Privacy Policy

Introduction

This Privacy Notice informs you about the data we collect about you, how we use it, and with whom we share it.

It is very important to us that you read the following Privacy Notice so that you are informed about the processing of your personal data and your rights under applicable data protection regulations.

Contents

1. Definitions
2. About ŠMIT ELECTRONIC
3. Collection, processing and retention of personal data
   • 3.1. General inquiry by e-mail
   • 3.2. Communication via social media profiles
   • 3.3. Browsing our website
   • 3.4. Newsletter subscription
   • 3.5. Links to other websites
4. With whom we share personal data
5. Transfer of personal data to third countries
6. Your rights
   • 6.1. Right to object to the use of your data
   • 6.2. How to exercise your rights
   • 6.3. Right to lodge a complaint with a supervisory authority
7. Changes to the Privacy Notice

1. Definitions

ŠMIT ELECTRONIC or WE refers to the company ŠMIT ELECTRONIC d.o.o., Croatia, Metanska 1, HR-44320 Kutina, OIB: 15852723582, operating under the brands ESHARK, S-BOX and WHITE SHARK. ESHARK is the White Shark premium brand.

GDPR means the EU General Data Protection Regulation: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC.

SERVICES means the purchase and sale of products offered by ŠMIT ELECTRONIC.

PERSONAL DATA / PERSONAL INFORMATION means any information relating to an identified or identifiable living individual.

CONTROLLER means a natural or legal person who determines the purposes and means of processing personal data and is responsible for the processing of such personal data in accordance with the GDPR and other applicable European and Member State data protection laws.

PROCESSOR refers to a natural or legal person who processes personal data on behalf of the Controller.

SUB-PROCESSOR refers to a natural or legal person who processes personal data on behalf of the Controller, as stated in the contract and in accordance with our instructions.

YOU refers to the natural person whose personal data is collected and processed by ŠMIT ELECTRONIC.

2. About ŠMIT ELECTRONIC

We, ŠMIT ELECTRONIC d.o.o., Croatia, Metanska 1, HR-44320 Kutina, OIB: 15852723582, are responsible as Controller for all personal data you provide to us in connection with the provision of our Services.

ŠMIT ELECTRONIC offers the purchase and sale of products. While providing Services to our customers and processing personal data, we act as Controller.

We act as Controller in situations where we process personal data for our own purposes and in the manner described in this Privacy Notice.

Contact details
ŠMIT ELECTRONIC
Metanska 1
44320 Kutina
Croatia

E-mail: kutina@smit-electronic.hr

3. Collection, processing and retention of personal data

Unless otherwise agreed, we will collect only the basic data necessary to provide our Services or in connection with our business relationship.

If business cooperation and a business relationship are established, we will also collect data related to business operations. This data may include information about purchases, services and other business activities, feedback, and any other information you may provide to us that is necessary for the business relationship.

We may collect your personal data directly from you or indirectly for one of the following reasons:

1. General inquiry by e-mail;
2. Communication via social media profiles;
3. Browsing our website, including third-party services such as Google Analytics;
4. Newsletter subscription;
5. Other sources, such as public databases, joint marketing partners, social media platforms, people you are connected with on social networks, public forums and other third parties.

We collect personal data depending on the specific situation listed above. We collect only necessary data.

3.1. General inquiry by e-mail

This applies to situations when you contact us with a question about our services or when you request new business opportunities.

Personal data we collect

• name;
• e-mail address;
• telephone number;
• country;
• related data, such as the name of your company, business role and telephone number.

Legal basis for collecting data

• performance of a contract, pursuant to Article 6(1)(b) of the GDPR;
• legitimate interest, pursuant to Article 6(1)(f) of the GDPR, for the purpose of providing our Services to you.

Data retention period

If we do not enter into a contract, we will delete your personal data within six (6) months after our last communication.

Also, based on legitimate interest, if you no longer wish us to contact you, you may object by sending an e-mail to our contact address.

3.2. Communication via social media profiles

This applies to situations when you have initiated communication with us through social media profiles.

Personal data we collect

• name;
• e-mail address;
• telephone number.

Legal basis for collecting data

• consent, pursuant to Article 6(1)(a) of the GDPR;
• legitimate interest, pursuant to Article 6(1)(f) of the GDPR.

Data retention period

If you have not engaged us for any of our Services, we will retain the data based on legitimate interests until you object to the processing of your personal data for this purpose.

If you have given consent, we will retain the data until you withdraw your consent.

3.3. Browsing our website

This applies to situations when you browse our website, including the use of third-party services such as Google Analytics.

Personal data we collect

We usually collect:

IP address;
browser type;
pages you visited;
the order in which you visited the pages;
information on whether you are a new or returning visitor.

This data is processed only in a way that does not identify anyone, but helps us maintain and improve our website and business.

For more information, please read our Cookie Policy.

Legal basis for collecting data

consent, pursuant to Article 6(1)(a) of the GDPR;
legitimate interest, pursuant to Article 6(1)(f) of the GDPR.

Data retention period

We retain the data until you object to the processing of your personal data for this purpose or until you withdraw your consent.

For more information, please read our Cookie Policy.

3.4. Newsletter subscription

Personal data we collect

e-mail address;
name.

We will send you e-mail updates and information about our new products and services, upcoming events or other advertising campaigns and news.

We also collect statistics on e-mail open rates and click rates.

Legal basis for collecting data

consent, pursuant to Article 6(1)(a) of the GDPR;
legitimate interest, pursuant to Article 6(1)(f) of the GDPR, for the purpose of informing you about us and our services.

Data retention period

If marketing communication is based on our legitimate interests, we will retain the data until you object to the processing of your personal data for this purpose.

If the processing is based on consent given, we will retain the data until you unsubscribe, that is, until you withdraw your consent.

ŠMIT ELECTRONIC may store your e-mail address for the purpose of sending promotional and educational newsletters. Your e-mail address is stored in Kutina, on the company’s server, and will also be forwarded to Mailchimp, which we use to send newsletters.

We will retain your e-mail address until you unsubscribe from the newsletter. You may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.

You may unsubscribe from receiving our newsletter at any time by clicking the Unsubscribe icon, which will be available in each individual newsletter issue.

By withdrawing consent, you will no longer receive our newsletters, but you will still be able to use our website and other services.

3.5. Links to other websites

This website contains links to other websites.

Please note that ŠMIT ELECTRONIC cannot be responsible for privacy practices on other websites.

We encourage our users to read the privacy statements of every website that collects personal data.

This Privacy Notice applies exclusively to information collected on the website eshark.gg.

4. With whom we share personal data

We may share your personal data with:

third parties as Sub-processors, if necessary or permitted by applicable law;
third parties as Sub-processors for the purpose of providing specific functionalities, such as targeted marketing and other tools necessary to provide our Services, for example Google Analytics and Lloyds design d.o.o., which technically maintains the website;
third parties legally authorized to process credit decisions, prevent fraud and pursue debtors;
third parties legally authorized to request access to and sharing of your personal data for criminal proceedings or due to threats to public safety.

Otherwise, no third party will have access to your personal data unless there is a legal requirement or you give us permission.

5. Transfer of personal data to third countries

Considering the above, we may share your personal data with third parties located outside the European Economic Area.

All transfers of personal data are carried out in accordance with EU GDPR data protection standards.

6. Your rights

In accordance with the EU General Data Protection Regulation, you have the following rights:

The right to be informed about the collection and use of your personal data, which is a key transparency requirement under the GDPR;
The right of access to personal data, meaning the right to request a copy of the personal data we hold about you;
The right to rectification of your personal data if the data is incomplete or inaccurate;
The right to erasure, or the right to be forgotten, when your personal data is no longer necessary or when your personal data has been used unlawfully;
The right to restriction of processing of your personal data in certain circumstances, as an alternative to the right to erasure;
The right to data portability, meaning that you can obtain and reuse your personal data for your own purposes;
The right to object to the processing of your personal data in a way that will stop or prevent us from processing your personal data in accordance with our legitimate interest, for example for direct marketing purposes;
Rights related to automated decision-making and profiling;
The right to lodge a complaint with a national data protection authority.

The above rights may be exercised in accordance with the EU General Data Protection Regulation and national personal data protection regulations.

6.1. Right to object to the use of your data

You have the right to object, meaning the right to stop or prevent an organization from using your data in certain circumstances.

We may not have to stop processing your personal data if we provide strong and legitimate reasons for continuing to use your data.

You may object to processing only when we use your data:

for our legitimate interests;
for direct marketing purposes.

In cases where we rely on legitimate interest as the legal basis for processing your data, you may object to such processing at any time.

In that case, we are obliged to prove to you:

that there are compelling legitimate grounds for processing the data on our side or on the side of a third party that override your interests, rights or freedoms; or
that processing the data is necessary in order to establish, exercise or defend legal claims.

On the other hand, in the case of direct marketing, we cannot refuse your objection and we will stop using your data for direct marketing purposes.

You may exercise this right by unsubscribing.

6.2. How to exercise your rights

If you have any concerns regarding the way we handle your personal data or wish to file a complaint about the way we have handled your personal data, you may contact our Data Protection Officer by sending an e-mail to:

kutina@smit-electronic.hr

6.3. Right to lodge a complaint with a supervisory authority

If you believe that we are processing your personal data unlawfully, you have the right to lodge a complaint with the supervisory authority for personal data protection.

In the Republic of Croatia, this authority is the Croatian Personal Data Protection Agency: www.azop.hr.

If your habitual residence, workplace or place of the alleged infringement is in another EU Member State, or if you believe that your rights have been violated in another EU Member State, you may lodge a complaint with the supervisory authority of that state.

7. Changes to the Privacy Notice

The last update of this Privacy Notice was in October 2020.

From time to time, you may check whether this Privacy Notice has changed or been amended in accordance with applicable data protection rules.

If you have any questions regarding your privacy, wish to withdraw your consent to the processing of your personal data, or exercise any of your rights arising from this Notice, you may do so at any time by sending an e-mail to:

kutina@smit-electronic.hr