Privacy policy an Cookie Policy
PART I — PRIVACY POLICY
1. Introduction
This Privacy Policy (the "Policy") describes how AML-KYC j.d.o.o., Papova ulica 4, 10000 Zagreb, Croatia, Company Registration Number (OIB): 23032607666 (the "Company", "we", "us" or "our") collects and processes personal data of visitors to the website seecapitalmarkets.com (the "Website").
The Policy has been prepared in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the "General Regulation" or "GDPR"), the Croatian Act on the Implementation of the General Data Protection Regulation (Official Gazette 42/2018), and the Croatian Electronic Communications Act (Official Gazette 76/2022).
The Website provides informational content regarding the capital and money markets of South-East Europe, including data on stock exchanges, investment funds, indices, real assets, currencies, and interest rates. The Website does not require visitors to register a user account or submit personal data in order to access the informational content.
Please read this Policy carefully before using the Website. By continuing to use the Website, you confirm that you have read and understood the content of this Policy.
2. Data Controller
The data controller for your personal data is:
AML-KYC j.d.o.o.
Papova ulica 4, 10000 Zagreb, Croatia
Company Registration Number (OIB): 23032607666
Email for data protection matters: dpo@seecapitalmarkets.com
For all questions regarding the processing of personal data, the exercise of your rights, or complaints, please contact the Company at the address above.
3. Personal Data We Collect
Given that the Website has a strictly informational purpose and does not require registration or submission of personal data by visitors, the Company does not collect personal data directly from visitors. By visiting the Website, only the following categories of data are automatically collected, and exclusively through cookies (see Part II of this document):
Technical and analytical data:
- IP address (in anonymised form in accordance with the GA4 standard)
- Browser type and version
- Device type and operating system
- Browser language
- Website usage data (pages visited, duration of visit, referral source, clicks)
- Approximate geographical location (at country or city level, not precise)
- Date and time of visit
Advertising data (where applicable and subject to your consent):
- Interaction data with advertisements (impressions, clicks)
- Identifiers for personalised advertising purposes (Google advertising network cookies)
The Company does not collect special categories of personal data (such as data concerning health, religion, race, political opinion, sexual orientation, or similar), biometric data, or data of children under 16 years of age.
4. Legal Basis and Purposes of Processing
Purpose of processing | Data type | Legal basis |
Basic Website functionality (technical security, language preference, dark/light theme) | Technical data | Legitimate interest (Art. 6(1)(f) GDPR) |
Traffic and behaviour analysis to improve Website content | Analytical data | Consent (Art. 6(1)(a) GDPR) |
Display of personalised and non-personalised advertisements | Advertising data | Consent (Art. 6(1)(a) GDPR) |
Compliance with legal obligations (e.g. responding to requests from competent authorities) | All of the above categories | Legal obligation (Art. 6(1)(c) GDPR) |
Consent for analytical and advertising purposes is obtained through a cookie consent banner on your first visit to the Website. You may withdraw or modify your consent at any time by clicking the "Cookie Settings" link located in the footer of every page.
5. Google Analytics and Google Advertising Network
The Website uses Google Analytics 4 (GA4) provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) for the purpose of traffic analysis and improving the user experience. Google Analytics uses cookies that enable the analysis of how the Website is used. Data collected through GA4 is anonymised at the IP address level and does not allow identification of individual users.
The Website also uses Google AdSense provided by the same legal entity, which enables the display of third-party advertisements. Google AdSense and associated advertisers may use cookies to display personalised advertisements based on your prior visits to this and other websites. A list of Google advertising partners is available at https://support.google.com/adsense/answer/9012903.
You may disable third-party advertising cookies at https://adssettings.google.com or through the consent management tool on this Website.
Google may transfer collected data outside the European Economic Area, in which case it applies Standard Contractual Clauses approved by the European Commission to ensure an adequate level of data protection.
6. Recipients of Personal Data
The Company does not sell or otherwise exchange personal data for commercial purposes. Personal data may be shared only with the following categories of recipients:
- Google Ireland Limited – as the provider of Google Analytics and Google AdSense services
- Hosting and technical support providers – who act as processors on the basis of a data processing agreement pursuant to Art. 28 GDPR
- Competent government authorities – when required by the Company's legal obligations (e.g. the Croatian Personal Data Protection Agency, courts, police)
7. Transfers of Data Outside the EEA
Data collected via Google Analytics and Google AdSense may be transferred to Google servers located outside the European Economic Area. Google Ireland Limited applies Standard Contractual Clauses approved by the European Commission, ensuring an appropriate level of data protection in accordance with Art. 46 GDPR.
The Company is not a party to any other data transfers outside the EEA.
8. Retention Periods
Data collected through Google Analytics is retained for a maximum period of 14 months from the moment of collection, after which it is automatically deleted. The retention period for advertising cookies is defined by the individual policies of the respective advertising service providers and typically does not exceed 13 months.
Strictly necessary technical cookies are deleted at the end of the session or within the period specified for each individual cookie in Part II of this document (Cookie Policy).
9. Your Rights
Pursuant to the GDPR, as a data subject you have the following rights concerning the processing of your personal data:
- Right of access – to request information on whether your personal data is being processed and to obtain a copy of such data
- Right to rectification – to request the correction of inaccurate data or the completion of incomplete data
- Right to erasure ("right to be forgotten") – to request the deletion of personal data where there is no lawful basis for further processing
- Right to restriction of processing – to request a temporary restriction of processing in certain circumstances
- Right to data portability – to receive your personal data in a structured, commonly used, and machine-readable format
- Right to object – to object to processing carried out on the basis of legitimate interest
- Right to withdraw consent – to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal
- Right to lodge a complaint with a supervisory authority – to file a complaint with the Croatian Personal Data Protection Agency (AZOP):
Croatian Personal Data Protection Agency (AZOP)
Selska cesta 136, 10000 Zagreb, Croatia
Phone: +385 (0)1 4609-000
Email: azop@azop.hr
Website: www.azop.hr
You may exercise your rights by sending a request to dpo@seecapitalmarkets.com or in writing to the Company's address. The Company will respond to your request within 30 days of receipt, or within a maximum of 90 days in exceptionally complex cases, in which case you will be notified of the extension.
10. Data Security
The Company applies appropriate technical and organisational measures to protect personal data from unauthorised access, loss, destruction, or alteration, including:
- Encrypted communication (HTTPS/TLS)
- Access to data restricted exclusively to authorised persons
- Regular updates of software components
- Cooperation with verified service providers ensuring a high level of data protection
Despite the measures applied, transmission of data over the internet is never entirely secure, and the Company cannot guarantee absolute security of data in transit.
11. Changes to This Policy
The Company reserves the right to amend this Policy at any time. Visitors will be informed of all material changes by notice on the Website. We recommend that you periodically review the current version of the Policy, which is always available at this address.
The date of the last update is indicated at the top of this document.
12. Contact
For any questions, requests, or comments regarding the processing of personal data, please contact us at:
AML-KYC j.d.o.o.
Papova ulica 4, 10000 Zagreb, Croatia
Email: dpo@seecapitalmarkets.com
PART II — COOKIE POLICY
13. What Are Cookies
Cookies are small text files that a website stores on your computer, tablet, or mobile device when you visit it. They allow the website to remember your actions, settings, and preferences over time, so that you do not have to re-enter the same information on every visit.
We use cookies to ensure the proper functioning of the Website, to analyse traffic, and – subject to your consent – to display relevant advertisements.
14. Cookie Types by Duration
Session cookies
Temporary cookies that are stored only while your browser is open. They are automatically deleted when you close your browser.
Persistent cookies
Cookies that remain on your device after you close the browser, for a predefined period of time or until you manually delete them.
15. Cookie Types by Origin
First-party cookies
Cookies set directly by the Website you are visiting (seecapitalmarkets.com).
Third-party cookies
Cookies set by other service providers whose technology is integrated into the Website (Google Analytics, Google AdSense, and associated advertisers).
16. Cookie Types by Purpose
16.1 Strictly necessary cookies (always active)
Legal basis: Legitimate interest (Art. 6(1)(f) GDPR)
Strictly necessary cookies are essential for the basic functioning of the Website. They enable navigation, remember your language preference, save your theme selection (dark/light), and store your cookie consent decision. Without these cookies, the Website cannot function properly, and therefore they cannot be disabled.
16.2 Analytical cookies
Legal basis: Consent (Art. 6(1)(a) GDPR)
Analytical cookies collect anonymous information about how the Website is used, via Google Analytics 4 (GA4). The collected data includes the number of visitors, traffic sources, most-visited pages, and average session duration. IP addresses are processed in anonymised form and do not allow identification of individual users. This data helps us improve the content and structure of the Website.
16.3 Advertising cookies
Legal basis: Consent (Art. 6(1)(a) GDPR)
Advertising cookies are placed by Google AdSense and associated advertising partners. They are used to display personalised advertisements on the Website and on other websites you visit, based on your interests, and to measure the effectiveness of such advertisements (impressions, clicks, conversions).
16.4 Functional cookies
Legal basis: Consent (Art. 6(1)(a) GDPR)
Functional cookies enable additional Website functionalities such as remembering your preferences and providing a personalised user experience. They do not track your activity on other websites.
17. List of Cookies
The following tables provide an indicative list of cookies used on the Website. The list may be updated from time to time in line with the technical evolution of the Website.
Strictly necessary cookies
Cookie name | Source | Duration | Purpose |
scm_consent | seecapitalmarkets.com | 12 months | Stores your cookie consent decision |
scm_lang | seecapitalmarkets.com | 12 months | Remembers your language preference (HR/EN) |
scm_theme | seecapitalmarkets.com | 12 months | Remembers your display setting (dark/light) |
.AspNetCore.* | seecapitalmarkets.com | Session | ASP.NET Core framework technical cookie for session management and antiforgery protection |
Analytical cookies (Google Analytics 4)
Cookie name | Source | Duration | Purpose |
_ga | Google (.seecapitalmarkets.com) | 2 years | Distinguishes users for statistical purposes |
_ga_ | Google (.seecapitalmarkets.com) | 2 years | Stores GA4 session state |
_gid Google | (.seecapitalmarkets.com) | 24 hours | Distinguishes users (if Universal Analytics compatibility is used) |
Advertising cookies (Google AdSense)
Cookie name | Source | Duration | Purpose |
IDE | doubleclick.net | 13 months | Ad personalisation and effectiveness measurement |
NID | google.com | 6 months | Google ad personalisation |
__gads, __gpi | seecapitalmarkets.com | 13 months | AdSense advertising identifier |
Note: The exact set of cookies and their durations depend on the configuration of service providers and may change independently of the Company. The current list of cookies is also available through the consent management tool in the footer of the Website.
18. Managing Your Consent
When you first visit the Website, a consent management tool (cookie consent banner) is displayed, giving you the option to:
- Accept all cookies
- Reject all non-essential cookies (only strictly necessary cookies remain active)
- Set customised preferences by cookie category
You may change your decision at any time by clicking the "Cookie Settings" link located in the footer of every page.
The withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.
19. Disabling Cookies via Your Browser
In addition to the consent management tool, you may also disable cookies through your browser settings. Detailed instructions for the most popular browsers:
- Google Chrome
- Mozilla Firefox
- Microsoft Edge
- Apple Safari
- Opera
Note: disabling strictly necessary cookies may limit or prevent the Website from functioning properly.
Additional information about cookies is available at www.allaboutcookies.org.
20. Final Provisions
This document combines the Privacy Policy and the Cookie Policy for the Website seecapitalmarkets.com. The Company reserves the right to amend this document at any time, in line with the technical evolution of the Website and changes to applicable regulations. The current version is always available at this address, and the date of the last update is indicated at the top of the document.
For any additional questions, please contact us at dpo@seecapitalmarkets.com.