PRIVACY AND COOKIE POLICY

This Privacy and Cookie Policy outlines the types of personal information we collect, how it is used, and the measures we take to protect your personal information when you use our website. This policy also covers the use of cookies on our site.

PRIVACY POLICY

The legal entity responsible for data processing is:

Simon Innotech d.o.o.
Ulica Baščanske ploče 5
10430 Samobor
Republic of Croatia

Email: support@lepinwatches.com

We appreciate your interest in our online shop. The protection of your privacy is very important to us. Below we provide detailed information about how we handle your data.

1. Access data and hosting

You can visit our websites without providing any personal information, aside from your IP address. Each time you access a website, the web server automatically saves a so-called server log file, which contains, for example, the name of the requested file, your IP address, the date and time of access, the amount of data transferred, and the requesting provider (access data), and documents the access. This access data is evaluated exclusively for the purpose of ensuring trouble-free operation of the site and improving our offering. This serves to safeguard our legitimate interests in a correct presentation of our offering, which prevail within the framework of a balancing of interests, in accordance with Art. 6 (1) (f) General Data Protection Regulation (hereinafter: GDPR). All access data will be deleted no later than seven days after your visit to the site.

Hosting

The services for hosting and displaying the website are partly provided by our service providers as part of processing on our behalf. Unless otherwise stated in this privacy policy, all access data and all data collected in forms provided for this purpose on this website are processed on their servers. If you have any questions about our service providers and the basis of our collaboration with them, please use the contact options described in this privacy policy.

2. Data processing for contract processing and contacting you

2.1 Data processing for contract processing

For the purpose of contract processing (including inquiries regarding and processing of any existing warranty and performance claims as well as any statutory updating obligations) in accordance with Art. 6 (1) (b) GDPR, we collect personal data when you voluntarily provide it to us as part of your order. Mandatory fields are marked as such, as in these cases we absolutely need the data to process the contract, and without it we cannot ship the order. The data collected can be seen from the respective input forms.

Further information on the processing of your data, in particular on the transfer to our service providers for the purpose of order, payment, and shipping processing, can be found in the following sections of this privacy policy. After the contract has been fully processed, your data will be restricted for further processing and deleted after the expiry of the retention periods under tax and commercial law in accordance with Art. 6 (1) (c) GDPR, unless you have expressly consented to further use of your data in accordance with Art. 6 (1) (a) GDPR or we reserve the right to use your data in any other way that is permitted by law and about which we will inform you in this policy.

2.2 Customer Account

If you have given your consent in accordance with Art. 6 (1) (a) GDPR by deciding to open a customer account, we will use your data for the purpose of opening a customer account and storing your data for future orders on our website. You can delete your customer account at any time. This can be done either by sending a message to the contact option described in this privacy policy or via a dedicated function in your customer account. After your customer account has been deleted, your data will be deleted unless you have expressly consented to further use of your data in accordance with Art. 6 (1) (a) GDPR or we reserve the right to use your data in any other way that is permitted by law and about which we will inform you in this policy.

2.3 Contact

As part of customer communication, we collect personal data to process your inquiries in accordance with Art. 6 (1) (b) GDPR if you voluntarily provide it to us when contacting us (e.g., via contact form, or email). Mandatory fields are marked as such, as in these cases we absolutely need the data to process your contact. The data collected can be seen in the respective input forms. Once your request has been fully processed, your data will be deleted unless you have expressly consented to further use of your data in accordance with Art. 6 (1) (a) GDPR or we reserve the right to use your data in any other way that is permitted by law and about which we will inform you in this declaration.

3. Data processing for the purpose of shipping processing

To fulfill the contract in accordance with Art. 6 (1) (b) GDPR, we will pass on your data to the shipping service provider commissioned with the delivery, insofar as this is necessary for the delivery of ordered goods. If you have any questions about our service providers and the basis of our cooperation with them, please use the contact option described in this privacy policy.

Data transfer to shipping service providers for the purpose of shipping notification

If you have given us your express consent to do so during or after your order, we will pass on your email address and telephone number to the selected shipping service provider on this basis in accordance with Art. 6 (1) (a) GDPR so that they can contact you before delivery for the purpose of notifying you of or coordinating the delivery.

Consent can be revoked at any time by sending a message to the contact option described in this privacy policy or directly to the shipping service provider at the contact address listed below. After revocation, we will delete the data you provided for this purpose unless you have expressly consented to further use of your data or we reserve the right to use the data in any other way that is permitted by law and about which we will inform you in this declaration. If you have any questions about our service providers and the basis of our cooperation with them, please use the contact option described in this privacy policy.

Delivery is carried out in cooperation with MBE Croatia (https://www.mbe.hr/), which provides comprehensive logistics services in partnership with leading courier companies, including GLS, DPD, Overseas Express, inTime, and Croatian Post – Paket 24.

4. Data processing for payment processing

We work with these partners to process payments in our online shop: technical service providers, credit institutions, and payment service providers.

4.1 Data processing for transaction processing

We will pass on the data necessary for processing the payment transaction to Stripe Payments Europe, Limited, 1 Grand Canal Street Lower. Grand Canal Dock. Dublin. D02 H210. Ireland, that work for us as the selected payment service provider, insofar as this is necessary to process the payment. This serves the purpose of fulfilling the contract in accordance with Art. 6 (1) (b) GDPR. In some cases, the payment service providers collect the data required for processing the payment themselves, e.g., on their own website or via a technical integration in the ordering process. The privacy policy of the respective payment service provider applies in this respect and you can find it here: https://stripe.com/en-hr/privacy

If you have any questions about our payment processing partner and the basis of our cooperation with it, you can contact us via email provided in this Policy or contact Stripe Payments Europe at the following email address: privacy@stripe.com or you can contact data protection officer at dpo@stripe.com.

5. Advertising by email

5.1 Email newsletter with registration and newsletter tracking

If you subscribe to our newsletter, we will use the data required for this purpose or separately provided by you to regularly send you our email newsletter based on your consent in accordance with Art. 6 (1) (a) GDPR. You can unsubscribe from the newsletter at any time and can do so either by sending a message to the contact option described below or via a link provided for this purpose in the newsletter. After unsubscribing, we will delete your email address from the recipient list.

We would like to point out that we evaluate your user behavior when sending the newsletter. For this purpose, we also analyze your use of our newsletter by measuring, storing, and evaluating opening rates and click rates for the purpose of designing future newsletter campaigns (“newsletter tracking”).

For this evaluation, the emails sent contain single-pixel technologies (e.g., so-called web beacons, tracking pixels) that are stored on our website.

For evaluation purposes, we link the following “newsletter data”:

the page from which the page was requested (so-called referrer URL),
the date and time of the visit,
the description of the type of web browser used,
the IP address of the requesting computer,
the email address,
the date and time of registration and confirmation,
and the one-pixel technologies with your email address or IP address and, if applicable, an individual ID. Links contained in the newsletter may also contain this ID.

If you do not wish to be tracked by the newsletter, you can unsubscribe from the newsletter at any time – as described above.

The information will be stored as long as you are subscribed to the newsletter.

5.2 Email newsletter without registration and your right of objection

If we receive your email address in connection with the sale of a product or service and you have not objected, we reserve the right to regularly send you offers for products from our range similar to those you have already purchased by email. This serves to safeguard our legitimate interests in advertising to our customers, which prevail within the context of a balancing of interests, in accordance with Art. 6 (1) (f) GDPR.

You can object to this use of your email address at any time by sending a message to the contact option described in this privacy policy or via a link provided for this purpose in the advertising email, without incurring any costs other than the transmission costs according to the basic rates.

After unsubscribing, we will delete your email address from the recipient list.

6. Cookies and other technologies

6.1 General information

To make visiting our website more attractive and to enable the use of certain functions, we use technologies on various pages, including so-called cookies. Cookies are small text files that are automatically stored on your device. Some of the cookies we use are deleted after the end of the browser session, i.e., after you close your browser (so-called session cookies). Other cookies remain on your device and enable us to recognize your browser the next time you visit (persistent cookies).

Protection of privacy on end devices

When using our online offering, we use technologies that are absolutely necessary to be able to provide the expressly requested telemedia service. Storing information on your device or accessing information already stored on your device does not require your consent.

For functions that are not absolutely necessary, storing information on your device or accessing information already stored on your device requires your consent. We would like to point out that if you do not grant your consent, parts of the website may not be fully usable. Any consent you may have granted will remain in effect until you adjust or reset the respective settings on your device.

Possible downstream data processing through cookies and other technologies

We use technologies that are absolutely necessary for the use of certain functions of our website (e.g., shopping cart function). These technologies collect and process IP address, time of visit, device and browser information, and information about your use of our website (e.g., information about the contents of the shopping cart). Within the framework of a balancing of interests, this serves the overriding legitimate interest in an optimized presentation of our offer in accordance with Art. 6 (1) (f) GDPR.

We also use technologies to fulfill the legal obligations to which we are subject (e.g., to be able to prove consent to the processing of your personal data), as well as for web analysis and online marketing. Further information on this, including the respective legal basis for data processing, can be found in the following sections of this privacy policy.

Cookie Settings

You can find the cookie settings for your browser at Microsoft Edge™ / Safari™ / Chrome™ / Firefox™ / Opera™ cookie settings.

If you have consented to the use of these technologies in accordance with Art. 6 (1) (a) GDPR, you can revoke your consent at any time by sending a message to the contact details described in the privacy policy.

6.2 Use of the CookieYes Consent Management Platform to manage consents

On our website, we use the CookieYes Consent Management Platform to inform you about the cookies and other technologies we use on our website, as well as to obtain, manage, and document your legally required consent to the processing of your personal data by these technologies. This is necessary according to Art. 6 (1) (c) GDPR to fulfill our legal obligation under Art. 7 (1) GDPR to be able to prove your consent to the processing of your personal data, to which we are subject. CookieYes is an offering from CookieYes Limited, 3 Warren Yard Warren Park, Wolverton Mill, Milton Keynes, United Kingdom, MK12 5NW, which processes your data on our behalf. When you visit our website, the CookieYes web server saves a so-called server log file, which also contains your anonymized IP address, the date and time of your visit, device and browser information, and information about your consent behavior. Your data will be deleted after three years unless you have expressly consented to further use of your data in accordance with Art. 6 (1) (a) GDPR.

Our service provider is located and/or use servers in the following countries, for which the European Commission has determined an adequate level of data protection: UK.

You can find the privacy policy of the respective consent management platform provider here:
https://www.cookieyes.com/privacy-policy/

If you have any questions, comments or requests regarding CookieYes privacy practices or about its Privacy Policy please contact it as follows: support@cookieyes.com

7. Use of cookies and other technologies

We use the following cookies and other third-party technologies on our website. Unless otherwise stated for the individual technologies, this is done on the basis of your consent in accordance with Art. 6 (1) (a) GDPR. Once the purpose no longer applies and we no longer use the respective technology, the data collected in this context will be deleted. You can revoke your consent at any time with future effect. Further information on your revocation options can be found in the “Cookies and other technologies” section. Further information, including the basis of our cooperation with the individual providers, can be found for the individual technologies. If you have any questions about the providers and the basis of our cooperation with them, please use the contact options described in this privacy policy.

7.1 Use of Google Services

We use the technologies described below from Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). The information automatically collected by Google technologies about your use of our website is generally transferred to a server of Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA and stored there. Unless otherwise stated for the individual technologies, data processing is based on an agreement concluded for the respective technology between joint controllers in accordance with Art. 26 GDPR. Further information about data processing by Google can be found in the Google Privacy Policy.

Our service providers are located and/or use servers in countries outside the EU and the EEA for which the European Commission has determined an adequate level of data protection.

Our service providers are located and/or use servers in countries outside the EU and the EEA. There is no adequacy decision from the European Commission for these countries. Our cooperation with them is based on standard data protection clauses of the European Commission.

Google Analytics

For the purpose of website analysis, Google Analytics automatically collects and stores data (IP address, time of visit, device and browser information, as well as information about your use of our website), from which user profiles are created using pseudonyms. Cookies may be used for this purpose. If you visit our website from the EU, your IP address will be stored on a server located in the EU to derive location data and then immediately deleted before the traffic is forwarded to other Google servers for processing. Data processing is carried out on the basis of a contract processing agreement with Google.

For the purpose of optimized marketing of our website, we have activated the data sharing settings for “Google Products and Services”. This allows Google to access the data collected and processed by Google Analytics and subsequently use it to improve Google services. The release of data to Google within the scope of these data sharing settings is based on an additional agreement between the responsible parties. We have no influence on subsequent data processing by Google.

For the purpose of optimized marketing of our website, we use the so-called User ID function. This function allows us to assign a unique, permanent ID to your interaction data from one or more sessions on our online presence and thus analyze your user behavior across devices and sessions.

For web analysis, the Google Analytics extension function Google Signals enables so-called “cross-device tracking.” If your internet-enabled devices are linked to your Google Account and you have activated the “personalized advertising” setting in your Google Account, Google can create reports on your usage behavior (especially the number of users across devices), even if you change your device. We do not process personal data in this regard; we only receive statistics compiled on the basis of Google Signals.

For web analysis and advertising purposes, the Google Analytics extension function uses the so-called DoubleClick cookie to recognize your browser when you visit other websites. Google will use this information to compile reports on website activity and to provide other services related to website usage.

Google reCAPTCHA

To protect against misuse of our web forms and spam by automated software (so-called bots), Google reCAPTCHA collects data (IP address, time of visit, browser information, and information about your use of our website) and analyzes your use of our website using JavaScript and cookies. In addition, other cookies stored in your browser by Google services are evaluated. Personal data from the input fields of the respective form is not read or saved.

Google Fonts

To ensure a consistent presentation of the content on our website, the “Google Fonts” script code collects data (IP address, time of visit, device and browser information), transmits it to Google, and then processes it. We have no influence on this subsequent data processing.

Google Tag Manager

Google Tag Manager allows us to manage various codes and services on our website. When implementing individual tags, Google may also process personal data (e.g., IP address, online identifiers (including cookies)). Data processing is carried out on the basis of a contract processing agreement with Google.

By using Google Tag Manager, various services/technologies can be integrated. If you do not wish to use individual tracking services and have therefore deactivated them, the deactivation will remain in place for all affected tracking tags integrated by Google Tag Manager.

7.2 Use of Facebook Services

Use of Facebook Pixel

We use the Facebook Pixel as part of the technologies described below from Meta Platforms Ireland Ltd., Block J, Serpentine Avenue, Dublin 4, Ireland (“Facebook (by Meta)” or “Meta Platforms Ireland”). The Facebook Pixel automatically collects and stores data (IP address, time of visit, device and browser information, as well as information about your use of our website based on events specified by us, such as visiting a website or subscribing to a newsletter). User profiles are then created using pseudonyms. As part of the so-called extended data matching, information that can be used to identify individuals (e.g., names, email addresses, and telephone numbers) is also collected and stored in hashed form for comparison purposes. For this purpose, the Facebook Pixel automatically sets a cookie when you visit our website. This cookie automatically uses a pseudonymous cookie ID to recognize your browser when you visit other websites. Facebook (by Meta) will combine this information with other data from your Facebook account and use it to compile reports on website activity and to provide other services related to website activity, in particular personalized and group-based advertising.

The information automatically collected by Facebook (by Meta) technologies about your use of our website is generally transferred to a server of Meta Platforms, Inc., 1601 Willow Road, Menlo Park, California 94025, USA and stored there. Further information about data processing by Facebook can be found in the Facebook privacy policy (by Meta).

Our service providers are located and/or use servers in the following countries, for which the European Commission has determined an adequate level of data protection: USA, Canada, Japan, South Korea, New Zealand, United Kingdom, Argentina.

The adequacy decision for the USA applies as the basis for transfers to third countries, provided that the respective service provider is certified. Certification is available.

Our service providers are located and/or use servers in the following countries: Australia, Hong Kong, India, Indonesia, Malaysia, Singapore, Thailand, Taiwan, Brazil, Mexico. There is no adequacy decision from the European Commission for these countries. Our cooperation with them is based on these guarantees: Standard data protection clauses of the European Commission.

Facebook Ads (Advertising Manager)

We advertise this website on Facebook (by Meta) and other platforms using Facebook Ads. We determine the parameters of each advertising campaign. Facebook (by Meta) is responsible for the precise implementation, in particular the decision on the placement of ads for individual users. Unless otherwise stated for the individual technologies, data processing is based on an agreement between joint controllers in accordance with Art. 26 GDPR. Joint controllership is limited to the collection of data and its transmission to Meta Platforms Ireland. Subsequent data processing by Meta Platforms Ireland is not included here.

8. Social Media

8.1 Social Buttons from Facebook (by Meta), Instagram (by Meta)

Our website uses social buttons from social networks. These are merely embedded in the page as HTML links, so no connection to the servers of the respective provider is established when you visit our website. If you click on one of the buttons, the website of the respective social network opens in a new window of your browser. There you can, for example, click the Like or Share button.

8.2 Our online presence on Facebook (by Meta), Instagram (by Meta)

If you have given your consent to this in accordance with Art. 6 (1) (a) GDPR to the respective social media operator, when you visit our online presence on the social media platforms mentioned above, your data will be automatically collected and stored for market research and advertising purposes, from which user profiles will be created using pseudonyms. These can be used, for example, to place advertisements within and outside the platforms that presumably correspond to your interests. Cookies are generally used for this purpose. Detailed information on the processing and use of data by the respective social media operator, as well as a contact option and your related rights and setting options to protect your privacy, can be found in the providers’ data protection notices linked below. If you still need help in this regard, you can contact us.

Facebook (by Meta) is an offering of Meta Platforms Ireland Ltd., Block J, Serpentine Avenue, Dublin 4, Ireland (“Meta Platforms Ireland”). The information automatically collected by Meta Platforms Ireland about your use of our online presence on Facebook (by Meta) is generally transferred to a server of Meta Platforms, Inc., 1601 Willow Road, Menlo Park, California 94025, USA and stored there. Data processing when visiting a Facebook (by Meta) fan page is based on an agreement between joint controllers in accordance with Art. 26 GDPR.

The adequacy decision for the USA applies as the basis for transfers to third countries, provided the respective service provider is certified. Certification is available.

Our service providers are located and/or use servers in the following countries: Australia, Hong Kong, India, Indonesia, Malaysia, Singapore, Thailand, Taiwan, Brazil, Mexico.

There is no adequacy decision from the European Commission for these countries. Our cooperation with them is based on these guarantees: Standard data protection clauses of the European Commission.

Instagram (by Meta) is an offering of Meta Platforms Ireland Ltd., Block J, Serpentine Avenue, Dublin 4, Ireland (“Meta Platforms Ireland”). The information automatically collected by Meta Platforms Ireland about your use of our online presence on Instagram is generally transferred to a server of Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, USA, Menlo Park, California 94025, USA and stored there. Data processing when visiting an Instagram (by Meta) fan page is based on an agreement between joint controllers in accordance with Art. 26 GDPR. Further information (information on Insights data) can be found here.

The adequacy decision for the USA applies as the basis for transfers to third countries, provided the respective service provider is certified. Certification is available.

Our service providers are located and/or use servers in the following countries: Australia, Hong Kong, India, Indonesia, Malaysia, Singapore, Thailand, Taiwan, Brazil, Mexico.

There is no adequacy decision from the European Commission for these countries. Our cooperation with you is based on these guarantees: Standard data protection clauses of the European Commission.

9. Contact options and your rights

9.1 Your rights

As a data subject, you have the following rights:

the right to be informed about the collection and use of your personal data, including its purpose, retention period, and how to exercise your other rights;
the right to request and receive a copy of your personal data that we hold
the right to immediately request the correction of incorrect or incomplete personal data stored by us;
the right to request that we limit how we process your personal data under specific circumstances, such as when accuracy is being contested
the right to object to the processing of your personal data for certain purposes, such as direct marketing
the right to request the deletion of your personal data stored by us, unless further processing is necessary:

to exercise the right to freedom of expression and information;
to fulfill a legal obligation;
for reasons of public interest or
to assert, exercise or defend legal claims;
According to Art. 18 GDPR, the right to to demand restriction of the processing of your personal data, provided that
you dispute the accuracy of the data;
the processing is unlawful, but you refuse to delete it;
we no longer need the data, but you need it to assert, exercise or defend legal claims or
you have objected to the processing pursuant to Art. 21 GDPR;
pursuant to Art. 20 GDPR, the right to receive your personal data that you have provided to us in a structured, common and machine-readable format or to request that it be transmitted to another controller;
pursuant to Art. 77 GDPR, the right to lodge a complaint with a supervisory authority. As a rule, you can contact the supervisory authority of your usual place of residence or work or of our company headquarters.

Right of objection

If we process personal data as explained above to protect our legitimate interests, which prevail within the framework of a balancing of interests, you can object to this processing with effect for the future. If the processing is carried out for direct marketing purposes, you can exercise this right at any time as described above. If the processing is carried out for other purposes, you only have the right to object if there are reasons related to your particular situation.

After exercising your right of objection, we will no longer process your personal data for these purposes unless we can demonstrate compelling legitimate grounds for the processing which outweigh your interests, rights and freedoms, or if the processing serves to assert, exercise or defend legal claims.

This does not apply if the processing is carried out for direct marketing purposes. We will then no longer process your personal data for this purpose.

9.2 Contact Options

If you have any questions about the collection, processing, or use of your personal data, or if you wish to request information, correction, restriction, or deletion of data, or if you wish to revoke consent you have given, or object to a specific use of your data, please contact us directly using the following contact details:

Simon Innotech d.o.o.
Ulica Baščanske ploče 5
10430 Samobor
Republic of Croatia

Email: support@lepinwatches.com

9.3 Croatian Personal Data Protection Agency

If you believe that that your rights guaranteed by General Data Protection Regulation and the Act Implementing the General Data Protection Regulation have been violated by us, you may submit a request to Croatian Personal Data Protection Agency for a determination of a violation of rights.

You can submit a request to determine a violation of rights in the following ways:

in person (declare orally on the record)
in writing to the address: Personal Data Protection Agency (Agencija za zaštitu osobnih podataka), Ulica Metela Ožegovića 16, 10 000 Zagreb
by filling out the online form on the web page of the Agency – https://azop.hr/zahtjev-za-utvrdivanje-povrede-prava/
by sending an e-mail: azop@azop.hr
by sending a fax to the number: 01/ 46-090-99