PRIVACY POLICY

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(L’Adria Estate – Piramida Ltd.)
Last updated: July 2025

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INTRODUCTION AND GENERAL PRINCIPLES

Piramida Ltd., a real estate and travel agency with registered office at Brajde 31, 52465 Tar, Croatia, VAT ID (OIB): 54890989849 (hereinafter: the Controller), takes the protection of personal data seriously and undertakes all necessary technical and organizational measures in accordance with best practice and the obligations set out in Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) and the Croatian Act on the Implementation of the GDPR (Official Gazette 42/2018).

Our operations follow the fundamental principles of data processing: lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, and integrity/confidentiality.

If you do not agree with this Privacy Policy, please do not use our website or provide personal data.

DATA CONTROLLER

In accordance with the GDPR, Piramida Ltd., Brajde 31, 52465 Tar, VAT ID (OIB): 54890989849, acts as the data controller.

Your personal data can only be accessed by authorized persons of Piramida Ltd. (the Controller) and its partners providing business support services (processors).

If you have any questions about how your data is collected or used, please contact us at:
Address: Piramida Ltd., Brajde 31, 52465 Tar, Croatia
E-mail: info@ladriaestate.com

WHEN WE COLLECT YOUR PERSONAL DATA

We may collect your personal data in the following ways:

• through contact forms on our website, requests for information, property listings submissions, or when you provide data for follow-up inquiries,

• when you contact us directly, including records of such correspondence and any personal data shared during communication,

• through your use of our website (technical and analytical data via cookies).

PERSONAL DATA WE COLLECT AND PROCESS

Piramida Ltd. processes personal data collected during business relations, such as: name, surname, VAT ID (OIB), address, property details, etc. Where necessary and unrelated to a specific contractual relationship, we may collect data from public sources (Court Register, Land Registry, FINA) or data legitimately provided by contractual partners or third parties.

Technical data (IP address, browser type, device) and website usage data (via cookies and analytics tools) are also collected.

PURPOSES OF PROCESSING PERSONAL DATA

We process only the personal data necessary and obtained in the context of business activities, whether received from you, third parties, or public sources.

We may use your personal data for:

• verifying your identity,

• providing contracted services and fulfilling obligations arising from agreements,

• responding to inquiries,

• providing requested information or services (when you have given consent),

• notifying you of changes related to our services,

• sending promotional emails (with your explicit consent),

• fraud prevention,

• marketing communications, newsletters, and analytics/advertising (cookies).

LEGAL BASIS FOR DATA PROCESSING

Under the GDPR, processing of personal data is lawful on the following bases:

• Performance of contractual obligations – when data processing is necessary to enter into or perform a contract with you (e.g. organizing property viewings, issuing invoices, providing requested information).

• Legitimate interests – when necessary beyond a contractual relationship (e.g. legal proceedings, fraud prevention, property and personal protection, auditing, improving services, responding to inquiries).

• Compliance with legal obligations – as required by Croatian law (e.g. accounting, anti-money laundering, real estate brokerage laws).

• Consent – where you have explicitly consented to processing for specific purposes (e.g. marketing). You may withdraw your consent at any time, without affecting the lawfulness of processing based on consent prior to its withdrawal.

COOKIES AND ONLINE TECHNOLOGIES

Our website uses cookies for functionality and security, and—with your consent—for analytics and marketing.

• Necessary cookies: always active.

• Analytics and marketing cookies: active only with your consent via the cookie banner.

More details can be found in our Cookie Policy.

DATA RETENTION

We store your personal data only as long as necessary to fulfill the purposes for which they were collected, or to meet contractual/legal obligations or legitimate interests.

Where processing is based on consent, data is retained until consent is withdrawn. Withdrawal of consent does not affect the lawfulness of prior processing.

Once your data is no longer needed, it will be securely deleted, unless longer retention is required by law.

DATA SHARING

Piramida Ltd. will not disclose or make personal data available to third parties without your specific consent, except:

• to service providers engaged as processors for tasks related to fulfilling your contract (e.g. law firms, IT providers, accounting services, utility transfer authorities),

• to competent authorities for compliance with their statutory responsibilities (e.g. Tax Administration),

• to courts or public prosecutors, or in equivalent legal proceedings,

• when disclosure is required by law.

Data may be transferred to third countries (e.g. USA – Wix, Google). In such cases, appropriate safeguards are applied (EU Standard Contractual Clauses).

YOUR RIGHTS UNDER GDPR

You have the following rights regarding your personal data:

• Right to restriction of processing – in cases where accuracy is contested, when you object, when processing is unlawful but deletion is opposed, or when data is no longer needed except for legal claims.

• Right of access – to request information about your personal data we hold and how it is processed.

• Right to erasure (right to be forgotten) – to request deletion of your data where it is no longer necessary for the original purpose, subject to legal obligations.

• Right to rectification – to correct inaccurate or incomplete data without undue delay.

• Right to object – to object to processing where there is no overriding legitimate or legal reason.

• Right to data portability – to receive your personal data in a structured, commonly used, machine-readable format and transfer it to another controller, where technically feasible.

You may exercise these rights at any time by contacting us (see Contact section).

HOW TO CONTACT US

Questions, comments, and requests related to this Privacy Policy are welcome and should be addressed to:

Piramida Ltd.
Brajde 31, 52465 Tar, Croatia
E-mail: info@ladriaestate.com
Phone: +385 98 977 8357

HOW TO CONTACT THE SUPERVISORY AUTHORITY

If you believe your personal data is not being handled properly, you have the right to contact the Croatian Data Protection Agency (AZOP): https://azop.hr/kontakt/

Tar, July 1, 2025

Piramida Ltd., Tar