Privacy Policy

1. Definitions

• Personal Data – any information relating to an identified or identifiable individual.
• Processing – any action or set of actions performed on a personal data or a set of personal data.
• Data subject – a natural person whose personal data is processed.
• Child – a natural person under the age of 16.
• DPO – Data Protection Officer

2. Principles of data protection

We promise to follow the following data protection principles:

Data processing is legal, fair and transparent. Processing activities have a legitimate basis. We will provide you with information regarding on-demand processing. Processing is limited by its purpose. The activities of our data processing are consistent with the purpose for which the personal information is collected. We collect and process the minimum amount of personal information you need for any purpose. We will not keep your personal information longer than necessary. We will do our utmost to ensure the security and integrity of the data.

3. User’s rights regarding personal information

Data subject has the following rights:

• Right to information – the user has the right to know whether their private data is being processed, what data has been collected, where it is obtained from, and why and by whom it is being processed.
• Right to data access – implies that the user has the right to access data collected about and from them. This includes the right to request and obtain a copy of the user’s personal information collected. The user can request access to copies of their data in machine-readable format via email.
• Right to correct data – implies that the user has the right to correct personal information that is incorrect or incomplete. The user can request the correction of personal information by contacting DPO via email.
• Right to remove data – implies that in certain circumstances the user may request the deletion of personal data from our records. The user can do this via email.
• Right to restrict data processing – implies that if certain conditions are met, the user has the right to restrict the processing of personal data. In this case, you can contact our DPO via email.
• Right to object to data processing – implies that in certain cases the user is entitled to object to the processing of personal data, for example in the case of direct marketing. In this case, you can contact our DPO via email.
• Right to file a complaint – in the event that we deny the user’s request, guaranteed by the right of access, we will provide the user with a reason why this happened. If the user is not satisfied with how his request applies, he can contact DPO via email.
• Right to withdraw consent – the user has the right to withdraw any consent to the processing of personal data.

4. Which personal information we collect about the user

Information provided to us by the user

This can be an email address, name, phone number, address, or information that is necessary to deliver a product / service to the user or to enhance the customer experience. We keep the information for the purpose of allowing users to perform activities on the site. This information implies the user’s name and e-mail address.

Information automatically collected about the user

Information from our partners

We collect information from verified partners with confirmation that they have a legal basis to share this information. This is either information you provided directly to them, or they have collected it on other legal bases.

Publicly available information

We may collect information about you that is publicly available.

Contact forms

When a user contacts us through the contact form on the website, we use that information solely to enable users to respond to their queries in a quality manner. The contact form information is stored for one year after it is received and is then permanently deleted.

Embedded content from other web sites

Tags on this site may contain embedded content (eg videos, pictures, articles, etc.). Embedded content from other webpages behaves the same as if a visitor had visited that other webpage.

These sites may collect information about you, use cookies, have additional third-party tracking embedded, and monitor your interaction with that embedded content, including monitoring your interaction with embedded content if you have an account and are logged in to the website.

5. How we use user private information

We use the user’s personal information to:

Provide a service. This includes receiving signups on our website, communicating about issues, notifications of changes in the way we do business. Improve the user experience. Fulfill obligations under law or contract.

We use your personal information for legitimate reasons and / or with your consent.

Based on a legitimate interest, we process user personal information for the purposes of:

• Sending offers specifically designed for the user
• Administrating and analysing our customer base with the aim of improving the quality of our products and services, and the availability and breadth of our range of products we offer
• Conducting customer satisfaction surveys

With the user’s consent, we process personal information for the following purposes:

• To send newsletter and offers.
• For all other purposes for which we have requested the user’s consent.

We process user personal information to fulfill an obligation that comes from the law and / or use user personal information for options foreseen by law. We reserve the right to anonymously collect personal information and use such information. We will only use information outside the scope of the Privacy Policy when it is anonymous. We keep your payment information and other information collected about you as long as necessary for accounting purposes or other obligations in accordance with the law, but no longer than that.

We may process user personal information for additional purposes, but if they are consistent with the original purpose for which the information was collected. To do this, we ensure that:

• The connection between the purpose, the context and the nature of the personal data is suitable for further processing
• Further processing will in no way hurt your interests.
• There would always be a certain protection to process.

We will always inform the user of further processing and its purpose.

6. How long we keep the user data

For users who register with our site (if any), we also store personal information that they provide on their user profiles. All users can view, edit, or delete their personal information at any time (except they cannot change their email).

7. Who has access to the user’s personal information

We do not share user information with third parties. With the following exceptions:

In certain cases, personal information is provided to our partners whom we trust with the aim of providing the service properly or improving the customer experience. We share user information with:

• Paddle - out payment systems provider
• Sendgrid - out emailing service (for sending emails)

We only work with processing partners who are able to provide a sufficient level of protection for users’ personal information. We disclose user personal information to third parties or public servants when we are legally required to do so. We may disclose your personal information to third parties if you have given your consent or if there is another legal ground for doing so.

8. How we protect user information

For communication and data transfer we use secure protocols (such as HTTPS) and SSL certificate and a reliable hosting provider. Alos, the user data is encrypted at rest.

We strive to maintain complete data security, but we cannot fully guarantee it. In case of breach of data privacy conditions, we will notify the competent authorities and users and take all legally necessary steps.

If a user has an account on our site, it is important that he or she has a good password that will ensure the security of the information.

We do not collect information about children or target them with our services.

9. Information about cookies

We use cookies and / or similar technologies to analyze user behaviour, administer the site, track user movements, and collect information about other users with a purpose of personalising and enhancing the user experience.

A cookie is a small text document stored on a user’s computer. Cookies store information that make the site work. Only we have access to cookies from our site. You can control your cookies through your internet browser. Choosing to disable cookies will interfere with the use of functionality of our websites.

We use cookies for the following purposes:

Necessary / required cookies – these cookies are required by the user to be able to use our site, such as logging in and creating tags. These cookies do not collect any personal information.

Cookies stored on the user’s computer can be removed through an Internet browser. For more information on cookies, see allaboutcookies.org.

We use Plausible Analytics to measure traffic to our site. By using Plausible Analytics, all the site measurement is carried out absolutely anonymously. Cookies are not set and no personal data is collected. All data is in aggregate only. The website owner gets some actionable data to help them learn and improve, while the visitor keeps having a nice and enjoyable experience.

10. Contact

INITEQ Ltd.
Sime Devcica 1
10000 Zagreb
VATID:  HR82371555398

For more contact information, see the contact page.

Changes to Privacy policy personal data protection rules

We reserve the right to make changes to our privacy policy.