Privacy Policy

Bruketa&Žinić&Grey d.o.o. /Ltd./ Privacy Policy

BRUKETA&ŽINIĆ&GREY d.o.o. /Ltd./ take your privacy very seriously. This Privacy Policy describes why and how we collect, use, protect and share your personal information, and how to contact us regarding your privacy protection and the GDPR.

BRUKETA&ŽINIĆ&GREY d.o.o. /Ltd./ may collect your data in different ways. Be careful when you disclose your personal information to us and check the accuracy and sensitivity of the data and information provided and inserted.

Whenever we have legitimate grounds for collecting your personal information, we are not required to seek your prior consent. However, whenever we have no legitimate ground or our legitimate ground is suspected, we will always ask for your consent to use your personal data, and use such data only for the purpose for which the consent was given.

Legal grounds for personal data processing

We collect, process and make use of your personal data only for the purposes for which they were requested, which include the following:

  • Processing is necessary for compliance with the legal obligations to which the company is subject;
  • Processing is necessary for the performance of a contract to which the user is party or in order to take steps at the request of the user prior to entering into a contract;
  • Processing is necessary for the purposes of the legitimate interests pursued by the company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the user which require protection of personal data;
  • On the basis of the explicit consent given by the user to the processing of his or her personal data for one or more specific purposes.

How we collect your data

We may collect your personal information in the following ways:

  • Directly from you, e.g. personal information you give us in order to enter into or perform a contract, when you come to the company’s premises, send us your CV, attend any of our events or events of our clients, have a phone call with an individual, participate in a prize draw or competition, etc.;
  • Indirectly, publicly available data on the third-party websites (e.g. posts on social media and open online discussion fora) obtained by the use of cookies, links and similar technologies.

What information you disclose to us

While interacting with BRUKETA&ŽINIĆ&GREY d.o.o. /Ltd./, you may be asked to provide some information in the following ways:

  • When you send your CV for job applications;
  • When you send your CV and portfolio for Talent Pool;
  • When you agree to receive our newsletter;
  • Our business contacts and collaborations may reveal some data about our business partners or their employees for the purpose of performing professional activities, but also for the purpose of establishing close business contacts and relationships;
  • When you attend our public event or a celebration or take part in our surveys, competitions or prize draws, we may solicit some information such as your business card, first and last name, contact data, interests and preferences;
  • When you participate in our public event or celebration, we may take your photograph or video;
  • When you use our online services, we may receive the content that you decide to share such as comments, photographs and posts from the online discussion forum or the particulars about your interests and preferences you share with us;
  • When we represent our clients whilst performing their marketing activities arising from the contractual relationship with such client;
  • When you become our employee in compliance with applicable legal requirements.

Information we collect from the social media and BRUKETA&ŽINIĆ&GREY d.o.o. /Ltd./ website

When you use some of our social media applications and website, we can receive information concerning your social media accounts, such as e.g.:

  • When you sign in to our website with your social media account, we can receive basic data from your social media profile. Such data will depend on the privacy settings of the relevant social media account, but may include your social media ID, first and last name, profile photo, gender and language information. We may also receive additional information from the relevant social media profile provided you give us your consent to access such information;
  • When you click the “like” button or a similar link on our website, we can create a log for your activity. Besides, the content you search for may end up posted on your profile or on the social media news site. We may receive information about further interaction with such content (e.g. if your contacts select the posted content link), and integrate such information with the details stored about you;
  • When you click the “like” button or a similar link on our pages on a social media website, we can receive information about your social media profile, depending on the privacy settings of your social media account;
  • Particulars about the content you search for. For instance, when you use our website, we can collect information about your visit, such as the pages you search for, the time and location of your activities, application settings and errors and hardware activities.
    We will use the abovementioned personal information until you request that your data be deleted. Your CVs and portfolios will be used with your consent.

Information we collect while working with our business partners and their employees

While working with our business partners that are legal/natural persons, we often establish friendly and collegial relationships with you as natural persons and find out your birth date to send you a birthday greeting or a gift for birthday or holiday, to invite you to our parties and other events and celebrations, and generally socialize with you professionally and privately. By providing such data, e.g. your birth date, you allow us to send you a birthday greeting and symbolically give you a gift. You can always withdraw your consent to such processing of personal information, without detriment, as set out herein.

We will use the abovementioned database until you withdraw your consent for their use. We will keep socializing and celebrating together until you tell us not to.

Information we collect from media relations

Our core business includes the provision of PR services, which is why we often need to contact journalists. When we communicate with journalists, we collect the contact information (first and last name, email address and phone number) they make available to us.

We will continue to contact journalists by using the contact information we received from them. Some contacts from our database and used to date are private, and some are official and specific-media related.

Every journalist, or a person who regards herself/himself as such, can always withdraw their consent to contacting and using their personal contact information without detriment, as set out herein.

We will store and use the abovementioned journalists’ contact database for professional purposes until journalists withdraw their consent given to us to contact them in such way and to obtain mutual professional benefit.

Information we collect from our employees in the context of employment

We greatly appreciate the privacy of all our employees and avoid collecting their personal information without having legitimate interests in so doing. In case we need any information about our employees and their children for the purposes of the exercise of certain rights, we will always seek their prior consent, provided that such consent is necessary and that we have no overriding legitimate interest.

Our employees are obligated to provide such data for time sheet record keeping requirements as laid down in applicable labor legislation and other regulations governing the abovementioned area. The employees are always obligated to update and timey disclose accurate data in case of any modifications to the data provided initially. The employees shall be held liable for the accuracy of such data.

Personal information about our employees may be collected, processed, used and shared with third parties where necessary to exercise their rights and benefits related to employment. For such purpose, the data will be collected, processed, used and shared with third parties as laid down by legislation related to accounting, pension and health insurance, health and safety at work, and legislation and regulations adopted for the purpose of the enforcement of the Labor Act.

The information about our employees will not be shared with other parties without explicit consent given by our employees, except in case of legal obligations and contractual commitments arising from their employment contracts.

The employee information will be stored as long as it is legally binding for us to store them, and will be deleted/destroyed as soon as applicable legal pre-requirements come into force.

Information we collect when we represent our clients as a data processor

BRUKETA&ŽINIĆ&GREY d.o.o. /Ltd./ is a marketing agency that represent clients as a data processor in performing their marketing activities in accordance with a contractual relationship established with the client. In such case, the data base controller is the client we represent, and not BRUKETA&ŽINIĆ&GREY d.o.o. /Ltd./.

Whilst performing the abovementioned activities, we will always present ourselves as a representative of the client that will be indicated by their accurate name. In such communication, if you want to exercise your rights in compliance with the GDPR, you will have to contact our client directly, but we will readily assist you and provide you any required information in this regard.

When we represent our client, we can collect your personal data in several ways as follows:

  • At events where you are invited as a guest and warned by disclaimer in advance that you will be photographed and video recorded for marketing purposes of our client, indicating where exactly such material will be published. When you participate in such event, you give your consent to photographs and video recordings and to the use of such material for marketing purposes of the client/event organizer/data controller;
  • When you take part in prize draws/competitions or other sorts of contests of our clients in accordance with positive legislation, you give your consent to the use of your personal information for the purpose of a prize draw/competition and marketing activities related to such prize draw/competition;
  • When you participate in surveys we conduct for our clients, you give us your consent to use your personal information/preferences/opinions (e.g. first and last name, age, etc.) for the purpose of market analysis and other purposes specifically and clearly indicated and explained during surveys;
  • For other purposes as requested explicitly by our client, data controller.

The personal information we collect as requested by our clients while performing our professional activity according to the contractual relationship established with our client will be deleted as soon as we complete the assignment given by the client. At the request of our client we return the data base to the client, but we delete it from our records.

How we use your personal data

Your data may be used for different purposes:

  • When we provide services in accordance with contractual obligations;
  • When we organize prize draws, competitions and other promotional offers;
  • When we consider your job application in case you contact us over our website, or differently, and submit your CV;
  • When we include your CV and portfolio in our Talent Pool in case you contact us over our online form and give such data to us;
  • When we send newsletters and other communication via email or other contact data, provided that we received your prior consent for such purposes;
  • When we carry out marketing activities, we may contact you with the aim of notifying you about new contents or similar activities;
  • When we produce anonymous, overall statistics about the use of our website, which we may share with third parties and/or make publicly available;
  • When you post publicly available material on our website, we may publish and make such material publicly available somewhere else, including for our own advertising purposes;
  • Every time you post or respond to a post on our website or our social media sites (e.g on online discussion fora), we may also take note of the name of the particular forum and the time and date of your post or the message with the particulars of your account to align our marketing communication with your activity. The content of your posts or fora messages will not be used for other purposes;
  • We may use the information collected during monitoring of our website, network services and email for your protection and the protection of our employees and partners. Such information may be forwarded to law enforcement or other competent authority as required by positive legislation. When you use our website and other network services, you give your explicit consent to the abovementioned;
  • We may use photographs and video recordings made during public events and celebrations we organize for ourselves and our clients and post them on our own or our client’s website, public media releases and for our own or our client’s marketing purposes. You will be notified in advance about such intentions when you arrive at the public event/celebration by appropriate disclaimers;
  • When we send newsletter as data processor on behalf of our client as data controller, and with your consent given to our client;
  • We may put together the information collected from different sources to provide better customer support and to offer you a better, tailor-made service, content, commercial content and ads;
  • In order to protect our employees, we may reveal individual personal information only if we believe it is necessary or appropriate in order to protect health and safety of our employee, assets and/or users, and
  • For legally required reporting and data processing purposes.

Sharing personal information

As a rule, BRUKETA&ŽINIĆ&GREY d.o.o. /Ltd./ will never share your information with third parties without your permission, but there are some exceptions to this rule:

  • We may engage third party service providers to process your information on our behalf for the abovementioned purposes (e.g. providing marketing support, etc.). Our service providers will act only in accordance with our guidelines and in compliance with our policy and are subject to appropriate obligations regarding confidentiality and security;
  • We are obligated and may share your information with third parties for legal and/or commercial purposes such as e.g. with the government and competent authorities to comply with positive legislation and to fulfil reasonable requirements of such authorities, as well as legal advisers who enforce or protect our legal rights, etc.;
  • We may share anonymous, overall or general data, without identifying you, with any other third party (e.g. partners, advertisers, media, public, etc.);
  • We may forward the information about our employees to competent authorities in order to exercise rights and benefits related to employment (pension and health insurance funds, etc.).

Personal information shared by you

Our website or social media include some arrangements that facilitate the transfer and sharing of messages, photographs, videos and other content that cease to be private or confidential after you post them, e.g. fora allow you to post comments, photographs and videos (under your account name) visible to other users of such service.

International transfer of your data

We process your data within the European Economic Area. In case we need to transfer your personal information outside the abovementioned area, such transfer will take place provided that the European Commission has verified the third country’s compliance with the specific data protection level or its application of adequate protection measures in line with positive legislation.

Marketing communication

When you willingly disclose your contact data to us for the purpose of performing our marketing activities, such communication with you may include receiving particulars about our latest products and services, awards, etc.

Protection of your data

We take a lot of actions to protect your data from unauthorized access and use, e.g.:

  • Your information may only be accessed by our employees who need such information to perform their job-related activities;
  • The information is stored in special and separate folders (special folders in personal computers, special locking storage cabinets), with clearly determined access rules;
  • We have taken adequate technical and organizational actions to prevent the loss, exchange and theft of your data or access to your data by unauthorized third party;
  • We have provided adequate physical, electronic and management systems to protect and store the data collected online.


BRUKETA&ŽINIĆ&GREY d.o.o. /Ltd./ use standard technologies applied in marketing activities, such as e.g. cookies to collect information about the use of our website and email communication. More specifically, it means that such technologies could give us information about the key elements used by visitors (such as links or graphics) to our website or in emails and recognize your browser next time when you visit our website.

You may adjust your browser settings to avoid saving cookies. However, in some cases some of our website functionalities will require cookies and may be disabled should you decide to decline cookies.

Automated data processing and profiling

Your personal information will be subject to profiling in the following cases:

  • Direct promotion;
  • Promotion.

Children’s privacy

In accordance with applicable legislation in the Republic of Croatia, we consider children to be persons under the age of 16. We do not collect personal information from children without the consent given by a parent or guardian.

If a parent or a guardian has questions regarding our processing of their children’s personal information, we apply the same privacy policy as we apply to adults.

Requirements from judicial authorities

In specific cases we are allowed to share your personal information without your knowledge or consent, such as the following:

  • To prevent or reveal crime;
  • To apprehend or prosecute a perpetrator;
  • To assess or charge taxes or fees;
  • As ordered by the court of law or any other legislation.

Your rights

At any given moment, without detriment, you may:

  • Withdraw your consent for any sort of marketing communication and other processing;
  • Request a processing confirmation (about the purpose of data processing, source, category of personal information, receivers or category of receivers to whom the personal information was or could have been transferred as well as the location of such transfer, the period foreseen for personal information storage, the use of any automated decision-making and profiling);
  • Have insight into your personal data;
  • Request personal data correction or modification;
  • Lodge a complaint against further or excessive personal data processing;
  • Block unlawful personal data processing;
  • Request deletion of your personal data;
  • Request personal information transfer to another controller. You can simply sign off from our list or send your request to our email address or directly contact our Personal Data Protection Officer.

We will take every request into consideration in compliance with applicable positive legislation governing personal data protection. We reserve the right to charge costs for request processing in cases where such requests are deemed unreasonable. We will respond to every request within maximum 30 days of receiving such request.

Right to lodge a complaint with a supervisory authority

At any given moment if you think that our processing of your data has violated the Croatian or European personal data protection regulations, you can lodge a complaint against processing of your personal data with a competent supervisory authority, the Croatian Personal Data Protection Agency, or in case of amendment to the applicable regulations, with another authority that will take over its jurisdiction, and as of May 25, 2018 with a supervisory authority within the EU.


Although we take available technical, organizational and human resources actions to protect personal data against accidental or intentional misuse, destruction, loss, unauthorized modification or access, we cannot guarantee that some of the personal data we collect will never be accidentally revealed, against the provisions herein.

To the utmost extent permitted by applicable law we are excluded of liability for damage caused to users or third parties arising from accidental leakage of personal data.

Since we cannot control personal data disclosure during access to or use of other portals that is directly to third parties (e.g. whilst taking part in endorsed activities), to the utmost extent permitted by applicable law we are excluded of liability for damage that may be caused to you or third parties on account of personal data disclosure.



Zagreb, Zavrtnica 17

If you have any questions regarding your personal data processing and the exercise of your rights laid down by the GDPR, do not hesitate to contact the Personal Data Protection Officer in the following way:

Personal Data Protection Officer:

Martina Arapinac Radičević
Remetinečka cesta 75A
Phone: 095 8000 216

In case of complaints against non-compliance with this Privacy Policy and other personal data protection regulations, we will fully investigate any complaint elements and do our best to resolve them as soon as possible.

This Privacy Policy enters into force on May 25, 2018.

We regularly review data processing information and verify their compliance with our Privacy Policy. The updated Privacy Policy version is available on our website, and in case of any significant amendments to our Privacy Policy that will affect your rights and freedoms, we will make sure we notify you directly.

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