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PRIVACY POLICY AND PERSONAL DATA PROTECTION

1. GENERAL

We hereby undertake to protect the confidentiality of your personal data in line with the current legislation. We intend to take every appropriate measure to protect you from any possible violations and abuse. Due to their sensitive nature, we dedicate special attention and care to user personal data.

2. IMPLEMENTATION OF PRIVACY POLICY

Every full-time and part-time employee of our company with access to personal and other user data has been made aware of the responsibility to protect personal and other data as well as of the provisions regarding personal data confidentiality and online shop user privacy.

Access to (number of persons) and scope of personal data have been restricted to the minimum level that still permits the optimum rendering of services. The responsibility to protect personal and other data is unlimited in duration and continues even after the expiry of our mutual relationship.

With other select companies with access to personal data (shop administrator – MS3 d.o.o., računovodske storitve – Unija d.o.o., and ERP system provider, administrator – RCL d.o.o., and technical support GA Sistemi), we have concluded agreements on the processing and protection of personal data in our databases.

3. THE DATA WE COLLECT

When you visit our website or during the purchase process, you are requested to provide your personal data. Any submissions of personal data are made on a strictly voluntary basis. By submitting your personal data and consent, you grant us your permission to collect, use and keep your data. Your data will only be used for the purposes laid out when you are submitting the data. Your data will be protected from abuse, unauthorised access, loss, disclosure, alteration or destruction.

Below, we have made a list of certain personal data categories that we collect, the manners of use and protection of your data as well as how to contact us. As required for the rendering of the services we offer, we collect, manage, process and store the following user data:

Upon order:

• Name and surname

• Delivery addresses

• Company or legal entity name (in case of legal entities)

• Legal entity tax ID (in case of legal entities)

• E-mail (user name)

• Encrypted password (in case the user has registered for the online shop)

• Contact phone number

• Country of residence

• Anonymous IP address;

• Other data that the user enter into online shop forms on a voluntary basis (comment).

 Contact form:

• Name and surname

• Phone (optional)

• E-mail

• Message

• Anonymous IP address

Online shop registration:

• Name and surname

• E-mail

• Encrypted password

• Time and date of registration

• Anonymous IP address

E-newsletter subscription:

• Name

• E-mail

• Anonymous IP address

Furthermore, we also collect:

• Other data that the user enters voluntarily in surveys.

• Other data that the user voluntarily adds to his or her profile.

• Communication with individual buyers.

We take no responsibility for the correctness and completeness of data and their currentness.

4. WHY WE COLLECT DATA

E-newsletter

By opting into the newsletter, you are submitting your name, e-mail and anonymous IP address. If you are opting into our e-newsletter, your e-mail will be used to communicate information on news, campaigns, discounts and events.

By opting into our newsletter, you hereby grant us your permission to export, store and process your data in a marketing automation tool used to send out our newsletter. The exporting, storing and processing or data via our marketing automation tool facilitate the continuous monitoring of your activities at www.grosbasket.com and make possible the analyses of anonymous and aggregated data on the use of www.grosbasket.com along with other content at the website. Your personal data will be used exclusively to render our service, in anonymous analyses and business optimisation and will not be made available to the public, except in the case of explicit permission by the user by means of special consent.

Alongside subscribing to the e-newsletter, the visitor of the website also consents to receive personalised messages and offers until opting out and which encompass the use of data in direct marketing, re-targeting via digital marketing platforms (Facebook, AdWords) with the following intent:

• Presentation of entire Grosbasket offer.

• Exporting and processing of data via digital marketing tools (an e-mail address cannot be associated with a specific individual).

• And processing of anonymous data (rendered anonymous in such a way that they cannot be associated with a specific individual).

This consent is optional and must be given explicitly by the user.

Commercial communications received via e-mail will include the following components:

• A clear indication of the commercial nature of the communication.

• A clear indication of the sender.

• Campaigns, promos and other marketing techniques will be clearly marked along with terms of participation.

• Clear instructions on opting out of receiving commercial messages.

• The provider will explicitly observe the user’s request to opt out of receiving commercial messages.

Contact form

When submitting a comment via the online contact form, please provide your name, surname, e-mail, message and phone number (optional). The data will be used to provide a quality response as quickly as possible.

Online shop registration

During registration, you will be submitting your name, surname, e-mail, encrypted password and anonymous IP address. After order completion, registered users will receive to their e-mail a link that they can use to track their order.

Online purchase

When submitting your purchase, you will be asked to enter your name, surname, address, postcode, city, e-mail, phone number, and/or company name and tax ID. The data will be used in the delivery, invoicing and order finalisation. An order confirmation will be sent to the e-mail you enter when submitting your purchase. The anonymous and aggregated data may be used for the purpose of statistical analyses.

6. YOUR RIGHTS BASED ON YOUR CONSENT

A natural person may require the controller of personal data at any moment to suspend or discontinue the processing of that individual’s personal data for the purposes listed above. Such requests should be e-mailed to [email protected] and accompanied by an accurate specification of the consent being withdrawn.

An individual also holds the following rights:

• Right to access to own personal data collected in connection to the natural person, while the controller may make use of every reasonable asset to verify the identity of the subject natural person, particularly in connection to online services and identifiers.

• Right to rectification of inaccurate data collected in connection to the natural person, while the controller may make use of every reasonable asset to verify the identity of the subject natural person, particularly in connection to online services and identifiers.

• The right to removal, i.e. deletion, of all data in case of fulfilment of the conditions under Article 17 of the General Data Protection Regulation.

• The right to withdraw from the use of personal data for direct marketing purposes, including profiling.

• The right to autonomous decision-making regarding the use of personal data based on automated processing.

• The right to lodge complaints against the controller of personal data with a supervisory body in case of suspected breach of the provisions of the General Data Protection Regulation by the processor of personal data. If you wish to rectify your personal data or suspend or withdraw your consent regarding the use of such data for the purposes that they have been collected for, please e-mail us. You can also decide to delete all data via your user account.

7. OWNERSHIP OF DATA

We own the data collected via this website. We hereby undertake not to communicate such data to third parties, except for the purpose of product delivery. The courier service provider will only be disclosed the data required to deliver the products purchased online.

8. RESPONSIBILITY OF THE NATURAL PERSON

The user also holds responsibility to protect personal data by taking the necessary precautions to ensure the safety of own user name and password and by installing suitable anti-virus software to protect the computer.

9. DISCLOSURE OF DATA IN EXCEPTIONAL CIRCUMSTANCES

The data that we collect and process will only be disclosed when required by legislation or in good faith when the latter is considered necessary due to proceedings before courts or other national authorities, and to protect and enforce our own legal interests.

10. COMPLAINTS AND DISPUTES

We operate in line with current consumer legislation. Furthermore, we have set up an efficient complaint management system and have appointed a person responsible for direct communication with customers via phone or e-mail. Complaints should be sent to [email protected]

The complaint procedure is confidential. We are aware that consumer disputes, at least from the viewpoint of their resolution before courts, are characterised by the disproportionality between a claim’s value and the expenses resulting from the proceedings. This is also one of the main obstacles that prevent consumers from raising judicial disputes. As a result, we are striving to the best of our abilities to resolve any possible disputes amicably. If you wish to rectify your personal data or suspend or withdraw your consent regarding the use of such data for the purposes that they have been collected for, please e-mail us. You can also decide to delete all data via your user account.

In case of suspicion of breach of provisions of our personal data protection policy, please contact us via e-mail at [email protected] We will investigate, take the necessary steps and provide a reply in reasonable time. Please send questions and comments or report issues regarding this privacy policy via e-mail at [email protected]

11. CHANGES TO THE PRIVACY POLICY

We reserve the right to amend and change this document (e.g. due to change of legislation), which is why we recommend you periodically visit this section of our online shop.

Our website also collects cookies. More information available here.

Last updated on: May 27, 2019

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