DATA PROTECTION AND PRIVACY POLICY

The Data Protection and Privacy Policy is a fundamental document that describes the purpose and objectives of collecting, processing and managing personal data, as well as ensuring an adequate level of data protection (hereinafter referred to as the ‘Policy’). In order to ensure fair and transparent processing, Twnty – Twnty d.o.o. (hereinafter referred to as: Twnty – Twnty) provides you with clear information on the processing and protection of personal data that it collects and processes and enables easy control and management of personal data and consents.

The rules have been formed in accordance with applicable regulations, Regulation (EU) 2016/679 of the European Parliament and of the Council – General Data Protection Regulation – GDPR and the Act on the Implementation of the General Data Protection Regulation (OG 42/18).

The following text contains information on the protection of privacy when using this website and information about internet cookies.

PRIVACY PROTECTION

The Privacy Policy describes how your personal data is handled when using the Twnty-Twnty online store. Personal data includes your identification data – name and surname, e-mail address, home address and telephone number, or data that is not otherwise publicly available, and that the Twnty-Twnty business receives and processes during your use of the online store. Personal data is collected solely on the basis of the voluntary provision of such information by users, such as when filling out a web form or when subscribing to the newsletter. Non-personal information and data may be automatically collected via internet cookies.

REASONS WHY WE PROCESS PERSONAL DATA

In order to conclude and fulfill contractual obligations, Twnty-Twnty d.o.o. processes personal data for the following purposes:

• opening user accounts
• processing orders
• delivery, or sending ordered shipments
• transmitting commercial communications via e-mail, telephone, post or courier delivery, within the limits of consent
• responding to inquiries
• resolving all disputes or complaints
• promoting Twnty-Twnty products and assortment
• sales and marketing activities

Twnty-Twnty will keep your personal data confidential and will not distribute, publish, provide to third parties for use or make them available in any other way available to any third party without your prior consent. Each visitor has the option of registering on the website twnty-twnty.com, which allows visitors to purchase products faster.

If you decide to become a registered user of the Twnty-Twnty web store, we need to process your data in order to identify you as a user of the web store and grant you access to various functionalities, products and services that are available to you as a registered user. You can cancel your registered user account by contacting us via customer service.

However, visitors to the Twnty-Twnty web store have the option to shop regardless of registration.

As a user of the Twnty-Twnty web store, you can choose not to register, but in that case you will not be able to use certain functionalities that registration provides you. In case you do not want to register for the purchase, it is necessary to enter the basic data required for the delivery or sending of the product, and depending on the selected payment method and country, the data required for the payment process.

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DATA WE COLLECT

When visiting and browsing the Twnty-Twnty website and store, we will process access data, server log files and cookies collected in this context in order to make our website, its contents and functionalities that you use available to you, and to ensure the stability and security of our IT system and databases.

Legal The framework for the lawfulness of data processing when visiting the Twnty-Twnty website and store is Regulation (EU) 2016/679 of the European Parliament and of the Council – General Data Protection Regulation – GDPR,Article 6, paragraph 1, indent f – processing necessary for the purposes of legitimate interests – technical availability of the website.

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For business purposes, Twnty-Twnty collects the following data:

• first and last name
• address of residence/residence/housing
• delivery address
• e-mail address
• contact phone number
• selected account password
• information about ordered products, such as item numbers and sizes
• payment data
• data about returns and complaints (e.g. reasons for return, defect notifications)
• order numbers
• shipment tracking numbers

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During your visit to our website and online store

You can visit the Twnty-Twnty website and online store without providing any information about yourself. In this case, we will collect technical access data that your browser will automatically transmit to our server when you browse our website. Access data includes the following information:

• time and date of access
• address of the website you accessed and are accessing
• content of the request (addresses and names of requested files)
• information about the browser and operating system used (versions, language settings)
• online identification data (e.g. IP address, device identification, session IDs)
• error messages, where applicable (if the requested content cannot be displayed)
• the last visited page where you were redirected to our site via a link

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When you visit our website, your access data will be automatically stored in the log files of our server and subsequently anonymized by shortening or deleting your IP address. After this procedure, it will no longer be possible to draw conclusions about your person based on the server log files.

When you visit the Twnty-Twnty web store, we will also collect the data that you directly provide by using the available functions. For example, we will learn which products you are interested in when you use the search function.

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Cookie Policy

The Twnty-Twnty website and web store use cookies to improve your user experience. A cookie is a standard text file that your web browser stores on your computer for a period of time specified by the cookie provider. Cookies allow information such as language settings, shopping cart contents and temporary identification features to be locally stored, which can be recalled during subsequent visits to the website in order to restore the appropriate settings that the user selected during the previous visit. This information can only be saved if you, as the user, allow this. The website and the store cannot access information without your permission and cannot access other files on your computer.

When you first visit our website and web store, you will independently select the level of cookies you want to store on your computer and thus fully control the process of using cookies.

You can view and delete cookies used in the security settings of your browser. You can configure your browser settings according to your wishes and, for example, refuse to accept third-party cookies or any cookies.

Cookie management is possible in several ways. It is important to keep in mind that removing or blocking cookies may negatively affect the functioning of the site and the availability of certain parts or features of the site, and thus the user experience when using it. Acceptance of cookies can be regulated through your browser settings, usually under “Tools” or “Preferences”. For more information about managing cookies, please refer to your browser’s “Help” section.

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Data we collect when you contact us

We will collect the communication data that you provide when you contact us via the contact form on our website, by email, by phone or otherwise. Depending on the channel you use, this may include, for example, contact information (e.g. email address or phone number) and the content of your message. Telephone conversations with Twnty-Twnty customer service are not recorded, nor are any other conversations made to Twnty-Twnty phone numbers.

We will also use offers provided by social networks such as Facebook and Instagram to interact with our customers. Please note that Twnty-Twnty has no influence on the terms of service of social networks or their data processing policies. Therefore, be sure to check the personal data you provide to us via social networks.

3.6. Data we collect when you sign up to receive the newsletter

If you have signed up for the Twnty-Twnty web store newsletter, we will store your data (e-mail address) that you provided for this purpose for sending the newsletter.

You can unsubscribe from the Twnty-Twnty web store newsletter at any time. To unsubscribe, use the unsubscribe link at the bottom of each Twnty-Twnty web store newsletter.

HOW TO USE THE COLLECTED DATA

We process your data in order to perform the contracts we have concluded with you and provide you with the services and products you have requested. The purpose of the processing is based primarily on the specific content of the contract. Additional details on the purpose of data processing can be found in the General Terms and Conditions of Use of the Twnty-Twnty web store.

We also process your data in order to provide user support in using the Twnty-Twnty website and web store. This may include the following eg:

• processing of your requests that you sent to our customer service
• service communication of a non-commercial nature (eg security information and technical support)

Depending on the selected payment method, the data required for the payment will be forwarded to the contractual partner who executes the payment. The billing service provider collects data within its own card payment application, in which case the service provider’s privacy notices apply. Twnty-Twnty does not have access to or store the data required for payment.

The legal framework for the lawfulness of data processing when processing an order and performing a purchase contract and transferring your data to external payment service providers is Regulation (EU) 2016/679 of the European Parliament and of the Council – General Data Protection Regulation – GDPR, Article 6, paragraph 1, indent b – processing necessary for the conclusion and performance of a contract.

We will use the data you enter (e.g. data on ordered products, returns) for internal statistical purposes and for market research purposes. Before using it, we will make the data anonymous by removing all personal data, e.g. by replacing your name and other data suitable for identification with random data.

In this way, we can measure which pages of our web store and products are popular, which devices our users generally use, and from which regions our website is accessed. The collected data helps us continuously optimize the existing offer and develop new functionalities and services.

The legal framework for the legality of processing this type of data is Regulation (EU) 2016/679 of the European Parliament and Council – General Data Protection Regulation – GDPR, Article 6, paragraph 1, indent f – processing necessary for legitimate interests – improving the functionality of the website and the quality of the offer.

CASES IN WHICH WE WILL SHARE PERSONAL DATA

Basically, we will only share your information if:

• you have expressly consented to this in accordance with Article 6(1)(a) of Regulation (EU) 2016/679 of the European Parliament and of the Council – General Data Protection Regulation – GDPR,
• the sharing is necessary pursuant to Article 6(1)(f) for the establishment, exercise or defence of legal claims and there is no reason to assume that you have an overriding legitimate interest in not sharing your data
• sharing is necessary to comply with a legal obligation pursuant to Article 6(1)(c) or (e) of the GDPR, in particular if we are required to provide information to a public authority,
• sharing is permitted by law and is necessary pursuant to Article 6(1)(b) of the GDPR to perform a contract with you or to take steps at your request prior to entering into a contract.

Some of the data processing described here may be carried out by external service providers acting on our behalf. The service providers mentioned in this document may include, computer centers that store and maintain our websites and databases, IT service providers that maintain our business systems, as well as consulting companies.

If and to the extent that we share data with our service providers, this data may only be used for the purpose of performing their services. The processing of your data by the contracted service providers will take place within the framework of the processing and execution of your order in accordance with Article 28 of Regulation (EU) 2016/679 of the European Parliament and of the Council – General Data Protection Regulation – GDPR. The contracted service providers are carefully selected business partners. They are contractually bound by our instructions, implement appropriate technical and organizational measures to protect the rights of data subjects and are subject to regular monitoring by us.

HOW LONG WILL WE KEEP YOUR DATA?

Unless otherwise stated here, your data will only be stored for as long as necessary to fulfill our contractual or legal obligations or the purposes for which the data was originally collected or for as long as we have a legitimate interest in storing such data.

The period for which we will retain your data will depend on the purpose for which we process it, as follows:

– to manage your registration as a user of the Twnty-Twnty web store

We will process your data for as long as you remain a registered user, i.e. until you decide to unsubscribe.

– for the development, fulfillment and execution of sales or service contracts

We will process your information for the time necessary to manage the purchase of products or services you have purchased, including potential returns, complaints or requests related to the purchase of products or services.

– for customer support

We will process your data for the time necessary to comply with your request or application.

– for marketing

We will process your data until you unsubscribe or cancel your newsletter subscription. We will also show you personalized ads until you change your settings or revoke such permission on your mobile device or browser. If you participate in promotional activities, we will retain the data for six (6) months from the end of the relevant activity.

– for usability and quality analysis

We will occasionally process your data for as long as we continue to carry out the campaign or quality research or until we anonymize your browsing data.

In all other cases, your personal data will be deleted, except for data that we are required to retain in accordance with legal retention periods. However, in such cases, we will restrict the processing of the data, i.e. your data will only be used in accordance with legal obligations.

Typically, your order and payment information and other information, if applicable, are subject to legal retention obligations, so we are required to retain such information for up to ten years.

Even if the data is not subject to legal retention obligations, we may refrain from deleting your data in cases permitted by law and instead limit its processing. This can be applied especially in those cases in which this data can be requested for further processing of the contract or for the exercise of rights or for the purpose of legal defense. The duration of the processing limitation will depend on the statutory limitation periods.

YOUR RIGHT TO PROTECTION DATA

We are committed to keeping your personal data confidential and ensuring the exercise of your rights. With this in mind, we, the joint controllers, have agreed that you can exercise your rights free of charge by writing to us at the following email address: info@twnty-twnty.com, simply informing us of the reason for your request and the right you wish to exercise. If we consider it necessary to identify you, we may require you to provide us with a copy of a document confirming your identity.

You always have the right to obtain information about our processing of your personal data. When providing such information, we will explain the data processing process and provide you with an overview of your personal data that we store.

In particular, and regardless of the purpose or legal basis we use to process your data, you have the following rights:

• ask us for access to the data we hold about you. We remind you that if you are a registered user of the platform, you can check this data in the section with your personal data.
• ask us to correct the data we hold about you. Please note that if you are a registered user of the platform, you can also access the section with the relevant personal data to change or update your personal data. In any case, please note that, at the moment you actively make your information available to us through any process, you warrant that it is true and accurate and undertake to notify us of any changes or modifications to your information. You are solely responsible for any loss or damage caused to the platform or the person responsible for the platform or any third party due to the reporting of wrong, inaccurate or incomplete information in the registration forms. Please note that, as a general rule, you must only provide us with your own data, not that of third parties, except to the extent permitted by this Privacy and Cookie Policy.
• request that we erase your personal data to the extent that it is no longer necessary for the purposes for which we continue to process it, as explained above, or where we are no longer legally permitted to process it.
• request that we cease or restrict the processing of your personal data, which includes in certain cases requiring us to temporarily suspend the processing of your data or to keep your data for no longer than is necessary.

You have the right to data portability, i.e. upon your request we will provide you with a digital copy of the personal data you have provided to us.

You also have the right to lodge a complaint with a data protection supervisory authority. The competent supervisory authority is the Personal Data Protection Agency, Martićeva 14, 10000 Zagreb, e-mail: azop@azop.hr.

RIGHT TO WITHDRAW CONSENT AND RIGHT TO OBJECT

If you wish to exercise your right of withdrawal or objection below, please contact us by e-mail: info@twnty-twnty.com.

Withdrawal of consent (consent)

Article 7(3) of the General Data Protection Regulation (GDPR) (EU) 2016/679 gives you the right to withdraw any consent you have previously given. This means that we will no longer process your data based on your consent in the future. Withdrawing your consent will not affect the lawfulness of processing based on consent prior to its withdrawal.

Objection to the processing of your data

If we process your data on the basis of legitimate interests in accordance with Article 6 paragraph 1, subparagraph f of the General Data Protection Regulation GDPR (EU) 2016/679, you have the right, based on Article 21, to object to the way your data is processed if there are reasons for this arising from the specifics of your situation or if the objection is directed against direct advertising.

DATA SECURITY

We use all appropriate technical measures to ensure security data, and in particular to protect your data from risks during data transmission, as well as from unauthorized access by third parties. These measures will be adjusted from time to time in accordance with the latest developments. In order to ensure personal data We use a secure transport protocol (SSL) to encrypt your data during transmission.

CHANGES TO THE DATA PROTECTION AND PRIVACY POLICY (GDPR)

We will update our Data Protection and Privacy Policy from time to time, when adapting to new versions of the website and web store or when changing legal regulations. Material changes will be documented in this document and, if necessary, we will secure the consent of our users. In any case, we suggest that you review this Data Protection and Privacy Policy from time to time in case we make minor changes or any interactive improvements, using it as a reference point for information on our website.