Privacy Policy

PRIVACY POLICY Kali tuna d.o.o. fishing, fish farming and fish processing

Welcome to Kali tuna d.o.o., fishing, fish farming and fish processing company privacy policy (Short Name: Kali tuna d.o.o.). Kali tuna d.o.o. company is owner of the website
Kali tuna d.o.o. company, VAT: 92418838517, headquarter Address: 23272 Kali, Put Vele Luke 70, activity: 03.21 Marine aquaculture (NKD 2007), ownership: J Trading Inc, Japan as the Controller of your data, is committed to respecting your privacy and your personal information. This Privacy Policy explains the policies and practices we follow to protect your personal information that we hold.

Kali tuna d.o.o., fishing, fish farming and fish processing in order to deliver your services, it is necessary for us to collect and process your personal information.

Who we are
Kali Tuna and our affiliated company Lubin ribarstvo d.o.o. have been contributing to the local industry and employment for a long time. We are not only focusing on our profitability, but also striving to share the benefits with the society through job development, stimulating the local economy, and further developing our sustainable business. Our local tuna farmers have more than 20 years of working experience. Their knowledge and diligent work attitude are the greatest assets to our company.

Data controller and legal framework
The collection and storage of data is carried out in accordance with the provisions of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation), the Act on Implementation of the General Data Protection Regulation (Official Gazette, No. 42/2018) and other regulations governing this area that are applicable in Republic of Croatia.

Scope of application
This Policy applies to any processing of personal data by Kali tuna d.o.o. unless other Kali tuna d.o.o. policy prescribes otherwise. Exceptionally, with regard to the processing of data of custemers of Kali tuna d.o.o., this Policy prevails over all other policies when such other policies prescribe rights and obligations regarding the processing of data in a different manner.

Implementation of data-protection principles
Kali tuna d.o.o. company within the framework of the implementation of this Policy, pays special attention to respecting the principles of data processing and processes data:
- Lawfulness, fairness and transparency - we process personal data lawfully, fairly and in a transparent manner in relation to the data subject.
- Purpose limitation - we collect personal data for a specific, explicit and legitimate purpose. We clearly state what this purpose is, and only collect data for as long as necessary to complete that purpose.
- Data minimisation - we ensure that personal data we process is adequate, relevant and limited to what is necessary in relation to our processing purpose.
- Accuracy - we take every reasonable step to update or remove data that is inaccurate or incomplete.
- Storage limitation - we delete personal data when we no longer need it.
- Integrity and confidentiality - we keep personal data safe and protected against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures

Legal basis for collection
The legal basis for the stated collection purposes may be:
- Legal;
- Contractual;
- Key interests of data subjects
- Legitimate interest overridden by interests of data subjects; or
- Consent or explicit consent of data subject, depending on the purpose of processing and the type of personal data.

Points of data collection
We collect your personal information in several ways:
- through the official e-mail Kali tuna d.o.o. company, when we make inquiries or reservations,
- third parties, subagents who enter into an agreement with us on your behalf with Kali tuna d.o.o.,
- by contacting our employees where you personally, voluntarily provide personal data for the purpose of processing for the realization of the agreed services.

Purposes for collecting personal information
We collect, hold, use and disclose your personal information for the purpose it was collected and related purposes, including:
(a) to identify you;
(b) to give you information about the goods or services we or our related entities provide;
(c) to consider your request for us to supply goods or services;
(d) to enable us to supply goods or services;
(e) to manage your accounts;
(f) to manage and deal with any possible legal actions, including dispute resolution;
(g) for billing purposes;
(i) to collect overdue payments;
(j) to respond to complaints;
(k) to administer community consultation;
(l) to deal with any enquiries or any feedback you may have;
(m) if you enter one of our competitions or promotions, to administer your participation in that competition or promotion;
(n) to manage and respond to requests for information;
(o) to assess your application for a community grant (if applicable);
(p) for general administrative purposes;
(q) for research, analysis and statistical purposes;
(r) for direct marketing;
(s) to perform risk assessments;
(t) to assist in monitoring and reviewing customer service;
(u) to establish and maintain customer records;
(v) for workplace health and safety purposes;
(w) for employment and recruitment purposes;
(x) to manage relationships with our business customers, suppliers, services providers and contractors;
(y) to comply with any applicable laws, regulations or codes of practice;
(z) to obtain a credit report;
(aa) to consider your credit worthiness;
(bb) to assess and process your commercial credit application; and
(cc) for any other purpose for which you have given your consent.

What type of personal information is collected from you?
Kali tuna d.o.o., as the data controller collects and process personal data based on laws regulating
These are the following data (which can be changed in terms of positive regulations):
- Name and surname;
- Address of residence (Croatian citizens);
- E-mail address;
- Telephone number
- Information that is publicly available

Information we process as a contractual obligation
When you contact us about a service we provide as part of our business, create an account on our website (buy a product or service from us, or otherwise agree to our terms and conditions) a contract is formed between you and us. Any processing of information that may lead to a contract - e.g. contacting us to enquire about a service or product - is also processed in this way as it may lead to a contractual obligation.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

We may use it in order to:
- verify your identity for security purposes
- sell products to you
- provide you with our services
- provide you with suggestions and advice on products, services and how to obtain the most from using our website
We process this information on the basis there is a contract between you and us, or that you have requested we use the information before we enter into a legal contract.

Additionally, we may aggregate this information in a general way and use it to provide information to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual are not personally identifiable.

Information we process with your consent
Through certain actions when there is no contractual relationship between us, such as when you browse our website or ask us to provide you with more information about our business, products or services, you are providing your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information.

Sometimes you might give your consent implicitly, such as when you send us a message by email to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide information, for example to monitor the performance of a particular page on our website.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us, or by choosing to unsubscribe from emails that we send you.

Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, in doing so. Where we process your information on this basis, we do so after having given careful consideration to:
- whether the same objective could be achieved through other means
- whether processing (or not processing) might cause you harm
- whether you would expect us to process your data, and whether you would consider it reasonable to do so.

For example, we may process your data on this basis for the purposes of:
- record-keeping for the proper and necessary administration of our organisation/business
- responding to unsolicited communication from you to which we believe you would expect a response
- protecting and asserting the legal rights of any party
- insuring against or obtaining professional advice that is required to manage organisational/business risk
- protecting your interests where we believe we have a duty to do so.

Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation, such as Labor law, tax or insurance obligations.
We may be required to give information to legal authorities if they request it or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.

Sending a message via our website or contacting our support team
When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

If you use the Contact Us feature to make inquiries or to sign up for newsletters or updates, we will know your name and email address. These will be stored in our email and contact system a password-protected, secure.

Kali tuna d.o.o., will not send any unsolicited information, including email. You will, however receive emails if you have provided us with your email address. To discontinue receiving emails from us, please contact DPO or click on the “unsubscribe” link in the emails.

Transfer of data to third parties
- The access to the personal data, where necessary and to a limited extent, may also be granted to third party processors.
- Company that provide IT or other services), who store such data in their databases until due processing of such data is completed.
- We will conclude a detailed contract with such parties regarding their powers and obligations during the processing of personal data, in accordance with the requirements of the Regulation.
- Under certain circumstances, external parties and Kali tuna d.o.o. company may jointly determine the purpose and manner of personal data processing. In that event, such external partners and Kali tuna d.o.o. company will be considered joint data controllers.
- Should, within the data processing, data be transferred to third countries, Kali tuna d.o.o. company will ensure the compliance with high standards of protection to in order to comply with the highest possible standard of personal data protection in accordance with the strict requirements of the Regulation.

Data storage period
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Data that was lawfully collected by is stored for a period of time prescribed by a particular law or other positive regulation.
Data that was contractually collected by the Kali tuna d.o.o. company is stored only for a period of time necessary to fulfil the contract or provide a service.
The period in which a company keeps personal data is limited to a strict minimum and accordingly Kali tuna d.o.o. company prescribes the deadlines for the retention or periodic review of certain personal data so that they do not keep longer than is necessary to fulfill the whole of the collected data.

Data provided by Kali tuna d.o.o. company collects on the basis of a contractual relationship, and will only be required for the purpose of fulfilling the contract or providing the service for the maximum of 5 years when a general statute of limitation is imposed under the Mandatory Obligations Act.

Kali tuna d.o.o. invoices issued and received as well as all other documents relevant to the determination and payment of VAT are kept within the deadlines prescribed by the General Tax Code, or 10 years from the beginning of the statutory limitation on the determination of the tax liability, subject to the condition that special regulations do not determine the longer deadlines for their keeping. The Accounting Act (Official Gazette 109/07 and 54/13) prescribes a period of at least 11 years for the keeping of documents on the basis of which the data are entered in the business books, with the deadline for the keeping of these accounting documents to expire on the last day of the business year to which relate to the affairs of the book in which the documents were entered.

Many of our External Third Parties are based outside the EU so their processing of your personal data will involve a transfer of data outside the EU including Japan. Brussels, 23 January 2019 European Commission adopts adequacy decision on Japan, creating the world's largest area of safe data flows.

What are the criteria to assess adequacy?
Adequacy does not require the third country's data protection system to be identical to the one of the EU. It is based on the standard of "essential equivalence". It involves a comprehensive assessment of this country's data protection framework, both of the protection guarantees applicable to personal data and of the relevant oversight and redress mechanisms available. The European Data Protection Authorities have established a catalogue of elements that must be taken into account when assessing the adequacy of data protection of another country.

Whenever we transfer your personal data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further European Commission: Adequacy of the protection of personal data in non-EU countries.

Technical and integrated data protection
Kali tuna d.o.o., as the data controller, takes utmost care to meet the highest organisational and technical data protection standards. We, therefore, taking into account state of the art developments, the cost of implementation and the nature, scope, context and purpose of processing, as well as the risks arising from data processing of various levels of probability and severity that may affect the rights or freedoms of natural persons, at the time of choosing the processing resources and at the time of the processing itself, take appropriate technical and organisational measures to enable the effective application of data protection principles.

Kali tuna d.o.o. company experienced a data breach, we would take emergency measures to secure our systems, then promptly notify all Site Users that a data breach had  occurred, providing all appropriate information to enable individuals to protect their privacy and any affected accounts, and providing contact information forquestions.
We would then remove further threats of breach to the best of our ability with the help of our professional and technical advisors. We would also notify all applicable law enforcement of the data breach and cooperate with any investigation.

Rights of the data subject
Regardless of the basis for data collection, you can, at any time, free of charge, request:
Access to data, rectification of data or completion of incomplete data in all databases of personal data, upon which Kali tuna d.o.o. company will grant you the access or rectify your data, depending on your request, in all its databases;
Erasure ("right to be forgotten") of personal data from all databases of personal data, upon which the Kali tuna d.o.o  company will erase such data from all its databases except those that the Kali tuna d.o.o. company is required to maintain and keep on the basis of positive regulations and when there are no overriding legitimate reasons for processing or when processing is not necessary for the establishment, exercise or defence of legal claims;
Restriction of processing of your data or lodge a complaint regarding the processing of such data;
Transfer of data we have collected about you to you yourself or to third parties ("right to data portability"), in accordance with positive legal regulations;
Withdrawal of consent, when data were given on the basis of consent, without any negative consequences;
To lodge a complaint with a supervisory authority – Personal Data Protection Agency (for more information, please visit

Please send your written request to the contact e-mail address of personal data protection officer company Data controller: Kali tuna d.o.o., fishing, fish farming and fish processing
VAT: 92418838517
Headquarter Address: 23272 Kali, Put Vele Luke 70
Phone: +385 23 28 28 00 
Telefax: +385 23 28 28 10

This Privacy Policy is available at official website Kali tuna d.o.o. company and at reception desks of all our facilities.
If you have any questions about this Privacy Policy or concerns about the way we process your Personal Data, please contact us by e-mailing us using the contact form provided here.
We retain the right to make changes to this statement with time, which might bring about a change in the publication date. We would therefore like to ask our visitors and users to access this statement from time to time, in order to be accurately informed about the ways in which we protect their privacy.

GDPR data subject request


Tuna farming technology is based on catching the wild tuna. With careful selection of food and controlled feeding regime, we can make a positive impact on quality, or more precisely, on the color and fat levels of the fish. With careful selection of food and controlled feeding regime, we can make a positive impact on quality, or more precisely, on the color and fat levels of the fish.