Privacy Policy

Last updated: March 11, 2026

Overview

Toward Shift d.o.o. respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, and share information when you interact with our website or use our services.

By accessing our website or engaging our services, you acknowledge that you have read and understood this Privacy Policy and consent to the practices described herein.

Information We Collect

Information You Provide

We collect information you voluntarily provide when contacting us or using our services:

  • Contact details including name, email address, and mailing address
  • Communication preferences and language choices
  • Property preferences, budget information, and search criteria
  • Financial information relevant to property transactions
  • Identification documents required for legal compliance
  • Any other information you choose to share in correspondence

Information Collected Automatically

When you visit our website, we may automatically collect certain technical information:

  • IP address and general geographic location
  • Browser type and operating system
  • Pages visited and time spent on our site
  • Referring website and exit pages
  • Device information and screen resolution

How We Use Your Information

We process your personal information for the following purposes:

  • Responding to your inquiries and providing requested information
  • Delivering real estate services you have engaged
  • Searching for properties matching your specified criteria
  • Coordinating property viewings and meetings
  • Conducting legal due diligence and transaction processing
  • Communicating updates about properties or services relevant to your interests
  • Complying with legal obligations and regulatory requirements
  • Improving our website functionality and user experience
  • Analyzing service usage to enhance our offerings

Legal Basis for Processing

We process your personal data based on one or more of the following legal grounds:

  • Contractual necessity: Processing is necessary to perform our services or enter into a contract with you
  • Consent: You have given explicit consent for specific processing activities
  • Legitimate interests: Processing serves our legitimate business interests while respecting your rights
  • Legal obligation: Processing is required to comply with Croatian or EU law

Information Sharing and Disclosure

We do not sell your personal information. We may share your information with:

  • Service providers: Attorneys, notaries, inspectors, and other professionals necessary to complete transactions
  • Property sellers: When you express interest in specific properties, we share relevant contact information
  • Financial institutions: Banks and lenders involved in mortgage applications you pursue
  • Government authorities: When required by law or in response to valid legal requests
  • Professional advisors: Legal counsel, accountants, or consultants who assist our business operations

All third parties receiving your information are obligated to handle it securely and use it only for specified purposes.

Data Storage and Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Secure storage of physical documents in locked facilities
  • Encryption of sensitive electronic data
  • Access controls limiting who can view your information
  • Regular security assessments and updates
  • Employee training on data protection obligations

While we strive to protect your information, no method of transmission or storage is completely secure. We cannot guarantee absolute security but commit to promptly addressing any breach that may occur.

Data Retention

We retain your personal information only as long as necessary for the purposes described in this policy or as required by law. Retention periods vary based on:

  • Active client relationships: Duration of service provision plus reasonable follow-up period
  • Transaction records: Seven years following transaction completion, as required by Croatian business regulations
  • Marketing communications: Until you withdraw consent or request removal
  • Website analytics: Typically aggregated and anonymized after 26 months

After applicable retention periods expire, we securely delete or anonymize your personal information.

Your Rights

Under applicable data protection laws, you have the following rights regarding your personal information:

  • Access: Request confirmation of what personal data we hold about you
  • Correction: Request correction of inaccurate or incomplete information
  • Deletion: Request deletion of your personal data in certain circumstances
  • Restriction: Request limitation on how we process your data
  • Portability: Receive your data in a structured, commonly used format
  • Objection: Object to processing based on legitimate interests or for marketing purposes
  • Withdraw consent: Revoke previously given consent at any time

To exercise these rights, contact us at [email protected]. We will respond to your request within one month, though complex requests may require additional time.

Cookies and Tracking Technologies

Our website uses cookies and similar technologies. For detailed information about the cookies we use and your choices, please refer to our separate Cookies Policy.

International Data Transfers

Your information is primarily stored and processed within the European Union. If we transfer data outside the EU, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.

Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected such information, we will delete it promptly.

Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. Significant changes will be communicated through prominent notice on our website or direct communication if you are an active client. The date at the top of this policy indicates when it was last revised.

Contact Information

If you have questions about this Privacy Policy or how we handle your personal information, please contact us:

Toward Shift d.o.o.
Ulica Svetog Polikarpa 24
52100 Pula, Croatia
Email: [email protected]

Supervisory Authority

If you believe we have not handled your personal information appropriately, you have the right to lodge a complaint with the Croatian Personal Data Protection Agency (Agencija za zaštitu osobnih podataka).