I. INTRODUCTORY INFORMATION
The Spirit in the Bottle Ltd. respects the privacy and protects the personal information of its users, employees, business partners or other persons with whom it conducts business cooperation and whose personal data is collected and processed in their daily business.
We process your personal information in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, on the non-application of Directive 95/46 / (hereinafter: the General Data Protection Regulation) and in conjunction with the National Implementation Act of the General Data Protection Regulation.
The Universal Data Protection Regulation contains a number of rules to ensure that personal data processing is carried out in accordance with the rights and fundamental freedoms of individuals. Also, the General Data Protection Regulation allows free movement of personal data within the EU without restriction and ban.
Pursuant to Articles 13 and 14 of the General Data Protection Regulation, we hereby inform you of how we process your personal information, which rights you have in connection with data processing and protection, and how you can exercise these rights.
We process and use your personal information legally, fairly and transparently, while protecting the security of your personal data from unauthorized or illegal processing, applying the most technical, security and organizational protection measures.
II. DATA ON THE COMPANY
The head of the processing is The Spirit in the Bottle Ltd. headquartered in Zagreb , Kutnjački put 8 , VAT(OIB): 56769884745 , registered in the Court Registry of the Commercial Court in Zagreb under the registration number MBS 081134349 (“The Spirit in the Bottle Ltd.”). The Spirit in the Bottle Ltd. processes your personal information for the purposes specified in item IV. of this Policy.
The Spirit in the Bottle Ltd.
Kutnjački put 8
Phone: +385 91 6393333
E-mail: [email protected]
III. CONTACT DETAILS OF THE RESPONSIBLE PERSON
The Spirit in the Bottle Ltd. has appointed a responsible person.
The Spirit in the Bottle Ltd.
Kutnjački put 8
E-mail address: [email protected]
IV. PERSONAL DATA CATEGORIES WHICH WE DO AND DRAW
Within its business activities, The Spirit in the Bottle Ltd. may collect the following categories of personal data by categories of respondents:
- Contact information (e.g. name, last name, e-mail address etc.)
- The information needed to conclude the contract (e.g. name, surname, address, VAT(OIB), etc.).
- Contact information (e.g. name, last name, e-mail address etc.)
- The information required for the conclusion of the contract (e.g. name, surname, address, VAT(OIB), etc.)
- The data needed to execute the contract (e.g. name, surname, e-mail, IBAN, etc.)
Candidates for Employment:
- Contact information (e.g. name, last name, e-mail address, cell phone number, etc.)
- Resume data (e.g. data on education, previous employment, work experience, photography, etc.)
- Test results
Former and current employees:
- All data prescribed by positive regulations relating to labor law, accounting and bookkeeping regulations (e.g. name, surname, address, VAT(OIB), year of birth,etc.),
- Data for the need for internal communication within the company (e.g. name, surname, employment, travel document number, driver’s license, number of children, etc.).
Associates and business partners:
- Contact information (for example: name, surname, e-mail address, cell phone number, etc.)
- Resume data (for example, data on education, previous employment, employment, etc.)
- The information needed to execute the contract (for example: name, surname, e-mail, IBAN, etc.)
- The data required to fulfill the legal requirements for entry into the Republic of Croatia or another country (name, surname, employment, travel document number, etc.).
The processing of the above categories of personal data will be carried out by The Spirit in the Bottle Ltd. exceptionally under the following conditions:
The respondent has given explicit permission to process these personal data for one or more specific purposes;
Processing is necessary for the purposes of fulfilling the obligations and the realization of the special rights of The Spirit in the Bottle Ltd. or the respondents in the area of labor law and social security and social protection rights to the extent that it is granted under European Union law, the law of the Republic of Croatia or collective agreement in in accordance with the Law of the Republic of Croatia, which prescribes appropriate protective measures for the fundamental rights and interests of the respondent
- processing is necessary for the protection of vital interests of the respondent or another individual
- processing refers to the personal information that is apparently disclosed by the respondent
- processing is necessary for the establishment, realization or defense of legal requirements.
V. METHODS OF COLLECTING PERSONAL DATA
The Spirit in the Bottle Ltd. can collect personal information in various ways, including:
- As part of the business process and during the fulfillment legal obligations or obligations from a service contract;
- During web site tracking, including e-mail communication directed to and from The Spirit in the Bottle Ltd.;
- By your job application,
- When you provide us with information on the publication of the content on our site or during your direct communication with The Spirit in the Bottle Ltd., including personal communication and online communication via the site or e-mail;
VI. PERSONAL DATA PROCESSING PURPOSES
The Spirit in the Bottle Ltd. may process personal information for the following purposes:
- Alignment with legal and regulatory regulations within and outside the territory of the Republic of Croatia
- Contracting and using the products and services provided by The Spirit in the Bottle Ltd. fulfillment of its obligations under the contract for the sale of services and products of The Spirit in the Bottle Ltd.;
- Offer services and products of The Spirit in the Bottle Ltd. in the market;
- Website analysis and administration and site usage control;
- Improvement of services and products of The Spirit in the Bottle Ltd., measurement of service satisfaction;
- Relationship management with respondents (site users and/or service providers) and other persons in the conduct of their business;
- Selection of candidates for employment
- For marketing activities (if you give consent)
VII. PERSONAL DATA PROCESSING BASIS
The Spirit in the Bottle Ltd. handles your personal information based on the following basis:
- Executing a contract on the sale of the service of the Spirit in the Bottle Ltd. or another contract concluded between the respondents and The Spirit in the Bottle Ltd.;
- Introduce Privileges to Receive Marketing Messages, Newsletters, Email Service Notifications, or Service Satisfaction Survey to Process Your Inquiries
- In order to fulfill the legal obligations of The Spirit in the Bottle Ltd., in particular with regard to accounting, bookkeeping, regulations of labor law and other legal obligations.
VIII. PERSONAL DATA RETENTION
Your personal information is kept in the period or by a specific regulation or not longer than what is necessary to achieve the purpose for which it is processed – if the storage period is not prescribed or a minimum storage period is prescribed.
We store personal information only when we need them for the purposes for which we collect them, that is, for the purpose of fulfilling contractual relations or statutory obligations and the longest to the following criteria:
- Personal data collected for the purpose of fulfilling its legal and regulatory obligations are stored according to the prescribed deadlines,
- Personal data collected for the purpose of selling the goods and services are stored in the duration of the contractual relationship;
- We store your personal information collected for marketing activities until you withdraw your privation, cancel your subscription or ask for deletion of your subscription, or after a certain period of inactivity
Personal data will be deleted upon discontinuation of contractual or employment relationship and no later than the expiration of any statutory obligation to store, except in the event of a court or other similar proceedings requiring data retention.
IX. PERSONAL DATA TRANSFER AND SHARING
The Spirit in the Bottle Ltd. may share your personal information with third parties only in the following cases:
- If there is a statutory obligation or explicit authorization under the law;
- If we engage another person as a so-called ” subcontractor, i.e. processing agent, who acts solely upon the order of The Spirit in the Bottle Ltd., whereby The Spirit in the Bottle Ltd. secures all data protection measures as if doing these tasks alone;
- If the data need to be forwarded to third parties for the performance of the contract with the respondent;
- On the basis of the privilege of the respondent.
Such third parties include:
- Legislative, supervisory and regulatory bodies within and outside the territory of the Republic of Croatia Financial institutions with which The Spirit in the Bottle Ltd. collaborated Auditors inside and outside The Spirit in the Bottle Ltd. and other bodies authorized to audit
- Suppliers that The Spirit in the Bottle Ltd. engages to perform services on behalf of and for the account of The Spirit in the Bottle Ltd., for the fulfillment of the contractual obligations with the respondents
- Other agencies, institutions, associations, insurance companies and partner companies with whom The Spirit in the Bottle Ltd. has concluded a business cooperation agreement based on which business users can negotiate and use the products and services that The Spirit in the Bottle Ltd. provides etc.
When transmitting the data of the respondent, The Spirit in the Bottle Ltd. strictly adheres to the principle of the processing limitation with the transmission of the minimum amount of data needed to realize the requested service and respecting all other relevant data protection principles.
We handle personal data in the Republic of Croatia. Exceptionally, we can handle them in other countries (for example, when a subcontractor from another country is engaged in providing a particular service or part of a service that includes processing of personal data), as a rule, to the member states of the European Union. Exceptionally, we can handle them in third countries as well, but in such situations, appropriate personal data protection measures are always applied, as far as personal data is processed in the Republic of Croatia (e.g. by applying the so-called EU Standard Contract Clauses for third country processors , other legally binding and enforceable instruments, binding corporate rules, certification, etc. )
X. USER RIGHTS
The Spirit in the Bottle Ltd. respects the right to privacy and data collected and processed only with the existence of legal basis for processing these subjects at all times retain certain rights in relation to the ceremony in their data.
About the actions you have taken regarding your request, The Spirit in the Bottle Ltd. will inform you, without unnecessary delay and no later than one month from the receipt of the request, of the actions taken. Exceptionally, this deadline may be extended, if necessary, taking into account the complexity and number of requests. In this case, The Spirit in the Bottle Ltd. will notify you within one month of receipt of the request for the reasons for the delay.
If you have submitted your application electronically, the information will be provided electronically if possible unless you have requested otherwise in your request. If The Spirit in the Bottle Ltd. does not act on your request within one month, without delay and no later than one month after the receipt of the request, it will notify you of the reasons for not doing so and of the possibility of submitting the complaint to the supervisory authority.
Any communication and actions that The Spirit in the Bottle Ltd. undertakes regarding the carrying out of the rights listed below shall be free of charge. However, if your claims are manifestly unfounded or excessive, in particular because of their recurring character, The Spirit in the Bottle Ltd. may charge you a fee, taking into account the costs incurred or refusing to comply with your requirements.
You can contact The Spirit in the Bottle Ltd., as the manager of the processing, in order to exercise the following rights:
(1) The right to access data – From The Spirit in the Bottle Ltd., as a processing manager, you can obtain confirmation of whether your personal data are handled, if processed, you have the right to access personal information and information as provided by Article 15 of the General Data Protection Regulation, such as: processing purposes, personal data categories, deadlines, etc.
If your personal data is eventually transmitted to a third country or an international organization, you have the right to be notified of the appropriate transfer security measures.
If you ask for it, The Spirit in the Bottle Ltd. will provide you with a copy of the personal data processed. For all further requested copies, The Spirit in the Bottle Ltd. may charge you a reasonable fee based on administrative costs. If the application is filed electronically, and unless otherwise requested, The Spirit in the Bottle Ltd. will deliver them in the usual electronic form.
(2) Right to Correction – You may request from The Spirit in the Bottle Ltd. correction of your personal information that is incorrect as well as, taking into account the purpose of the processing, their , if the data is incomplete, giving an additional statement.
(3) Right to Delete (“Right to Forget”) – You can request from The Spirit in the Bottle Ltd. as a processing manager deleting your personal data if one of the reasons set out in Article 17 of the General Data Protection Regulation is fulfilled (e.g. if personal data is no longer necessary for purposes for which they have been collected or otherwise processed or if they are which is based on the processing of your personal data withdrawn or if there is no other legal basis for processing or if the personal data has to be deleted for compliance with a legal obligation under EU law or under the regulations of the Republic of Croatia or if the data is unlawfully processed or filed objection to direct marketing).
We hereby inform you that The Spirit in the Bottle Ltd. may not delete your personal information if their processing is necessary, for example, to comply with the statutory obligation of custody or for reasons of public interest to set up, enforce or defend the legal requirements.
(4) The right to limit processing – You can request from The Spirit in the Bottle Ltd. limitation of the processing of your personal data if one of the cases referred to in Article 18 of the General Data Protection Regulation is met, including, for example, if it is necessary to check the accuracy of your personal data.
(5) Right to Data Transfer – If the processing of your personal data is based on the consent or is required to execute a contract or to take action before the conclusion of the contract and if the processing is carried out by automated means, you may: request the obtaining of personal data obtained in a structured, in a standard format and in a machine-readable format, or transfer your personal information to another processing manager. In addition, you may request that your personal information be transmitted directly from The Spirit in the Bottle Ltd. to the other manager provided that this is technically feasible for The Spirit in the Bottle Ltd. In that case, The Spirit in the Bottle Ltd. provide you with all the correct information about the new processing manager whom you intend to transfer your personal information, giving your written consent to The Spirit in the Bottle Ltd..
(7) The right to complain and the right to file a complaint with the data protection authority – Notwithstanding your right to contact the administrative body or the court, if you consider that processing your personal data by The Spirit in the Bottle Ltd. it is a violation of the General Data Protection Regulation and/or applicable regulations of the Republic of Croatia, you may file a complaint with the Personal Data Protection Agency . Regardless of the foregoing, if you consider that the processing of personal data carried out by The Spirit in the Bottle Ltd. you may contact their responsible person at the following address: [email protected] so that we jointly try to resolve your complaint.
(8) Automatic data processing – The Spirit in the Bottle Ltd. does not perform automatic data processing.
XI. PERSONAL DATA PROTECTION
In order to protect the personal data collected, The Spirit in the Bottle Ltd. carries out the appropriate physical, technical and organizational protection measures, taking into account the nature, scope, context and purpose of processing, as well as the risks of different levels of probability and severity for the rights and freedoms of the respondent.
The access to the data within The Spirit in the Bottle Ltd. is limited to those data necessary to perform certain business tasks, exclusively to authorized persons who are directly engaged in providing or maintaining the service, and to improve the quality and collection of services, in accordance with clearly defined roles and Responsibilities within The Spirit in the Bottle Ltd. All employees of The Spirit in the Bottle Ltd. are bound by confidentiality contracts and engage exclusively with the partners with whom we are dealing with the appropriate protection measures.
The Spirit in the Bottle Ltd. can not guarantee 100% security of data transfer over the internet, websites, mobile applications, computer systems or any other public network.
In order for The Spirit in the Bottle Ltd. Website to work properly, in order to be able to further improve the site, in order to improve your browsing experience, the site must save a small amount of information (Cookies) on your computer.
The cookie information is saved to your computer by the web site you visit. Cookies usually save your settings, web settings, such as your preferred language or address. Later, when you open the same web page again, the internet browser sends back the cookies that belong to that page. This allows the page to display information tailored to your needs.
Key cookies allow us to serve you with content and track traffic to our pages and apps, and the analytic cookies we use and third parties who process data for us for data analysis (e.g., Google Analytics) allow us to manage and improve the performance and design of our websites and applications, as well as tracking, reviewing, researching, and reporting.
Browsers and devices have tools that allow cookies to be disabled on web pages and apps. If you disable cookies, you may not be able to access all features of our services. We suggest that your key cookies stay active for a better user experience and help us improve and develop our products and services.
XIII. FINAL PROVISIONS