Last update: 23. 09. 2019

This Privacy Policy sets out how CENEJE, a trade and business consulting company, d.o.o., Štukljeva cesta 40, 1000 Ljubljana, collects, stores and uses your personal information. The effective date of these privacy policies is June 8, 2018.

This Privacy Policy applies to the (i) use of our websites on (sub) domains: smind.si, smind.hr, smind.online, certifiedshop.com and certifiedshop.si (the “Website”); (ii) subscriptions to our news updates and services, (iii) informing you through our social channels and applications, and (iv) your use of any other, present or future, online or offline service (hereinafter referred to as (i) – (iv) : Services).

This Privacy Policy applies to our users, that is, natural and legal persons who use our Services (hereinafter: Users).

Please read our Privacy Policy carefully. We recommend that you print or properly store a copy of these privacy policies and any future versions that apply to your consent records that you have provided to us.

About us

Your personal information is controlled by CENEJE, a trade and business consulting company, d.o.o., Štukljeva cesta 40, 1000 Ljubljana (hereinafter: Shopper’s Mind).

If you have any questions, please contact us by sending an email to privacy@smind.si or by calling +386 59 0999 20.

How we collect, use and otherwise process your personal information

We obtain your personal information when you provide it to us, for example, through your use of our Services, when you contact us directly by email, telephone, in writing, or through social media where you provide us with personal information. When permitted by law, we may obtain information about you from other sources.

What types of personal information do we collect or collect about you?

The type of information we collect about you are:

• E-mail address,
• name and surname,
• date or year of birth,
• place or region of residence,
• information about your computer or computer. mobile devices (e.g., your IP address and browser type, device type),
• Information on how you use our Services (eg what pages you viewed, the time you viewed them, and what you clicked on).

How we use your personal information (processing purposes)

At Shopper’s Mind, we follow the principles of transparency and careful handling of personal information. We need your consent to be able to process the personal information we have obtained from you for certain purposes. All information on the purposes for using and processing your personal information is below.

1. Regarding of your Use of Services

1A: Intended use in relation with rating online retailers, products and services Certified Shop® (for individuals)

By completing the questionnaire for rating online retailers, the User agrees to provide personal information. In this case, that is the IP address of the device from which he logs in, but if the User arbitrarily provides other personal information (name, email, place and region of residence, gender, year of birth), this consent also applies to them. At login, the User has the option to choose for what purposes the processing of personal data is accepted by:

(MANDATORY – based on the performance of the Services and the legitimate interest) Consent to process voting data in the online merchant evaluation system and to track activity and interests is valid until revoked and to the extent of:

• processing data in a questionnaire system for rating online retailers, keeping and processing the list of all voters, verifying the votes / ratings of online retailers and the like
• data processing in a marketing automation tool to help us continuously monitor your activities on the Websites. This enables us to perform the Services, contact you related to your activities, and aggregate analysis of the use of Websites and Services

(MANDATORY) The consent that we may make your information publicly available (name, place, opinion of the merchant, product or service) is valid until canceled and includes:

• publication of your opinion of retailer, stating your name and place of residence on the Website, on ceneje.si, jeftinije.hr, idealno.rs and idealno.ba, in rated online stores, advertisements, social networks and other marketing announcements

(OPTIONAL) The consent that we may contact you again and provide you with information about Certified Shop® content and ask for additional ratings or reviews is valid until canceled and in scope:

• information and updates on Certified Shop®
• all communication and prompts to further evaluate your online merchant experience, including, for example, satisfaction with their products or services, delivery, complaint process, etc.

1B: Intended Use in relation with application for Certified Shop® Trust Marks (for Legal Entities)

By filling in the Certified Shop® Confidentiality Label form, the User agrees to provide personal information. In this case, these are: first and last name, email, phone number, company name, company role and IP address of the logging device. At login, the User has the option to choose for what purposes the processing of personal data is accepted by:

(MANDATORY – based on the performance of the Services and the legitimate interest) The consent to track your activities and interests on the Website is valid until the CANCEL and includes:

• data processing in a marketing automation tool to help us continuously monitor your activities on the Websites. This enables us to perform the Services, contact you related to your activities, and aggregate analysis of the use of the Websites and Services

(MANDATORY – based on the performance of the Services and the legitimate interest) Consent to sign up for information and notices related to the Certified Shop® trust mark is valid until the CANCEL and shall include:

• all communication related to the status of the Certified Shop® Trust Mark application and other trust mark information
• Submitting the certification process account to award the trust mark and maintain the trust marks for three months
• data processing in the client relationship management system (CRM) and payment and execution tool for ordered Service
• aggregated data processing

(OPTIONAL) Consent to receive personalized notices and offers includes:

• the use of direct marketing data
• remarketing to digital advertising platforms (Facebook, AdWords …) to promote the Services
• processing and retrieval of data into digital advertising tools (use of email to segment users, in which case email cannot be attributed to a specific individual)

(OPTIONAL) Consent to receive Shopper’s Mind Content is valid until the CANCEL and includes:

• Use information to send Shopper’s Mind content and occasionally send other content, such as ecommerce trends, news, guides, ecommerce notifications, and more.

1C: Uses in relation with subscribing to Shopper’s Mind Content

By filling out the application form to receive Shopper’s Mind Content, the User agrees to provide personal information. In this case, these are: first and last name, email and IP address of the device from which you are logging in. At login, the User has the option to choose for what purposes the processing of personal data is accepted by:

(MANDATORY – based on the performance of the Services and the legitimate interest) The consent to track your activities and interests on the Website is valid until the cancelation and includes:

• data processing in a marketing automation tool to help us continuously monitor your activities on the Websites. This enables us to perform the Services, contact you related to your activities, and aggregate analysis of the use of the Websites and Services

(MANDATORY – based on the performance of the Services and legitimate interest) Consent to receive Shopper’s Mind Content is valid until the cancelation and includes:

• Use information to send Shopper’s Mind content and occasionally send other content, such as ecommerce trends, news, guides, ecommerce notifications, and more.

(OPTIONAL) Consent to receive personalized notices and offers includes:

• the use of direct marketing data
• remarketing to digital advertising platforms (Facebook, AdWords …) to promote the Services
• processing and retrieval of data into digital advertising tools (use of email to segment users, in which case email cannot be attributed to a specific individual)

1D: Uses in relation with registration on Ecommerce Day Event

By filling out the Ecommerce Day Event Registration Form, the User agrees to provide personal information. In this case, these are: first and last name, email and IP address of the device from which you are logging in. At login, the User has the option to choose for what purposes the processing of personal data is accepted by:

(MANDATORY – based on the performance of the Services and the legitimate interest) The consent to track your activities and interests on the Website is valid until the cancelation and includes:

• data processing in a marketing automation tool to help us continuously monitor your activities on the Websites. This enables us to perform the Services, contact you related to your activities, and aggregate analysis of the use of the Websites and Services

(OPTIONAL) Consent to receive Shopper’s Mind Content is valid until the cancelation and includes:

• Use information to send Shopper’s Mind content and occasionally send other content, such as ecommerce trends, news, guides, ecommerce notifications, and more.

(OPTIONAL) Consent to receive personalized notices and offers includes:

• the use of direct marketing data
• remarketing to digital advertising platforms (Facebook, AdWords …) to promote the Services
• processing and retrieval of data into digital advertising tools (use of email to segment users, in which case email cannot be attributed to a specific individual)

(OPTIONAL) Consent for photographing, recording, editing and posting of recordings is valid until the cancelation and includes:

• editing and posting photos and recordings of event attendees, for the purpose of promoting Ecommerce Day, I authorize the taking, recording, editing and publication of recordings on websites, social networks, print publications containing event content and other promotional messages (e-mail, ads …).
• IMPORTANT: In case of unaccepted consent for the participant of the event, we ask that you consider a special seating arrangement ̶ at the end of the conference room. Such seating arrangements shall be exercised in order to respect the individual’s right to privacy and to facilitate the taking of photographs and the recording of the event for the aforementioned purposes.

1E: Uses for use in relation with the application for competition Web retailer of the year

By completing the application for competition for Web retailer of the year, the User agrees to provide personal information. In this case, these are: first name, email, phone number and IP address of the device from which you are logging in. At login, the User has the opportunity to choose for what purposes the processing of personal data is accepted by:

(MANDATORY – based on the performance of the Services and the legitimate interest) The consent to track your activities and interests on the Website is valid until the cancelation and includes:

• data processing in a marketing automation tool to help us continuously monitor your activities on the Websites. This enables us to perform the Services, contact you related to your activities, and aggregate analysis of the use of the Websites and Services

(OPTIONAL) Consent to receive Shopper’s Mind Content is valid until the cancelation and includes:

• Use information to send Shopper’s Mind content and occasionally send other content, such as ecommerce trends, news, guides, ecommerce notifications, and more.

(OPTIONAL) Consent to receive personalized notices and offers includes:

• the use of direct marketing data
• remarketing to digital advertising platforms (Facebook, AdWords …) to promote the Services
• processing and retrieval of data into digital advertising tools (use of email to segment users, in which case email cannot be attributed to a specific individual)

1F: Uses for use in connection with a Free Legal Aid Application)

By completing the Free Legal Aid Application Form, the User agrees to provide personal information. In this case, these are: first and last name, email, phone number, company name and IP address of the device from which you are logging in. At login, the User has the opportunity to choose for what purposes the processing of personal data is accepted by:

(MANDATORY – based on the performance of the Services and the legitimate interest) The consent to track your activities and interests on the Website is valid until the cancelation and includes:

• data processing in a marketing automation tool to help us continuously monitor your activities on the Websites. This enables us to perform the Services, contact you related to your activities, and aggregate analysis of the use of the Websites and Services

(OPTIONAL) Consent to receive Shopper’s Mind Content is valid until the cancelation and includes:

• Use information to send Shopper’s Mind content and occasionally send other content, such as ecommerce trends, news, guides, ecommerce notifications, and more.

(OPTIONAL) Consent to receive personalized notices and offers includes:

• the use of direct marketing data
• remarketing to digital advertising platforms (Facebook, AdWords …) to promote the Services
• processing and retrieval of data into digital advertising tools (use of email to segment users, in which case email cannot be attributed to a specific individual)

2. Website management and enhancement, which involves monitoring your activities and interests and customizing the user experience on the Website and creating personalized notifications and offers. All this is necessary for our legitimate interest to better understand the wishes of our Users and to customize our Websites and Services.

3. Protecting our business and our business interests, including for the purpose of reviewing our credit and past experience, fraud prevention and debt collection. This is necessary to protect our legitimate interests in preventing criminal activities such as fraud or money laundering, to ensure that our Websites and Services are not misused and our business is protected. We will only carry out such verifications when permitted by law.

4. Communication with our business advisers and legal representatives. This is necessary for our legitimate interests to obtain legal or professional business advice, and we will only provide your personal information, as necessary, to the minimum necessary and anonymized whenever possible.

5. Sharing personal information with third parties (hereinafter referred to as: data recipients) associated with us in connection with our provision of the Services, such as:

• our IT and infrastructure business partners,
• capital-related companies,
• advertising partners.

This will be required either to perform the contract we have entered into with you (or to prepare an offer), for our legitimate interest in the effective conduct and management of our business, for compliance with the legal obligations binding us, or for our own direct marketing purposes. When we share your personal information, we will do so consistently on a need-to-know basis, subject to appropriate confidentiality restrictions as much as possible and only to the extent strictly necessary for any of these purposes.

6. Enforcement of our legal rights and compliance with laws, regulations and other legal requirements. This is necessary for our legitimate interest in safeguarding our business and exercising our contractual and other legal rights, and in ensuring physical, network and information security and integrity. In addition, it is necessary for our legitimate interest to provide a secure and uncompromising IT system and networks, including backup and archiving, prevention of malware, viruses, errors or other malicious code, and prevention of unauthorized access to our systems and all forms of attack or damage to our IT systems and networks. We may need to use and process your personal information in order to comply with the legal obligations we have to comply with. For example, we may require you to provide a piece of your personal information for the purposes of enforcing a legal anti-money laundering obligation, or to disclose your information to a court upon receipt of a court order. We may also need your personal information to comply with applicable legal obligations, such as tax law and other binding laws.

7. With respect to disclosure requirements and in the case of sale or purchase of a business and / or assets, whether actual or potential. This is necessary for our legitimate interests in selling and / or ensuring and promoting the success of our business.

8. For statistical and research purposes. We will aggregate the data and use it for the legitimate interests of processing personal data for research purposes, including market research, better understanding our customers and tailoring our products and services to your needs.

9. Identification of possible offenses or threats to public safety to the competent authority. This is necessary for our legitimate interest in promoting the success of our business, in preventing crime, in fulfilling legal obligations in the general public interest, or in the legitimate interests of government and law enforcement agencies.

10. With respect to any legal dispute or proceeding. This is necessary for our legitimate interest in promoting and ensuring the success of our business, in resolving disputes and in making such disclosures as are required by law or which we consider to be reasonable in law.

When we process your personal information based on your consent, you may at any time withdraw your consent by sending us an email at privacy@smind.si. The effective date of such cancellation is 30 business days from the day we received your request.

Retention of personal data and processing period

Your personal data is stored by Shopper’s Mind on its own servers located in Slovenia and servers of cloud service providers located in EU Member States and in the USA. Occasionally, personal data may be processed outside the EU and the US.

Shopper’s Mind will process your personal data to the extent that is relevant and limited to what is required for processing purposes. There are certain issues associated with this, such as whether we need to continue to retain this information in order to fulfill our contractual obligations with you or for our legitimate interests; whether we have any legal obligation to continue processing your information, such as any recordkeeping obligations required by applicable tax and accounting laws; and whether we have a legal basis (such as consent) to continue processing your personal information.

For more information on where and how long your personal information is stored, and your right to delete and transfer your personal information, please contact us at privacy@smind.si.

How we protect your personal information

We have taken the appropriate technical and organizational measures to protect your personal data and to protect it against unauthorized or unlawful use or processing and against the accidental loss or destruction or corruption of your personal information. These measures include:

• the principle of minimum data and processing,
• training our employees on the importance of confidentiality and maintaining the privacy and security of your data,
• commitment to take appropriate disciplinary action to enforce employee responsibility for privacy,
• continuous and comprehensive updating and testing of our personal data protection policies and measures,
• careful and responsible choice of our business partners,
• use of secure servers to store your personal information,
• appointment of an authorized person for the protection of personal data,
• a request for proof of identity from any individual requesting access to their personal information.

We would like to remind you that the transfer of information (including personal data) through the Internet is not always completely secure. If you provide us with any information via the Internet (via email, our Website, or otherwise), you do so entirely at your own risk. We cannot be held responsible for any costs, expenses, loss of profits, damage to reputation, liability or any other form of loss or damage suffered by you as a result of your transmission of information over the Internet.

Web plugins and other tools

a) YouTube

We use Google-controlled plugins on our Websites. The site operator is You Tube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. If you visit our Website that contains the YouTube Plugin, you are connected to YouTube servers. YouTube is then notified of the website you have visited.

If you are signed in to a YouTube account, it allows you to link your browsing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account.

YouTube allows our Websites to contain video tips and related content. This is a legitimate interest under Art. 6 (1) (f) of the General Data Protection Regulation (hereinafter: GDPR).

More information about handling user data is available in the YouTube Data Protection Statement: Data Protection Statement.

b) Google Maps

On our Websites, we use the Google Maps mapping service through the API. Managed by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. To use Google Maps, your IP address must be saved. This information is usually uploaded to a Google server in the US and stored there. We, as the Website Provider, have no influence on this data transfer.

The use of Google Maps is in the interest of displaying specific locations on our Websites (such as the location of our corporate headquarters). This is a legitimate interest under Art. 6 (1) (f) GDPR. For more information on how to handle user data, see the Google Privacy Statement at https://policies.google.com/privacy.

c) Slack

We use the Slack communication tool for internal communication. For this reason, the personal data of customers, Users and associates or contractual partners may be transferred to Slack Technologies, 500 Howard Street, San Francisco, CA 94105, USA (hereinafter: Slack Technologies). The processing of personal data through Slack is carried out on the basis of our legitimate interest within the meaning of Art. 6 (1) (f) GDPR.

We have concluded with Slack Technologies a contract on the processing of personal data, in which the latter undertakes to respect EU law in the field of personal data protection.

Slack Technologies is registered with the EU-US Privacy Shield with regard to international data transfers and thus offers an additional commitment to comply with EU rules on personal data protection.

With regard to international data transfers, Slack Technologies has also concluded a data transfer agreement with the so-called Standard Contract Clauses, which obliges the latter to process personal data solely according to our instructions and to comply with EU rules on the protection of personal data.

d) Net-Results

We use the Net-Results of the US provider Net-Results Marketing Automation, 1738 Wynkoop Street, Suite 201, Denver, CO 80202 to operate the Services, submit Shopper’s Mind Content, monitor your activities on the Websites, and perform aggregate analysis to optimize the Websites. It stores your email, the IP address of the device, and the following information, if any: name, phone number, address, business name, and some other information. Information about your activities and interests is also stored on our Web sites, e.g. which pages you viewed, what you clicked, and the like. This information is stored with a Net-Results provider on its servers in the US.

With the seller and maintainer of Net-Results software solution, Frodx d.o.o, Business zone A34, 4208 Šenčur pri Kranju we have concluded a contract on processing of personal data, and with Net-Results we have concluded a contract on transfer of personal data (standard contractual clauses) in which the latter commits itself to respecting EU data protection law. Net-Results is registered for the EU-US Privacy Shield on international data transfers.

The Net-Results platform privacy policy is available at  https://www.net-results.com/privacy-policy/.

The use of the Net-Results service is carried out under Article 6 (1) (f) of the GDPR. We have a legitimate interest in selecting technology providers that offer tools to optimize our business.

e) LimeSurvey

We use the open source LimeSurvey software solution (www.limesurvey.org) from LimeSurvey GmbH Services & Consulting, Barmbeker Strasse 7a, 22303 Hamburg, Germany, to prepare and conduct online surveys. LimeSurvey runs on the same web server as Websites. The information processed by LimeSurvey is not transmitted to third parties. This software solution uses cookies, especially for the temporary storage of processing processes.

You can read more about LimeSurvey’s privacy policy at https://www.limesurvey.org/policies/privacy-policy.

The use of the LimeSurvey software solution is implemented under Article 6 (1) (f) of the GDPR. We have a legitimate interest in selecting technology providers that offer tools to optimize our business.

f) Salesforce CRM

Shopper’s Mind uses one of the leading and more advanced Salesforce CRM software from SalesForce.com Inc., The Landmark @ One Market Street, Suite 300, San Francisco, CA 94105, USA, for effective and secure customer relationship management cloud computing technology. The latter means that part of the data relating to you is stored in data centers within the EU (France, Germany) and part of the data is stored in data centers in the United States (USA).

The service provider is the recipient of numerous certifications (https://trust.salesforce.com/en/compliance/) in the field of information security and compliance with personal data protection legislation, which is why Shopper’s Mind has contracted data processing services to this service provider . In addition, Salesforce was approved by eTrust, and awarded with data protection certificate by TÜV Saar.

The transfer of personal data to EU data centers is subject to the principle of free movement of data within the EU, while the transfer of data to the US is based on the Privacy Shield tool, jointly designed by the US Department of Commerce and the European Commission, and which serves as a support mechanism for meeting data protection requirements for the transfer of personal data from the EU to the US. Your data is stored exclusively in the EU and the US, which does not exclude the possibility that specialized third-party experts may access the stored data from time to time for the purposes of maintaining, correcting incidents or performing upgrades and providing other forms of technical support. Such access to third-country data is based on SalesForce’s Binding Corporate Rules (https://www.salesforce.com/eu/company/privacy/), which have been endorsed in a special process by The French Supervisory Authority (CNIL) and are valid throughout the EU.

We have entered into a contract with Salesforce.com, Inc. for the processing of personal data, which obliges the latter to comply with EU rules on the protection of personal data. You can read more about Salesforce.com’s privacy policy https://www.salesforce.com/company/privacy/full_privacy/

The use of Salesforce CRM services is based on Art. 6 (1) (f) GDPR. We have a legitimate interest in optimizing the operation of our services or services to better manage our customer relationships.

Cookie Policy

What are cookies and why are they needed?
These are small text files that most websites store on devices that users access the Internet to identify the individual devices that users have used when accessing. Their storage is under the full control of the browser that the user has ̶ this can be limited or disabled if the cookies are stored. Cookies are not harmful and are always limited in time.

Cookies are small text files that are downloaded to a user’s computer when they visit a site, and usually contain:

• the name of the cookie and the server from which the cookie was sent,
• cookie life,
• value (unique number).

Cookies are important for providing user friendly web services. The most common e-commerce features would not be possible without cookies. Web-site interaction with cookies is faster and easier with the help of cookies. With their help, a website remembers one’s preferences and experience, saving time and making web browsing more efficient and enjoyable.

Cookie upload settings
Some cookies are deleted as soon as you close your browser. These cookies are called session cookies or temporary cookies because they only last as long as a single session and are no longer stored after the session. Such cookies usually only contain an identification code that can only be recognized by the website that installed the cookies.

Other cookies have a certain life or validity period. These are used to make it clear that you have already logged in to a certain site, or to keep information about some settings, such as language selection.

At Ceneje.si we use 3 groups of cookies, of which you can change the setting for one group. The cookie settings apply to the device on which you currently use our site.

Necessary cookies, which are necessary for the proper functioning of the Ceneje.si website and to ensure the smooth operation of the Ceneje d.o.o.

• Cannot be excluded (these cookies do not require your consent)

Analytical cookies, for anonymously measuring website traffic and collect data on website usage so we can continually improve our user experience based on our findings.

• Cannot be excluded (by using the site you agree to the installation)

Advertising cookies and retargeting cookies, which may serve advertisements tailored to your interest on our website and / or external sites.

Disabling web cookies
You may refuse some or all of the cookies used on our web sites by changing your browser settings, but this may impair your ability to use our web sites and some or all features.

Temporarily disable the download / save of web cookies by using the “private window” (Incognito) in your browser. Private browsing allows you to browse the web without storing any information about the pages you have visited on your web browser.

Permanent shutdown of web cookies (until the next time you visit or re-enable them) which you can control in your web browser. For information on cookie settings, select the web browser you are using:

• Internet Explorer (from Version 8)
• Chrome
• Firefox
• Opera (English page)
• Safari (English page)

Attention! You should be aware that permanently disabling / deleting cookies will lose the ability to maintain your personal preferences, login status, online purchases and much more, and that pages will not function properly or be deprived of additional options. For example, websites will load a little slower, since images and all pieces of content will have to be loaded from the beginning each time.

Which cookies uses our websites on (sub)domains smind.si, smind.hr, smind.online, certifiedshop.com and certifiedshop.si?

1. Cookies on the website smind.si and smind.hr:

The name of the cookie	Purpose	Cookie time	Company
__gads	Advertising/Targeted advertising	2 years	Google Inc.
__mauuid	Net Result differentiate users	20 years	Forward IT Solutions
_ga	Website view statistics	2 years	Google Inc.
_gid	Website view statistics	1 day	Google Inc.
_hjIncludedInSample	The effectiveness, functionality of web analytics and Hot Jar services	session	Hot Jar
_hjMinimizedPolls	It is used to keep the widget on the website minimized.	1 year	Hot Jar
cookie_notice_accepted	Permission to use cookies on the site smind.si	1 month	Ceneje d. o. o.

                                                                                           

2. Cookies on the ecommerceday.smind.hr web site, ecommerceday.smind.si, webmaster.smind.si, webtrgovacgodine.smind.hr:

The name of the cookie	Purpose	Cookie time	Company
_ga	Website view statistics	2 years	Google Inc.
_gid	Website view statistics	1 day	Google Inc.
_hjIncludedInSample	The effectiveness, functionality of web analytics and Hot Jar services	session	Hot Jar

For the purposes of measuring the activities of Users, we use the following functionalities on our Websites:

a) Shopper’s Mind

We use Shopper’s Mind cookies primarily to optimize the functioning of the Website.

Shopper’s Mind cookies are stored pursuant to Article 6 (1) (f) of the GDPR. We have a legitimate interest in optimizing the operation of our Websites.

b) Google Universal Analytics

We use Google Universal Analytics on our Websites for purposes of traffic analysis. Managed by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA.

Google Analytics uses cookies. The information obtained by a cookie about your use of this Website is generally transmitted to a Google server in the United States and stored there.

You can disable Google Universal Analytics cookies at the following online link https://tools.google.com/dlpage/gaoptout. If you choose not to accept certain cookies, you will not be able to use certain features on our Websites. If you choose not to receive personalized ads, then you may receive ads online, but these ads will not be tailored to your preferences and browsing patterns.

Google is registered with the EU-US Privacy Shield with respect to international data transfers, and is therefore bound to abide by EU data protection rules.

You can read more about Google’s privacy policy at https://policies.google.com/privacy?hl=en.

Google Universal Analytics cookies are stored pursuant to Article 6 (1) (a) of the GDPR.

c) Net-Results

We use the US-based online marketing tool from the US provider Net-Results Marketing Automation, 1738 Wynkoop Street, Suite 201, Denver, CO 80202 on our Websites. We use the tool to submit Shopper’s Mind content and track your activities and interests on the Websites.

Net-Results uses cookies. The information that a cookie obtains about your use of the Website is typically transmitted to and stored on a US server.

Net-Results is registered with the EU-US Privacy Shield with regard to international data transfers and is therefore bound to abide by EU data protection rules.

Advertising based on the User’s use of our Websites (behavioral targeted advertising)

Our Websites use cookies for the so-called behavioral targeted advertising. These are text files that help to store information on the usage of the visited Web site (number of visits, times of visits, time spent on individual pages, etc.), ie User profiles, on your computer. These usage profiles are aggregated and analysed to allow content that is tailored to the individual User’s interests when displaying online advertising (such as a banner) on other websites. In no case shall cookies store personal information such as first and last name, address and email address.

In this case the IP address is collected directly by the behavioral targeting service provider, but as a rule stores it only in abbreviated or encrypted form (i.e., the IP address is replaced by another set of numbers that does not allow the original IP order of numbers to be re-detected and can no longer be reversed track and process further).

Behavioral targeted advertising and other forms of advertising on our Websites are performed partly by ourselves and partly by outsourcers:

a) Google Remarketing

We use the Google Analytics remarketing feature in conjunction with Google AdWords and DoubleClick. This service is provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA.

This allows your ads to show based on your interests, which are determined by your previous usage and browsing history on one device (such as your mobile phone) and other devices (such as your tablet or computer).

When you give your consent, Google will associate your web and app browsing history with your Google Account for this purpose. That way, any device that logs into your Google Account can display the same personal promotional message.

If you have this feature enabled, Google Analytics collects advertising IDs that are temporarily linked to our Google Analytics data to identify and create cross-device ads.

You can permanently disable device remarketing / targeting by turning off personalized advertising in your Google Account. To do so, follow this link: https://www.google.com/settings/ads/onweb/.

The collection of information collected under your Google Account is solely based on your consent, which may be submitted or withdrawn by Google pursuant to Article 6 (1) (a) of the GDPR. The collection of information that is not aggregated in your Google Account (for example, because you do not have a Google Account or have waived it) is based on GDPR Article 6 (1) (f), whereby we have a legitimate interest in analysing the anonymous behavior of Users purposes.

For more information and Google’s privacy policy, visit: https://www.google.com/policies/technologies/ads/.

b) Facebook pixel

We use the so-called Facebook Pixel code on our Websites from Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA, http://www.facebook.com (“Facebook”). Facebook Pixel is part of the code included on the Websites. This tool allows us to track the activities of Users, and consequently show them personalized advertisements on the Facebook social network. To this end, Facebook Pixel will directly create a connection to Facebook servers. In this case, the Facebook server will be notified that you have visited our Website, and Facebook will add this information to your personal profile on their website. More information about collecting and using your personal information, including your rights and options, can be found here: https://sl-si.facebook.com/about/privacy.

You can disable the feature as stated here (you must be logged in with your Facebook account): https://sl-si.facebook.com/business/help/1415256572060999?helpref=uf_permalink.

Facebook Pixel also allows us to create a so-called virtual audience for the purpose of advertising to users with similar features on the Facebook social network. Facebook will store a cookie on your computer for this purpose. Click here to withdraw your consent: https://www.facebook.com/ads/website_custom_audiences/.

Facebook cookies are stored under Article 6 (1) (a) of the GDPR.

c) DoubleClick

We use the DoubleClick Online Marketing Tool on our Websites operated by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. The DoubleClick tool allows us to display advertisements (banners) on Web pages and measure their effectiveness. This information is not used in connection with the personal data of other Google services until the User has given its consent.

DoubleClick uses cookies. The information collected by a cookie about your use of the Website is generally transmitted to a Google server in the United States and stored there.

Google is registered with the EU-US Privacy Shield with respect to international data transfers, and is therefore bound to abide by EU data protection rules.

DoubleClick cookies can be disabled at the following online link https://policies.google.com/technologies/ads?hl=en. If you choose not to accept certain cookies, you will not be able to use certain features on our Websites. If you choose not to receive personalized ads, then you may receive ads online, but these ads will not be tailored to your preferences and browsing patterns.

You can read more about Google’s DoubleClick privacy policy at https://policies.google.com/privacy?hl=en.

DoubleClick is used pursuant to Art. 6 (1) (f) GDPR. We have a legitimate interest in optimizing the operation of and the advertising of the Website.

d) OptinMonster

We use the OptinMonster marketing software from US provider RETYP, LLC., 3701 Savoy Lane, West Palm Beach, 33417 FL, USA for displaying promotional messages and obtaining email addresses. You can unsubscribe at any time from the ‘unsubscribe’ link in the footer of the sent message. Data is only collected based on your active behavior (for example, when you sign up to receive emails via a popup form). OptinMonster does not store the collected data on its own servers, but immediately forwards it to a tool selected by Shopper’s Mind.

You can read more about OptinMonster privacy policy at https://optinmonster.com/privacy/.

OptinMonster is used pursuant to Art. 6 (1) (f) GDPR. We have a legitimate interest in analysing the behavior of Users so that we can optimize the operation of the Websites and advertise them.

International transfers of personal data

If we transfer your personal information outside the European Economic Area, we will do so after careful review of appropriate legal bases and safeguards such as:

• data protection policies known as “Binding Business Rules” or “BCRs,”
• standard contractual clauses adopted by the European Commission or the Information Commissioner and approved by the European Commission in accordance with the relevant law,
• standard contractual clauses adopted by the European Commission or the Information Commissioner and approved by the European Commission in accordance with the relevant law,
• a code or codes of conduct drawn up by an association or other body approved by the Information Commissioner,
• approved certification mechanisms (such as the EU-US Privacy Shield),
• or where permitted by the Information Commissioner or the contractual clauses between the controller or data processor and the data controller, processor or recipient of personal data in a third country or international organization.

The rights of the data subject

We would like to remind you of the rights regarding your personal information, which can be claimed by sending an email to privacy@smind.si. These allow you to:

• request access to your personal information and information regarding our use and processing of your personal information,
• requesting the correction or deletion of your personal information,
• requesting the correction or deletion of your personal information,
• you request that we restrict the use of your personal information,
• you require your personal data that you have provided to us (we will provide it in a structured and machine-readable format, such as an Excel spreadsheet), and you have the right to transfer that personal information to another data controller,
• you object to the processing of your personal data for certain purposes (see section below entitled “Your right to object to the processing of your personal data for a specific purpose”),
• you withdraw consent to our use of your personal information, relying on your prior consent. If you withdraw it, it will not affect the lawfulness of our use and processing of your personal information based on your consent before the day you withdraw it.

You also have the right to file a complaint with the supervisory authority. In the Republic of Slovenia, this is the Information Commissioner, whose contact details are available here: Information Commissioner.

For further information on your rights regarding your personal information, including certain restrictions that apply to some of these rights, see Articles 12 to 23 of the GDPR available here: REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL.

Your right to object to the processing of your personal data for certain purposes

With respect to your personal information, you also have the following rights, which you can exercise in the same way as in the previous section:

• you may object to the use or processing of your personal information when used or processed for the purpose of performing a public interest task if we process your personal information for our legitimate interests, including “profiling” (for example, predicting your behavior based on personal data) based on any of these purposes,
• you may object to the processing of your personal information for direct marketing purposes (including any automated assessment we make of you, or any of your features, if related to such direct marketing).

You may also exercise your right to oppose the use or processing of your personal information for direct marketing purposes by:

• clicking the unsubscribe link at the bottom of each of our marketing emails and follow the instructions that appear in your browser after clicking that link, or
• sending an email to privacy@smind.si requesting that we stop sending you marketing messages. You must specify the type of messages you want to unsubscribe from.

Whenever you object to direct marketing using a different communication method than marketing communications received from us, you must provide us with your name and sufficient information to identify you in connection with the communications you have received.

Our use of automated decision making, including profiling

Based on personal information we obtain from you, automated decision-making (including profiling) is performed in certain cases.

Changes to our Privacy Policy

We may change our privacy policy from time to time, and we will notify you. By continuing to access our Websites on or after this date, you agree to be bound by a new version of our privacy policy.

When we intend to use your personal information for a new purpose, we will provide you with information about that purpose and any other relevant information before using your personal information for that new purpose.

Changes to your personal information

Please let us know of any changes to your personal information we hold about you that are kept accurate and up-to-date.

Authorised person for protection of personal data

You can contact our Authorised person for protection of personal data at dpo@smind.si. Information about authorized person for protection of personal data is located at this link.