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Check the actual company, not its group name

AZOP’s 2023 explanation points to the public participant list. The reviewed Commission adequacy list has the same qualification: establish the receiving legal entity, participation and covered data. No organisation’s certification was checked here.

For a Zagreb business using both an American affiliate and a software provider, each recipient needs its own assessment. The provider’s marketing assurance does not establish the affiliate’s route, or the other way round.

Sources: Croatian Personal Data Protection Agency (AZOP): Scope of participating U.S. organizations; questions 1, 3 and 6–7 European Commission: Current adequacy list: United States limited to participating commercial organizations

If participation does not cover it, assess another route

AZOP discusses other Chapter V tools and safeguards where relevant adequacy does not apply. Assess the actual route, its conditions and any additional measures before relying on it. Purposes, access, contracts, security, information to people and onward disclosures still matter.

Sources: Croatian Personal Data Protection Agency (AZOP): Chapter V explanation and historical Schrems II / Privacy Shield account Croatian Personal Data Protection Agency (AZOP): Scope of participating U.S. organizations; questions 1, 3 and 6–7

Scope

  • AZOP’s general article was updated 6 September 2022, before the July 2023 framework; it remains historical context, not exclusive current advice. Croatian interpretation was AI-assisted. No actual transfer or full GDPR review is completed.

Next step

Identify the actual U.S. recipient and assess its relevant participation or another applicable transfer route before access.

Sources & review notes

The source records distinguish access dates from substantive review dates. Updating an explanation does not itself recheck the law.

AZOP third-country transfer guidance, updated September 6, 2022

Croatian Personal Data Protection Agency (AZOP)

Passage, dates and research notes

official-guidance · Chapter V explanation and historical Schrems II / Privacy Shield account

Ažurirano: 6.9.2022.

Accessed: 2026-11-13T01:00:31.006741+00:00 · Meaning reviewed: 2026-11-13T01:11:25.461559+00:00 · Next review target: 2026-12-13

Actual full body read. This page expressly predates the July 2023 framework and cannot by itself establish present U.S. transfer options. Current 2026 related-news widgets do not update the 2022 article body. Used only as historical context with later AZOP guidance and the live Commission list. Croatian interpreted with AI assistance.

AZOP: July 10, 2023 adoption of the EU-U.S. adequacy decision

Croatian Personal Data Protection Agency (AZOP)

Passage, dates and research notes

official-guidance · Scope of participating U.S. organizations; questions 1, 3 and 6–7

poduzećima iz SAD-a koja sudjeluju u okviru za zaštitu podataka između EU-a i SAD-a.

Accessed: 2026-11-13T01:02:21.899527+00:00 · Meaning reviewed: 2026-11-13T01:11:25.461559+00:00 · Next review target: 2026-12-13

Actual country-regulator article read, including participating-organization scope, certification and the public-list check. Its account is from 2023 and was corroborated against the live Commission adequacy list. No actual company certification or subsequent litigation survey is claimed. Croatian interpreted with AI assistance.

Data protection adequacy for non-EU countries

European Commission

Passage, dates and research notes

official-guidance · Current adequacy list: United States limited to participating commercial organizations

(commercial organisations participating in the EU-US Data Privacy Framework)

Accessed: 2026-11-13T01:02:19.267221+00:00 · Meaning reviewed: 2026-11-13T01:11:25.461559+00:00 · Next review target: 2026-12-13

Actual current page read, including its qualified U.S. list entry and later review references. This shared EU source corroborates the country-regulator account; it is not counted as an independent Croatian-specific rule or as a specific recipient check.

Detailed rule records (1)
Croatian U.S. data transfers: check the later framework and the actual recipient Depends on the facts

Establish the actual data recipient and a current GDPR Chapter V transfer route. AZOP’s later 2023 explanation limits the EU-U.S. adequacy route to participating U.S. organizations, corroborated by the Commission’s live list. The 2022 Privacy Shield discussion is historical and does not by itself state all present U.S. transfer options.

When to check: Before relying on the named invoice, export, filing or transfer arrangement. Source review: 2026-11-13.

AZOP third-country transfer guidance, updated September 6, 2022 AZOP: July 10, 2023 adoption of the EU-U.S. adequacy decision Data protection adequacy for non-EU countries
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