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PRIVACY POLICY

Privacy statement

Obsession d.o.o., Ljubljana, Poljanski nasip 6, 1000 Ljubljana (Obsession d.o.o., Ljubljana - personal data controller) values and protects your privacy, strives for the highest level of security and pursues the principles of transparency and careful handling of personal data. This privacy statement elaborates on the managing and collection of the personal data provided by our digital platforms that facilitate the access to the website and the use of corresponding services for our visitors. Obsession d.o.o., Ljubljana processes personal data in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of individuals and the processing of their personal data and on the free movement of such data and repealing Directive 95/46 / ES (hereinafter referred to as the General Data Protection Regulation or GDPR), in compliance with the current Personal Information Protection Act and other personal data protection regulations.

Continue reading to learn more about our processing of your personal data.

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Legal basis for data processing

Personal data collected through application forms in an online store - or otherwise communicated to the controller - Obsession d.o.o., Ljubljana (first name and surname, email, telephone, street name and number, postal code, location, country, region, shopping cart contents, IP address) are gathered with the purpose of conducting the principal activity of the company Obsession d.o.o., Ljubljana i.e. an online shop, particularly for responding to customer demand, and for designing, concluding and implementing a contract. Such information processing is part and parcel of an exquisite service and is therefore valid on the basis of a contractual relationship between the customer and the service provider. The implementation of the contract whose party is the data subject represents the legal basis for the lawful processing of the personal data, i.e. the application of pre-contractual measures taken in response to the data subject's request (Article 6 (1) (b) GDPR).

Providing that your consent is the legal basis for data processing, you hold the right to revoke your consent at any time. However, this shall not affect the lawfulness of the personal data processing by Obsession d.o.o., Ljubljana prior to your withdrawal of consent (Article 6 (1) (a) GDPR). We will discontinue the managing of collected personal data for this specified purpose in case of revocation.

It is our legal obligation to transmit your personal data to law enforcement or other national authorities if deemed imperative. Furthermore, we are legally obligated to store accounting and taxation documents (Article 6 (1) (c) GDPR).

The distribution of personal data with our contractual partners to ensure efficient management and vital protection of operation along with the establishment, exercise and defense of legal claims represent the so-called legitimate interest of the company Obsession d.o.o., Ljubljana (Article 6 (1) (f) GDPR.)

Grounds for the collection of personal data by Obsession d.o.o., Ljubljana

Below are further specified the main categories and objectives of data assembled by the company Obsession d.o.o., Ljubljana:

• As a segment of general business processes of Obsession d.o.o., Ljubljana

We collect personal data from visitors to the website, customers and suppliers (including third-party service providers). Relevant personal data are in particular personal information, such as first name, and other contact data necessary to conduct a business relationship with you or your organization.

• As a query assistance

You may choose to permit personal data transmission, including your first name, email address, or other contact information when you connect with us via phone, email, post or by using our digital platforms or other communication channels. Personal data enable us to respond to your information queries, to prepare necessary steps and purchase offers, and to appropriately respond to warranty claims or other requests.

• Customers and potential customers

Personal data of customers and potential customers, including names, contact information, payment habits and credit cards are collected to conduct a business relationship with individuals or organizations. Data may be transferred to logistic partners for the purposes of ordering and delivering the products. Automatic data collection via digital tools enhances your safety and ensures confidentiality.

• Business development

Confidential personal data supplied by you or automatically gathered via our digital tools, shall be utilized to better acknowledge the preferences of our customers, to propose customized solutions and shall serve as a basis for relevant marketing notifications and offers. Personal data shall be used to significantly improve the quality of the products, procedures and website.

• Marketing communications

We shall process your personal data with your expressly granted consent to inform you about the business activity, products and services of the company Obsession d.o.o., Ljubljana. If you object to such utilization of your personal data or if you do not wish to obtain further marketing information, you may unsubscribe at any time. Find unsubscribe links at the bottom of various communication channels or contact us by email or post to terminate your subscription. Your personal data will be permanently erased from our systems after the obtained withdrawal unless we store and manage your private data on an alternative legal basis.

• Surveys for visitors and customers

Personal data of the visitors to our website may be gathered as a survey matter of the company Obsession d.o.o., Ljubljana.

• Considering the preferences of visitors and customers

Personal data of the visitors to our website or customers may be gathered to ensure the availability of particular products and to take into account the interests of our clients.

• Legislative compliance

Personal data shall be collected in compliance with legislation. Collected personal and non-personal data are treated as strictly confidential and will not be traded or transmitted to third parties except for the particular instances mentioned in this statement.

How we capture your data

We collect provided personal data either as a result of your registration to receive marketing information in the course of our business relations, your participation in public forums or other activities on our digital tools, as a result of responding to customer surveys or other ways of communication with us. Personal data are gathered via diverse technologies, for instance »cookies«.

Your personal data will not be transmitted to third parties, except in the following occasions:

• When third parties provide services on our behalf, such as responding to your enquiries, parcel deliveries and other services, etc. These companies are prohibited from using your personal data for purposes that are not strictly specified by us or required by legislation.
• When we distribute personal data within our company or with third parties in order to ensure the safety and confidentiality of our customers, to protect our legal rights and property in compliance with legal procedures or in other instances, if we believe that disclosure is legally required.

Command and control

We facilitate a certain control in decision-making with regards to collection, processing and transmission of personal data. In accordance with local legislation, your control and decision-making may incorporate the following points:

• You may alter your stance on receiving the latest news and marketing notifications.
• You may decide if you wish to receive marketing information about the products and services that we believe would interest you.
• You may decide if you wish to receive notifications from advertising networks, providers of data exchange and marketing analytics services and other services.
• You may demand access to your personal data that we retain to supplement any incorrect or incomplete information, and in certain circumstances, you may request that we erase your personal data from our systems (fundamental rights of individuals).

You may assert your control in decision-making or require access to your personal data by contacting us via telephone or email and abide by obtained instructions. Please consider the fact that we may not be able to fully comply with your interests and preferences or provide you with certain products and services should you choose to restrict further collecting and processing of your personal data. If you have any questions about specific personal data that we process and store, contact Obsession d.o.o., Ljubljana at [email protected] We will respond to your demand within one month with the right to an extension of an additional month. We will notify you in case of an extension within one month upon the receipt of your request.

Safety, integrity and data storage

Safety, integrity and confidentiality of your personal data are at the core of how we deliver trusted business insights. Our group implements technical, administrative and physical security measures aimed at providing security against unauthorized access, disclosure, use and modification of personal data. We consistently test our safety procedures to contemplate suitable innovative technologies and methods.

The transfer of sensitive personal and transactional data on the website is carried out in a safe mode by means of a protocol SSL (SecureSocketsLayer). Encrypted personal data are transferred to the provider's server in a secure format. The system prevents the interception of customers' personal and transactional data in an online store.

Global payments platform Stripe arranges and forwards safe authorizations and transactions with payment cards. The authorizations of payment cards are carried out in real-time with immediate data verification in the banking system.

Please consider the fact that despite our best efforts, safety measures are not inherently immaculate and impossible to evade.

We will retain your personal data as long as this is necessary for the processing purposes mentioned in this data privacy statement, except if extended storage period is needed or permitted by the legislation. In this respect, a regular review takes place.

Modifications to this privacy statement

We may occasionally alter this privacy statement to adjust it according to the latest technologies, industrial practices, legislative requirements and for other purposes. A valid version of this privacy statement will be published on our digital platforms. We recommend frequent monitoring of the Privacy Statement. If required by applicable legislation, we will obtain your consent prior to any alterations.

Comments and queries

Should you have objections or questions regarding privacy, contact Obsession d.o.o., Ljubljana in writing. You are eligible to lodge a complaint if you are dissatisfied with our processing of your personal data. Use provided contact information. In the case of a complaint you should provide the company Obsession d.o.o., Ljubljana with your contact information. We will address your appeal and reply in 30 days.

Privacy and cookies

Protection of our customers' personal data is one of the areas ingrained into the core of our business culture. We strive to accomplish and even surpass all the goals with diligence as confidentiality is fundamental to maintaining trust.

The following user data are collected for business purposes:

• first name and surname;
• shipping addresses;
• company name or name of the legal entity(if the user is a legal entity);
• tax number of the legal entity (if the user is a legal entity);
• email address (username);
• encrypted password;
• contact number;
• country of residence;
• other data that users voluntarily enter in the online store forms;
• other data that users voluntarily subsequently add to their profile.

The seller is not responsible for the accuracy, completeness and currency of the personal data submitted by the users. Users' IP addresses are being collected to ensure safety. Each user is assigned a session cookie to identify and track the shopping basket. www.obsession.si may store other cookies on your computer, for instance: encrypted user identification number (to identify the user during the next visit), product reviews (to obtain a clear overview) and cookies used by Google Analytics (analysis of the visits to a website).

All the aforementioned information, except for cookies, are stored on the server leuchtenonline.de under the applicable legislation. Session cookies are stored on the server merely for the duration of the visit and are deleted after an hour of inactivity, while persistent cookies remain on the visitor's hard drive.

The implementation of the privacy policy

Obsession d.o.o., Ljubljana has adopted Privacy Policy. Employees who are in any way involved with users' personal data are familiar with the contents of Privacy Policy.

Which are my rights according to GDPR?

a) The right to be informed

We guarantee the exercise of all your statutory rights with regards to personal data processing in accordance with GDPR provisions. You are granted access to complimentary information about your personal data at our disposal, i.e. the right to access, rectification and erasure of personal data. Should you enquire further information regarding the erasure or processing of your personal data, contact us at [email protected] or send us a request via post at Obsession d.o.o., Ljubljana. You may contact our authorized person for data safety (Data Protection Officer - DPO) via email: [email protected] who shall also respond to your questions about the confidentiality, the method of data collecting and processing or your requirements for the exercise of statutory rights in relation to your personal data.

Notifications upon an obtained order: we highly value supreme user experience, therefore you will be contacted by our advisor upon the delivery of the product to inquire whether your expectations were met. Upon request, our advisor may provide you with further information regarding exclusive offers in case of repurchase. Should you wish to learn more about exceptional deals, you will regularly receive marketing materials via email or text messages. You may terminate your consent at any time by contacting us at [email protected] or by clicking on the link »Unsubscribe«. We also retain the right to enquire about the frequency of visits to our website. Your appreciated opinion will be utilized to enhance the overall user experience. Should you fill out promotional forms (coupons) on social networking sites, you will regularly receive notifications about promotional coupons on your email. The same aforementioned termination procedure applies in this case.

b) The right of access

You have the right to request access to your personal data (consent whether the data concerned are being processed or not) from the company Obsession d.o.o., Ljubljana as the controller of personal data in accordance with Article 15 of the General Data Protection Regulation (GDPR) and the following information:

• the purposes of the processing,
• the categories of personal data obtained, the recipients or the categories of recipients that have or will receive personal data, especially the recipients in third countries and international organizations,
• the estimated retention period for the personal data or, if this is not possible, the criteria used to determine this period,
• automated decision-making and profiling,
• the purposes and anticipated ramifications of such data processing for an individual,
• one (free of charge) copy of personal data in a set format (a copy shall be provided in electronic form if not otherwise specified). The controller may impose a reasonable charge taking into consideration the costs for any additionally required copies.

c) The right to rectification

You have the right to rectification of any inaccurate personal data relating to you (Article 16 of the General Data Protection Regulation - GDPR).

d) The right to restrict processing

Under the conditions set out in Article 18 of the General Data Protection Regulation – GDPR, you hold the right to request from the company Obsession d.o.o., Ljubljana the restriction of processing of your personal data at any time in the following instances:

• the correctness of your personal data is disputed for the time period which allows the controller to verify the accuracy of personal data,
• you request limited processing instead of deletion under the conditions of a justified right to erasure,
• the data is no longer required for the purposes pursued by us, but you need the data to assert, exercise or defend legal claims,
• you as an individual have lodged a formal objection referring to the data processing under the conditions set out in Article 21(1), until it is verified that legitimate interests outweigh your reasons.

e) The right to erasure, objection, portability and appeal

Pursuant to the conditions set out in the General Data Protection Regulation, you also hold the right to:

• erasure of all your personal data (the right to be forgotten) if the specific circumstances of the Article 17 of the General Data Protection Regulation (GDPR) apply, especially in case of unlawfully processed data;
• access to your personal data in a structured, commonly used and machine-readable format, as well as the right to request us to forward this personal data to another controller (portability), without hindrance from the original controller in accordance with Article 20 of the General Data Protection Regulation (GDPR);
• to cease the processing of your personal data in case of a legitimate interest of the controller and for the purposes of direct marketing including profiling (the right to objection) – Article 21 of the General Data Protection Regulation (GDPR),
• to object to the decision based merely on automated processing including profiling bearing significant legal effects on you, pursuant to the presumptions of Article 22 of the General Data Protection Regulation;

You may lodge a complaint against the controller to the information commissioner Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit - Graurheindorfer Str. 153 - 53117 Bonn should you believe that data processing significantly breaches the General Data Protection Regulation and other applicable legislation.

Procedure to exercise legal rights

I confirm that I am fully aware of my right to contact the controller in writing at: [email protected] to address any of the aforementioned claims with respect to exercising personal data rights.

I confirm that I am entirely familiar with the fact that the controller may request further information from me for the purposes of reliable identification with respect to exercising personal data rights. However, the controller may refuse to take further action in case of clearly demonstrated unsuccessful identification.

About cookies

What are cookies and why are they necessary?

Cookies are short encrypted text files that are sent to the browser by the website you visit. This enables the website to recognize and remember the data at the time of your visit and help positively navigate your browsing experience. Cookies enable us to customize the contents of our website, consider your preferences and track the visits to our online shop. Your overall browsing experience is significantly more pleasant, quicker and more effective with the help of cookies.

Disabling cookies

You decide whether you will allow the storage of cookies on your device. You may supervise and modify the cookie settings in your web browser.

Choose the web browser you use for further information on cookie settings.

• Chrome
• Firefox
• Opera
• Internet Explorer 9
• Internet Explorer 7 in 8
• Safari

Should you modify or erase cookie files stored in your browser, modify or upgrade your browser or device, you may possibly have to disable cookies as well. The procedure for managing and deleting cookies varies according to the browser. Should you require technical assistance in this process, you may explore customer support in your browser.

You may also disable Google Analytics tracking at the following link: https://marketingplatform.google.com/about/.

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May, 2020