Izjava o privatnosti podataka

ADRIATIC SUMMER j.d.o.o. (hereinafter: the Company), in accordance with the provisions of Article 7 of the Personal Data Protection Act (Narodne novine, No. 106/12 – consolidated text) and Article 7 of Regulation (EU) 2016/679 of the European Parliament and Council of April 27, 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), informs all users regarding the processing of personal data.

**Privacy Statement**
**Effective Date: September 2023**

This Privacy Statement applies to the Company and all its websites and other applications. It describes how we collect and use information, which may include personal data you provide on our websites. It also outlines the choices available to you regarding our use of your personal data and how you can access and update that information.

This Privacy Statement is considered an addition to the terms of the General Terms and Conditions of the Visage Concept Store online store.

This Privacy Statement applies to any and all users of the Company's services concerning privacy, specifically in relation to the Personal Data Protection Act of the Republic of Croatia and Regulation 2016/679 of the European Parliament and Council of April 27, 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

**Data Collection**

he types of personal data we collect include: - Your first name, last name, email address, phone number, and home address. - Personal identification number, ID card or passport number. - A copy, scan, or photograph of your ID card or passport and date of birth may be collected for identification purposes, either upon request by a delivery driver or through an application. Biometric data (such as facial photos) from IDs or passports, even if uploaded to our website or online application, will never be stored or processed. Service may be denied (e.g., delivery of a shipment if you do not provide an ID card or passport). - Bank account numbers may be collected for transferring money during cash on delivery payments or for refund requests in case of order cancellation and product returns. - Video recordings may be collected in any of the Company's premises. If voice recordings are collected, you will always be informed. Video recordings are primarily collected for quality, safety, and fraud detection purposes. License plate numbers of vehicles may be visible on video recordings. - Credit card information (card type, number, cardholder name, expiration date, and security code) may be collected if payment by credit card is offered for a particular service, in

accordance with credit card rules and credit card processors. Data related to your marketing preferences or provided during participation in surveys, contests, or promotional offers. You can always choose which personal data (if any) you want to provide. However, if you choose not to provide certain details, it may affect some of your transactions with us or result in services being denied.

**Data We Collect Automatically**

When you use our website, we also collect information automatically, some of which may be personal data. This includes data such as language settings, IP address, location, device settings, device operating system, login information, usage time, requested URL, status report, user agent (browser version information), operating system, browsing history, user ID from external services like social networks (if you consent and explicitly permit this), and types of data viewed. We may also collect data automatically through cookies.

**Purposes of Processing**

We use your data for the following purposes:

A. **Delivery Information**: We use your personal data to complete and manage your delivery requests or requests from third parties involved in the delivery process, including the delivery driver, recipient, payment receiver, and our cooperators who may arise from using our online or offline services. B. **Customer Service**: We use your personal data to provide Company services. C. **User Reviews**: We may use your data to send you an email invitation to write a user review after providing you with a service. This can help other users choose the service that best suits them. If you submit a user review, it may be published on our website. D. **Marketing Activities**: We also use your data for marketing purposes, to the extent permitted by law. When using your personal data for direct marketing purposes (e.g., commercial newsletters and marketing notices about new products and services or other offers we believe may interest you), we include an opt-out link if you do not want to receive them. E. **Other Communications**: Depending on the data you provided, we may contact you via email, mail, phone, or SMS. This may be for several reasons: a. To address and respond to your requests as needed. b. If you have not completed a purchase or your shipment has not been delivered, we may send you an email or SMS as a reminder to complete the delivery request, especially if there is a delivery exception (e.g., shipment sent to the wrong address, recipient was absent, or similar events). c. When using our services, we may send you a questionnaire or request a review of your experience with our website. We believe this additional service is beneficial for both you and us as your feedback can help us improve our website. F. **Analysis, Improvement, and Research**: We use personal data for research and analysis purposes. We may engage a third party to conduct this on our behalf. We may share or disclose the results of such research (including with third parties) in an anonymous, aggregate form. We use your personal data for analytical purposes, to improve our services, enhance user experience, and improve the functionality and quality of our online delivery services. G. **Security, Fraud Detection, and Prevention**: We use information, which may include personal data, to prevent fraud and other illegal or unauthorized activities. We also use this information to investigate and detect fraud. Personal data may be used to assess risk and for security purposes, including user authentication. For these purposes, personal data may be shared with third parties such as law enforcement authorities, all in compliance with applicable laws and external advisors. H. **Legal Purposes and Compliance**: In certain cases, the information you provide, which may include personal data, is necessary for resolving legal disputes or complaints, regulatory investigations, and compliance, to enforce agreements, or for compliance with legal requirements by law enforcement agencies if legally mandated. If we use automated means to process personal data resulting in legal effects or significantly affecting you, we will use reasonable measures to protect your rights and freedoms, including the right to human intervention. We will never process personal data in automated decision-making that would place you in a disadvantaged position compared to other private individuals

**Legal Bases**

For purposes A and B, we rely on contract performance: Using your data may be necessary for the performance of a contract you or another party have entered into with us for providing delivery services and purchases. For instance, if you use our services to order a product and arrange delivery online or offline, we will use your data to fulfill our obligation to perform and manage that service within the contract we have with you. If there is no specific contract, the General Terms and Conditions and General Terms of Use of the website and online application apply. For purposes C – H, we rely on legitimate interests: We use your data for our legitimate purposes, such as providing the most relevant content for the site, emails, and newsletters, improving and promoting our products and services, and content on our website, administrative purposes, fraud detection, and legal purposes. When using personal data for our legitimate purposes, we always prioritize your rights and interests over our rights and interests. For purpose H, we also rely, as applicable, on our obligation to comply with applicable laws. If required by applicable law, we will seek your consent before processing your personal data for direct marketing purposes. If required by applicable law, we will seek your consent. You can withdraw your consent at any time by contacting us at any of the addresses provided at the end of this Privacy Statement. If you wish to object to the data processing described in C – F and there is no direct opt-out mechanism available (e.g., in your account settings), please contact info@visageconceptstore.eu.

**Data Sharing**

This may include personal data such as your name, contact details, payment information, and any preferences or service requests you have provided when ordering delivery. We share your data with our partners, including transportation companies and independent contractors, solely for processing the shipment from receipt to delivery and any related activities (including, but not limited to, customer service). We do not sell or rent your data.

**Authorities**

We disclose personal data to law enforcement and other government bodies if required by law or strictly necessary to prevent, detect, or prosecute criminal offenses and fraud.

**International Data Transfers**

The transfer of personal data described in this Privacy Statement may involve international transfers to countries whose data protection laws may not be as comprehensive as those within the European Union. When required by European law, we will only send personal data to recipients who provide an adequate level of data protection. In such cases, we enter into contracts to ensure that your personal data remains protected according to European standards. You can request access to these contractual items at the contact information provided below.

**Security**
All our business and online applications and partners implement reasonable measures to prevent unauthorized access and misuse of information, including personal data. To protect and secure information and personal data, we use appropriate business systems and procedures. We also employ security procedures and technical and physical restrictions to access and use personal data on our servers. Access to personal data is permitted only to authorized personnel for business purposes.
**Data Retention**
We will retain your data, which may include personal data, if we deem necessary to provide you with a service, comply with applicable laws, resolve disputes with you or other third parties, and prevent fraud. The duration of retention will be determined by the nature of the service provided, the type of data, and applicable legal and regulatory requirements.
**Your Rights**
You have the right to:
- **Access**: Request a copy of the personal data we hold about you. - **Rectification**: Request that we correct any inaccuracies in the personal data we hold about you. - **Erasure**: Request that we delete your personal data under certain circumstances. - **Restriction**: Request that we restrict the processing of your personal data under certain circumstances. - **Portability**: Request that we transfer your personal data to another data controller or provide it to you in a structured, commonly used, and machine-readable format. - **Objection**: Object to the processing of your personal data under certain circumstances, including processing for direct marketing purposes. If you wish to exercise any of these rights, please contact us at the contact information provided below.
**Contact Information**
For any questions or requests regarding this Privacy Statement or your personal data, please contact us:
**Email**: info@visageconceptstore.eu **Address**: ADRIATIC SUMMER j.d.o.o. , Kamila Pamukovića 38, 22211 Vodice
**Changes to This Privacy Statement**
We may update this Privacy Statement from time to time to reflect changes in our practices or legal requirements. We will notify you of any significant changes by posting the revised Privacy Statement on our website or through other communication channels.
**Last Updated**: September 2023

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