Autocesta Zagreb – Macelj d.o.o.
Privacy Policy for motorway users and visitors of the www.azm.hr website
With this Privacy Policy, Autocesta Zagreb – Macelj d.o.o., Garićgradska 18, Zagreb (hereinafter: AZM) protects the privacy of its users – visitors of the website www.azm.hr and users of the motorway – and takes care of their personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (the Regulation) and the Act on the Implementation of the General Data Protection Regulation (Official Gazette 42/2018) (the Act). Pursuant to Article 13 of the Regulation, AZM uses this Privacy Policy to transparently and publicly disclose the ways in which it processes personal data, exclusively in accordance with the principles of the Regulation.
Personal data and processing of personal data
Personal data means any information relating to an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified, directly or indirectly.
Processing of personal data means any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Collection of personal data
AZM collects personal data that data subjects provide voluntarily, and through video surveillance of the motorway route. Data are collected in the following ways:
- By automated processing when vehicles enter and use the motorway, while driving along the motorway route and at toll plazas, in the form of video recordings from the video surveillance system of individual sections of the motorway route
- By sending e-mails to AZM e-mail addresses
- Through the contact form on the AZM website
- Through personal contact with AZM employees
Personal data are collected and processed only for specified purposes communicated to users – data subjects, and are not further processed in a manner incompatible with the purpose for which they were collected, unless otherwise provided by law or based on the user’s consent.
Purpose and legal basis of processing
Motorway users
AZM collects, i.e. processes by automated means, personal data of motorway users in the form of recordings that allow the recognition of vehicle registration plates and, depending on recording conditions, possibly the faces of the driver and passengers. The purpose of processing is the performance of tasks carried out in the public interest and compliance with AZM’s legal obligations.
The legal basis for processing for these purposes is the fulfilment of AZM’s obligations under the Roads Act (Official Gazette 84/11, 18/13, 22/13, 54/13, 148/13, 92/14, 110/19, 144/21, 114/22, 04/23), such as monitoring and analysing road safety on public roads, organising the toll collection system, and informing the public about the condition and passability of public roads, emergencies on public roads and weather conditions relevant to safe traffic.
Personal data collected through video surveillance are kept for a maximum of six (6) months in accordance with the Regulation and the Act, except where they serve as evidence in judicial, administrative, arbitration or other proceedings.
Visitors of the www.azm.hr website and personal contact
Providing data is necessary in order to respond to enquiries and complaints sent by e-mail to one of our e-mail addresses or made through personal contact with AZM employees.
The legal basis for this purpose is the legitimate interest of AZM and/or the user. Some data are collected automatically – you can read more in the section on web cookies.
Personal data collected in order to respond to enquiries and complaints are kept until the enquiry or complaint procedure is completed, except where they serve as evidence in judicial, administrative, arbitration or other proceedings.
Contact form on the website
The contact form on the Contact page collects your name and surname, e-mail address and the content of your message, solely in order to reply to your message. The legal basis for the processing is your consent, which you give by ticking the box next to the form before sending your message. You can withdraw your consent at any time by writing to dpo@azm.hr; this does not affect the lawfulness of processing before the withdrawal.
Messages are stored in the website management system, which only authorised AZM employees can access, and may be forwarded to AZM’s official e-mail address. They are kept for no longer than 12 months from receipt and are then deleted automatically, except where they serve as evidence in judicial, administrative, arbitration or other proceedings. The sender’s IP address is not stored.
Access to personal data, transfer to third countries
Personal data are used exclusively for the purposes stated above and, in the course of processing, will be available to external processors with whom AZM has concluded contracts. External processors are reputable EU organisations engaged by AZM to perform outsourced functions, namely the authorised company for the management, supervision and maintenance of the motorway, accounting, IT support, and consulting and legal services.
In addition, on the basis of legal obligations, personal data will be made available to representatives of competent authorities (e.g. the police, courts, the Personal Data Protection Agency), upon written request.
Personal data are not transferred to third countries, in accordance with the Regulation and the Act.
Security of personal data
Personal data will be stored and processed within the statutory period and protected by adequate security measures. Backup copies are made of all data.
All personal data are protected by adequate technical and organisational measures against unauthorised access, alteration, loss, theft or any other breach and misuse, including:
- The obligation of all external processors and all recipients to protect users’ personal data through appropriate contracts or contractual clauses
- Application of the principle of data minimisation, i.e. reducing the amount of personal data collected and processed
- Application of the principle of transparency, i.e. appropriately informing data subjects about the processing of their personal data
- Regular checks of security and personal data protection measures
Web cookies
The website www.azm.hr uses web cookies. The information collected in this way may contain personal data and serves the better functioning of the website and an improved user experience. When visiting the website, users can give or refuse their consent to their use. More information is available in the Cookie statement.
Rights of data subjects
AZM ensures the conditions for users to decide on the processing of their personal data. In particular, the following rights are provided:
– the right of access, the right to rectification, the right to erasure, the right to restriction of processing, the right to data portability, the right to object, and the right to lodge a complaint with a supervisory authority.
Users can request the exercise of these rights:
- electronically, to the e-mail address: dpo@azm.hr
- in writing, to the address Autocesta Zagreb – Macelj d.o.o., Garićgradska 18, Zagreb, marked “Personal data protection”.
If users believe that the processing of their personal data is contrary to the General Data Protection Regulation, they have the right to lodge a complaint with the competent supervisory authority. For the Republic of Croatia, the supervisory authority is the Personal Data Protection Agency (Agencija za zaštitu osobnih podataka), Selska cesta 136, 10000 Zagreb, Croatia, web: https://azop.hr/, tel.: +385 1 4609 000.
Note – identification of the applicant is necessary when submitting a request. The reason is the protection of the user as the owner of the personal data.
Resolving misunderstandings or additional questions
To resolve possible misunderstandings or ask additional questions regarding personal data protection, users can contact us at dpo@azm.hr.
Entry into force and amendments to the Privacy Policy
This Privacy Policy enters into force and applies to all users from 25 May 2018.
This Policy may be amended and supplemented. The current version is always available on the website www.azm.hr, at AZM’s registered office and at all sales points on the motorway.
Contact
For any additional questions, you can contact us at:
Autocesta Zagreb-Macelj d.o.o.
Garićgradska 18, 10000 Zagreb, Croatia
Telephone: +385 1 3689 600
E-mail: office@azm.hr