PRIVACY POLICY

1. THE PURPOSE OF THE PRIVACY POLICY

As the data controller, Center Invest d.o.o. (hereinafter referred to as: “CI” or “us”) is dedicated to protecting and respecting your privacy and your right to fair processing of your personal data. We are aware of the importance of personal data handling, and we are complying with the applicable data protection regulations, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as: the “GDPR”).

This Privacy Policy (hereinafter referred to as: the “Policy”) is intended for the customers of CI (Perfect gift), users of Perfect gift websites and products, and other persons (hereinafter referred to as: “individuals” or “you”) to familiarize themselves with the content, method, and basis for the collection, use, and storage (hereinafter referred to as: the “processing”) of personal data by CI, as well as with additional explanations of the content of the personal data processing consent.

The expressions and terms used in this Policy (e.g. “personal data”, “processing”, “collection” etc.) have the meaning set out in Article 4 of the GDPR.

The Policy encompasses the following information:

  • the type of data we collect,
  • the basis and purpose of collection of said data,
  • the retention period for individual types of personal data,
  • the method of use of collected data,
  • the rights of data subjects related to personal data processing,
  • the contact persons responsible for data protection.

2. THE DATA WE PROCESS

We collect personal data in order to be able to perform our services, inform customers of our promotional and marketing activities, and comply with our legal obligations.

Unless otherwise stated, we mainly collect the following data:

  • contact information (name, address, e-mail address, phone number, etc.) that you provide to us in order for us to be able to complete your order or prepare an offer, or when you contact us in any other way;
  • other information that you provide to us along with your consent for its processing (information about your interests, photos, personal descriptions etc.);
  • transaction data (information about your bank or credit card, transaction account, ID for VAT etc.) that we need in order to complete your order or comply with our other obligations;
  • information about website access and user information (hereinafter referred to as: the “access data”) that we process in order to provide protection, control the functioning and improve our websites or our network, provide protection against abuse or fraud, and comply with our other obligations, which mainly include: the Internet protocol (IP) address used to connect your computer to the Internet, your login data (username, password), the type and version of your browser, the time zone setting, the type and version of browser add-ons, the operating system and platform, device information, the type of mobile phone you use, unique device identifier (e.g. device IMEI, the MAC address of the wireless network interface of the device or the phone number used by the device), information about the mobile network you use, the time zone setting in the device, information about your visit (the time of arrival to our website, your behavior on our website, your departure, the services you looked at or searched for, the response time of the website, any download errors, the time you viewed a specific website, information about your interaction on the page, such as your movements, clicks and mouse control functions, including date and time;

2.1. 2.1. ACCESS DATA
Cookies and similar technologies

Cookies are small files that your browser stores into a specific dedicated folder on your device. The cookies stored can be used e.g. to find out whether you have already visited a website, inform us of the activities and browsing patterns of our visitors, and identify a data subject through their IP address (the number or address of the device connected to the Internet) or the account information you provide us with during your login. Most browsers accept cookies automatically; you can, however, change your browser settings by disabling the storage of cookies or provide your explicit consent for every time that cookies need to be stored. You can delete stored cookies at any time. Please remember that disabling cookies may limit or prevent you from using our website or parts of our website.

We use “session state cookies” and permanent cookies. Session state cookies expire when you log out of your account or close your browser. Permanent cookies stay on your computer or mobile device until you delete them or until they expire.

In addition to cookies, we also use other similar technologies such as web beacons (pixels), tracking URL addresses etc. A web beacon is a graphic image with the size of one pixel that can be delivered to your computer as a part of the website request or through an application, advertisement or HTML electronic message. We can use pixels to download information such as the type of your device or operating system, IP address, and the time of your visit from your device. They are also used to install and read cookies in your browser. Tracking URL addresses are used to determine the website that brought you to our website, or to determine the application used.

The type of information we collect through cookies and similar technologies include: IP address, device ID, pages visited, browser type, browsing information, operation system, Internet service provider, time stamp, whether you responded to an advertisement, the URL you used to access our website, the possibilities you used or the activities you undertook on the website.

Our website and applications use cookies for different purposes in which we have a legitimate interest:

Technical (process) cookies: We try to provide our visitors with an advanced, user-friendly website and applications that automatically adapt to their desires and needs. Therefore, we use technical cookies to display our website, to make sure that our website is functioning correctly, and to help our users create a user account, sign in, and edit their orders. Technical cookies are therefore essential for the correct functioning of our website.

Functional (setting) cookies: Functional cookies are also used to remember your wishes and help you with the functional use of our website. If you use our websites to perform online purchases, cookie storage allows the system to remember your selected currency, your language, your searches, and the products you have already viewed. We can also use cookies to remember your registration details so you no longer have to enter your login credentials every time you visit our website. Passwords and other data are always coded. Even though these functional cookies are not mandatory for the functioning of our websites, they improve your user experience and allow for an additional functionality.

Analytical cookies: We use these cookies to gain an insight into the way visitors use our websites. This allows us to understand what works and what doesn’t, improve our website and application, and understand the success rate of our advertisements and notifications. The data we collect may include websites you visited, the websites you came from and left, or the platform you used, including a time stamp for each individual action.

This means that we can also use data on how you use our website, i.e. the number of clicks on each individual website, the mouse and page movements, the keywords you search, and the text you enter into our website. We use analytical cookies as part of our online advertising, in order to better understand how visitors use our website after they see an online advertisement or notification. They can include third-party advertisement.

Advertising cookies: We use third-party cookies and our own cookies to display ads on our website and other websites. This is called “retargeting” and is based on search history, such as products and services viewed or searched, and displayed prices.

We therefore use cookies for the following purposes:

  • to evaluate the size and sample of our visitors and the way they use our website;
  • to improve the safety and functioning of the website;
  • to store information about your browser settings, which allows us to adapt your website to your interests;
  • to speed up your search;
  • to recognize individual data subjects when they return to our website, which allows for an improved user experience.

You can prevent cookies from being stored on your device by choosing the option of blocking or disabling cookies in your browser settings.

2.1.1. 2.1.1. DATA WE COLLECT THROUGH EXTERNAL PROVIDERS

We contractually cooperate with external service providers (contractual partners) that help us better understand the use of our websites. With the help of cookies and other similar technology, our contractual partners can collect data about your use of our websites necessary to prepare analyses on the use of our websites (how visitors navigate our website, which products they are looking at, general information about transactions). Information and analyses provided by our contractual partners will be used to help us better understand the interests of the visitors of our websites, and to provide security, technical, and contextual improvements of our websites. The processing of data our contractual partners receive through our website is contractually limited, as they may only use said data for the purpose of preparing analyses of the use of our websites pursuant to our orders.

Google Analytics

n order to optimize our website and services, we use Google Analytics which encompasses analytical tools in the form of software provided by Google Inc., Mountain View 1600 Amphitheatre Parkway Mountain View, CA 94043, USA (hereinafter referred to as: “Google”). This allows us to improve the functioning of our website and the provision of our services. The data (analyses) obtained allow us to see general patterns of the use of our website, and help us record issues encountered by the visitors of our website. They also tell us whether our advertisement is efficient or not, and allow us to optimize the success of our advertising. Google services use cookies and other similar technologies to collect information on the use of services and to report on website trends; this information, however, is anonymized and do not allow us to identify individual data subjects. A string of cookies can be used to collect information and report statistic information on the use of the website to Google, without including visitors’ personal identification. The main cookie used by Google Analytics is »__ga«.

Data subjects who do not want the information on their visit to our website to be indicated in the Google Analytics report may install a browser add-on to opt out of the use of Google Analytics available at https://tools.google.com/dlpage/gaoptout.

You can also prevent the storage of cookies by using appropriate browser settings; in this case, however, you will perhaps be unable to use all functions of our websites.

Additional information about Google services and Google Analytics is available at the following links https://policies.google.com/technologies/ads, https://www.google.com/analytics/learn/privacy.html?hl=sl, and https://privacy.google.com/#.

Google ensures an adequate level of personal data protection and has received appropriate certificates in the framework of the EU–USA Privacy Shield.

2.1.1. DATA TO BE TRANSMITTED TO THIRD PARTIES

PLUG-INS/ADD-ONS

Plug-ins are small programs expanding the functionality of programs and, consequently, of our website.

All third parties to whom data are transmitted through plug-ins set out below provide a sufficient level of personal data protection and have received appropriate certificates in the framework of the EU–USA Privacy Shield; alternatively, data are processed within EU countries.

Facebook

Our website uses Facebook social network plug-ins managed by Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA (hereinafter referred to as: “Facebook”). Plug-ins carry the Facebook logo or the “Facebook social network plug-in” or “Social Plug-in” add-on. For an overview of Facebook plug-ins and their appearance, please see https://developers.facebook.com/docs/plugins.

If you are browsing one of our websites containing such a plug-in, your browser will establish a direct connection with Facebook servers. Facebook will directly transfer the content of the plug-in to your browser and include it into the website. Through this inclusion, Facebook will receive the information that your browser called up the correct page of our website, even if you do not have a Facebook profile or if you are currently not signed into your Facebook account. This information (including your IP address) will be sent by your browser to the Facebook server in the USA and save it on the server.

Whenever you are using the plug-in if you are signed into your Facebook profile and, for example, click “Like” or write a comment, this information is also directly transferred and saved to a Facebook server. Information is also published on your Facebook profile where your Facebook friends can see it.

To find out more about the purpose and scope of data acquisition, their subsequent processing and use on Facebook, and your rights and privacy protection settings, please see Facebook data protection tips at http://www.facebook.com/policy.php.

If you do not wish the information that Facebook acquires through our website to be recorded and saved to your Facebook account, you must sign out of your Facebook account before visiting our website. You can also prevent the loading of the Facebook plug-in by using a suitable software add-on for your browser.

YouTube

On our websites, we use plug-ins of Youtube.com managed by YouTube, LLC (901 Cherry Avenue, San Bruno, CA 94066, USA – hereinafter referred to as: “YouTube”). If you visit a website containing such a plug-in, your browser will set up a direct connection with YouTube servers. These plug-ins transfer information about the websites you visited to YouTube servers. If a data subject is signed in as a YouTube user, YouTube can connect this data with their personal user account/profile. When using these plug-ins (e.g. by clicking “Play” on a video or by adding a comment), this data is connected to your YouTube user account. If you do not wish the data that YouTube acquires through our website to be saved to your YouTube account, you must sign out of your YouTube account before visiting our website. To find out more, please read the following privacy policy: https://policies.google.com/privacy.

Twitter

On our websites, we use plug-ins – buttons for Twitter offered by Twitter Inc. (1355 Market St., Suite 900, San Francisco, CA, 94103, USA – hereinafter referred to as: “Twitter”). These plug-ins can be called “Twitter” or “tweet” and/or Twitter logotypes. Among other functions, these plug-ins allow you to share a comment or a URL through Twitter. When you visit a website containing a Twitter button or plug-in, your browser will set up a direct connection with Twitter servers. The content of the Twitter button is transferred directly from Twitter to your browser, and therefore has no impact on the scope of data collected by Twitter through this plug-in. Information about your visit (i.e. the IP address of the user, previously visited websites, etc.) are transferred to Twitter. If you do not wish the data that Twitter acquires through our website to be saved to your Twitter account, you must sign out of your Twitter account before visiting our website. To find out more, please read Twitter’s privacy policy: twitter.com/privacy.

LinkedIn

On our websites, we use plug-ins by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA or LinkedIn Ireland Unlimited Company, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland, for users from EU Member States (hereinafter referred to as: “LinkedIn”). Connections with LinkedIn plug-ins are recognizable through the LinkedIn logo or through the “Share” button on our website. If you visit this website, a direct connection will be generated between your browser and the LinkedIn server. In this way, LinkedIn receives information about the fact that you visited our website using your IP address. If you click on the “Share” button connection when you are signed into your LinkedIn account, you can connect the content of our websites with your LinkedIn profile. In this way, LinkedIn can connect your visit to our websites with your LinkedIn user account. If you do not wish the data that LinkedIn acquires through our website to be saved to your LinkedIn account, you must sign out of your LinkedIn account before visiting our website. To find out more about data processing (purpose, scope, further processing and use), your rights, and the possibilities of changing your settings, please read the LinkedIn privacy policy at www.linkedin.com/legal/privacy-policy.

LEGAL BASIS AND THE PURPOSE OF DATA COLLECTION

3.1. Legal basis

Your data is processed pursuant to the following provisions of the GDPR, according to the basis pursuant to which they are obtained:

  • on the basis of express consent of the data subject for the processing of their personal data (hereinafter referred to as: “consent”) – article 6(1)(a) of the GDPR – (data provided in online or written forms, electronic messages, etc.)
  • the necessity of the performance of a contract at the request of the data subject – article 6(1)(b) of the GDPR – (data related to a service ordered by the data subject)
  • based on legal interests – article 6(1)(f) of the GDPR (access data)
  • in order to comply with our legal obligation – article 6(1)(c) of the GDPR – (data collected on the basis of regulations that are binding for us)

3.2. Purpose of processing

We will only collect your personal data in the scope and for the purpose for which you provide us with them on the basis of your consent, or insofar such a collection is necessary for us to comply with our legal obligation or legal interest.

3.2.1. Processing based on consent of an individual

We can process and store your personal data based on your explicit consent and only for the purposes for which said consent has been provided, but in particular:

  • for any and all forms of direct marketing, i.e. for providing you with information about products or services that you are ordering or for which we believe that could be of interest to you, such as notifications about any changes to our websites, general terms and conditions, introduction of new or changes to existing services or products, special offers, prize draws, and useful information about our services and products or other activities,
  • for identifying the data subject,
  • for preparing individually tailored offer related to our services or products,
  • for ensuring your cooperation in interactive functions of our websites, prize draws, voting, etc. if you so choose.

Osebne podatke pridobljene na podlagi soglasja Posameznika, obdelujemo le za tisti namen za katerega je bilo soglasje dano (npr. za obveščanje o marketinških aktivnostih, za sodelovanje v nagradnih igrah, ipd.).

Even though your provision of personal data is voluntary, the provision of personal data marked as required in the dedicated forms is a prerequisite for us to be able to complete your order and comply with our contractual obligations. If you do not wish to provide us with the personal data set out as mandatory for the execution of each individual purchase, you will not be able to use some of our services (e.g. make a purchase on our websites, use product repair services, etc.).

For communication purposes or for the purposes of notifying data subjects, CI can use any and all data provided at the time of consent, e.g. e-mail or regular mail, SMS/MMS messages (by using the provided phone number), or any other method selected by the data subject at the time of consent.

Your personal data will not be transmitted to third parties and will not be processed by them, unless this Policy explicitly specifies otherwise.

For order execution purposes, your data (first name, last name, address, phone number, email address and other data necessary for the performance of the service, such as transaction account number for the execution of the payment) will be transmitted to authorized third parties with whom we have concluded personal data processing contracts and who perform certain tasks related to personal data processing related to the execution of your order in our name and for our account (e.g. couriers delivering your goods, payment system providers, etc.).

Informing data subjects by email includes transmitting your email address to an external contractual provider with the purpose of displaying advertisement messages – in the event of external mailing lists, such an external provider must be named.

For a minor who cannot provide their own consent pursuant to the applicable legislation, one of their parents, guardians, or custodians must provide consent. Such a consent applies until it is revoked or changed by said parent, guardian, custodian or the minor, when the latter obtains the right to do so pursuant to the applicable legislation.

We cannot be held responsible for any errors, disputes or damage arising as a consequence of providing false information.

The data subject may revoke, change or limit their data processing consent at any time, in the same manner as said consent was given. In any case, the data subject may communicate their intention to revoke or change their consent by sending an email to [email protected]. The revocation or change of the consent only applies to the data being processed on the basis of said consent.

Below, we present some methods for providing your personal data processing consent and the purpose of the processing of said data.

3.2.1.1. Consent upon registration on our website or in our online store

In the process of registering on our website, you provide us with your consent allowing us to process all registration data, as well as all data pertaining to the content of your purchases, for the purposes of executing your order. You can provide your consent before concluding your registration process, by confirming that you accept our General Terms and Conditions and our Privacy Policy by checking the field “I have read and accept the General Terms and Conditions and the Privacy Policy, and I agree with the processing of my personal data for the execution of this purchase”.

The data you provide during the registration process will only be used for the execution of the order sent by you, and to comply with our contractual obligations, i.e. send information leaflets, offers, invoices, and other communication that could be necessary in order to execute your order and to inform you of any changes in our General Terms and Conditions or in our Privacy Policy.

In the event of your explicit consent, we will also use your data to inform you about the introduction of new services or a change in existing services or products, special offers, prize draws, and useful information about our services or products or any other marketing activities. To provide such a consent, check the field “I have read the Privacy Policy and agree with the processing of my personal data to remain informed about services or products” under the following text:

“I allow Center Invest d.o.o. to use and process my personal data set out above for the purpose of informing me in writing about its Perfect gift services or products, special offers, campaigns, new products, prize draws, and other marketing activities, and for the purpose of receiving personal invitations to fashion shows, jewelry exhibitions, media and other events, and grand openings of new stores.

I confirm that the aforementioned data is accurate and up-to-date. My personal data can be used by Center Invest d.o.o. until my consent is revoked.

By checking the box, you confirm that you have read the Privacy Policy and agree to the processing of your personal data for the purpose of receiving information about services or products.

The aforementioned consent is not a condition for the implementation of a purchase in our branches or in our online store.