1. General provisions
FABULAR BRANDING d.o.o. from Zagreb, Rokov Perivoj 3 (hereinafter: Fabular) is the controller of personal data of Users and such data shall be processed within the scope of these Rules of Privacy.
FABULAR respects your privacy and processes Users’ personal data in accordance with the 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 movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), and with the Act on the Implementation of the General Data Protection Regulation (Official Gazette number 42/2018).
2. Which personal data are processed?
Personal data that are processed refer to all the information received from Users once they have signed up for our newsletter and/or our “Brand Test”. The mentioned data include names and last names, e-mail and postal addresses, and telephone and mobile numbers.
3. Why are personal data processed?
Fabular processes Users’ personal data for the following purposes:
a) Personal data processing for sending “Brand Test” results
Among other things, while taking the “Brand Test”, the User may provide personal data such as name, last name, e-mail address, postal address, and telephone and mobile phone numbers. These personal data are processed by Fabular only for the purpose of receiving the completed test in its email and to send back the results of the test to the User via e-mail.
The User is not obliged to leave any personal data and Fabular shall send the test results back to the User even if the User does not leave his/her name and last name. The only data required by Fabular to do so is the e-mail address, which can be, but not necessarily, a personal piece of information.
b) Personal data processing for marketing purposes
The following personal data: User name and last name and e-mail address may be processed for the purpose of sending newsletter and advertising messages on the activities, novelties and services offered by Fabular.
When processing personal data for direct marketing needs, the User shall be required to provide consent for his/her data to be processed for the purpose of sending the newsletter. The User has the right to withdraw his/her consent at any time by sending an email to: firstname.lastname@example.org or using the link for unsubscribing from the list of users who receive marketing information. This link can be found in all emails received by Fabular containing marketing communication. Withdrawal of the User’s consent shall not have a detrimental effect on the branding services provision by Fabular to the User and shall not affect the lawfulness of processing based on consent before its withdrawal.
c) Personal data processing for the purpose of compliance with legal requirements
Fabular may process Users’ personal data for the purpose of meeting legal requirements imposed by public authorities. This particularly refers to (i) the processing of data in order to meet fiscal and accounting obligations and (ii) the disclosure of information required by public authorities, including courts, based on and within the scope of generally applicable provisions (for example, for the purpose of exerting rights of Fabular, other Users or third parties, including the intellectual property rights).
d) Personal data processing for the purpose of the legitimate interest of Fabular or a third party, except where such interest is overridden by the interests or fundamental rights and freedoms of Users and/or third parties
Fabular processes personal data such as name, last name and e-mail addresses of all its business associates and regular clients for the purpose of the legitimate interest of Fabular.
4. Who are we giving personal data to?
Fabular may give personal data of Users to:
a) service providers who allow Fabular to provide branding services
The services that may be required are, for example: infrastructure and IT service provision, customer support, website optimisation, accounting services and legal aid. Unless necessary or required by mandatory regulations, they shall not be authorised to disclose or use for their purposes Users’ personal data and shall act on behalf and as per the instructions of Fabular.
b) authorities, including courts, regulatory bodies and other public bodies
Personal data shall be provided to the abovementioned bodies to the extent to which this is required for the purpose of: (a) meeting a legal requirement referring to Fabular; (b) protection and exertion of a right by Fabular, other Users or third parties, including the intellectual property rights; (c) protection of security of Fabular, other users or third parties;
5. User rights in respect of their personal data
The User may send a request to Fabular to exert the following rights:
a) to access and to correct his/her personal data;
b) to suspend the processing of his/her data for marketing purposes;
c) to object to the personal data processing if these are processed for the purpose of the legitimate interest of Fabular or third parties
d) to delete personal data if:
Personal data are no longer required for the purposes referred to under point 3;
The User withdraws the consent the processing is based on and there are no other legal grounds for processing;
The User objects to the processing and there are no legitimate interests for which processing should be carried out;
Personal data are processed with no legal grounds;
e) to restrict processing if:
the accuracy of personal data has been contested by the User, for the period in which Fabular shall verify the accuracy of personal data;
processing has no legal grounds but the User objects to the removal of data and requires restriction of use instead;
Fabular requires no longer personal data of the User for the purposes referred to under point 3, but the data are required by the User for the purpose of realising or meeting legal requirements or defending against these.
The abovementioned requests and/or notifications shall be sent via post, telephone and/or email to:
Fabular branding d.o.o.
Rokov Perivoj 3
Telephone number: +385 1 409 4200
6. Duration of data processing
Personal data of Users that Fabular processes for the purpose of sending back the results of the “Brand Test” shall be processed only for the purpose of sending the test results via e-mail to the User and shall thereafter be deleted.
Personal data shall be processed for the purpose of sending the newsletter and advertising messages until the User withdraws the consent.
7. Data security
Data security maintenance shall be understood as ensuring confidentiality, integrity and availability (for permitted purposes) of personal data. Confidentiality shall mean that only those persons having authorisation to use data may have access to these. Integrity shall mean that data must be accurate and suitable for the purpose they are processed for. Availability shall mean that authorised users must be able to access data if they require these for the permitted purposes. Furthermore, Fabular shall undertake all appropriate measures against unlawful or unauthorised processing of personal data, as well as against accidental loss of personal data or damages incurred in respect of personal data. These principles shall be executed in a manner as to ensure appropriate protective measures, both in respect of hardware and in respect of software (including the physical entrance and access control system, locks, security doors, passwords for accessing data that are processed in digital form etc.).
8. Rights and legal remedies
In case of violation of rights relative to the processing of personal data, you may file a complaint to the Personal Data Protection Agency. In any case, to solve all potential problems related to privacy in as fast and simple manner as possible, it is recommended to send complaints or requests to Fabular prior to contacting public authorities.