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PRIVACY AND DATA PROTECTION POLICY

These Privacy and Data Protection Policy (hereinafter: “Policy”) explain how the company DEFINICIJA HRANE d.o.o. (hereinafter: “DEFINICIJA HRANE”, “Data Controller”) collects, uses, and manages your personal data within the “BABY FOOD CHART” application (hereinafter: “Application”, “BABY FOOD CHART”), all in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

DEFINICIJA HRANE, as the service provider of the Application, is committed to protecting and respecting your privacy. Please read this Policy carefully to understand why and how we collect your personal data and how it will be used.

Regarding the personal data we collect, DEFINICIJA HRANE is the “Data Controller”, i.e., the one who determines the purposes, needs, and means by which personal data are processed. If you wish to contact us regarding these policies or concerning your personal data, please use the contact details provided below.

How and when do we collect your personal data?

We collect your personal data when necessary to fulfill your consumer (user) needs or for the needs of our business:

  • when you access the Application, we will collect your Mobile ID;
  • when you contact us via email and request assistance or ask a question so that we can fulfill any of your rights guaranteed by applicable regulations;
  • when you contact us via social media, we collect the information you provided to us when making inquiries or requests.

There is no password or username required to enter the Application; therefore, DEFINICIJA HRANE recommends that all Application users take care of their device’s entry password. We recommend changing the password periodically (at least once a year).

The specific categories of your personal data mentioned above are collected either based on the consent presented to you when entering the Application via a pop-up window or based on legitimate interest.

What data and for what purpose do we collect directly from you?

The typical categories of data we collect from users include: name, surname, email address, date of birth, gender, etc.

We collect your personal data for the purpose of:

  • providing the service;
  • efficiently responding to your inquiry and processing your requests;
  • statistical data processing;
  • sending materials, offers, and contacting you;
  • improving the quality of content, functionality, and services;
  • monitoring and improving our relationship with you.

What privacy rights do you have?

Please note that at any time, you have the right to request the following from DEFINICIJA HRANE:

TO PROVIDE YOU ACCESS TO YOUR PERSONAL DATA
You can ask DEFINICIJA HRANE what personal data it uses, and you can also request access to that personal data. You have the right to know the purpose of processing, which categories of your personal data we keep, the bodies or categories of bodies with whom your personal data is shared, the retention period of data, as well as the source of data in cases where data is indirectly collected.

TO PROVIDE YOU WITH A COPY OF THE PERSONAL DATA WE HOLD
You can contact us if you want a copy of some or all of the personal data we hold about you.

TO REQUEST CORRECTION OF INACCURATE DATA
We want your personal data to be accurate and up-to-date. You can ask us to correct or remove personal data that you believe is inaccurate or outdated.

TO REQUEST DELETION OF PERSONAL DATA
You may request that we stop processing or even request deletion of personal data about you that we hold. If we need your personal data to fulfill some contractual obligation to you, DEFINICIJA HRANE may no longer be able to perform such contractual obligations. Also, if your personal data is necessary for DEFINICIJA HRANE to fulfill certain legal obligations, your request may not be able to be fulfilled.

TO LIMIT ACCESS TO YOUR DATA (TO US AND/OR THIRD PARTIES) IN CERTAIN PROCESSES OR ENTIRELY
If you want to challenge the accuracy of data, or we no longer need personal data for the purpose of processing, but you need it to establish, execute, or defend legal claims, or you have objected to processing on the basis that the Data Controller considers legitimate, you have the right to request restriction of personal data processing.

TO LODGE A COMPLAINT ABOUT HOW WE USE YOUR DATA
Please remember that you have the right to object to the processing of personal data based on the legal basis considered legitimate by the Data Controller.

TO REQUEST DATA TRANSFER TO ANOTHER PROCESSOR (RIGHT TO DATA PORTABILITY)
If processing is based on your consent or is carried out by automated means, you have the right to request that the Data Controller transfer data to another processor.

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To exercise any of the above rights, please use the contact details from the Information about the Company section.
If you are not satisfied with how we have collected or used your personal data, you can lodge a formal complaint with the Personal Data Protection Agency.

Where is your data stored?

We store the personal data we collect about you in a secure environment. Your personal data is protected against unauthorized access, disclosure, use, alteration, or destruction by any organization or individual. We do not store data in paper form. Processed data is stored in IT systems, but sometimes data is stored on servers of our trusted service providers.

Personal data within the “SETTINGS” section, i.e., the “BABY INFORMATION” subsection within the Application

Since the Application recommends food/recipes based on your child’s birth date or age, the Application provides the possibility of entering the following personal data within the “SETTINGS” section, i.e., the “BABY INFORMATION” subsection within the Application:

Birthdate (where you can enter the date, month, and year of birth of the child for whom you want food/recipe recommendations via the Application)

Name (where you can enter the name and/or surname of the child for whom you want food/recipe recommendations via the Application)

Gender (where you indicate the gender of the child for whom you want food/recipe recommendations via the Application by choosing one of the 2-character displays)

It is not possible to use the Application without entering the above-mentioned personal data (Birthdate, Name, and Gender). DEFINICIJA HRANE does not collect or process your personal data or the personal data of your child or any other personal data you enter within the “SETTINGS” section, i.e., the “BABY INFORMATION” subsection within the Application.

If you have entered the wrong birth date of the child for whom you want food recommendations via the Application by mistake or want to adjust the Application for another child, or for any other reason, you want to change some other data, you can change the above-mentioned data within the “SETTINGS” section, i.e., the “BABY INFORMATION” subsection within the Application at any time.

Within the Application, it is possible to enter your notes on your child’s reaction to certain foods/recipes listed within the Application, the date of the first trial of certain foods/recipes listed within the Application, and how the child reacted to a particular food/recipe listed within the Application (hereinafter: “Notes”).

DEFINICIJA HRANE does not collect, store, process, or share personal data that you enter within the “SETTINGS” section, i.e., the “BABY INFORMATION” subsection within the Application, nor the personal data you enter in your Notes.

All personal data you enter into the Application within the “SETTINGS” section, i.e., the “BABY INFORMATION” subsection within the Application, and in the Notes within the Application, are available exclusively to you as the user of the Application and are stored exclusively on the mobile phone/device of the user on which the Application is installed, and DEFINICIJA HRANE does not have access to them, nor does it collect, store, process, or share them with third parties.

By deleting the Application, all personal data entered within the “SETTINGS” section, i.e., the “BABY INFORMATION” subsection, and all personal and other data entered in the Notes that you have independently saved within the Application are automatically deleted.

Sharing personal data with third parties

Privacy protection is important to us, so DEFINICIJA HRANE will never share your personal data with third parties except for the purposes described in these Policies. We will always inform you about the sharing and transfer of data and seek your consent.

DEFINICIJA HRANE collaborates and shares your personal data solely with trusted partners, using secure IT systems. When we do so, data is transferred to servers located in the EU or in a country that provides an adequate level of protection in accordance with EU legislation.

In some cases, our partners may process your data outside the European Union. However, the contracts we conclude with such entities oblige them to treat your data with special security measures in accordance with the regulations in force in the Member States of the European Union. In the case of data transfer to the US, we will seek your permission considering the consequences of the “Schrems II” ruling and the invalidation of the Privacy Shield.

The purposes for which we share data with our trusted partners include, for example, marketing, finance, advertising, etc. These service providers are required, under relevant agreements, to use the data entrusted to them only in accordance with our guidelines and strictly for the purpose we have defined. We also require them to adequately protect your data and treat it as a business secret.

How long will we keep your personal data?

DEFINICIJA HRANE will not retain your personal data longer than the period necessary for the data to fulfill the purpose of its use. When you are interested in something and decide to ask our experts a question, we will process your request and your personal data, for which the legal basis is our legitimate interest since you have directly contacted us. In this case, we process your email address and other data you provide to us in your question. We will keep the category of personal data we process for this purpose for a maximum of 6 months after which they are deleted. If you are interested in details and retention periods, you can contact us at: kmatkovic@definicijahrane.hr or tniseteo@definicijahrane.hr

Our partners and other websites

The Application may contain links to third-party websites (e.g., our partners’ websites).

These Policies apply only to this Application, so when connecting to other websites, we refer you to read their privacy policies.

Entry into force and changes to the Privacy Policy

DEFINICIJA HRANE may amend these Privacy Policies at any time by publishing the amended text in the Application itself. In this case, a notice of the change in the Privacy Policies will be displayed when entering the Application via a pop-up window.

These Privacy Policies shall enter into force on June 9, 2021.

Information about the Company

Company:
DEFINICIJA HRANE limited liability company for consultancy

Headquarters and Business Address:
Zagreb (City of Zagreb), Radnička cesta 20

VAT / OIB Number:
89495786785

Share Capital:
20,000.00 HRK

Company Management:
TENA NISETEO, OIB: 16127066843, Zagreb, Furjanićka ulica 23, Director, representing independently and individually

KARMEN MATKOVIĆ MELKI, OIB: 72035486641, Zagreb, Radnička cesta 20, Director, representing independently and individually

Business Bank:
Privredna banka Zagreb d.d.

IBAN:
HR2923400091110472197

The company is registered in the Commercial Court Register of the Commercial Court in Zagreb under the subject registration number (MBS): 080760559.