1.1 We are committed to safeguarding the privacy of borboleta.co visitors and service users according to the principles and provision of the General data protection regulation (EU) 2016/679.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of borboleta.co visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
2. CONTACT INFORMATION
Borboleta d.o.o. za trgovinu i usluge - podružnica v Ljubljani
Dunajska cesta 136, 1000 Ljubljana, Slovenia
Company registration number: 8097399000
VAT number: SI87385031
2.1 Online sales to non-VAT registered customers (distance sales) on www.borboleta.co, are subject to the contractual relationship between "Borboleta d.o.o. - branch office in Ljubljana" and "Borboleta d.o.o. Croatia", where "Borboleta d.o.o. - branch office in Ljubljana" is authorized to conclude sales contracts in the name and on behalf of "Borboleta d.o.o. Croatia" (the owner of ‘’Borboleta’’ brand and the owner of the goods).
2.2 When you place an order and conclude a contract with "Borboleta d.o.o. - branch office in Ljubljana" on www.borboleta.co, you placed an order and concluded a contract with "Borboleta d.o.o. Croatia".
2.3 Important information about “Borboleta d.o.o. Croatia”
Borboleta d.o.o. Croatia
Gundulićeva ul. 1, 10 000 Zagreb, Republic of Croatia
Croatia company register number (MBS): 081028468
Croatia VAT number: HR96776797706
3. TERMS OF SERVICE, NOTICES, AND REVISIONS
4. HOW WE USE YOUR PERSONAL DATA
4.1 We may process data about your use of borboleta.co and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency, and pattern of your service use. This usage data may be processed for the purposes of analyzing the use of the website and services.
4.2 We may process your account data ("account data"). The account data may include your name, email address and date of birth. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
4.3 We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services.
4.4 We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include identifiable data. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
4.5 We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services.
4.6 We may process information contained in any inquiry you submit to us regarding goods and/or services ("inquiry data"). The inquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you.
4.7 We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers.
4.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details, and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions.
4.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters] ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters.
4.10 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping.
4.11 In addition to the specific purposes for which we may process your personal data, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
4.12 Please do not supply any other person's personal data to us, unless we prompt you to do so.
5. PROVIDING YOUR PERSONAL DATA TO OTHERS
5.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy
5.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5.3 We may disclose your personal data to our suppliers, postal services or subcontractors insofar as reasonably necessary.
5.4 Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
5.6 We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store—you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.
5.7 We also use Google Analytics to help us understand how our customers use the Site - you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.5.8 To help personalize your journey we currently use the following companies, who will process your personal data as part of their contracts with us:
Facebook, Instagram and Twitter - We are displaying targeted adverts based on behavior and shopping history;
Google analytics to monitor site traffic and browser behavior;
AdWords and Google Shopping display products and adverts based on browser behavior and shopping history;
Mailchimp for our email marketing campaigns where messaging is created in and sent from Mailchimp;
Checkout / Paypal - Provide an international payment gateway in various native currencies and provide our international shipping and logistics;
AfterShip - automated tracking solution which support tracking 461 international couriers worldwide.
5.9 In addition to the specific disclosures of personal data we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
6. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
6.1 In this section, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
6.2 We and our other group companies have offices, facilities, and stores in multiple countries across a globe. You can find a full list on our website. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission or the use of binding corporate rules.
6.3 The hosting facilities for our website are situated in Shopify Inc. datacenter located in Canada. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
6.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
7. RETAINING AND DELETING PERSONAL DATA
7.1 This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. When you place an order through our website, we’ll keep the personal data you give us for five years, so we can comply with our legal and contractual obligations
7.3 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the necessary timeline for an operational function of our website and business.
7.4 Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
7.5 At the end of that retention period, your data will either be deleted completely or anonymized, so that it can be used in a non-identifiable way for statistical analysis and business planning.
8. YOUR RIGHTS
8.1 Your principal rights under the data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.2 You have the right to confirmation as to whether we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.
8.3 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.4 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include for example: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, (b) you withdraw consent to consent-based processing, (c) you object to the processing under certain rules of applicable data protection law, (d) the processing is for direct marketing purposes, (e) and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: (a) for exercising the right of freedom of expression and information, (b) for compliance with a legal obligation, (c) or for the establishment, (d) exercise or defense of legal claims.
8.5 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: (a) you contest the accuracy of the personal data, (b) processing is unlawful but you oppose erasure, (c) we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; (d) and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.6 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
8.7 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.8 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.9 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.12 With regard to practicing your data protection rights under the GDPR, you can contact us via e-mail or phone using the contact information provided in section 2.
- Social Media. Some of our websites include social media cookies, including those that enable users who are logged in to the social media service to share content via that service.
- Google Analytics. This website uses functions of the web analytics service Google Analytics. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States. Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and allow an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. The storage of Google Analytics cookies is based on Art. 1 lit. f GDPR. The website operator has a legitimate interest in the analysis of user behaviour in order to optimize both its website and its advertising.
- Companies we hire to provide services on our behalf, such as site analytics, place cookies when you visit our sites.
- Companies that deliver content, such as videos or news, or ads on Borboleta sites, place cookies on their own. These companies use the data they process in accordance with their privacy policies, which may enable these companies to collect and combine information about your activities across websites, apps, or online services.
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