Njuškalo web portal is owned by the company Njuškalo d.o.o., Zagreb, Miroslava Miholića 2, PIN: 94718723416 (hereinafter: “Njuškalo”).
We at Njuškalo attach great importance to personal data
handle your personal data when you use our services.
Everything you need to know, explained clearly and transparently:
WHAT KIND OF DATA IS COLLECTED AND HOW?
We value your privacy, which is why we collect only the data necessary to:
• provide services and support
• improve your user experience
• improve existing services and inform you about new services developed for you
• comply with legal regulations
You give us your data by filling out the forms when using our services, your data is collected automatically when you use Njuškalo and we may also obtain data when you use our external partners’ services on Njuškalo (e.g. payment confirmation).
We collect the data entered when:
• you sign up, fill out surveys, questionnaires and other online forms
• you communicate with other users using Njuškalo messages
• providing support and advice or responding to complaints
• you pay for services or get a refund
• you perform other activities on Njuškalo.
In that regard, we collect your first and last name, address, contact details, personal identification number and other information that you provide.
We may also automatically collect the data available when accessing and using Njuškalo, including:
• geolocation (only if you allowed it to be used)
• information about your device (model, device identifier, mobile network, etc.)
• service usage records that may contain IP addresses, time and duration of access, browser type, type of access to Njuškalo’s website, viewed pages or functions used in mobile apps, usage errors, etc.
• content, time and duration of phone conversations with Njuškalo and the phone number from which the call is made
• type of services you use, when and how.
Data obtained from other sources:
• from other users (e.g. comments, ratings, abuse reports, customer's delivery address, etc.)
• from external partners, within the scope of services provided (e.g. phone number used to make a payment by text message and alike)
• from social networks, provided
that you have linked your Njuškalo account to a social media account (e.g. user
profile name, phone number, e-mail address and other information you have
permitted to be used).
We will ask for your additional permission in the following cases:
• to collect and process special categories of personal data, such as sexual orientation, health status, religion, etc.
We cannot know if the data collected or processed relates to persons under the age of 16. If we find that such data is processed, we will close the user account and initiate the data erasure procedure. In the event that we get contacted by a guardian of a person whose data is processed and the guardian can be identified and has access to personal data via “Moje Njuškalo”, the data may be altered at his/her written request. We advise all parents and guardians to teach children how to handle personal data online in a safe and responsible manner, as well as about safety in general.
HOW WE USE YOUR DATA
Data collected and obtained through the provision of services is processed exclusively:
• for the purposes for which the data has been provided
• for the purposes for which you have given your consent
• on legal grounds, i.e. under applicable legal regulations, legitimate interest or Terms and Conditions of Use.
You are entitled to:
• know what personal data we have and process
• request rectification of data
• transfer your data and content
• withdraw any consent given at any moment, in part or in whole.
If you have any objections regarding data processing or your rights, feel free to contact us and we will try to resolve your complaint.
If you still find that your rights are being violated, you may file a complaint to the competent authority –Croatian Personal Data Protection Agency.
We may use your personal data to:
• provide information and assistance
• enable and facilitate the use of Njuškalo’s services and web portal
• customise the content according to your interests
• conduct surveys and adjust to your requirements
• inform you about new services and service updates
• inform you about events and special offers by Njuškalo
• provide you with our partners’ information that may be of your interest
• prevent fraud or other prohibited or illegal activities
• protect the security and integrity of Njuškalo and your data
• conduct business and statistical analyses
• develop new services and products accordingly
• fulfil legal obligations.
We do not sell, rent or borrow any user lists or users’ personal data to any third parties.
Data that has been anonymised or aggregated in a way that you can no longer be identified as a natural person is not regarded as personal data.
HOW WE PROTECT YOUR DATA
We are fully committed to protecting data from unauthorised access, disclosure or erasure, regardless of the storage or processing location or the format of the data.
We cooperate with trusted and professional partners obligated to implement high security standards.
We implement recognised IT security standards:
We take measures to ensure data integrity and availability of the processing system, taking into account the latest technological advancements. Data is stored in high-availability data centres in Croatia.
We are aware that there is no fully secure system and that security needs to be constantly upgraded.
You and all other users of Njuškalo are our partners in ensuring security.
Update your data regularly and allow us to send you recommendations on how to protect your data from abuse.
WHO WE SHARE YOUR DATA WITH
Your data is shared only with our contractual partners. Only the data necessary to provide certain services is shared.
Any person with access to your data as well as our partners assume the obligation of confidentiality as part of the contractual relationship and they are also obligated to implement organisational and technical protection measures.
Your data is also shared with internet users and users of Njuškalo. You can choose which personal data you want to publish on Njuškalo’s website or share with other users when using Njuškalo's services.
Third parties will process your data only for the purpose of:
If so prescribed by the law, data is also processed for the purpose of:
Data you have provided to us – first name, last name and e-mail address – is transferred to third countries when we send you promotional messages (Mailchimp).
Service providers and third parties will process personal data based on Njuškalo’s instructions and in compliance with this Policy and other applicable regulations (General Data Protection Regulation (EU) 2016/679, Act on the Implementation of the General Data Protection Regulation and other applicable laws, depending on the processing).
For more information on the transfer of data to third parties, please send an e-mail to email@example.com.
WHAT COOKIES AND TOOLS WE USE
We use tools to analyse how you use Njuškalo and to collect information about your habits and activities, which allows us to better identify your needs and improve the quality of our offer.
We use our own and our partners' cookies to identify your computer and provide you with a better service.
Data collected is not linked to your personal data on Njuškalo’s website.
Said tools may collect and store technical data, such as cookies, user and/or visitor IP address, mobile device identifier, browser data and alike, but without identifying the person.
By using proper settings on your computer, browser or mobile device, you can reject or delete cookies and continue to use Njuškalo, in which case some of Njuškalo’s functions will not be fully available.
MORE ABOUT YOUR RIGHTS
You can send us a request for data erasure, data rectification, restriction of processing, data transfer and data inspection. If you do not agree with data processing, you have the right to object and to file a complaint.
The request for data erasure and restriction of processing may be rejected if your identity as the owner of the personal data cannot be verified or if there are some other legal restrictions. If you use Njuškalo on behalf of another person or company, we will not be able to identify you. In that case, you may exercise your request only with the approval of that person or company.
Below you can read more about your rights and how to exercise them.
RIGHT TO ERASURE AND RESTRICTION OF PROCESSING
At any moment, you may request us to erase personal data collected during the use of Njuškalo’s services or to restrict the purpose of using your data, either in part or in whole.
Request for personal data erasure can be submitted to our address in writing, verbally or by sending an e-mail to firstname.lastname@example.org.
If you have a Njuškalo user account, you can submit the account closure and data erasure request via the “Moje Njuškalo” interface.
Upon receipt of the data erasure request, we will confirm that the request has been received and the account closure and data erasure procedure will be initiated.
Any unauthorised attempt to close your account and erase data can be cancelled within 24 hours from receiving the notification thereof. After 24 hours, the processing of your data will be restricted and the erasure procedure will be initiated.
Your data will be kept depending on its purpose and in accordance with the applicable regulations or legitimate interests arising out of or in relation with the use of Njuškalo. Upon expiration of the specified time limit, the data will be erased.
For example, records of financial transactions or invoices must be kept in accordance with a legally defined time limit, whereas other categories of data will be kept by the time limit we have specified for preventing fraud, responding to complaints or other legitimate purposes (2 years).
If the time limit for erasure is extended due to technical or other justified reasons, you will be notified in writing.
At any moment, you may restrict the use of the e-mail address for receiving notices and promotional messages by Njuškalo.
You can modify your data and settings using the “Moje Njuškalo” interface or simply unsubscribe from the newsletter list via the link found in the e-mail.
RIGHT TO DATA PORTABILITY
As the owner of an active user account, you can at any moment submit a request to have your data and content transferred to another service provider.
You can download your data yourself via the “Moje Njuškalo” interface for registered users.
You can download the following data in digital form:
• your contact details
• your ads available via the “Moje Njuškalo” interface.
We protect the privacy of our users and do not allow the download of any content that could harm your rights or the rights of other users.
Due to technical limitations, we cannot enable automated data transfer to another service provider.
RIGHT TO INFORMATION (DATA ACCESS)
You are the owner of your data and you have the right to know what data is stored or processed. You can also submit a request for additional information.
You can check your data via the “Moje Njuškalo” interface for registered users.
If you would like to get more information or if you are not a registered Njuškalo user, please send a written request to our address or an e-mail to email@example.com.
RIGHT TO DATA RECTIFICATION
It is important that your data is accurate, so please check it from time to time.
To help you in that regard, we can also check the accuracy of the data as technically and legally permissible. For instance, we can verify your phone number, e-mail address or other data.
We will send you reminders on the importance of using accurate data. Please rectify your data via the Moje Njuškalo interface,
Rectification of the data used for basic identification (e-mail address, PIN)
can be made by sending a written request to firstname.lastname@example.org using
the e-mail address registered in your user account.
LINKS TO OTHER WEBSITES
If you leave Njuškalo’s web pages using a certain link, please familiarise yourself with other service providers’ privacy rules and find out how they protect your personal data.
NOTICE ON CHANGES TO THE POLICY AND CONTACT INFORMATION
You will also be informed about any significant changes by e-mail or in some other appropriate way.
By registering or continuing to use Njuškalo after the Policy has been amended, you confirm that you are familiar with the applicable rules and you agree to have your data processed for the purposes specified above.
• in writing to Njuškalo’s head office
• by e-mail to email@example.com.
The Policy was amended on 12 June 2020 and it applies as of enter publication date.
In the event of any changes to this Policy, previous versions thereof may be requested via the contact form.