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PRIVACY AND COOKIES

FIRSTLINE GLOBAL EUROPA j.d.o.o., Glavani 49/2, 51221 Kostrena, Croatia, VAT: SI92596665, (hereinafter “we”) pays close attention to the protection of personal data. This document provides information on what data from our buyers are processed and for what purpose, if the data in our possession are based on the buyer’s consent or on a legal basis.

1. WHAT KIND OF PERSONAL DATA DO WE COLLECT?

If you use our services, we collect various types of data, such as contact information and other settings. We follow the type of items you are viewing in our online store, through which device and to which of our offers by email you have shown interest. Based on the data collected, we can develop more personalized offers, improve our services and our online sales. If you make a purchase from us, we also process the name and surname and other personal information that we need for the conclusion of the contract and the delivery of your orders. We collect the following personal information:

  • identification data, in particular name and surname;
  • contacts that include personal information through which we can contact you, in particular e-mail address, telephone number, delivery address, billing address. 
  • Information about your orders, which include in particular information on the items ordered and the method of payment, including the number of the current account and information on complaints;
  • information on the user’s online habits, including the instances in which you browse the Web through our mobile app, in particular information on the items and services you are looking for, the links on which you click, the search and scrolling of our website and data of the device from which the Web is accessed, such as the IP address and associated position, the device ID, its technical parameters, such as the operating system, the version, the screen resolution, the selected browser and its version, and data derived from cookies and similar technologies identify the devices;
  • information on your behavior in relation to reading the messages we send you, in particular the time needed to open the message and information on the devices from which you access the web, such as the IP address and associated position, the ID of the device, its technical parameters, such as the operating system, the version, the screen resolution, the selected browser and its version;
  • Derived data, including personal data relating to user settings, information on items purchased, information on habits and online behavior associated with reading the messages we send you. it mainly concerns information on sex, age, consumption habits and attitudes towards different objects and services;
  • data in connection with the use of the call center, which include, in particular, recordings of telephone calls at the call center, the identification of the messages sent to us, including the identification of the IP address.

2. WHY DO WE COLLECT PERSONAL INFORMATION AND WHY DO WE HAVE THE RIGHT TO DO SO?

We process your personal information in different situations and for various purposes. If you visit our online stores where we use cookies, your information will be used mainly to determine the number of visitors and improve our services. If purchases are made from us, we will use your information to process orders, protect our legal requests and fulfill our legal obligations. With the help of your contact information and other information, we can simultaneously view and send our personalized offers. With your consent, we provide information to third parties for submitting offers on other websites and for accessing some additional services. We have the right to process your personal information based on the preparation or execution of a contract with you, the fulfillment of legal obligations, our legal claims or your consent.

Within our activities, we process personal data for various purposes and to varying degrees, in particular:

  • without your consent based on the execution of a contract, our legitimate interest or in order to fulfill legal or contractual obligations,
  • Based on your consent.

What type of data processing can be performed without your consent depends on the purpose for which the related processing is related and in what relationship you are, if you are only a visitor to our online store or a buyer. Your data can be processed if you are the recipient of the goods or services that have been ordered by us, if you contact us or visit our online store.

The use of cookies and other technologies, transmission of data to advertising and social networks

If you visit our online store, we save and consequently read tiny files from your device, such as cookies. The so-called cookie is a small set of letters and numbers that we store on your browser or on your computer’s hard drive. Some cookies allow us to interact with your activities while you browse our pages from the moment you open the browser window until the moment you close it. The moment the browser window is closed, the associated cookies are deleted. Some cookies remain in the device for the set time and are activated every time they visit the sites created by the associated cookies.

We also use web signals (also known as web beacons). These are small images that have a similar function to cookies. Compared to cookies stored on your computer’s hard drive, web signals are an integral part of a site. For the sake of simplification in this document, all these technologies will be described later as cookies. Later in this document, we will only discuss storage space for simplification purposes.

Some cookies are stored directly on your device by our websites. These cookies help us to:

  • with your identification when you switch between the individual web pages of our domain and for new visits. In this way, the products put in the shopping cart are not eliminated, but at the same time, we can save information on which version of our website should be displayed if there are multiple versions available at a given time;
  • to determine if you have given us consent in accordance with this document, or if, for example, you have decided to participate in a concrete research;
  • in ensuring security, for example we can verify that your connection to our domain has not been used improperly and that someone does not carry out activities using your data.
  • in identifying, studying and removing errors and defects on our web pages.
  • These cookies and other files are essential for the operation of our online store. If you disable cookies in your browser, our pages may not function properly, which would prevent us from offering our products and services.

We also store cookies on our website on your device, which allow us to:

  • track the number of visits to our websites or individual content, create statistics and reviews and measure ad performance;
  • view various aspects of our web pages if we test new features;
  • Adapt the content of our site to your needs, for example give priority to the articles you have previously searched and show other offers based on your preferences on our web pages;
  • store cookies for other sites that can be used (a) to collect information on user behavior on our or other websites; (b) to display personalized offers and personalized advertisements in advertisements and social networks on other sites outside of our domain; (c) to connect to social networks such as Facebook, including automatic signing, providing features like “Like”, showing personalized offers and personalized ads on social networks and other sites outside our web.

In order to display personalized offers and personalized advertisements in advertisements and social networks on other sites outside our domain, we also provide information on the online behavior of our social networks and advertisements. We do not provide these partners with your identification data. The list of social and advertising networks we use is listed in Who is managing your personal information and with whom do we share it?

How to monitor cookies?

Cookies can be managed and controlled in different ways. Keep in mind that the removal or blocking of cookies can adversely affect your user experience and accessibility to certain pages of our online store. Most browsers automatically accept cookies, but you can specify whether to accept cookies via the browser control that is normally found in the Tools or Browser settings menu. For more information on how to change your browser settings or how to block, manage or filter cookies, visit the website: www.allaboutcookies.org.

Use of personal information of website visitors

If you visit our online store, we process your information on your website based on our legitimate interest (i.e. without your consent) for the purpose of:

  • Creating statistics and reviews, in particular tracking the number of visits to our websites or individual content and measuring the effectiveness of the ads; our legitimate interest is to measure the effectiveness of our sites and advertising costs; To this end, through your behavior on the web, we can obtain and use other derived data; or we can transmit the derived data to our partners as described in the section “Who processes your personal data and to whom we provide”.
  • test new functions and applications before distribution, to avoid their malfunction, which could affect your purchase on our site. Our legitimate interest in this case is the flawless functioning of our services for you;
  • take measures against attacks on our sites and compromise their operation and ensure the security of information; our legitimate interest in this case is the flawless functioning of our services for you and the security of your information.

The information on your behavior on the web is not taken only through cooki but is completed with the following information:

  • The IP address of the device (the address of the device, through which it communicates with other devices on the Internet);
  • the operating system of the device, its version and language settings;
  • the browser used on the device, its version and language settings;
  • URL of the page from which you access our site.

For this purpose, we use personal data for a maximum period of 38 months. The data is stored in a pseudonymised form.

Data on user behavior on Web pages are also processed based on our legitimate interest (i.e. without your consent) in order to prepare personalized offers and personalized ads that we publish online. In this case, our legitimate interest is to offer promotions that suit you best. The collected data is then analyzed. Based on this data, we can classify our users into groups, preparing the offers that are closest to their interests. If then purchases are made, the data arrived together with the original they will be used for this purpose.

For this purpose, we use personal information for 1 month.

If a purchase is made from us

To make a purchase from us, you need to visit our online store, the operations described are in the section “If you visit our websites”. If the purchase is made on our site, the data processing will be extended as follows:

Treatment based on the implementation of the contract

If the purchase is made by a natural person, we process the information received only to process the order received. There is talk of identification, contact and information on the order.

If the purchase is made as a legal entity and the contract between us and a representative of the company is executed, we process the data in the same way, based on the conclusion and implementation of the contract with the person representing the company.

The use of data for the purpose of processing your order means that we use the data separately for:

  • the ability to complete an online order, for example, do not delete the items you have added to cart or information from the order being prepared;
  • possibility of communication, for example as confirmation of shipment
  • need to pay for the goods,
  • delivery needs; In this regard, we may also forward your information to our transport partners, solely for the purpose of providing such goods as described in the section “Who processes your personal information and with whom do we share it?”;
  • regarding the claim for goods or services ordered; In this regard, we may forward your information to the supplier of the goods or to the service center as described in the section “Who processes your personal information and with whom do we share it?”;
  • in relation to other requirements that are communicated to us through our call center as described in “If you communicate with us through different channels”.

For this purpose, we use personal data over time which is essential for the processing of your order, or for resolve a complaint.

Treatment on a legitimate interest basis

If the purchase is made with us, we retain your identification and contact information and order information based on our legitimate interest (without your consent) for the purpose of protecting legal claims and our records and internal controls . Our legitimate interest in this case is the protection of legal claims and the supervision of the regular provision of our services.

In addition, based on our legitimate interest (i.e. without your consent), we process your identification and contact information, settings and order information (if a purchase is made later) for the purpose of :

In order to create personalized offers and personalized ads that we display on web pages, as described in “If you visit our websites”, we also use information about your orders.

Your satisfaction with our services is measured on the basis of NPS research, which we send you via e-mail as part of the Judge.me program. We send the questionnaire to random users who made a purchase in the previous month. The survey results are used only for our personal use.

In order to protect legal complaints and to retain data for internal controls, we process the data for a period of 3 years and another year compared to complaints that are applied by the end of the prescription period. In the case of legal, administrative or other proceedings, we process your personal data for the period necessary for the duration of these proceedings and for the rest of the limitation period after its termination.

For other purposes, we use personal data for up to 6 months. Against this type of treatment that is carried out on the basis of our legitimate interest, you can object.

Processing based on compliance with legal obligations

We too must fulfill certain legal obligations. If we process the data for the purposes indicated above, we do not need your consent. On this legal basis, we process your identification and contact information, order data, in order to take into account the laws in force at the time of writing the memorandum in question, in particular:

  • Mandatory code
  • Consumer Protection Law
  • Value added tax law
  • The Tax Certification of Accounts Act
  • Accounting law
  • Electronic Communications Act
  • The law on the prevention of money laundering and terrorist financing

For this purpose, we use personal information for up to 10 years (plus the current year) based to the last document issued relating to your order. 

If you are the recipient of the goods or services that have been ordered by us.

If you are the recipient of the goods or services that have been ordered by us, we process your identification and contact information:

  • Based on our legitimate interest in order to prepare, conclude and implement a contract with our client. The implementation of this contract is also our legitimate interest;
  • Based on our legitimate interest in obtaining information on which we can improve our services for you in the future, or data for the preparation of our internal statistics and reviews; in this case, our legitimate interest is to improve our services for our customers;
  • in order to implement the true obligations, in particular on the basis of the applicable laws listed in the previous paragraph of the related memorandum;
  • for the purpose of protecting legal claims and our internal records and controls; our legitimate interest in this case is the protection of legal claims and the supervision of the regular execution of our services.

For the preparation, conclusion and execution of a contract with our customer, we use personal data in the time strictly necessary for processing the order. At the end of this period, the data will continue to be maintained on the basis of our legitimate interest in order to protect the legal claims and our records and internal controls, for a limitation period of 5 years and, if necessary, another year later. its expiry in the case of an application at the end of the limitation period.

When we initiate a judicial, administrative or other procedure, we process your personal information for the time strictly necessary for the execution of these procedures and until the remaining part of the limitation period expires at the time of its termination. Our legitimate interest in this case is to protect legal claims and to monitor the smooth execution of our services. For the purposes of compliance with legal obligations, we use personal data for a maximum of 10 years for each order.

If you communicate with us through different channels

If you communicate with us through various channels, in particular through call centers, e-mails, chats and social networks, your identification and contact information and mutual communication records are processed on the basis of our legitimate interest (or without your consent) for the purpose of:

  • processing your requests; if you made a purchase with us and your request refers to the order, we can process it based on the execution of the contract;
  • recording your needs so that we can check their regular and timely execution;
  • demonstrating that we have received and processed your request, for example if this is how the order is ordered or a complaint is made;
  • An analysis of the requirements to improve the quality of our services.

For this purpose, we store personal data for a period of 3 months. If an order is made through one of our channels, we can store the data for the protection of legal requests for the 5-year prescription period and for another year after the expiry date in relation to the requests made at the end of the prescription. In the case of legal, administrative or other procedures, we process your personal information to the extent necessary for the duration of these proceedings and the rest of the limitation period after its cessation.

3. WHO PROCESSES YOUR PERSONAL INFORMATION AND WITH WHOM DO WE SHARE IT?

In most cases, we process your data for our purposes as their manager. In this case, we will forward your information to our partners for the provision of payments, transportation and other matters related to your order. We also provide information to our analytics who process it in accordance with our instructions. With your consent, we may also provide information to advertisers and social networks to display personalized ads on other websites.

Personal information is processed by us as managers. This means that we define the purposes defined above for which we collect your personal information and processing methods and are responsible for the correct implementation of this information.

Your personal information may also be transmitted to other entities operating as a manager:

  • as regards the processing of your order to our partners who are involved in processing the order, as indicated in the “If you make a purchase with us” section , and in particular, the partners who manage the payment systems: Mollie, Keizersgracht 313, 1016 EE Amsterdam, Netherlands, Paypal.com, 2211 North First Street, San Jose, California 95131, ZDA; and the partners that allow the online store to function properly: Wealthy Affiliate, Wealthy Affiliate (Niche Marketing Inc.), Box 18 2354 Millstream Rd Victoria, BC, Canada V9B 6L2. You can read their privacy policy on this link: https://www.wealthyaffiliate.com/privacy/.
  • the delivery company, who delivery the parcel: GLS Italia, with its office in Trieste, Via Edgardo Morpurgo, 2, 34148 Trieste TS, Italy, and GLS Slovenia with its headquarter Cesta v Prod 84, 1000 Ljubljana, Slovenia.
  • based on your consent to advertising and social networks as described in the “Use of cookies and other technologies” section, the transmission of data to advertising and social networks, or by name: Google Ireland Limited (registration number: 368047) , with its headquarters in Gordon House, Barrow Street, Dublin 4, Irska; The company’s privacy policy is available here: https://policies.google.com/technologies/adsFacebook Ireland Limited, with its headquarters 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, D02 X525, Irska; The company’s privacy policy is available here: https://facebook.com/about/privacy

4. FROM WHAT SOURCES DO WE OBTAIN PERSONAL DATA?

Personal data is collected directly from you through our online store or in communication with you. Some other information may also be obtained from our partners, such as banks or transportation companies.

We mainly process personal information provided by the user directly when purchasing items and services, during the creation and use of the account or when communicating with us, for example through a call center. We also collect personal information directly from you by following your online habits while browsing our online store or reading our messages.

If the purchase is made at our shop, we can receive further information on the orders from the banks, our partners who manage the payment systems and the transport partners, for example with the implementation of the sales contract concluded. account number information, payments made and delivery of goods.

5. TRANSMISSION OF DATA OUTSIDE THE EU

In some cases, we may also transfer your personal information to countries that are not members of the European Economic Area.

In the context of the transmission of data to the recipients listed in Who can manage your personal information and with whom we share it, we may also forward your information to third countries outside the European Economic Area, which does not necessarily provide an adequate level of protection of personal data.

These interventions will be carried out only if the recipient concerned undertakes to comply with the standard contractual provisions issued by the European Commission, accessible at http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L: 2004: 385: 0074: 0084: CS: PDF

6. WHAT ARE YOUR RIGHTS IN RELATION TO THE PROCESSING OF PERSONAL DATA?

In connection with your personal information you have many rights. These include the right of access, review, cancellation and limitation of processing, transfer, opposition and appeal. Just like we have the rights and duties regarding the processing of your personal data in relation to the processing of your personal data. These rights include:

Right to know

In a nutshell, you have the right to know what information we collect, for what purposes and for how long, from where we collect your personal information, to whom we provide it, who processes it in addition to us and what your rights are in relation to processing of your personal information. You can read it all in the “Protection of customers’ personal information” section. However, if you are not completely sure of the personal information we collect about you, you can ask us to confirm whether or not we collect personal information in relation to you and, in that case, you have the right to know this information. Based on the right of knowledge, a copy of the data processed may be requested, providing you with the first free copy.

Right to correct data

The errors are human. If you see that your personal information is incorrect or incomplete, you have the right to ask to coreggerle as soon as possible.

Right to erasure

In some cases, you have the right to request the deletion of your personal information. The data will be merged in the shortest possible time if one of the following conditions occurs:

  • We no longer need the data that have been collected
  • You have revoked your consent to the processing of personal data, these are the data for which your consent is required, but at the same time we have no other reasons for further processing of this information;
  • You have exercised your right to object to the processing of data (see the lower section of the right to object to data processing) for the personal data that we process based on our legitimate interest
  • you assume that the processing of personal data that we carry out is no longer in accordance with generally binding legal regulations.

Keep in mind that even if one of the reasons described is satisfied, this does not mean that all your personal information will be immediately deleted. However, this right cannot be exercised if the processing of personal data continues to be necessary for the fulfillment of our legal obligations or for the determination, execution or defense of our legal claims (see “Why do we treat personal data and why are we entitled? “).

Right to limit the processing of data

In some cases, it is possible to exercise the right to limit the processing of personal data in addition to the right to erasure. This right allows you to request in some cases that your personal information is specifically marked and excluded from any processing operation – in this case the effect is limited in time (and not lasting as in the case of the right of cancellation). We must limit the processing of personal data:

  • if you dispute the accuracy of personal information until we agree on what information they are correct;
  • If your personal data is processed without an appropriate legal basis (for example, above the estimated purpose) and instead of deleting such data, it will be limited;
  • If we no longer need your personal information for the purposes described above
  • if there is an objection to the processing of data. The right to object is described in more detail under the title Right to file an objection against data processing).

Right to data transferability

You have the right to obtain from us all your personal information that you have provided to us and which is processed based on the contract entered into. Your personal data is provided in a structured, coherent and readable format. The simple transfer of data which is automatically processed in our electronic databases.

Right to object to data processing

For reasons relating to your particular situation, you have the right to object to the processing of personal data based on Article 6, paragraph 1, letter (e) or (f) of Regulation (EU) 2016/679 and to object to the processing data for direct marketing purposes (see “Why we process personal data and why we have the right”). The processing of your data for commercial activities will be stopped immediately. Also in other cases it will come used the same procedure.

Right to appeal

The exercise of the rights listed above, will in no way affect your right to lodge a complaint with the competent authorities. You can exercise this right when you believe that your personal data is treated in an unjustified way or in violation of generally binding legal rules.

7. HOW CAN CERTAIN RIGHTS BE EXERCISED?

To exercise the rights communicated in this document, you can contact us by e-mail info@firstline-global.com.

Your request will be taken into consideration as soon as possible, within a maximum time of one month. In special cases, especially when it comes to more complex procedures, we have the right to extend this deadline for another two months. Of course, if such an extension is necessary, and the reasons for it, a written communication will be sent.

CONTACT

  • info@firstline-global.com

FIRSTLINE GLOBAL EUROPA d.o.o. Glavani 49/2, 51221 Kostrena, Croatia

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