Last updated: [date]
This policy explains what personal data we collect when you use this website and order our services, why we need it, who we share it with, how long we keep it and what rights you have. We wrote it in plain English. If anything is unclear, please contact us.
Ordering a police clearance certificate means sharing sensitive information with us: a copy of your passport, a signed power of attorney and, in the end, a document about your criminal record. We take this seriously. We collect only what the Croatian authorities and the delivery of the service need, we keep your documents in private storage that is not publicly accessible, and we delete them after your order is completed.
1. Who is responsible for your data
The controller of your personal data under the General Data Protection Regulation (EU) 2016/679 (GDPR) is:
- [Company name]
- Address: [address]
- OIB (Croatian personal identification number of the company): [OIB]
- Email: [email]
- Phone: [phone]
The services are carried out by a licensed Croatian attorney (odvjetnik), a member of the Croatian Bar Association, acting under your power of attorney. [The relationship between the company and the attorney, and whether the attorney acts as a joint or separate controller, is to be confirmed.]
Data protection contact: [email for data protection requests]. [If a data protection officer is appointed, add their contact details here.]
2. What data we collect
When you place an order
- Identity details: full name (and any previous names), parents’ names, date and place of birth, citizenship, passport number and, if you have one, your OIB.
- Background details for the application: the period when you lived in Croatia, the country where you will use the certificate and the purpose (for example immigration, a visa or work).
- Documents you upload: a scan of your passport and your signed power of attorney.
- Contact and delivery details: email address, phone or WhatsApp number and delivery address.
- Order and payment details: the options you choose (courier delivery, express), the order number, the invoice, the amount paid and the payment status. You do not pay on this website. You pay the invoice we email you.
- The documents we obtain for you: the police clearance certificate (criminal record certificate) with the apostille and, if you ask us for them, the certificate of no criminal proceedings and the sworn translation.
When you contact us
If you use the contact form or write to us by email or WhatsApp, we receive your name, contact details and your message. Please do not send passport scans or details about a criminal record through the contact form. Use the secure upload on the order page instead.
When you visit the website
Our hosting server records basic technical information needed to deliver the website and keep it secure, such as the time of a request and the pages requested. We do not use this information to identify you. See section 9 for cookies.
3. Criminal record data
The certificates we obtain contain data about criminal convictions, or confirm that there are none. Under Article 10 of the GDPR, this data needs special protection and may only be processed under official authority or where the law allows it with appropriate safeguards.
We process this data only because you ask us to, on the basis of your signed power of attorney, and only to obtain the document from the Croatian authorities and deliver it to you. The attorney handles it as part of their professional work, which is governed by Croatian law on the legal profession and bound by professional secrecy. [Legal basis under Croatian law, including the Act on the Legal Consequences of Conviction, Criminal Records and Rehabilitation and the Act on the Implementation of the GDPR, to be confirmed by the attorney.]
We never use criminal record data for any other purpose. We do not include it in emails, we do not discuss its content with anyone except you, and we do not give advice on what is written in your record through this website. If your certificate shows a record, the attorney will contact you directly.
4. Why we use your data and on what legal basis
| Purpose | Legal basis (GDPR) |
|---|---|
| Preparing and submitting your application to the Ministry of Justice, Public Administration and Digital Transformation and to the competent court | Performance of a contract with you (Art. 6(1)(b)). For criminal record data: Art. 10, under your power of attorney and Croatian law |
| Arranging the apostille and, if you ask us for it, the sworn translation | Performance of a contract (Art. 6(1)(b)) |
| Delivering the documents to you by courier or by email | Performance of a contract (Art. 6(1)(b)) |
| Taking payment and issuing invoices | Performance of a contract (Art. 6(1)(b)) and legal obligations under accounting and tax law (Art. 6(1)(c)) |
| Sending you order updates and answering your questions | Performance of a contract (Art. 6(1)(b)) or, before you order, steps you asked for (Art. 6(1)(b)) |
| Keeping the website and our systems secure, and preventing fraud | Our legitimate interest in a safe service (Art. 6(1)(f)) |
| Establishing or defending legal claims | Our legitimate interest (Art. 6(1)(f)) |
| Optional cookies (if we use them) | Your consent (Art. 6(1)(a)), which you can withdraw at any time |
We need the order details to provide the service. If you do not give them, we cannot submit your application. We do not use your data for marketing, and we do not make decisions about you by automated means, including profiling.
5. Who we share your data with
We share only what each recipient needs for its part of the work:
- The Ministry of Justice, Public Administration and Digital Transformation (Criminal Records Department), which issues the police clearance certificate.
- The competent municipal court, which issues the apostille and, if you ask us for it, the certificate of no criminal proceedings.
- A sworn court translator (stalni sudski tumač), if you order a translation. Sworn translators are bound by confidentiality.
- The courier or postal service, if you choose delivery of the paper original, which receives your name, delivery address and phone number to deliver the documents.
- Your bank or payment service and ours, which process the payment when you pay our invoice. They act under their own privacy policies.
- Our hosting and email providers ([hosting provider], [email provider]), which store data on our behalf under a data processing agreement.
- Our accountant ([accounting firm]), for invoices only.
- Public authorities, where the law requires us to share data.
We never sell your data and we never share it for advertising.
6. Transfers outside the European Economic Area
We store your data in the European Union [hosting location to be confirmed]. Some providers may process data outside the European Economic Area. In that case they use safeguards approved under the GDPR, such as the European Commission’s standard contractual clauses or an adequacy decision.
When we send your documents to an address outside the EU, the courier must carry your name and address to that country. This transfer is necessary to deliver the service you asked for (Art. 49(1)(b) GDPR).
7. How we keep your documents safe
- Passport scans, powers of attorney and certificates are stored in private storage that is not publicly accessible. They are never placed in the website’s public media library and never have a public link.
- Files get random names, and only authorised staff can open them after logging in.
- The website uses an encrypted connection (HTTPS).
- Our emails never contain your documents, links to them or any details of your criminal record.
- You do not enter any payment details on our website. You pay the invoice we email you.
8. How long we keep your data
- Uploaded documents and application details (passport scan, power of attorney, parents’ names, date and place of birth, passport number, OIB, copies of the certificates): deleted automatically within 30 days after your order is completed or cancelled.
- Invoices and payment records: kept for as long as Croatian accounting and tax law requires.
- Contact form messages: kept for as long as needed to answer you and deal with any follow-up, then deleted [period to be confirmed].
- Records the attorney must keep under the rules of the legal profession: [to be confirmed by the attorney].
We may keep data longer only if we need it to establish or defend a legal claim, and only for as long as that need lasts.
9. Cookies
We use only two kinds of cookies:
- Necessary cookies. These make the website work, for example to remember your language, keep the order form secure and remember your cookie choice. They do not need your consent.
- Optional cookies. For example, statistics about how the site is used. We set these only after you agree in the cookie banner, and you can change your choice at any time through the cookie settings link at the bottom of every page.
We do not use advertising cookies or tracking pixels. [List of cookies to be added once the cookie consent tool is set up.]
The WhatsApp button is a simple link. Nothing from WhatsApp loads on our pages. If you click it and chat with us, WhatsApp (Meta) processes your data under its own privacy policy.
10. Your rights
Under the GDPR you have the right to:
- access the personal data we hold about you and get a copy;
- correct data that is wrong or incomplete;
- have your data deleted, unless we must keep it by law;
- restrict how we use your data in certain cases;
- receive your data in a common, machine-readable format (data portability);
- object to processing based on our legitimate interest;
- withdraw your consent at any time, where we rely on consent. This does not affect processing that took place before.
To use any of these rights, email us at [email]. We may ask you to confirm your identity. We will reply within one month. Please note that if you ask us to delete your data while your application is in progress, we may not be able to complete the order.
11. The right to complain
If you think we have not handled your data correctly, please tell us first so we can try to fix it. You also have the right to complain to the Croatian supervisory authority:
Croatian Personal Data Protection Agency (Agencija za zaštitu osobnih podataka, AZOP)
Selska cesta 136, 10000 Zagreb, Croatia
Website: azop.hr
If you live in another EU country, you can also complain to the data protection authority in that country.
12. Changes to this policy
We may update this policy when our services or the law change. The date at the top shows the latest version. If a change affects an order you have already placed, we will tell you by email.