Privacy Policy

Controller: PIRAMIDA d.o.o. za poslovanje nekretninama i turistička agencija (real estate company and travel agency), operating under the brand L’Adria Estate, Brajde 31, 52465 Tar, Republic of Croatia, OIB (personal identification number): 54890989849.

Contact for questions and requests concerning personal data: info@ladriaestate.com, +385 98 977 8357, or by post to the registered office address.
Version and date of application: version 2026-02, applicable from 01 / 07 / 2026.

1. Purpose of this Policy

This Policy explains which personal data we process, for what purposes, on what legal bases, how long we retain them, with whom we may share them, and what rights you have. The Policy applies to website visitors, persons who send us enquiries, prospective and existing clients, owners and users of properties, buyers, tenants, lessees, their representatives and beneficial owners, persons viewing properties, business partners and other persons whose data we lawfully process in the course of our business.

2. Principles of processing

We process personal data lawfully, fairly and transparently, only for specified and legitimate purposes. We collect only the data that are necessary, we endeavour to keep them accurate, we do not retain them longer than necessary, and we apply appropriate technical and organisational protection measures.

3. What data we process

Identification and contact data: full name, OIB (personal identification number), date of birth where required, address, citizenship, telephone, e-mail, data on the representative or attorney-in-fact.
Data on the property and the legal transaction: address and location, land registry and cadastral data, ownership status, technical data, documentation, price, photographs, video recordings, floor plan, data on encumbrances and other data relevant to the brokerage.
Data required for customer due diligence: data and copies of identification documents where legally required, data on the beneficial owner, political exposure, the purpose of the business relationship, the source of funds and other data prescribed by the rules on the prevention of money laundering and terrorist financing.
Data on communication and interests: the content of enquiries and correspondence, criteria for the property sought, notes on calls and meetings, offers and negotiations.
Viewing data: full name, contact details, date and time of the viewing, property reference, signature and relevant communication.
Financial and accounting data: data required for issuing invoices, recording payments, calculating fees and fulfilling tax and accounting obligations.
Technical and internet data: IP address, device and browser type, security logs, data on website usage and cookies, depending on your consent settings.

4. From which sources we obtain data

We usually obtain the data directly from you. We may also obtain them from owners, co-owners, representatives, attorneys-in-fact, the other contracting party, another registered broker or a business partner, where there is an appropriate legal basis for doing so. We verify some of the data in publicly available or official sources, for example the land registry, the cadastre, the court register, the register of beneficial owners and other competent records, to the extent permitted by law. Where we have not obtained the data directly from you, we will provide information on the processing within the statutory period, except where a statutory exception applies.

5. Purposes, legal bases and retention periods

We process personal data for the following purposes, on the following legal bases and for the following periods:
a) Responding to enquiries and taking steps prior to a contract
• Legal basis: steps taken at the data subject’s request prior to entering into a contract; legitimate interest in orderly communication
• Data: contact details, content of the enquiry, property criteria
• Retention period: 12 months from the last relevant communication if no contract is concluded; an active demand profile for a maximum of 24 months, with the possibility of earlier erasure
b) Conclusion and performance of the brokerage agreement
• Legal basis: performance of a contract and legal obligations
• Data: identity, property, agreement, communication, offers, documentation
• Retention period: for the duration of the agreement and 5 years after its termination or the completion of the transaction; longer only where necessary due to a dispute or another statutory period
c) Keeping brokerage records and viewing confirmations
• Legal basis: legal obligation and legitimate interest in evidencing the actions performed
• Data: data on the agreement, property, price, fee, viewing and signature
• Retention period: 5 years from termination of the agreement, from the viewing or from completion of the transaction, unless a regulation or proceedings require longer
d) Prevention of money laundering and terrorist financing
• Legal basis: legal obligation
• Data: identification data, copies of documents, beneficial owner, risk assessment, source of funds
• Retention period: 10 years after the end of the business relationship or the relevant transaction, after which the data are erased or the documentation destroyed, save for statutory exceptions
e) Accounting, taxes and collection
• Legal basis: legal obligation; performance of a contract
• Data: invoices, statements, data on payment and fees
• Retention period: at least 11 years for accounting documents for which that period is prescribed
f) Handling complaints and legal claims
• Legal basis: legal obligation and legitimate interest in defending legal claims
• Data: agreements, communication, evidence, complaints
• Retention period: until final conclusion of the proceedings and expiry of the applicable time limits for legal claims
g) Photography, video recording and advertising of the property
• Legal basis: performance of a contract; legitimate interest in professional presentation; consent where required
• Data: photographs, video, floor plan, basic property data
• Retention period: for the duration of the active brokerage and for a maximum of 12 months after its termination, unless longer retention is required as evidence or further use has been separately agreed
h) Newsletter and direct marketing
• Legal basis: consent or another permitted basis under the applicable electronic communications rules
• Data: name, e-mail, record of consent
• Retention period: until withdrawal of consent or objection; evidence of consent and withdrawal is retained for 5 years
i) Website security and technical logs
• Legal basis: legitimate interest in protecting systems and users
• Data: IP address, security logs, device data
• Retention period: as a rule up to 12 months, unless a longer period is required because of a security incident
j) Analytics and marketing cookies
• Legal basis: consent
• Data: online identifiers and website usage data
• Retention period: according to the lifetime of the individual cookie stated in the cookie settings; until withdrawal of consent for future processing
If the same document falls within several categories, the longest statutory or justified period applies. Upon expiry of the period, the data are erased, anonymized or access is permanently restricted, depending on the purpose and the legal obligation.

6. Specific note on data for the prevention of money laundering

As an entity subject to the regulations on the prevention of money laundering and terrorist financing, we may be obliged to establish and verify the identity of the customer and the beneficial owner, assess risk, check political exposure and, where applicable, collect data on the purpose of the business relationship and the source of funds. Providing these data is a legal obligation. If you cannot or do not wish to provide them, we may be obliged to refuse to establish or continue the business relationship or to carry out a particular action. We do not use data collected for this purpose for marketing.

7. Photographs, video recordings and confidentiality of the property

On the basis of the brokerage agreement, we may photograph and video-record the property, produce a floor plan and publish the technical data required for advertising. We endeavour to remove or obscure personal documents, photographs of individuals, vehicle registration plates, security codes and other data that are not necessary for presenting the property. The exact address, the identity of the owner and other sensitive details are not published without an appropriate basis. If the client requests discreet or confidential brokerage, we limit the data on the property and the transaction to persons who need them for the purposes of the brokerage, to the extent permitted by law.

8. With whom we may share data

— authorised persons, employed agents and persons performing administrative or technical tasks for PIRAMIDA d.o.o. under an obligation of confidentiality;
— providers of hosting, business e-mail, IT support, security solutions, cloud storage, CRM, analytics and other digital services, when acting as processors;
— the accounting service and collection providers, to the extent necessary to fulfil contractual and legal obligations;
— lawyers, notaries public, translators, land surveyors, energy certifiers, photographers, videographers and other professional associates where their involvement is necessary or has been specifically agreed;
— other registered brokers for the purpose of cooperation on a specific transaction, applying the principle of data minimisation and without increasing your agreed fee;
— prospective contracting parties, property owners and other persons involved in negotiations, only to the extent necessary for the brokerage and respecting any request for anonymity where applicable;
— competent authorities and institutions, including courts, the Tax Administration, the authorities competent for the prevention of money laundering, the Ministry, the Croatian Chamber of Economy (HGK) and other public bodies, where there is a legal obligation or a valid request.
We do not sell personal data. Where an external provider processes data exclusively on our instructions, we regulate data protection obligations with that provider. Where the recipient independently determines the purposes and means of processing — for example a notary public, a lawyer or a competent authority acting within its powers — that recipient may act as a separate controller.

9. Transfers outside the European Economic Area

We give preference to providers and processing locations within the European Economic Area. If a particular digital provider or its sub-processor processes data outside the EEA, the transfer is carried out only by applying an appropriate mechanism, for example a European Commission adequacy decision, standard contractual clauses and, where necessary, additional safeguards. You may request information on the specific provider and the safeguards applied via our privacy contact.

10. Cookies and similar technologies

Necessary cookies are used for the operation, security and basic functions of the website. Functional, analytics and marketing cookies are used only where valid consent has been given for them. You may refuse or withdraw consent via the “Cookie settings” link. A detailed list of the current cookies, providers, purposes and durations should be set out in the Cookie Policy and in the consent management tool itself.

11. Whether providing data is mandatory

The data required for identification, for concluding and performing the contract, for keeping statutory records, for issuing invoices and for implementing anti-money-laundering measures may be contractually or legally mandatory. Without these data we will not be able to conclude a contract, advertise the property, organise certain activities or continue the business relationship. Data for the newsletter, non-essential cookies and additional marketing are provided voluntarily, and withholding them does not affect the basic brokerage service.

12. Your rights

Right of access: you may request confirmation as to whether we process your data, information about the processing and a copy of the data.
Right to rectification: you may request the rectification of inaccurate data and the completion of incomplete data.
Right to erasure: you may request erasure where there is no longer a legal basis for the processing; the right is not absolute and does not apply where we must retain the data by law or for legal claims.
Right to restriction: you may request the temporary restriction of processing in the cases prescribed by the GDPR.
Right to data portability: for data you have provided to us, where the processing is based on consent or a contract and is carried out by automated means, you may request the data in a structured and machine-readable format.
Right to object: you may object to processing based on legitimate interest on grounds relating to your particular situation.
Objection to direct marketing: you may object at any time to processing for direct marketing purposes; following an objection we will no longer use the data for that purpose.
Withdrawal of consent: you may withdraw consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.
Complaint to the supervisory authority: you may lodge a complaint with the Croatian Personal Data Protection Agency (AZOP).
You may send your request to info@ladriaestate.com or to the registered office address. In order to protect the data, we may request additional confirmation of identity. We will respond to a duly submitted request without undue delay and, as a rule, within one month. The period may be extended where the request is complex or where several requests have been received, of which we will inform you in good time.

13. Automated decision-making

We do not take decisions producing legal effects concerning you or similarly significantly affecting you based solely on automated processing. Recording the criteria for the property sought and sending relevant offers is not considered such automated decision-making.

14. Data security

We apply measures appropriate to the risk, including restricting access on a need-to-know basis, confidentiality obligations, backups, system updates, protection of user accounts and other technical and organizational measures. No system is entirely immune to risk, but in the event of a personal data breach we will act in accordance with our legal obligations.

15. Children’s data

Our services are not intended for children, and we do not knowingly collect children’s personal data via the website. If we learn that such data have been submitted without an appropriate basis, we will take steps to erase them.

16. Amendments to the Policy

We may amend the Policy due to changes in regulations, technology or the way we do business. We will publish the applicable version and the date of application on this page. If an amendment materially affects the manner of processing, we will take reasonable steps to notify the persons concerned.

17. Contact and complaints

For questions or to exercise your rights, please contact: PIRAMIDA d.o.o., Brajde 31, 52465 Tar, e-mail: info@ladriaestate.com, telephone: +385 98 977 8357.
Supervisory authority: Croatian Personal Data Protection Agency (AZOP), Zagreb. Current contact details are available on the official AZOP website.