Under the GDPR, the controller is the subject that, alone or jointly with others, determines the purposes and means of the processing of personal information.
The controller for the data processing related to the activities on our Website & Online Store is AN idea, Anja Naraločnik s.p., incorporated and registered in Slovenia, with a registered office at Šaleška cesta 2A, 3320 Velenje, Slovenia, registration no.: 8088390000, VAT no.: SI 70610851.
For any clarification, question or requirement related to your privacy and the processing of your personal data, please contact [email protected]
1.2 Personal Data We May Collect About You
You are under no obligation to provide any such information. Providing your personal data to us (in particular, your personal details, your email, your address, your credit/debit card numbers and bank code and your telephone number) is necessary for processing your order for the purchase of products on our Online Store, supplying other services provided on the Website upon your request, or when your personal data is needed to fulfil obligations required by law or regulations. The refusal to provide us with any personal data necessary for performing the above purposes may consequently prevent us from processing your order for the purchase of products sold on our Online Store or fulfilling obligations required by law and other regulations. Therefore, failure to provide personal data may constitute, in some cases, a legitimate and justified reason for not processing your order for the purchase of products sold on our Online Store or not providing the Website’s services.
Disclosure of further personal data to us other than that required for fulfilling legal or contractual obligations and to properly browse our services with necessary traffic data is, on the contrary, optional and does not have any effect on the use of our Website & Online Store and of its services or on the purchase of products on our Online Store. We will inform you at every step whether disclosing your personal data to us is required or optional by marking with an appropriate symbol (*) the information that is required or data needed for the purchase of products and/or for the provision of requested services on our Website & Online Store.
1.3 Minimum Age
Protecting the safety and privacy of children is very important to us. We do not accept registrations or orders submitted by, and will not knowingly collect or use personal data from anyone under the age of sixteen (16) years, or any other age limit set out by the law of his/her country of residence. By registering or making any purchase on our Website & Online Store, you confirm that you have reached the age of majority in your country of residence.
1.4 Use Made of Your Personal Data
Whenever we process your personal data, we do so on the basis of a lawful “justification” (or legal basis) for processing. In the majority of cases, the processing of your personal data will be justified on one of the following bases:
|The purposes for which we process your personal data are the following:||The processing of your personal data is justified by the following legal basis:|
|Process your purchases and to provide you with the services and information offered through our Website & Online Shop and which you request||Performance of a contract|
|Administer your account with us||Performance of a contract|
|Verify and carry out financial transactions in relation to payments you make||Performance of a contract|
|Audit the downloading of data from the Website||Our legitimate interest to get to know our customers better and improve our services accordingly|
|Improve and customise our Website & Online Shop, and our products, services and our business in general, such as by tracking your product preferences, shopping history and interactions with our Website & Online Shop||Our legitimate interest to get to know our customers better and improve our services accordingly|
|Identify visitors to our Website & Online Shop||Our legitimate interest to improve our products and services|
|Carry out data analytics and market research||Our legitimate interest to get to know our customers better and improve our services accordingly|
|Carry out data enrichment, such as by analysing your product preferences, shopping history and interactions with our Website & Online Shop together with data collected from third parties, such as data that you agree to share with us on social networks (e.g., Facebook, Instagram, etc.) and/or that we may collect from publicly accessible databases||Your prior explicit consent|
|Correspond with you to resolve your queries or complaints||Your prior explicit consent|
1.5 Newsletter and Marketing Communications
On our Website & Online Store, users can opt-in to receive newsletters and commercial communications.
We always collects the explicit, free and unambiguous consent of users prior to submitting newsletters and marketing communications to these users or, more in general, before undertaking electronic marketing initiatives dedicated to them.
In such cases, users may be invited to submit personal information in addition to their e-mail address (e.g., gender, country of residence, etc.) for the purpose of having newsletter and marketing communications tailored to the user profile.
Users can always easily withdraw their consent from receiving newsletters and commercial communications in the following ways:
With respect to personal information of non-registered users who have opted to receive newsletters and marketing communications, AN idea, Anja Naraločnik s.p. acts as the sole Controller.
Under the explicit user’s consent, newsletter and marketing communications may be tailored to the user “profile”, based on the personal information our Website & Online Store collects or receives about the concerned user.
With respect to the customers of our Website & Online Store, it is in our legitimate interest to process personal information to offer more interesting products, to improve our Website & Online Store and to personalize the products offered.
The main purpose of profiling is to propose products, services and initiatives more responsive to the tastes, shopping habits and interests of users and customers.
Personal information may be also used for remarketing, retargeting or profiling purposes, including via third parties (e.g., social networks, etc.).
Neither our Website & Online Store nor the Controller will ever carry out any profiling activities relating to children.
1.7 Browsing Data
Our Website & Online Store collects non-sensitive browsing data by automatic means in order to enable and improve user navigation (e.g., IP address, date/time of the visit and its length, any referring URL, the pages visited on the Site, the device used and other information).
The processing of such information allows users to access the Site and fully enjoy its features and services. Furthermore, browsing data may be used to verify that our Website & Online Store is functioning properly.
From time to time, browsing data are processed anonymously for statistical purposes.
Browsing data are unlikely to allow identification of the relevant data subject. However, by their very nature, browsing data may allow identification of the users if associated with other information.
The browsing data described above are stored only temporarily in compliance with the applicable law.
At checkout, our Online Store asks users to provide personal information for the essential purpose of fulfilling their purchase orders and comply with contractual obligations (e.g., name and surname, e-mail address, delivery address, etc.).
Such personal information is also essential for the Customer Service to assist customers on enquiries and for any related necessity, before or after the sale (for instance, with respect to the order delivery status or on product returns).
Personal information related to orders will be stored as long as required to comply with contractual obligations and with the applicable tax and financial reporting obligations.
We may also verify the payment instruments used by customers to purchase on our Online Store (e.g. credit or debit card, etc.) for the main purpose of preventing fraudulent activities or pursuant to the applicable anti-money-laundering laws. As full reliance for payment verification is given to third party payment processors, the Controllers do not process or store any financial information belonging to customers.
Failure to provide the personal information required at checkout will prevent users from completing an order on our Online Store.
Based on our legitimate interest to improve our relationship with customers, we will send to the latter email communications with product suggestions, discounts, feedback requests or other updates. Customers are always free to unsubscribe from such email communications (for instance, by clicking on the “unsubscribe link” at the bottom of each email).
1.9 Registration of Personal Account
When users opt-in to register a personal account, they are asked to submit personal information (e.g., date of birth, gender, etc.). Our Website & Online Store clearly indicates which personal information is mandatory (or not) to set up a personal account.
Users must submit personal information that is true and accurate at the moment of registration and are invited to maintain their personal information up-to-date (if any modification occurs) by logging into the personal account to make all relevant changes.
Users who choose to enable or log in to their personal account via a social media, should be aware that when they connect their personal account to a social media account, our Website & Online Store collects certain personal information the User has already provided to that social media (for example, the email address and public profile on Facebook).
The Controller does not oversee or control such social media services or the user’s profiles on these services, and does not establish privacy settings or rules for how personal information on those services will be used. Users are highly encouraged to read all policies and information regarding the applicable social media services to learn more about how they process personal information.
1.10 Disclosure of Your Personal Data
We may disclose your personal data to any of our affiliate companies, or to our service providers who assist us in providing the services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in performing other tasks, from time to time.
For the avoidance of doubt, we will get your express opt-in consent before we share your personal data with any third party company for marketing purposes.
Your personal data will be accessible by authorized personnel of AN idea, Anja Naraločnik s.p. and affiliated companies, and service providers acting on our behalf on a need-to-know basis. Transfer of your personal data from your country of residence to third countries (notably to countries where we operate) will be involved; some of these countries are subject to a data protection adequacy decision of the European Commission, whereas others are not, such as the US. To ensure the protection of your personal data is consistent with applicable law, such transfers outside your country of residence or the EEA will be made pursuant to the EU Model Clauses, the EU-US or CH-US Privacy Shield certification, Binding Corporate Rules or other acceptable legal mechanisms of which you can request a copy via [email protected]
We may also share your personal data with third parties in connection with potential or actual sale or restructuring of our company or any of our assets, or those of any associated company, in which case personal data held by us about our users may be one of the transferred assets.
We will also respond to requests for personal data where required to do so by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us.
We place great importance on the security of all personal data associated with our users. We have adopted security measures to protect personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access. For the best possible protection of your personal data outside the limits of our control, your device should be protected (such as by updated antivirus systems) and your internet service provider should take appropriate measures for the security of network data transmission (such as, for example, firewalls and anti-spam filtering).
While we take reasonable steps to protect your personal data, we cannot guarantee that the personal data you disclose to us will be 100% secure, nor that any data breach will not occur.
You accept the inherent security implications of dealing on-line over the Internet and will not hold Passionate Fempreneur or their processors responsible for any data breach unless it is due to our negligence.
1.12 Retention of Your Personal Data
Our general approach is to retain your personal data only for as long as required to fulfil the purposes for which it was collected. We generally retain your personal data for three years from the end of our relationship or from the last contact from you, unless local law requires otherwise. However, in some circumstances we may retain personal data for longer periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements.
In specific circumstances we may also retain your personal data for longer periods of time corresponding to the applicable statute of limitations so that we have an accurate record of your dealings with us in the event of any complaints or challenges.
1.13 Your Rights
You have the following rights with respect to your personal data:
o you contest the accuracy of the personal data until we have taken sufficient steps to correct or verify its accuracy;
o the processing is unlawful but you do not want us to erase the data;
o we no longer need your personal data for the purposes of the processing, but you require such data for the establishment, exercise or defence of legal claims; or
o you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether we have overriding compelling legitimate grounds to continue processing.
Where personal data is subject to restriction in this way, we will only process it with your consent or for the establishment, exercise or defence of legal claims.
You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data infringes applicable law.
For further information regarding your rights, to exercise any of your rights, or if you have any complaints or questions regarding the processing of your personal data please contact [email protected]
Please note that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. We will endeavour to respond to your request as soon as possible and in any case within the applicable timeframes.
1.14 Changes to this Policy
2.1 Acceptance Procedures
2.2 What are cookies
Cookies are text files containing small amounts of information that a user’s device (computer, tablet or mobile) downloads when it visits a website. They allow the site to “remember” your device, but not specifically who is using it, and improve your user experience. By associating the identification numbers in the cookies with other customer information when, for example, you log-in to the site, then we know that the cookie information relates to you.
2.3 What is their purpose
Cookies are used generally for different purposes, such as letting the user navigate between pages efficiently, implementing the user’s preferences and generally improving their browsing experience, by customizing the website according to their navigation and user profile. They can also help ensure that the adverts that the user sees online are more relevant to them and their interests.
2.4 What cookies do we use?
Our Website & Online Store uses several types of cookies, each of which has a specific function. Below is a table explaining them:
|TYPE OF COOKIE||FUNCTION|
|Technical cookies which do not require any Opt-in by users|
|Navigation cookie||From the first access these cookies allow our Website & Online Store to function correctly and allow you to view content on your device by recognising the language and market of the country from which you’ve chosen to connect. If you are a registered user, they will allow you to be recognised and to access the services offered from the dedicated areas. Navigation cookies are technical cookies and are needed for the functioning of the website.|
|Functionality cookies||These cookies allow you, upon your express request, to be recognized when you re-visit our Website & Online Store, so that you do not have to re-enter your information every time (for example: “Remember me”). If you have added items to your shopping cart and closed the session without completing the purchase and without removing those items, these cookies allow you to continue the shopping experience the next time you visit the website (within a limited period of time) and find the same items that you selected. Functionality cookies are not essential to the operation of the website, but rather improve the quality of your browsing experience.|
|Analytical cookies||These first party cookies are used to collect data in an anonymous and aggregate way. These cookies are used to prepare statistical analyses on the navigation methods of our Website & Online Store users. We treat the results of these analyses anonymously and exclusively for statistical purposes only.|
|Cookies which require the users’ Opt-in|
|First-Party and Third-Party marketing and profiling cookies||These cookies are aimed at creating user-related profiles to send commercial messages that meet the preferences shown during the visit, or to improve your navigation experience: while you navigate on our Website & Online Store, these cookies are useful for showing you products of interest to you or which are similar to those you have viewed. Third party cookies are those that have been sent by our trusted third party companies. These cookies allow you to be provided with our commercial offering on other affiliated websites (e.g. profiling, advertising, targeting and retargeting cookies) – e.g. Flash Cookies and Pixel Tags. With third party cookies we do not have control of the information provided by the cookie and we do not have access to this data. This information is entirely controlled by third party cookies as described in the respective policy. To find out more about the aforementioned third parties cookie, you can inform yourself on their respective policies and knowingly manage your consent or refusal, for this we invite you to visit http://www.youronlinechoices.com.|
|Social Network Cookies|
These cookies are necessary to allow your social account to interact with our website. For example, they are used to express your appreciation and to share it with your social networking friends. The social network cookies are not needed for navigation. For more information on the policies regarding the use of social network cookies, it is possible to consult the respective privacy and cookies policies:
A full overview of the cookies we use on our Website & Online Store and their respective names and purposes can be found hereunder:
|Cookie name||Purpose / Supplier|
|__cfduid||Cloudflare cookie is used to identify individual clients behind a shared IP address and apply security settings on a per-client basis.|
|_ga||Cookies for user statistics|
|PH_HPXY_CHECK||The cookie uses a security system to prevent brute-force attacks and does not allow the user to identify.|
|autoptimize_feed||To optimise the page speed / loading of the website.|
|cookie_notice_accepted||Records that cookie notice has been accepted|
|vchideactivationmsg_vc11||Enables to send messages from contact form|
|wordpress_test_cookie||Tests whether or not the browser has cookies enabled|
|act, c_user, datr, fr, m_pixel_ratio, presence, sb, spin, wd, xs||Social Network Cookies (Facebook)|
|csrftoken, datr ds_user_id, fbm_124024574287414, ig_cb, mcd, mid, rur, sessionid, shbid, shbid, shbts, urlgen, csrftoken||Social Network Cookies (Instagram)|
|mailchimp_landing_site, MC_PLUMS_LOGIN, MC_USER_INFO, MC_USER_PROFILE, OptanonAlertBoxClosed, OptanonConsent, __zlcmid, _derived_epik, _ga, _gcl_au, _mcga, _mc id, optimizelyEndUserId||Social Network Cookies (Mailchimp)|
2.5 How to Disable and Manage Your Cookie Preferences
Most browser applications automatically accept cookies but you can set it to receive an alert each time an operator tries to send you cookies/pixel tags, and/or prevent it from accepting them. On most browsers, the “Help” portion of the toolbar will tell you how to prevent it from accepting cookies, how to have it notify you when you receive cookies/pixel tags, or how to disable cookies/pixel tags altogether.
Below are pages describing these settings in more detail for each browser:
If you use multiple browsers (e.g. Internet Explorer, Google Chrome, Firefox, etc) you must repeat this procedure with each one, and if you connect to the web from multiple devices (e.g. from work and at home), then you will need to set your preferences on each browser on each device.
Please note that if you disable completely cookies from the browser, then it is possible that some parts of our Website & Online Store will not function properly such as the normal surfing of the site, the purchase activity, and finally you may also lose any personalized activity, such as, the advertising you receive when you visit this website will not be tailored to your interests.
2.6 How to disable third party cookies and advertising or targeting cookies
You may learn how to disable third party cookies and advertising or targeting cookies on your computer by checking http://youronlinechoices.com/.
2.7 Information Sharing
For any further information please contact us via [email protected]
Last update – March 2019