The company MLINAR pekarska industrija d.o.o. (hereinafter: Mlinar) undertakes to maintain confidentiality of personal data of all persons (Users) who provide such personal data to Mlinar in the process of registering in the Mlinar Loyalty application, and to treat such data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) and with the Act on Implementation of the General Data Protection Regulation and other laws regulating personal data protection.
Data controller
This document describes how the controller MLINAR pekarska industrija d.o.o., Radnička cesta 228 c, Zagreb, Phone: 01/2382-300, E-mail: info@mlinargrupa.com, www.mlinar.hr processes personal data.
Mlinar collects consumers’ personal data only to the extent necessary to perform its contractual obligations, to fulfil its legitimate interests and its legal obligations or if you have given your consent for the processing of your personal data.
Consumers’ personal data will not be available to third parties in any way, except to the extent necessary to use the app, exercise the rights under the loyalty program, or in the event that this is required in order to act upon an instruction of any competent authorities of the Republic of Croatia.
Legal notice
The Privacy Policy pertains to confidentiality of personal data collected when users register for the Mlinar Loyalty program (Mlinar Loyalty application). This Privacy Policy is an integral part of the Participation Terms and Conditions applicable to the Mlinar Loyalty mobile application.
Mlinar, as the provider of Mlinar Loyalty program services, complies with applicable regulations with a view to protecting the privacy of Mlinar Loyalty application users, especially with the General Data Protection Regulation.
Mlinar Loyalty application users (hereinafter: “Users”) are instructed to read everything provided in this document in order to better understand what data is collected and processed by Mlinar, for which purpose, based on which legal basis, with whom that data is shared and why, what protection measures it implements and what your rights are regarding the processing of your personal data.
Every User who has any questions regarding personal data may send an e-mail to the following address: zastita.podataka@mlinargrupa.com.
By accepting this Privacy Policy (by clicking), or upon User registration in the Mlinar Loyalty application, the User confirms to have read and understood, also that they consent to personal data processing as outlined in this document.
When registering in the Mlinar Loyalty application, the User must provide the following information: E-mail, city/town, gender, year of birth and optionally, Users can also provide another User’s referral code. If the User intends to take part in prize-winning games or competitions via the Mlinar Loyalty application, he/she may be requested to provide other personal data such as, for instance, first and last name, address, phone number or other, depending on the requirements of the relevant prize-winning game or competition.
If the User does not provide the required mandatory data to register in the Mlinar Loyalty application, he/she will not be permitted to register because it will be technically impossible to register and activate the Mlinar Loyalty application without such data.
Apart from this data, Mlinar also automatically collects data from your cell phone, which may include your IP address, and there are also situations where we automatically collect other types of data, such as date and time of accessing Mlinar Loyalty application, information about the hardware, software or browser you are using or about the operating system on your computer, application version or your language settings. During the use of Mlinar Loyalty application, IT systems and software systems collect certain personal data whose transmission is implicit in the use of Internet communication protocols. This concerns information that is not associated with specific individuals but, by its nature, could, through processing and combination with third-party data, enable the identification of users. This category of data includes IP addresses or the domain names used by data subjects connecting to the application, the URI addresses of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the server’s response, and other parameters relating to the operating system and the users.
During the use of the application, IT systems and software systems for managing the application collect some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not linked to specific individuals, but by its nature could, through processing and linking with third-party data, enable the identification of the user. This category of data includes the IP address or domain names of the computers used by users connecting to the website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's response (successful, error, etc.) and other parameters related to the operating system and users.
Mlinar collects and processes personal data of Mlinar Loyalty application users for the purpose of ensuring secure identification of Users who access the Mlinar Loyalty application, using the benefits of the Mlinar Loyalty program, communicating with the User and carrying out any legal proceedings related to exercising User rights. We also partly implement automated processing in order to constantly improve our processes in the interests of the Users, to make the offered goods or services individualised for the Customer, and to adapt the offer of our products and services to the Users’ habits and needs.
Mlinar collects and processes personal data of Users who wish to receive product and special promotion information so that it may send notifications to them, invite them to take part in prize-winning competitions by e-mail, social networks or other communication channels for which the User had previously registered, for the requirements of any legal proceedings connected with account usage, to individualise notifications, or for market research and for improving the efficiency and quality of our services.
Mlinar pays special attention to protection of personal data of children and persons under the age of 16, because children deserve special protection in regard to their personal data seeing as they may be less aware of the risks, consequences and relevant protection measures or their rights in connection with personal data processing. This right to protection pertains especially to processing and using personal data of children for the purpose of marketing or for creating personal or user profiles and collecting children’s personal data when they are using services offered directly to the child. Consent of holder of parental responsibility is not necessary at the moment of registration or activation of the Mlinar Loyalty application, but if the User indicates their year of birth and registers as an underage person, Mlinar will take special care when processing that User’s personal data in the context of its services and offering marketing activities; it will make sure that all information and communication is given using clear and simple language that the child can easily understand.
Mlinar will not collect or process any special categories of personal data within the meaning of Article 9, paragraph 1 of the General Data Protection Regulation (such as information about your health or your religious beliefs).
By providing his/her personal data and by confirming (clicking) to accept the participation terms and conditions and this Privacy Policy on the terms of use of personal data, the User enters into a contractual relationship which serves as the basis for participating in the Mlinar Loyalty program via the Mlinar Loyalty application; consequently, processing of such personal data is legal because it involves taking action at the User’s request in order to participate in the loyalty program.
If he/she wants to, any User registering to participate in the loyalty program can opt to receive product and special promotion information by entering his/her data and selecting the option of consent for marketing purposes in the Mlinar Loyalty application.
Mlinar will not share the User's personal data with any other parties, except in cases defined in the following item and in situations when this is required under law.
When the performance of a contract for the purchase of products and services in accordance with the Customer’s order requires it, Mlinar will share the User’s personal data with the following persons:
1. The service provider for the development of the benefits platform for the Mlinar loyalty mobile application and other executors for the purpose of executing the contract and achieving the purpose, with whom Mlinar has concluded a contract and who are bound by our instructions and over whom we exercise supervision for the purpose of lawful processing of personal data.
2. Sponsors and co-organizers of prize competitions and prize games.
3. Third parties when such processing is necessary to comply with the legal obligations of the controller or for the purpose of performing tasks of public interest (e.g. the Ministry of the Interior, AZOP, etc.)
Data retention period
Mlinar will retain the personal data of registered Mlinar Loyalty application users for as long as the purpose of processing is being performed, which is the period from the moment of the User’s registration in the Mlinar Club app until the moment when the user account is deleted. Mlinar retains personal data of registered Users who wish to receive product and special promotion information for as long as the purpose of processing is being performed or until consent is revoked.
At any time, the User may request and obtain from Mlinar the complete information about the personal data that has been stored by it, or rectification of that data, by sending an e-mail to the address of the data protection officer: zastita.podataka@mlinargrupa.com.
Your Rights
Right of access to data
You have the right to obtain information on whether your personal data is being processed, which categories of personal data are being processed, for what purposes, the recipients or categories of recipients, the expected period for which the data will be stored, and similar information.
Right to rectification
You have the right to request the correction of inaccurate or incomplete personal data concerning you.
Right to erasure (right to be forgotten)
You have the right to request that Mlinar erase your personal data (the right to be forgotten) if your personal data is no longer necessary for the purpose for which it was collected, as well as for other reasons provided for under the General Data Protection Regulation.
Right to restriction of processing
You have the right to request the restriction of processing of personal data in cases where you contest the accuracy of the data, when you consider the processing to be unlawful, when you object to erasure, or when you have lodged an objection to the processing and are awaiting confirmation of whether the legitimate grounds of the controller override the reasons of the data subject.
Right to data portability
You have the right to have your personal data transferred to another data controller.
Right to file a complaint
If, despite all measures taken to protect personal data, you believe you have grounds for a complaint, please contact the Data Protection Officer at the following email address: zastita.podataka@mlinargrupa.com.
Customer and User also has the right to lodge a complaint directly with the supervisory authority, the Personal Data Protection Agency, at the following contacts:
PERSONAL DATA PROTECTION AGENCY (AZOP)
Metela Ožegovića 16, Zagreb
Phone: +385 1 4609 000
Fax: +385 1 4609 099
Email: azop@azop.hr
Website: http://www.azop.hr
In accordance with relevant regulations, Mlinar has appointed a data protection officer who can be contacted in connection with any questions regarding the processing of your personal data or exercising your rights to personal data protection. Contact details: zastita.podataka@mlinargrupa.com.
Changes of the Privacy Policy
Mlinar may change this Privacy Policy and the terms of use of personal data at any time by publishing the amended text of the Privacy Policy, about which you will be notified by a newsletter, push notification, notification or in some other appropriate way. As a result, Mlinar recommends that Users occasionally check this Privacy Policy for changes. If a User disagrees with this Privacy Policy, we instruct such User to exit the Mlinar Loyalty application and not access it or use it anymore.
Measuring app traffic
Our app uses Google Analytics, an analytics service provided by Google, Inc. (“Google”). Information about our app usage will be transferred to Google and stored in Google services servers. More information about Google’s privacy rules can be found at http://www.google.com/privacy.html.