.

"IDENTITY"

is a BUSINESS NAME, that is, a provider of digital software for connecting users.

"Users"

are persons who log in to the platform.

1. Information about the data controller

IDENTITY

Registered address: ADDRESS

Email address: info\@thehereandnow.app

Website: www.thehereandnow.app

Contact number: +385 99 848 3627

2. Principles of data protection

In relation to personal data, we will:

Process it fairly, legally and in a clear, transparent way;

Collect personal data only for specific and lawful reasons;

Use them only in the way we have informed you;

Ensure they are correct and up-to-date based on the information you provide

Keep your data only for as long as is necessary to achieve the purpose of the business.

Process them in a way that ensures they are not lost, destroyed or used for anything you are not aware of.

We will give them to users with whom you have chosen to connect for the purposes of bringing them into contact, for the purpose of further developing the relationship and getting to know each other.

3a. Types of data we collect

The types of data we collect include:

Your personal information including your name, year of birth, location, email address and phone number.

We collect personal information from you including any electronic devices (such as mobile phones, tablets and desktop computers) that you use when:

Use any of our services on our platform.

You register for an account on the digital application software.

You access the Event as a participant.

You exchange messages with other users within our platform.

You update your account information when you communicate with us.

We collect this data either because it is necessary for us to perform our service, it is in our legitimate interest to do so, or to comply with our legal obligations.

3b. How we collect your data

We collect data during the exchange of messages between users, accepting or rejecting other users through the connection service at events, by accessing an event by entering its active area, blocking other users, during login and registration, and updating your account information. In addition to the above, the following details are included (this is not an exhaustive list):

IT systems

Personal information is kept secure in our digital and/or electronic IT systems, which are password protected, and access to the above information is limited to IDENTITY only and will require access to perform our job duties and to provide our digital services as an advertising platform .

Marketing correspondence

If you have subscribed to our brochure via our website or other electronic platforms such as social media, we will send you brochure updates by email to share any news and information about our services and to inform you of what we are up to. This is the only time we will send you marketing messages or emails.

You can stop receiving marketing messages/emails from us at any time by emailing us.

4. Why we collect your data

To fulfill and provide our services by ensuring that we comply with the relevant legal obligations to provide our service.

To inform you about any special offers/news at that time. It is in our legitimate interest to do so in order to improve our services and also grow our business. We, of course, offer the option of opting out of receiving our marketing and update notifications.

To enable you to fully use our application software.

To prevent and detect fraud against you or us.

5. Why we process your data

IDENTITY can process your data only for special purposes in accordance with the provisions of the GDPR and the Croatian Data Protection Act:

So that we can perform the service on your behalf

To ensure that we can promote the legitimate interests of IDENTITY, workers and employers, where necessary.

All the processing we carry out falls under one of the permitted reasons. We will need to collect your personal information in order to perform the relationship we have entered into with you as a customer/visitor of our digital application software for one of our services.

We also process data to ensure that we can carry out activities that are in the legitimate interest of IDENTITY.

6. If you do not give us your information

Our main reason for processing your data is so that we can fulfill our contractual obligations agreed with you as a customer, user or visitor using our application software.

If, as a user, you do not provide us with data so that we can fulfill our agreed obligations, we cannot fulfill our obligations in providing our services to you.

7. Sharing of your information

Your data will only be shared within IDENTITET, so that application managers who are employees or owners of the application can perform their duties. We will also not share your data with authorities or third parties outside the European Economic Area.

Sharing of your data:

We will never share or sell your data/personal information to any third party, except in the case of the exceptions listed below.

Exceptions

We may share your data with the following companies, as an essential part of being able to provide our services, only for these specific purposes:

Prospective employers and recruitment agents

Payment service providers that process card payments for employers. They only receive the data they need to provide the relevant service and only for that purpose. For example, payment processing itself.

Professional service providers, such as our software host/web designer who can help us with our online software.

We may also share some of your information with others for the following reasons:

If the police or a regulatory or governmental authority investigating illegal activity asks us to provide such information regarding your activities while using our services, we will be legally required to do so.

8. Security of your data

We acknowledge our commitment to ensure the protection of your data from accidental loss or disclosure, destruction and misuse. We have implemented protective processes for this.

IDENTITY has taken the following steps to protect the personal data of customers it owns or has access to:

i. May appoint or employ individuals with special responsibilities for:

· Data processing and control.

· Comprehensive review and audit of your data protection systems and procedures.

· Monitoring the effectiveness and integrity of all data that must be protected.

ii. It provides information and training to its Workers/Employment Agents to make them aware of the importance of protecting personal information, to teach them how to do so and to understand how to treat information confidentially.

iii. It can take into account any personal data it holds, where it comes from, who it is shared with and also with whom it might be shared.

iv. It conducts risk assessments to identify any vulnerabilities in its personal data handling and processing and to take steps to reduce the risk of mishandling and potential data security breaches. The process includes an assessment of the impact and use and potential misuse of personal data.

v. Recognizes the importance of seeking consent from individuals (where appropriate) to obtain, record, use, share, store and retain their personal data and regularly reviews its procedures for doing so, including the audit trails required and followed for all decisions on consent.

IDENTITY understands that the consent of potential and current customers must be given voluntarily, concretely, informed and unambiguous.

IDENTITY will seek consent on a specific and individual basis where appropriate. You will receive complete information about the activities for which consent is requested. Relevant persons have the absolute and unhindered right to withdraw this consent at any time.

It has adequate safeguards in place to detect, report and investigate alleged or actual personal data breaches, including those caused by security breaches. He is aware of his reporting duty and breaches that cause significant harm to affected individuals to the Data Protection Commission and the data subject and is aware of the possible consequences.

To understand the implications of the transfer of personal data within the EU. If access to your data is required, the following applies:

The principle of legal privilege is always applicable. Therefore, those with access to such data will only have the minimum amount of access to the resource that they need to perform their role.

Access to personal data is securely protected. Passwords used must meet the specified complexity requirements and must be kept confidential by the user and must not be shared with anyone else, including colleagues (if any).

We regularly monitor our software system for possible vulnerabilities and attacks.

Where we share your data with third parties, we have a written contract with them to ensure that your data is kept securely and in accordance with the requirements of the Croatian GDPR.

Third parties must implement appropriate technical and organizational measures to ensure the security of your data.

Sending information over the Internet is not completely secure and therefore any such transmission is at your own risk. Once we receive your data and send it to third parties, we use all the procedures listed and appropriate technical and organizational security measures to prevent unauthorized access, alteration, deletion or transfer of said personal data.

Payments

We will never store or process your card details/card payment details/bank account details ourselves, they are processed and may be stored by our third party service providers. Your payment card information will be encrypted by the third-party payment service provider.

9. How long do we keep your data?

IDENTITY keeps your data only as long as it is necessary for us to achieve the purpose for which it was collected or further processed. This period is usually 8 years.

After the expiration of the storage period, personal data is deleted, destroyed or anonymized, unless otherwise specified by law or regulation for certain types of personal data.

To delete personal data that is in electronic form, such a deletion method is used that it is impossible to restore or restore all or part of the deleted personal data.

You have the right to exercise your right to delete this data by submitting a verbal or written request (by phone call, post or email), although we recommend a written request.

IDENTITY carries out annual checks of the personal data we hold to ensure that it has all been deleted at the end of the retention period.

10. Automated decision making

No decision about you will be made solely on the basis of automated decision-making (where a decision about you is made using an electronic system without human intervention) that has a significant impact on you.

11. Your rights in relation to your data

Data protection laws in Croatia, including the GDPR, give you certain rights in relation to the data we have about you. These rights are defined as follows:

The right to information. This means that we have to tell you how we use your data and that is the purpose of this privacy notice.

Right of access. You have the right to access the data we have about you. To do this, you need to submit a request for access to the subject [Your first and last name] by email to info\@thehereandnow.app. This information will be made available free of charge, unless the request is manifestly unfounded or excessive, particularly if it is repeated. In such circumstances, IDENTITY may reject the request.

The right to correct any inaccuracies. If any data we have about you is incomplete or incorrect, you can request us to correct it.

The right to delete information. If you want us to stop processing your data, you have the right to request that we securely delete or destroy it from our systems if you believe there is no reason for us to continue processing it.

The right to restriction of data processing. For example, if you believe that the data we hold is incorrect, we will stop processing the data (although we still keep it) until we are satisfied that the data is correct.

The right to data portability. You can transfer the information we have about you for your own purposes.

Right to access and obtain a copy of your personal data being processed: You have the right to request confirmation as to whether we are processing any of your personal data. In the event that we process your personal data, you can gain access to your personal data and certain information about how we process it. In certain cases, you can request that we send you a copy of your data in electronic form.

The right to object to the inclusion of any information. You have the right to object to the way we use your data where we use it for our legitimate interests.

The right to regulate any automated decision-making and profiling of personal data. You have the right not to be subject to an automated until making decisions in a way that adversely affects your legal rights. If you have given your consent for us to use your data, you also have the unlimited right to withdraw that consent at any time.

Withdrawal of consent means that we will stop processing data for which you have previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases we may continue to use data where permitted with a legitimate reason for doing so.

If you wish to exercise any of the above rights, please contact us as soon as possible by email at info\@thehereandnow.app.

12. Amendments to our privacy policy

We reserve the right to amend our privacy policy, while of course we ensure compliance with the relevant GDPR legislation and Croatian laws.

13. If you want to file a complaint

We hope you will be satisfied with our services. In the event that you are not satisfied with any of our services or wish to submit a complaint to IDENTITY, please contact us by email at info\@thehereandnow.app so that we can investigate your complaint as soon as possible. We will do our best to offer you an amicable solution, if possible within 14 days.

14. Data Protection Officer

Our data protection officer is Tomislav Crnički, who can be contacted at:

info\@thehereandnow.app