PLITVICE TIMES j.d.o.o. commits to protect customers’ personal information in such a way that it only collects the basic information about the customers/users necessary to fulfil its commitments – inform customers about the usage of collected information, regularly provides the customers with options regarding the usage of their information, including the option to remove their names from lists used for marketing campaigns.
All information about the users is confidential and available only to the employees who require the information to perform their job. All employees of PLITVICE TIMES j.d.o.o., as well as business partners are responsible for upholding the privacy policies.
This document outlines our approach to compliance with the General Data Protection Regulation (GDPR) and all other relevant data-protection legislation. It also sets forth your privacy rights. Please take a moment to familiarise yourself with our privacy practices.
Who we are and how to contact us
Information we collect and how we use it
We collect and use your personal information for a variety of reasons including:
We will use your personal information to carry out our obligations arising from any contract you as our customer have entered into with us, including sending important notices such as communications relating to payment, delivery services, changes to our terms, conditions, and policies and to notify you about changes to our service.
To pay for the Services you have requested from us
We will collect your payment information to pay for any Services you have requested from us. Credit and debit card information is processed directly by PayPal payment providers who perform payment services on our behalf. The Plitvice Times receive payment information from customers.
To facilitate registration through social networks
We may collect your publically available social media profile details including your name and email address when you sign up for one of our services through a social media account. We may use these details for the purposes of our registration process in order to enter into a contract with you. Where we do, we do so in pursuit of our legitimate interest in understanding the demographics of our customers and readers.
To place an advertisement
We may process your personal information if you opt to place an advertisement. We only process this information to deliver the advertising service you have requested as per the terms and conditions you accept.
To deliver marketing, promotions and to conduct research
To receive marketing communications
We may periodically send promotional emails about features, events, exclusive offers and competitions to the email address you have provided – we will only do so with your consent. We have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing communications tailored to your interests. You may at any time choose not to receive marketing communications from us by following the unsubscribe instructions included at the end of each email communication.
For competition and promotional purposes
If you choose to enter a competition or promotion, we will use your personal information to administer these promotions and as per the terms and conditions you accept when you enter. In some cases, your competition entry may be shared with the promoter and this will be specified when you enter. If you win a competition, your contact information will be used to notify you as the winner and to award the relevant prize. We will publish your name on our website and indicate the prize you have won.
To understand how you use our services
To track how you gain access to or read our content
We collect information relating to your use of our services to track how you gain access to or read our content. We use log-in information, cookies and similar technologies, device information and internet protocol (“IP”) addresses to log your use of our services as follows:
When you sign up for or subscribe to one of our services, we will track and aggregate non-personal information previously collected about you through our services with the personal information provided when you register or subscribe. If we link other data with your personal information we will treat that linked data as personal information for as long as it remains combined. We use this information to evaluate your personal preferences and interests, which under the GDPR may constitute as customer profiling. We do so in pursuit of our legitimate interests which are:
To research and improve The Plitvice Times’ products, services, and customer communications
To understand which content you find useful or interesting
To develop and maintain relationships with our customers and readers
To deliver relevant content to our readers
To understand the demographics of our customers and readers
We log technical information that your browser sends us including: the internet protocol (IP) address; browser type and version; time-zone setting; access time; browser plug-in types and versions; operating system; and platform and device type
We log usage information about the use of our website and services, including: a history of the pages viewed and other actions taken, including the full Uniform Resource Locators (URL) clickstream to, through and from our site; articles, content and products viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page and any phone number used to call our customer service number
Technical information, including: the type of mobile device used; unique mobile identifies, such as the devices IMEI number; mobile network information; the mobile operating system; the type of mobile browser used; and the time-zone setting
Details of our mobile applications used including but not limited to: traffic data; location data; weblogs; and other communication data and the resources accessed
Some of our location-enabled services require your personal GPS location data for the feature to work. If you wish to use a particular feature, you will be asked to specifically consent to your data being used for this purpose. This consent can by withdrawn at any time.
To support our advertising services
Third-party vendors, including Google, maydisplay advertising on our Services. Some of the ads you see are targeted based on interests that have been inferred from the type of content you view when visiting our site. This type of behavioral advertising is targeted towards groups of users in an anonymous and aggregated manner as opposed to you as an individual. Such online advertising helps support the content, products and services we provide.
We and third-party vendors use first-party cookies and third-party cookies together to inform, optimise and serve ads based on your browsing activities and interests. Any information we disclose to advertisers and advertising networks is non-personally identifiable.
To correspond with you
If you correspond with us via contact form, we will use your contact information to respond to your enquiry. We process this information in pursuit of our legitimate interests to develop and maintain relationships with our customers and readers.
To manage our everyday business needs
We may use your personal information to manage our every business needs, including for internal purposes such as auditing, data analysis, troubleshooting, accounting, providing customer service, technical support and fraud prevention in our legitimate interest. Our legitimate interest is the effective management of our business.
To verify your identity
To exercise your data rights, we may need to collect additional personal information from you to verify your identify and to process your request.
Anonymous information we process
The legal basis for processing your information
We collect your information for a number of purposes and rely on a number of different legal bases to use your personal information.
To enter into and perform a contract with you
We use your personal information to carry out our obligations arising from any contracts entered into between you and us or to take the necessary steps at your request prior to entering into a contract with us including:
To provide you with services or products you have requested
To process your payment information
To provide customer and technical support
To administer competitions or similar promotions
To send important notices such as communications relating to payment, delivery services, changes to our terms, conditions, and policies and to notify you about changes to our service
With your consent, which can be withdrawn at any time
We will, in certain circumstances, rely on your explicit consent to process your personal information. Where we do, you have the right to withdraw your consent at any time. In most circumstances, your consent can be withdrawn by following the unsubscribe instructions included at the end of each email communication from us.
We process your personal information for carefully considered and specific purposes which are in our legitimate interests and enable us to enhance the services we provide, but which we also believe benefit our customers. Our legitimate business interests do not automatically override your interests. You have the right, free of charge, to object to our use of your personal information for our legitimate interests.
We will retain your personal information as needed to fulfil the purposes for which it was collected. We will retain and use your personal information no longer than is necessary to comply with our business and legal obligations. Where we enter into a legal contract with you, we will hold your personal information for a period of seven years from the date of completion of this contract by reference to the statute of limitation for a legal claim under contract.
We may transfer your personal data outside the European Economic Area (EEA). These countries do not always afford an equivalent level of privacy protection and in such circumstances we take specific steps, in accordance with data protection law to protect your personal information. In particular, for transfers of personal data outside the EEA we rely either on an adequacy decision by the European Commission or on contractual protection approved by the European Commission.
Your data rights
You have several rights under data-protection law in relation to how we use your personal information. You have the right, free of charge, to:
Request a copy of the personal information we hold about you in a structured, commonly used and machine readable format
Rectify any inaccurate personal information we hold about you
Withdraw your consent where we have relied upon your consent to process your information
Erase the personal information we hold about you subject to certain exceptions
If technically feasible, have your personal information transmitted to another data controller in a machine readable format at your request
Restrict processing of your personal information in certain circumstances
Object to our use of your personal information for our legitimate interests, for profiling and for direct marketing purposes
Not be subject to a decision which is based solely on automated processing where that decision produces a legal effect on you or otherwise significantly affects you. We do not make automated decisions of this nature
Lodge a complaint with the appropriate data-protection authority if you have concerns about how we process your personal data
These rights are in some circumstances limited by data-protection legislation. If you wish to exercise any of these rights please contact us at firstname.lastname@example.org.
We will endeavour to respond to your request within a month. If we are unable to deal with your request within a month we may extend this period by a further two months and we will contact you and explain why.
The Plitvice Times processes personal data for the purpose of exercising the right to freedom of expression and information and for journalistic purposes.
This processing is exempt from compliance with certain obligations of the GDPR.
We may process your personal information for journalist purposes where you submit content to be published online and in our printed publications
Where you have voluntarily contributed your experience to us and we publish this information
If we publish a letter you have written to the Editor
It is important to understand that certain rights which you have in relation to your personal information may not apply where that data is processed for journalistic purposes.