I. INTRODUCTION

Company Mamić 1970 d.o.o. from Zagreb, Hercegovačka 46, Personal Identification Number: 62862231629 respects your privacy and believes that the protection and security of personal data is important. We feel that everyone has the right to know which personal data we collect about them.

Therefore, in accordance with the regulations of the General Data Protection Regulation (hereinafter: GDPR), this Policy informs you which personal data we may collect when visiting our website (regardless of where you visit it from) or when you do business with us, for which purposes we use them, how do we use them, for how long we keep them, to whom we can share them, and what are your rights as respondents.

Mamić 1970 d.o.o from Zagreb, Hercegovačka 46, Personal Identification Number: 62862241629 is responsible for processing personal data.

Contact data:
Mamić 1970 d.o.o.
Zagreb, Hercegovačka 46, 10000 Zagreb
Phone: +385 1 4059 405
Email: mamic@mamic.hr

In the event of any inquiries, objections or requests for the realization of the rights related to the Personal Data Protection Policy, you may contact Mamić 1970 d.o.o. as the person responsible for processing the personal data, that is the manager of the processing.

Mamić 1970 d.o.o. points out that all their employees and associates are familiar with the Personal Data Privacy Policy and are trained to conscientiously and properly handle the personal data of the respondents.

II. PERSONAL DATA THAT WE MAY COLLECT

Mamić 1970 d.o.o. is a company engaged in the sale of luxury watches and their associated accessories, as well as watch service. With regard to this business and with the aim of providing quality and comprehensive services, it may collect certain personal information in the following categories:

1. Personal data including name, surname, maiden name, nickname or similar, marital status, title, date of birth and sex and other personal information that You voluntarily provide to us
2. Contact data including address, telephone number, email address
3. Transaction data including name, surname, address, bank account information
4. Technical data including computers’ IP address, browser type and version, browser plug-ins, operating system, mobile device type and name, time zone and location, and other device technology used to access our website
5. Data about visiting websites and contents that includes clickstream data, duration of page visits, download errors, data about the information You have viewed

We do not collect personal data that are in accordance with the GDPR regarding the Special Category of Personal Data, that is we do not collect data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, and we are not processing genetic data, biometric data for the purpose of the unique identification of the individual, data related to health or data on sex life or sexual orientation.

III. PURPOSE AND LEGAL BASIS OF PERSONAL DATA PROCESSING

We collect and process your personal data for the following purposes based on the following legal bases:

Purpose: Sending invitations to selected events and notifying about them, sending marketing products’ and companies’ information and notifications, newsletters, publications, brochures, and other promotional materials
Type of data: personal data, contact data
Lawful basis: consent

Purpose: Answering inquiries, improving service provision and ensuring provision of required services, reservation of goods
Type of data: personal data, contact data
Lawful basis: legitimate interest of the processing manager to provide requested services, consent

Purpose: Taking watches for service, contacting about the service and keeping track of received watches
Type of data: personal data, contact data
Lawful basis: fulfillment of the contractual obligation of the watch service, legitimate interest of the processing manager for performing the watch service

Purpose: Notification of changes of the Personal Data Protection Policy
Type of data: personal data, contact data
Lawful basis: legitimate interest of the processing manager

Purpose: Realization of contracts on card payments, protection of transactions, prevention of money laundering
Type of data: transaction data, personal data
Lawful basis: fulfillment of the contractual obligation, legitimate interest of the processing manager to ensure that the payment is made completely and without fraud and embezzlement, legal obligation

Purpose: Keeping, upgrading and protecting our website, improving and adapting our website, user experience, offers and services
Type of data: technical data, data about visiting websites
Lawful basis: The legitimate interest of the processing manager to ensure the safety and functionality of the website and to meet the needs and preferences of customers for the provision of services

Purpose: Keeping records of realized purchases, services, compliments, complaints, expressed interests and orders
Type of data: personal data, contact data
Lawful basis: legitimate interest of the processing manager in order to maintain and improve the business, order goods and meet the demands of the respondents

IV. TYPE OF PERSONAL DATA COLLECTION OBLIGATION AND CONSEQUENCES OF NOT PROVIDING PERSONAL DATA

In accordance with Art. 13 paragraph 2 of the GDPR we point out that you are not obliged to provide the above mentioned personal data, but that not providing them may, in some cases, disable the provision of services or reduce the quality of services provided.

For example, without any basic personal data it is not possible to send invitations to certain social events.

In the case of watch services company Mamić 1970 d.o.o. is unable to service the watch without collecting the above mentioned personal data. It is necessary for the protection of the customer, for the right reception of the watch and its’ restitution to the particular person and contacting the person about the service. The same applies to transaction data for which there is a statutory obligation to collect and process personal data.

V. PERSONAL DATA COLLECTION PROCEDURE

We may collect your personal data in various ways:

• Information you have made available to us: personal and contact data that you give us when communicating with us by phone, e-mail, fax, by your personal arrival to our business premises, filling out some of the forms on our website and other
• Data collected by us: When visiting our website we can collect the above mentioned technical data, sites visited and content information through the use of cookies and similar automated technologies

VI. THIRD PARTIES AND PERSONAL DATA SHARING

The respondent’s personal data collected by Mamić 1970 d.o.o. will not be distributed, published, provided, or otherwise made available to third parties (including third parties in other countries and international organizations) without your prior consent.

Except for the above, we may disclose and distribute your personal data to a limited scope and only as much as necessary:

• on the basis of a legally binding decision or order of the competent authority or on the basis of a statutory obligation
• to the third parties – Rolex SA, Montres Tudor SA, entities that maintain our IT systems or provide accounting services (which are subjects to a contractual obligation of confidentiality)
• based on your consent

We take care that third-party recipients of your personal data that are processing these data for our needs are doing so based on our guidelines and within their scope, whereby they provide protection, measures and actions with personal data in accordance with GDPR.

VII. ROLEX SECTION

While navigating on the Rolex section of our website, some cookies are controlled by ROLEX SA which applies the following Cookies Policy.

VIII. TIME RATE OF PERSONAL DATA RETENTION

Your personal data that we collect and process will be retained for as long as necessary, taking into account the purpose for which the data was collected and the type of data, but for at least 12 months. In addition to this, we may retain your personal data for as long as it is prescribed or permitted by the applicable regulations or until you withdraw your privilege for those personal data processed on the basis of the consent. For example, we have to keep certain bookkeeping data up to 10 years.

IX. RESPONDENTS’ RIGHTS BASED ON GDPR

GDPR prescribes that each respondent from which personal data is collected has certain rights. Below we will let you know what your rights are based on GDPR.

• The right of access and confirmation by the processing manager regarding the personal data concerning the respondent in accordance with Art. 15 of the GDPR: The right to ask for a confirmation of whether your personal data is being processed and to what extent
• The right to a correction (Art. 16 of the GDPR): The right to seek correction or amendment in the event that the personal data we collect about you is inaccurate or incomplete.
• The right to erase („to forget”) (Art. 17 of the GDPR): The right to request the erasure of personal data that we collect about you if there is no longer any purpose for which they have been collected, if their processing is disproportionately affected by your legitimate protected interests or if processing is based on consent. There is a possibility that it is not justified to erase all personal data if it is against the legally prescribed storage obligations, ongoing processes, and the like
• The right to restrict the processing (Art. 18 of the GDPR): The right to request processing limitation of your data if: you dispute the accuracy of your data, but during a period that allows us to verify the accuracy of the data; if processing of your data is illegal, but you have refused to cancel it and instead you seek to restrict the use of the data; if we do not need your personal data for a particular purpose, and you still need them to set up, enforce or defend the legal requirements; if you file a complaint against the processing of data
• The right to data portability (Art. 20 of the GDPR): In the event that your personal data is processed automatically, and it is personal data that you have given us on the basis of your consent or it is the data necessary to fulfill our contractual obligations, on your request we may forward your personal data you or to the third person of your choosing in a structured, standard and machine-readable format.
• The right to objection (Art. 21 of the GDPR): If we process your data for the purposes of performing a public interest task, performing public authority or processing based on the needs of our legitimate interests, you may file a complaint against data processing if there is a stronger interest in protecting your data. You can submit an objection to sending marketing material at any time without giving reasons.
• The right to revoke a declaration of consent at any time (Art. 7, par. 3 of the GDPR): The right to withdraw at any time all the consents you have given to process your personal data, after which no more personal data is processed for the purpose for which it was granted. The revocation does not affect the legitimacy of earlier processing based on a revoked consent. Revocation of a consent can affect the ability or the quality of providing certain services.
• The right to file a complaint with the competent supervisory authority: The right to file a complaint with the competent supervisory authority – the Personal Data Protection Agency. Regardless of the mentioned above, you can always contact the processing manager for joint resolution of your complaint.

You can realize your rights as a respondent by submitting a written claim to Mamić 1970 d.o.o. as the processing manager indicated in the introduction to this Policy, indicating which right you want to realize.

In the case of a request for the realization of a right we may ask you for certain personal data to confirm your identity and to ensure the right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any other person who is not eligible to receive it.

We will notify you, without undue delay but no later than one month after the receipt of your request, about any actions you have taken regarding your request or any other inquiries or objections. Exceptionally, this deadline may be extended for an additional two months if necessary, taking into account the complexity and number of requests, but in that case we will notify you within one month of the receipt of the request, stating the reasons for the delay.

Any communication and actions that Mamić 1970 d.o.o. undertake connected to these rights are free of charge. However, if your requests are obviously unfounded or excessive, especially because of their recurring character, we may charge you a fee, taking into account the costs incurred, or refuse to comply with your requirements.

X. CONSENT

Personal data collected on the basis of consent is collected in such a way that it is provided in writing or in digital form (via mail, website or some other electronic channel) where it is explicitly stated which personal data is collected and for which purposes it will be used.

If you as a respondent have not given a consent for a particular purpose of collecting personal data, it will not be used for that purpose. It is noted that the aforementioned does not apply to the collection of personal data and their processing for the purposes for which the company Mamić 1970 d.o.o. has a legitimate interest, which is necessary for the fulfillment of the contractual obligation or constitutes a statutory obligation.

The respondent has the right to withdraw his consent at any time through a link in each marketing message or by contacting us in any form.

When completing forms or sending inquiries via e-mail or phone, you will be giving your consent to using the information you provide in order for us to respond to your inquiry or for the purposes for which you have provided us with the personal data.

XI. PERSONAL DATA SECURITY

Company Mamić 1970 d.o.o., for the purposes of protecting your data, has undertaken the appropriate technical and organizational measures that protect your data, inter alia, from loss, manipulation, or unauthorized access. These measures are regularly checked and continually adapted to be up to date with the current state of technology. If there is a violation of your personal data that may represent a major risk to your rights and freedoms, we will notify you of this in accordance with the applicable law.

XII. COOKIES AND WEBSITES

The cookie is an information saved to your computer by the website you visit. Cookies usually save your settings, website settings, such as your preferred language or address. Later, when you open the same website again, the internet browser sends back the cookies that belong to that page. This allows the page to display information tailored to your needs.

Mamić 1970 d.o.o. can publish on its website cookie content for advertising and tracking traffic statistics based on the interests and information of visitors to our social networking websites.

If you use content on social media sites in Mamić 1970 d.o.o. or in apps, the cookie from the mentioned networks and apps could be stored on your device from which you access our website.

Visitors have the right and the ability to block cookies. Internet browsers are typically programmed in the way that accepting cookies is the default setting, but it can easily be set otherwise by changing your browser settings. If you want to restrict or block all cookies that include websites / apps Mamić 1970 (which may disable the use of certain sites) or other websites / apps, the respondent can easily do so in their browser settings.

On our website there may be links that lead to some other websites, apps, or extensions. Thus, links to Facebook, Instagram, Youtube, LinkedIn, Twitter, Gmail, GlobalBlue, to Rolex’s official site, to Tudor’s official site and to other relevant sites can be found on our site. Please note that we are not responsible for the security or privacy of any data collected by these websites, apps, or extensions by using them, so please read the privacy statements that apply to those sites.

XII.I. Rolex Section

While navigating on the Rolex section of our website, you may interact with an embedded website from www.rolex.com. In such case, Privacy Notice and Cookies Policy of www.rolex.com are sole applicable.

XIII. PERSONAL DATA ACCURACY AND UP-TO-DATENESS

In order to be able to provide you with a quality service it is important that the personal data you have made available to us is accurate and up to date. Please let us know about any changes regarding your personal data during our cooperation.

XIV. POLICY CHANGES

Mamić 1970 d.o.o. has the right to update this Policy if it is needed in order to maintain the best business model and to ensure the compliance with GDPR and the application of the rules for the protection of personal data.

In order to get acquainted with these policy changes, we may notify you of them.

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