Privacy policy

 

**Data Processing Controller/Controller and Service Provider Responsible:**
Narmiko d.o.o. Hrvatska / Bellepoque.hr
Email: privacy@bellepoque.hr
Address: Petrova 59a, 10000 Zagreb, Croatia

The protection of your personal data is of utmost importance to us. In the following sections, we aim to inform you about the data collected during your visit and the purposes for which it is used. If you have any questions regarding the handling of your personal data, please reach out to our data protection officer. We store personal data in compliance with applicable laws and regulations, and we delete it when its intended purpose has been fulfilled or at the user’s request.

We want to explicitly state that Bellepoque.hr will not sell, share, or make user data available to third parties, except as outlined in this Policy. User personal data may be shared with third parties on occasion, such as service providers hired to deliver services, perform service analyses, and provide technical support on behalf of Bellepoque.hr. These service providers are contractually obligated to use personal data solely for the purposes defined in the contract and are expressly forbidden from selling or sharing personal data with other third parties, except when legally required. When user data is shared with third parties, Bellepoque.hr takes all necessary measures to ensure that the data is processed only for purposes aligned with the original collection purpose and within the scope of the user’s consent.

There are two additional situations in which personal data may be shared with third parties:
1. If Bellepoque.hr’s business activity, including user data, is sold, transferred, or assigned to third parties, the buyer, successor, or recipient is obligated to handle personal data in accordance with this Policy.
2. When legally binding conditions, court orders, or requests from government authorities necessitate data disclosure for legal proceedings or criminal investigations.

**1. BASIC INFORMATION ON DATA HANDLING**

**1.1 Extent of Personal Data Processing**
We at bellepoque.hr collect and use our users’ personal data to the extent necessary for the operation of our website, the provision of content and services, and the fulfillment of our business purposes. Generally, we collect and use personal data only with the user’s consent. Exceptions may occur when obtaining prior consent is not possible for factual reasons, and data processing is permitted due to legal requirements.

**1.2 Purposes and Legal Basis for Personal Data Processing**
We process personal data to fulfill our contractual obligations or protect our legitimate interests, which are related to our business purpose. When we obtain consent from the data subject for processing personal data, the legal basis is Article 6 (Lawfulness of Processing), paragraph 1, sentence 1 lit. a of the EU General Data Protection Regulation (EU-GDPR). When processing is necessary for a contract with the data subject, Article 6, paragraph 1, sentence 1 lit. b GDPR serves as the legal basis. Legal requirements that our company must adhere to establish Article 6, paragraph 1, sentence 1 lit. c GDPR as the legal basis. Vital interests of the data subject or another person, as well as the protection of legitimate interests, fall under Article 6, paragraph 1, sentence 1 lit. d GDPR as the legal basis.

If processing is required to protect our company’s legitimate interests or those of a third party, and these interests do not override the fundamental rights and freedoms of the data subject, Article 6, paragraph 1, sentence 1 lit. f GDPR serves as the legal basis.

**1.3 Categories of Recipients, Personal Data Origin, and Data Transmission**
We may share personal data with business partners and service providers to achieve our business purposes. We typically receive personal data directly from the data subject or with their consent. Data is not shared with third parties unless legally required, contractually necessary, or with the explicit consent of the data subject. When sharing data with external service providers or partner companies, we ensure that they comply with data protection laws and regulations. Please refer to individual providers’ data protection notices.

**1.4 Transmission to Third Countries**
Generally, we do not transfer personal data to third countries (countries outside the EU). If such transfers occur, we ensure the necessary permissions are obtained, and the third-country recipient guarantees an adequate level of data protection, as per Art. 49, paragraph 1 GDPR, or we use EU standard contractual clauses.

**1.5 Data Security**
We have implemented robust technical and organizational measures to safeguard your data from accidental or intentional manipulation, loss, destruction, or unauthorized access. Our security procedures are regularly reviewed and updated to align with technological advancements.

**1.6 Data Deletion and Storage Periods**
Personal data is deleted or blocked when its purpose no longer exists, as determined by the relevant legal or contractual requirements. Data may be retained beyond this period if mandated by EU regulations, laws, or other applicable statutes. The data is also blocked or deleted when statutory storage periods expire, unless further storage is necessary to fulfill a contract or for legal obligations.

**2. GENERAL DATA COLLECTION WHEN VISITING OUR WEBSITE**

When you visit our website for informational purposes, without registering or providing additional information, we collect only the personal data that your browser automatically transmits to our server. This data is essential for the technical operation of our service and to ensure website stability, security, and protection against misuse.

**Description and Extent of Data Collection:**
When you visit our website, our system automatically records the following data:
– Browser type and version
– Operating system and user interface
– Internet service provider
– IP address
– Access status/HTTP status code
– Date and time of the visit
– Time zone difference to Greenwich Mean Time
– Content of the request (specific web page)
– Amount of data transmitted
– Websites from which the user’s system accessed our website
– Websites visited by the user’s system through our website
– Mobile device information (manufacturer and model)
– Low-level tracer

This data is also stored in our system’s log files, but it is not associated with other personal data.

**Legal Basis for Data Processing:**
The legal basis for the temporary storage of this data and log files is Art. 6, paragraph 1, sentence 1 lit. GDPR.

**Purpose of Data Processing:**
The temporary storage of the user’s IP address is necessary to deliver the website to their computer during the session. Log file storage is required to ensure website functionality, optimize the website, and maintain IT system security. This data helps us adapt to different browsers, operating systems, and devices used by our visitors.

**Duration of Storage:**
Data is deleted when it is no longer needed for its intended purpose. For data used to provide the website, this occurs at the end of the session. For data stored in log files, this occurs within seven days at the latest. Extended storage may occur, with the user’s IP addresses either deleted or anonymized to prevent identification.

**Right to Object and Removal:**
The recording of data for website provision and log file storage is essential for website operation, and users cannot object to it.

**3. REGISTRATION**

On our website, users have the option to register by providing personal data in an input form. This data is transmitted to us and stored. The following data is collected during the registration process:

– First name
– Last name
– Email
– Password
– Address
– Telephone number
– Company (

optional)
– Country
– Academic title (optional)

During registration, data such as the user’s IP address, registration date, customer number, entity-ID, and email hash is also stored. Users are asked for their consent during registration. After completing registration, users receive personal access protected by a password and can view and manage their registration data. Registration is voluntary but may be necessary to access our services.

**Legal Basis for Data Processing:**
If the user consents, the legal basis for processing this data is Art. 6, paragraph 1, sentence 1 lit. a GDPR. If registration serves to fulfill or initiate a contract, the legal basis is also Art. 6, paragraph 1, sentence 1 lit. b GDPR.

**Purpose of Data Processing:**
User registration is necessary for providing specific content and services, particularly for using our web shop. Registration is required for the performance of a contract with the user or to initiate pre-contractual steps.

**Duration of Storage:**
Data is deleted when it is no longer needed for its intended purpose, such as when a user cancels or modifies their registration. Even after contract completion, personal data may be retained to fulfill contractual or legal obligations. Personal data may be stored for fraud prevention, with a maximum retention period of 6 months.

**Right to Object and Removal:**
Users can cancel their registration at any time and request data modifications. Data required for contract fulfillment or legal obligations cannot be deleted prematurely.

**4. CONTACT**

Our website includes a contact form for electronic communication. If users use this form, the entered data is transmitted to us and stored. The data includes:
– First and last name
– Email address
– Subject
– Message

No data is stored when the message is sent. Alternatively, contact can be established via the provided email address. In this case, the user’s personal data transmitted via email is stored. This data is not shared with third parties and is used solely for processing the conversation.

**Legal Basis for Data Processing:**
If the user consents, the legal basis for processing this data is Art. 6, paragraph 1, sentence 1 lit. a GDPR. If email contact aims to conclude a contract, the legal basis is also Art. 6, paragraph 1, sentence 1 lit. a GDPR.

**Purpose of Data Processing:**
Personal data from the contact form is used exclusively for establishing communication. For email contact, data processing is necessary for legitimate interests, including preventing misuse of the contact form and securing our IT systems.

**Duration of Storage:**
Data is deleted once it is no longer needed for its intended purpose. For data from the contact form, this occurs when the conversation ends. For data collected during the email exchange, it is deleted within seven days after the conversation concludes.

**Right to Object and Removal:**
Users can withdraw their consent and object to the storage of their personal data at any time. However, in such cases, the conversation cannot continue. Users can request the deletion of all personal data collected during the contact process.

**5. Newsletter**

We employ both the double opt-in procedure and the confirmed opt-in procedure for newsletter registration. In the double opt-in process, we send a confirmation email to the provided email address, requesting confirmation of your desire to receive our newsletter. If confirmation is not received within 72 hours, the data is automatically deleted. Upon confirmation, your email address is stored for the sole purpose of sending you the newsletter. Additionally, we collect and store your IP address during registration and confirmation, along with the timestamps, to prevent misuse of your personal information.

Email Service Provider: Our newsletters are sent using Sendinblue. The email address is the only mandatory information for newsletter delivery. The provision of additional, specially marked information is voluntary and is used exclusively to personalize the newsletter. We also store the IP addresses used during registration and confirmation, as well as the associated timestamps, to maintain records of your registration and address any potential misuse of your personal data. The legal basis for this is Art. 6(1)(a) GDPR.

If we have obtained your email address in connection with an order, and you have not objected, we reserve the right to send you regular offers by email for products similar to those you have already purchased from our product range. You can object to the use of your email address and the processing of data to create user profiles for marketing purposes at any time without providing reasons. You can do this by sending a message to privacy@bellepoque.hr or by using the unsubscribe link in our email newsletter. This action will incur only the transmission costs according to the basic rates of your existing Internet contract.

With the data we collect, we create a pseudonymous user profile to provide you with a newsletter tailored to your interests. The following data is collected:

– Did you open the newsletter?
– What did you click on within the newsletter?
– When and for how long did you visit our website?
– What products and categories did you view?
– When and what did you purchase?
– What category and in what quantity?

You can opt out of the cookie-based collection and analysis of online data described above at any time by clicking the Opt-out button below. The opt-out cookie will remain in effect in the browser you are using until you delete it using that browser. However, if you delete the cookie or use a different browser or computer, the email service provider Emarsys and Certona will no longer be able to recognize that you have declared your objection. Alternatively, you can configure your browser to not accept cookies.

If you have registered on our webshop and placed products on your wish list, you will receive emails informing you about the products on your wish list. You can unsubscribe from these notifications by unchecking the box at the end of the wish list or by using the unsubscribe link in the emails.

**6. Your Order in Our Online Shop**

When you place an order in our webshop, we require personal data to process the order. Mandatory details necessary for contract processing are specifically marked as such, while other details are voluntary. We use the data provided to process your order. Additionally, we may share your payment details with your chosen payment service provider and your address details with the selected shipping logistics service provider for order fulfillment. The legal basis for this is Art. 6(1)(b) GDPR.

You can also create a user account on a voluntary basis, which allows us to store your data for future purchases. This registration is based on the provisions in Point 3 of this declaration. We may also use the information you provide to notify you about additional products in our range or send you technical information via email. Commercial and fiscal regulations require us to retain your address, payment, and order details for ten years. However, we restrict processing after three years, meaning that your data is only used to meet legal requirements. You can object to the use of your data for advertising and data analysis purposes at any time by sending your objection to privacy@bellepoque.hr.

To prevent unauthorized access to your personal data, particularly financial data, the order process is encrypted using the “Secure Socket Layer” (SSL) hybrid encryption protocol for secure data transmission.

**7. Our Payment Service Providers**

We offer various payment options, such as credit card or direct bank transfer. For this purpose, payment data may be transferred to the payment service providers we work with. The legal basis for transferring this data is Art. 6(1)(b) and Art. 6(1)(f) GDPR. You can find more details about the processing of your personal data by the payment service providers in their respective privacy policies.

**8. Cookies and Similar Technologies**

We use cookies to improve our website’s user experience, optimize it, and for advertising purposes. Cookies are small text files that are stored on your computer when you visit our website and allow for the identification of your browser during subsequent visits. Cookies store information such as your language preferences, the duration of your visit, or your entries on the site, reducing the need to re-enter data during each session. They also enable us to detect your preferences and customize our website to your interests.

Most browsers accept cookies by default. If you want to prevent cookie acceptance, you can change the setting to “accept no cookies” in your browser. You can also delete cookies stored on your computer at any time, although this may affect the functionality of our website. We use different types of cookies:

**9. Primary Provider Cookies – Essential Cookies**

These cookies are set by our website and can only be read by our website. They are necessary for various functions, such as maintaining a shopping cart, protecting the website from attacks, marking sessions, and more. The data collected by these cookies is pseudonymized and cannot be traced back to individual users. The legal basis for processing personal data via essential cookies is Art. 6(1)(f) GDPR.

**10. Third-Party Cookies – Marketing Cookies**

Marketing cookies are set when you consent to their use by organizations other than our website operator. These cookies are typically used by marketing companies. We use third-party cookies from providers like Google and Microsoft for various purposes, such as conversion tracking, reCAPTCHA, and more. These cookies collect data related to your browsing behavior for marketing and advertising optimization. For example, we use Google AdWords and Google Analytics Remarketing Lists for Search Ads to deliver personalized online advertising and track the effectiveness of our ads. You can control the use of these cookies through your browser settings or through opt-out mechanisms provided by these providers.

Please note that when data is transferred to the USA, measures are in place to ensure data protection in accordance with Art. 44ff DS-GVO through the conclusion of EU standard contractual clauses and, if necessary, supplementary measures.

**10.1 Google Tracker**

– Google AdWords and Conversion Tracking: To attract attention to our services, we use Google AdWords ads and conversion tracking to provide personalized online advertising. Google may collect data such as your IP address and website interactions. You can opt out of this tracking through browser settings or using Google’s opt-out tools.

– Google Analytics Remarketing Lists for Search Ads (RLSA): We use RLSA to customize advertising based on user behavior on our website. This allows us to show more relevant ads to users who have shown interest in our offerings.

**10.2 Microsoft Bing Tracker**

We use Bing Ads Conversion Tracking to measure the effectiveness of Bing search ads and display ads more frequently for relevant search queries. You can opt out of this tracking through your Microsoft account settings.

**Revised Privacy Policy: Effective as of May 15, 2022**

**10.2.1 Bing Conversion Tracking**

We also utilize Bing Ads Conversion Tracking. When you visit our website through a Bing search ad, a Bing Ads cookie is set on your computer. With Bing Conversion Tracking, we optimize search engine advertising campaigns by adjusting ad frequency. Ads are displayed more frequently for search queries that often result in purchases, while less relevant queries see fewer ads.

We collect the following data:

– Browser type/version
– Operating system used
– Hostname of the calling computer (IP address)
– Time of the server query

If you prefer not to participate, you can unsubscribe anytime at [Microsoft’s privacy settings](https://account.microsoft.com/privacy/ad-settings). For further information on Bing Ads Conversion Data Protection, consult [Microsoft’s privacy statement](https://privacy.microsoft.com/de-de/privacystatement).

In cases where personal data is transferred to the USA, we ensure compliance with Art. 44ff DS-GVO through EU standard contractual clauses and supplementary measures. The legal basis for processing personal data via marketing cookies is Art. 6 paragraph 1 sentence 1 lit. a GDPR.

**10.2.2 Bing Ads Remarketing Lists for Search Ads (RLSA)**

We also employ Microsoft Bing Ads Remarketing Lists for Search Ads. Visitors to our website are identified through a general website tag and optional event snippets, and their behavior is recorded. This behavior, such as dwell time on the site, completed or abandoned shopping cart operations, and bounce rates, is used to tailor advertising on the Bing search results page. This ensures that users with a strong interest in our website see more prominent ads, while less interested visitors see fewer or no ads on the search engine.

The following data is collected through cookies:

– Browser type/version
– Operating system used
– Hostname of the calling computer (IP address)
– Time of the server query

For data transfers to the USA, guarantees are in place according to Art. 44ff DS-GVO, including EU standard contractual clauses and supplementary measures. The legal basis for processing personal data via marketing cookies is Art. 6 paragraph 1 sentence 1 lit. a GDPR.

**10.3 Facebook Custom Audiences**

1. This website uses Facebook Custom Audiences with the pixel function (“Facebook Pixel”) and the server-side conversion API (“API”) of Facebook Ireland Ltd. (“Facebook”). This allows users of the website to see interest-based advertisements (“Facebook Ads”) on Facebook and related apps and websites. These ads are tailored to your interests to enhance your experience on our website.

2. Your browser establishes a direct connection to Facebook’s server through the Facebook Pixel, which transmits web events from your browser directly to Facebook via a server connection. These events are used to optimize the Facebook Pixel’s performance. If you’re registered with a Facebook service, your website visit can be linked to your account.

3. We have no control over the extent and further use of data collected by Facebook. Even if you’re not registered with Facebook or logged in, Facebook may collect and store your IP address and other identification features.

4. The legal basis for processing personal data using marketing cookies is Article 6(1)(1)(a) GDPR.

5. We use the Facebook Pixel and API to target our Facebook Ads to users interested in our online offer, ensure that ads match user interests, and evaluate the effectiveness of Facebook ads for statistical and market research purposes, including tracking conversions. This falls under our legitimate interest according to Art. 6(1)(1)(f) GDPR.

6. In the event of data transfer to the USA, guarantees are provided according to Art. 44ff DS-GVO, including EU standard contractual clauses and supplementary measures.

7. Third-party information: Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland; Directors: Gareth Lambe, Shane Crehan; Registered with the Companies Registration Office of the Republic of Ireland; Company number 462932.

8. More information on data processing by Facebook can be found at [Facebook’s privacy page](https://www.facebook.com/about/privacy). For details about Facebook Ads, visit [this page](https://www.facebook.com/about/ads/).

9. To opt out of Facebook Pixel and API data collection and prevent targeted ads, use this [opt-out link](https://www.facebook.com/adpreferences/ad_settings/?entry_product=account_settings_menu). Note that this sets an “Opt-Out” cookie, specific to the browser and our domain.

**11.1 Tools for Marketing Purposes**

We use cookies for marketing purposes to provide appealing advertising to our users. We may share this information with third parties, including Ad-networks.

**11.1.1 Google Analytics and Conversion Tracking**

This website uses Google Analytics, an advertising analysis service by Google Inc. (“Google”). We process data under Art. 6 paragraph 1 sentence 1 lit. a GDPR. Google Analytics uses “cookies” to analyze your use of our website.

The information generated by the cookie, such as:

– Browser type/version
– Operating system used
– Referrer-URL (the site visited previously)
– Hostname of the calling computer (IP address)
– Time of the server query

is typically transmitted to a Google server in the USA and stored there. We anonymize IP addresses with the “anonymizeIP” code in Google Analytics to collect data anonymously. In exceptional cases, the full IP address may be sent to a Google server in the USA and shortened there.

For data transfers to the USA, Google adheres to the EU-US Privacy Shield ([Privacy Shield details](https://www.privacyshield.gov/EU-US-Framework)).

Google uses this information to evaluate your website use, compile reports on website activities, and provide services to us related to website and internet use. You can prevent cookie storage by adjusting your browser settings. However, please note that this may limit website functionality. Additionally, you can opt out of data collection and processing by Google through [this browser plug-in](http://tools.google.com/dlpage/gaoptout?hl=de).

This website also uses Google Analytics for cross-device visitor analysis via a User-ID. You can deactivate this feature in your customer account settings under “My Data” > “Personal Data.”

For user terms, visit [Google Analytics terms](http://www.google.com/analytics/terms/de.html), data protection overview at [Google Analytics privacy](http://www.google.com/intl/de/analytics/learn/privacy.html), and data protection declaration at [Google Policies](https://www.google.com/policies/privacy/).

**12. Surveys**

**12.1 Customer Satisfaction Surveys**

We conduct voluntary customer satisfaction surveys to enhance our products and services. We use Shopper’s Mind Hrvatska (SMIND), a Croatia-based service provider, to conduct these surveys. When you participate, the following data is provided to SurveyGizmo LLC:

– Email address
– Email hash
– Language
– IP address
– Survey results
– Response ID

We process this data under Article 6 (1) sentence 1f of the GDPR, based on our legitimate interest in optimizing our products and services.

**12.2 Cookies and Similar Technologies**

We use cookies to improve our website, optimize user experience, and for advertising purposes. Cookies are small text files stored on your computer when you visit our website, enabling the identification of your browser. Cookies store information such

as language settings, visit duration, and entries made, reducing the need for re-entry during subsequent visits. Cookies also help us understand your preferences and tailor our website to your interests.

Most browsers accept cookies by default. To prevent cookie acceptance, you can change settings to “accept no cookies.” Instructions for your specific browser are available from your browser manufacturer. You can delete stored cookies at any time; however, this may limit website functionality.

We use cookies and similar technologies, including tracking pixels, to optimize our marketing and analyze web traffic. These technologies help collect statistical data for marketing and web analysis purposes without revealing personal information.

**13. Instruction on the Rights of Affected Persons**

**13.1 Rights of the Affected Person**

If we process your personal data, you are the affected person under the GDPR and have the following rights against us:

**13.2 Right to Information**

You can request confirmation of your processed personal data. If such processing exists, you can obtain information about:

– The purpose of processing your personal data
– Categories of personal data processed
– Recipients or categories of recipients to whom your personal data has been or will be disclosed
– Planned storage duration or criteria for determining storage duration
– The right to correction or deletion of your personal data, restriction of processing, or objection
– The right to file a complaint with a supervisory authority
– All available information about the origin of the data if it was not collected from you
– The existence of automated decision-making, including profiling, and relevant information about its logic, significance, and consequences for you

You also have the right to inquire about data transfers to third countries or international organizations and information about suitable safeguards under Art. 46 GDPR for such transfers.

**13.3 Right of Correction**

You can request correction or completion of incorrect or incomplete personal data without undue delay.

**13.4 Right of Restricting Processing**

Under specific circumstances, you can request the restriction of processing of your personal data. This applies if the accuracy of your personal data is contested, processing is unlawful, we no longer need the data for the intended purpose, or you have objected to processing.

**13.5 Right of Deletion/Obligation of Deletion**

You can request the deletion of your personal data, subject to certain conditions. Exceptions include data required for legal obligations, public interest, archiving, research, or statistics under Art. 89 GDPR.

**13.6 Right of Notification**

We must notify recipients of your personal data about corrections, deletions, or processing restrictions unless this proves impossible or involves disproportionate effort.

**13.7 Right of Data Portability**

You can receive your personal data in a structured, machine-readable format and transfer it to another responsible entity, where technically feasible. This right does not apply if processing is necessary for public interest or when the exercise of public authority is involved.

**13.8 Right to Object**

You can object to the processing of your personal data based on legitimate interests, including profiling, unless we have compelling legitimate reasons for processing or the processing is for legal claims. You can also object to direct advertising.

**13.9 Right to Revoke Consent**

You can revoke your consent to data processing at any time. Revoking consent does not affect the legality of prior processing.

**13.10 Automated Decision-Making**

You have the right not to be subject to decisions based solely on automated processing, including profiling, if it has legal effects on you or significantly affects you. Exceptions include processing based on your explicit consent or for tasks in the public interest.

**13.11 Right to Complain to a Supervisory Authority**

You have the right to complain to a supervisory authority if you believe that your personal data processing violates GDPR.

The relevant supervisory authority for you is:

– Agencija za zaštitu osobnih podataka
– Selska cesta 136
– 10 000 Zagreb, CROATIA
– Website: [azop.hr](https://azop.hr/)

**13.12 Right in the Case of Data Processing for Direct Advertising**

You have the right to object to the processing of your personal data for direct advertising at any time. Once you object, your data will no longer be processed for such purposes.

**13.13 Reference to the Right to Object in a Balancing of Interests**

If we process your personal data based on a balance of interests, you can object. In this case, please state the grounds for your objection. We will then either stop or adjust data processing or provide compelling legitimate grounds for continued processing.

**14. Links to Other Websites**

Our website may contain links to other providers. Please note that our data protection declaration applies exclusively to bellepoque.hr, and we have no control over the data protection practices of other providers.

**15. Changes to the Data Protection Declaration**

We reserve the right to change or adjust this data protection declaration at any time, in compliance with applicable data protection provisions.

Last Update: May 15, 2023

 

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