Data protection notice

This data protection notice (hereinafter. „Notice“) describes how the company Mindsmiths ltd. (hereinafter: „Mindsmiths“) collects, uses and discloses personal data in the course of the services we provide on this web site, https://www.mindsmiths.com/ as well as our accounts on social networks, Facebook, Instagram, LinkedIn, YouTube and Twitter. 
 

The term „personal data“ refers to any information relating to an identified or identifiable natural person („data subject“). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, identification number, location data, an online identifier and similar. Identification can be by the information alone or in conjunction with any other information in our possession or likely to come into such possession.   
 

Data Controller


Mindsmiths ltd. Ulica Pere Budmanija 5, HR-10000 Zagreb, Croatia
PIN: 09138384211
Contact: hello@mindsmiths.com
acts as data controller in relation to processing of personal data addressed in this Notice. This means that Mindsmiths ltd. decides how such personal data is processed and for what purpose.w question go to app settings and press "Manage Questions" button.




What personal data do we collect, when do we collect them and how do we use such personal data


Data that we collect through this website, our accounts on social networks and through electronic mail are the following:

  • Contact data (name, email address, telephone number)
    This data we collect when you submit us a query through the provided form on our website or you send us electronic mail or send query or you communicate/interact with us through social networks. We use such data only for the purpose of fulfilling/responding to such queries or commenting and the data collected are not used for any other purpose. In case you do not provide us with the respective data when your personal data are collected in order to respond to your requests/queries, or comments, we may not be able to provide our responses to such your requests/queries or comments.
  • On line identifiers (IP address, Internet browser you use, operating system you use, type of equipment you use, access point and similar). In order to automatically collect these data, we use „cookies“. To learn more about our use of cookies and how you can change your settings to delete or refuse cookies, please check our cookies policy here.
  • Information about the use of our website (for example, time, duration and number of visits to web site, pages you opened and similar). In order to automatically collect these data, we use „cookies“. To learn more about our use of cookies and how you can change your settings to delete or refuse cookies, please check our cookies policy here.;
    Online identifiers and information about the use of our website we collect when you visit our website and we use this information to manage our website and our technical solutions, understand how visitors navigate through our website, enhance your experience on our website and improve our services.




The legal basis for processing of personal data


We collect contact data when processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract. For collection of data contained in essential cookies, processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party. For collection of data contained in other cookies, we ask for your consent.




Categories of recipients of the personal data


We commit to confidentiality and protection of personal data and we shall not share or make available personal data to third parties without special approval, except as otherwise required by the law. In such case, we distribute personal data only to third parties that are able to demonstrate implementation of appropriate technical and organizational measures in order to ensure protection of your rights. If we transfer personal data outside the European Economic Area or to countries that are not recognized by the European Commission as countries providing adequate level of protection of personal data, we will, as required by applicable law, ensure that data subject's rights are adequately protected by appropriate safeguards.




Security measures


For the purpose of protection of your personal data, we have put in place appropriate technical and organizational measures, which ensure the level of security, that corresponds to the risks presented by processing of data and nature of personal data that are subject of protection, having in mind characteristics and costs of their implementation. After accessing the risk we have undertaken all reasonable measures in order to protect personal data from accidental or unlawful destruction or loss, alteration, unauthorized disclosure of, or access to personal data, particularly in cases where processing includes transmission of personal data through network, and from all other unlawful form of processing.




Retention period


We will keep the personal data for as long as it is necessary for the purposes for which the data were collected. After the personal data is no longer necessary for the purpose for which the same were collected, we will destroy or anonymize those personal data, so that they are no longer in a form which permits identification of data subjects, except if it is necessary to store the data for specific period of time, in accordance with the applicable laws, prescribed statutory periods for the purpose of defending a legal claim or enforcement of our rights in which case the same data shall no longer be processed for other purposes.




Further processing for new purposes


If we intend to use your personal data for a new purpose, not covered by this Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent for such new processing.




Your Rights under data protection laws


  • Right of access
At any time you may request from us to obtain confirmation as to whether or not your personal data are being processed, and, where that is the case, you have the right to access to the personal data and receive information on their processing.
  • Right to rectification
You have the right to request that we correct or complete without delay any personal data if it is found to be inaccurate and incomplete.
  • Right to erasure
You have the right to request your personal data be erased, where it is no longer necessary for the purpose for which we are processing the same. In case the request is justified and under condition that there is no such law, which would impose storage obligations on us, personal data will be erased without undue delay. In case there are reasons, which prevent or limits us in fulfilling your request, we will inform you without delay in our response to your request.
  • Right to withdraw consent
The right to withdraw the consent to the processing at any time, if the processing is carried out based on the consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
  • Right to restriction of processing
You have the right to request from us to obtain restriction of processing of your personal data if you contest the accuracy of such personal data (for a period enabling us to verify the accuracy of the personal data), if the processing is unlawful and you oppose the erasure of the personal data, if you have objected to the processing of your data and if we no longer need the data for the purpose of the processing but they are necessary to you for the establishment, exercise or defence of legal claims and therefore you wish that we store further the same.
  • Right to data portability
The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, where applicable.
  • Right to object
The right to object to the processing of personal data, where applicable.
  • The right to lodge a complaint with the supervisory authority




Ways to exercise your rights


You have the right to exercise any of the afore listed rights at any time by contacting us at hello@mindsmiths.com. When making the request, please provide us with data necessary to act upon your request and for your identification. We shall also without delay act upon your request or contact you for further information where necessary. We shall also provide you with the information on actions taken without undue delay and in any event within one month as of receipt of the request. That period may be extended by two further months, where necessary, taking into account the complexity and number of the requests. We shall inform you of any such extension within one month as of receipt of the request, together with the reasons for the delay. The same information shall be provided free of charge. However, where requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character, we reserve the right to charge. In such case, we reserve the right to charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested or refuse to act on the request. If you consider that violation of your rights have occurred, you may lodge a complaint with the Croatian Personal Data Protection Agency: Selska cesta 136, 10000 Zagreb azop@azop.hr 00385 (0)1 4609-000




Change of this Data Protection Notice


We conduct regular quarterly audits of personal data processing. Because of this as well as because of possible changes in the law and the changing nature of technology, this Notice may periodically change. We therefore encourage you to check from time to time all changes and updates to this Notice, which will be published at this website. This Data Protection Notice was last updated in December 2020.





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