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Privacy policy

PRIVACY AND SECURITY

About privacy policy

This privacy policy (”Policy”) sets out the way in which NOELLE d.o.o. (hereinafter: “NOELLE d.o.o.”) collects, uses and manages your personal data on the website that FHR d.o.o. can access by using www.noellebrush.com. NOELLE d.o.o. is dedicated to respecting your privacy and keeping your data safe. We kindly ask you to carefully read our Policy to understand why and how we collect your personal data and how they will be used. As regards the personal data we collect, NOELLE d.o.o. is the “data processor” responsible for establishing the needs and means of personal data processing. As the www.noellebrush.com website service provider, NOELLE d.o.o. is dedicated to protecting your privacy and personal data.

If you would like to contact us about the Policy or your personal data, we kindly ask you to use the following contact information: Company name: NOELLE d.o.o. Address: Nova Ves 45/1 Telephone: 01/4641-508 Email: info@noellebrush.com.

How and when do we collect your personal data?

NOELLE d.o.o. collects personal data in order to conclude and perform sales contracts, record purchase orders, perform user identification, analyse business operations, carry out marketing activities, implement a reward system, deliver products, draw up sale and purchase documentation, provide technical assistance and authorise payments with credit and debit cards. Additional information about situations and circumstances when your personal data will be collected can be found below, in the section

What do we use your personal data for?

There you can learn about possible ways of personal data use you can encounter when visiting our website, making a purchase or using our services. In each of the above cases you will also get clear additional information about the purpose of data processing, while in certain cases we will ask for your express consent to process data. We will not use your personal data for marketing purposes unless you agree to it. If you would like to receive information about our products, services, offers and promotions, we kindly ask you to tick these options when joining our Loyalty Programme or subscribing to our newsletter. If you need additional information, please consult sections Marketing and Loyalty Programme below. We will keep your personal data confidential, and NOELLE d.o.o. and/or our reliable partners will ensure their adequate protection (for more information please read section: Does NOELLE d.o.o. share data with third parties? below).

What data do we collect directly from you?

When the user engages in certain activities on www.noellebrush.com such as opening a user account, using the online shop, filling out surveys, commenting, posting content, participating in competitions or prize games, sending feedback, requesting information about services, replying to a job offer, etc., NOELLE d.o.o. may request from the user to provide additional personal data. In this case the user is required, before providing additional personal data, to carefully read this Privacy Policy and the General Terms of Service and agree to their application in relation to additional data. Some of the required data are mandatory and some are optional, depending on the type of activity. If the user fails to provide mandatory data for an activity that requires them, they will not be allowed to engage in the activity. NOELLE d.o.o. collects and uses personal data to enable the use of services and activities provided through www.noellebrush.com, improve the functioning of www.noellebrush.com, create a customer database for the purpose of improving services and/or marketing, contact the users for the purpose of delivering marketing notifications, improve advertising and promotional activities, and analyse the use of www.noellebrush.com. Furthermore, personal data can be used for problem solving, performance of administrative tasks and contacting the users.

NOELLE d.o.o. collects the following personal data from the data subject on www.noellebrush.com: name and surname, password, telephone number, address, email address, product delivery address, invoice delivery address, postal code, city, sex, date of birth, company name and TIN (for companies). The following persons can consult the user’s personal data in order to carry out the necessary activities related to the sales contract between the customer and NOELLE d.o.o.: legal persons participating in the execution of a sales contract such as courier and bookkeeping companies, IT support, marketing support, companies affiliated with NOELLE d.o.o. and public bodies requiring the submission of personal data in accordance with binding regulations, of which NOELLE d.o.o. keeps a database of personal data.

What are your privacy rights?

NOELLE d.o.o. agrees that every user should have the opportunity to ensure that their personal data are accurate, complete and up-to-date. If the user deems that their personal data are incomplete, incorrect or not updated, they can contact NOELLE d.o.o. by sending an email to info@noellebrush.com. Keep in mind that you can, at any time, do the following: Request access to your personal data

You can ask NOELLE d.o.o. what personal data it uses and/or request access to such personal data; you are entitled to know about the purpose of data processing, personal data categories we hold about you, institutions or institution categories with which we share your personal data, data retention period and the data source, if they are collected indirectly.

• Ask NOELLE d.o.o. to provide you with a copy of personal data we hold. You can contact us if you would like to have a copy of some or all data we hold about you.

• Request the correction of incorrect data We want your personal information to be correct and up-to-date. You can ask NOELLE d.o.o. to correct or remove the information you consider incorrect or outdated.

• Request the deletion of personal data You can ask NOELLE d.o.o. to discontinue data processing or even delete the personal data we hold about you. If your personal data are needed to fulfil a contractual obligation to, this could prevent NOELLE d.o.o. from fulfilling such contractual obligations. Furthermore, if your personal data are necessary for fulfilling certain legal obligations (such as tax obligations), we might not be able to grant your request.

• Restrict access to your data in certain processes or completely (to NOELLE d.o.o. and/or third parties) If you want to contest the data accuracy, or if we no longer need personal data for the purpose of processing and you need them in order to set up, enforce or process legal requirements, or if you have opposed data processing on the basis that we consider substantiated, you are entitled to request restriction of personal data processing.

• Submit a complaint about the way in which NOELLE d.o.o. uses your data Keep in mind that you may submit a complaint about personal data processing that NOELLE d.o.o. considers legally substantiated.

• Request the transfer of data to some other data processor (transferability of rights) If data processing is based upon your consent or performed automatically, you may ask NOELLE d.o.o. to transfer the data to some other data processor. In order to exercise any of the abovementioned rights, we kindly ask you to use the NOELLE d.o.o. contact information provided in section on privacy. If you are dissatisfied with the way we have collected or used your personal data, you may submit a formal complaint to the Personal Data Protection Agency.

Where do we keep your personal data?

We keep the personal data we collect about you in a safe environment. Your personal data are kept safe from unauthorised access, disclosure, use, alterations or destruction by any organisation or individual. Some data are still stored in hard copy, but we aim to digitise all personal data that we process. The processed data are stored in our premises and IT systems, but sometimes we store data on our trusted service provider servers.

NOELLE d.o.o. will ensure that the user’s personal data are kept in a safe place (with reasonable administrative, technical and physical protection to prevent their unauthorised use, access, disclosure, copying, or modification) accessible only to authorised persons of NOELLE d.o.o. The data collected for the purposes stated in this Policy will only be retained for as long as necessary to fulfil their purpose. Your personal data will not be kept in a format that allows you to be identified longer than NOELLE d.o.o. reasonably deems it necessary to fulfil their purpose. NOELLE d.o.o. will keep certain personal data within the legally prescribed period, i.e. in line with the regulation obliging NOELLE d.o.o. to retain them. If you have given us your consent, we will process your personal data until you decide to withdraw it. If you make a substantiated complaint about the personal data processing, we will no longer process your data. If a court, an administrative or an out-of-court procedure is initiated, personal data may be stored up to their conclusion, including the time period for filing an appeal, if applicable. NOELLE d.o.o. will retain certain personal data within the time period prescribed by the relevant regulation obliging the data controller to keep such data.

Does NOELLE d.o.o. share data with third parties?

Your privacy is important to us, so we will never share your personal data with third parties except for the purposes described in this Policy. As you already know, Noelle d.o.o. cooperates with other companies, which means that we sometimes share your personal data by using secure IT systems. In this way data are transmitted to an EU country or a country ensuring the level of protection that complies with the EU legislation. We can also share your personal data with our trusted partners who maintain our IT system or render services in the name and for the account of NOELLE d.o.o. for the purposes such as marketing, finance, advertising, payment processing, delivery and other services performed on-site or elsewhere. Relevant contracts stipulate that the said service providers are obliged to use the data entrusted to them solely in accordance with our guidelines and for the determined purpose. Furthermore, they have been instructed to adequately protect our data and classify them as a business secret. Our partners rendering services in the name and for the account of NOELLE d.o.o. may in certain cases process your data outside the European Union. However, the contracts we enter into with the said entities bind them to handle your data in accordance with special security measures prescribed by applicable regulations of the EU Member States. NOELLE d.o.o. does not record or store the transaction data required for card payments.

How long will NOELLE d.o.o. retain your personal data?

NOELLE d.o.o. will not retain your personal data longer than needed to fulfil their purpose. You can find more information about the data retention periods in section What will your data be used for? What will your data be used for? We will use your personal data in a number of ways, mostly for fulfilling our contractual obligations to you, but sometimes also for improving your shopping experience, for direct marketing or for security reasons. Order processing and service rendering When you make a purchase through the website, we might ask you to provide certain personal data necessary for the correct order processing. The customer hereby agrees that NOELLE d.o.o. may process provided personal data for the purpose of its own record-keeping and statistics, creating customer databases, providing information about products, services and delivery, delivering promotional material as well as for improving customer relationships and the level of services. NOELLE d.o.o. may provide the above data to a third party in order to perform a contract, protect the interests of the customer and NOELLE d.o.o., prevent any potential misuse, gain better understanding of customer’s individual needs and requirements, and boost the service level of NOELLE d.o.o. resulting in improved customer satisfaction. NOELLE d.o.o. will keep personal data as long as this is necessary for the purposes provided for in this Privacy Policy and the General Terms of Service. In order to ensure that the products and services you purchase from us are delivered to the correct address, we share your personal data needed to provide certain services with trusted external partners (for example your name, delivery address and accompanying message, such as the time of day when you would like to have your order delivered). In addition to personal data, NOELLE d.o.o. may request other, personally non-identifiable data that are not considered personal data (for example, data about the use of the website, computer and Internet server, preferences, hobbies, interests, activities). NOELLE d.o.o. uses them to select data that are relevant to the user in a better, more accurate and personalised way as well as for promoting the website and additionally directing and customising its content to the user. On the basis of the said data, NOELLE d.o.o. learns what content is the most popular among certain users.

Cookies

We will retain and assess the information about your recent visit to our website and about how you have used its different pages for analytical purposes, i.e. to understand the way in which users use our website. In order to maintain the website and ensure that its functionality is at an expected level, NOELLE d.o.o. uses the technology known as “cookies”. Cookies are small files that are sent to your computer and can be accessed later. They can be temporary or permanent. Owing to the cookies, you can easily search our website and get results that are relevant to you. Cookies tell us what you and other website visitors are interested in, which helps us improve it. Find out more about cookies in our Cookie Policy.

Other websites

This Privacy Policy refers only to the use of data collected by NOELLE d.o.o. from the user (data subject). Other websites that can be accessed via www.noellebrush.com have in place their own data collection and confidentiality statements, and the methods of their use and publication. If the user visits one or more other websites via www.noellebrush.com, NOELLE d.o.o. recommends them to carefully read the related data confidentiality statement. NOELLE d.o.o. will not be held liable for the third party terms and conditions of service. Marketing NOELLE d.o.o. would like to inform you about our products and services you might be interested in. However, we can send you marketing material only if you agree to it. Keep in mind that, even if you have opted for receiving our marketing notifications, you may opt out at any time. Entry into force of the Privacy Policy and subsequent amendments This Privacy Policy enters into force on 25 June 2018. NOELLE d.o.o. reserves the right to amend this Privacy Policy and publish the amendments on the website.

HRK