Focus natura d.o.o. (hereinafter referred to as ‘the Company’ or ‘us’) takes care of personal data according to the applicable law, such as the General Data Protection Regulation.
Guided by the said standards, the Company as the controller collects and processes data in a lawful, honest and transparent way, in accordance with the current regulations and by taking the appropriate technical and organizational measures aimed protection of personal data from unauthorized access and misuse.
The Company is aware that personal data protection is important to our clients and examinees. Therefore we want to demonstrate which personal data we collect, how we manage the data and how do we protect it.
Purposes, scope and legal basis of processing
Personal data is collected for special, explicit and legal purposes, and to the extent that is necessary. Also, the data is processed in compliance with those purposes.
The company will collect and process personal data only when it is permitted under regulations:
– data processing is necessary for compliance with legal obligation
– data processing is necessary when the examinee has given consent to the processing of his or her personal data for one or more specific purposes
– data processing is necessary for execution of contracts where the examinee is a customer or to take action at the request of an examinee before the contract award procedure
– data processing is necessary to protect essential interest of an examinee or other individual
– data processing is necessary for the purpose of the legitimate interests of the Company.
Collection and use of personal data
Personal data identify you directly or indirectly. That is data such as your name, e-mail, telephone number, IP address or postal address.
The company does not collect your personal data if you do not explicitly submit that data (e.g. by requesting information on a certain product or service, by conclusion of contracts or requesting certain actions before conclusion of contracts, by entering customer loyalty programs, by signing up for a newsletter, by participating in surveys, competitions and contests, by ordering samples or brochures, by requesting donations and by seeking information while submitting resumes or pending offers or applying for open positions and employment in our Company…).
Your personal data is collected, stored, used or transferred in the necessary content and time frame for a specific case. For example, in order to answer your queries, fulfil your requests, inform you about our products, competition or contest results, perform a contractual obligation or necessary actions before conclusion of contract, or to perform our other legal or statutory obligations. For those reason, the Company sometimes has to transfer personal data to external service providers for further processing. Service providers could be involved in the context of call centres, product shipping, distribution of advertising material or to organise and conduct contests. Those third-party service providers are required to accept the current legislation, comply with our instructions and adjust to our internal rules on personal data protection, as well as to use the appropriate organisational and technical protection measures. For those reasons, your data might have to be transferred to other states in and outside the EU, while the Company makes sure that that transfer is entirely pursuant to the law, using all data protection measures available.
The Company guarantees not to sell, forward or lend your personal data to third parties if it is not necessary to fulfil a certain purpose the data was given to us for, i.e. the Company guarantees your data will not be given to any unauthorised recipient.
It is possible that we have to deliver your personal data to a competent public authority if it is required by a low or other binding regulation.
The collected data will be kept for as long as necessary with regards to the purpose they were collected for, i.e. within the deadline according to the current regulations.
Use of personal data for advertising and marketing purposes
When your personal data is used for advertising and marketing purposes according to the current personal data protection legislation, your data will be stored and used for that purpose, like sending newsletters, product samples, competitions and contests invites by e-mail, mail or other channel of communication you chose.
If your personal data is used for sending customised advertisements and promotions through creating and maintaining a user profile, you will be noticed prior to sending such advertisements or promotions and we will ask you for a special, specific informed consent prior to this type of data processing.
When needed, your data will be used for analysis and improvement of our internet services, marketing, advertising, market research and sales efforts efficiency through surveys or other types of queries, or in a way to ensure your personal data is anonymised, i.e. cannot be attributed to a specific individual.
Exercising the data subject’s rights
You can request information on your personal data that we process or request correction of your data. You can request cessation of use or erasure of your personal data. Also, you can withdraw your consent for all or specific purposes (unless it is not possible, e.g. if the data is processed for statistical purposes when personal data no longer allow for identification). You can also transfer your data to a different controller, provided that it fulfils legal conditions, or you can unsubscribe from receiving our informative and promotional material.
You can also file a complaint on the use of your personal data in situations we base on the existence of our legitimate interest, and, decidedly, when we use it for the purpose of direct marketing.
We will take into account to the maximum possible and reasonable extent that your personal data that you made available to us are recorded properly, but it is your responsibility to make sure they are correct, and we ask you to update them regularly and timely, i.e. that you deliver a request for any changes or corrections.
To exercise all your rights and obligations in terms of the use of personal data, you can contact us at adresuoffice@focus-natura.hr, at our head office address specified on our web site, or according to the instructions on the delivered promotional material.
When you contact us and file the above mentioned requests, we will make a reasonable effort to confirm your identity and stop unauthorised personal data processing.
Upon receiving your requests, we will conduct the required activities within an appropriate time frame, but not later than 30 days after receiving your request, and we will inform you about it as needed, all in accordance with legislation.
Data safety
We implement technical and organisational measures to prevent the loss, change, theft or third-party unauthorised access to your data, i.e. any unauthorised processing. Access to your personal data is limited only to those employees the data is necessary to for providing our service or handling your enquires. We continually educate our employees about the importance of data confidentiality and preserving the privacy and security of your personal data. We collect only the data necessary for the subject matter and we do not keep it for longer than necessary, i.e. regulated by legislation.
You will sometimes find links to other websites or web portals on our web site, and we can also offer you some features of social media that include personal data sharing. Our recommendation is that you familiarize yourself with personal data protection policy of those portals, social media or third parties, as well as with their security measures, because they can be different from this policy and our measures, and we cannot be held responsible for them.
Third party web sites that are linked to from this web site will not control, create or reflect the Company. The Company, its management and employees are not accountable for the contents of the third party web sites, or for whether those web sites can comply with the current laws and regulations. The company, its management or employees are not accountable for any type of direct or indirect damage made by the use or reliance to the actions taken based on the information on third party web sites.
The limitation of liability
Despite the fact that we take any available technical, organisational and personnel measures of personal data protection from accidental or intentional misuse, elimination, loss, unauthorised change or access, we are unable to guarantee that some of the collected personal data we collect would never be accidentally discovered, contrary to this Privacy policy.
We rule out the responsibility of damage caused to users or third parties by accidental revealing of personal data to the greatest legally permissible extent.
Since we have no control over personal data you deliver while accessing or using other web portals, that is third parties (e.g. while taking part in sponsored activities), we rule out the responsibility of damage that can be caused to you or third parties by delivering personal data to the greatest legally permissible extent.
Amendments and updates
We reserve our right to change or update parts of this Privacy policy at any moment and without advance notice. Occasionally visit our website to be informed with changes and updates of the Privacy policy. We will indicate the date of application of the current version.
This Privacy policy was last modified on 1st September 2020