Privacy policy

Introductory provisions

This Policy applies to all your personal data collected by Intercosmetic Europe DOO Beograd., 175 Pukovnika Milenka Pavlovića, Belgrade (Zemun) 11273, and/or smorodinacosmetics.rs's authorised sellers, customer complaint managers, etc., collectively referred to in this Policy as "smorodinacosmetics", "we", "us" and "our".

At the end of this Policy, you can find the definitions of the key terms and concepts used in this Policy (for example, personal data, processing, data processor, ...).

Who is responsible for the processing of your personal data?

The organisations responsible for processing your personal data are: Intercosmetic Europe DOO Beograd., 175 Pukovnika Milenka Pavlovića, Belgrade (Zemun) 11273;

How to contact us if you have any questions or requests about your personal data? We have appointed a responsible person and created a special contact address for the protection of personal data. This manager processes your questions or requests regarding this Policy or the special Privacy Notice about your personal data and its processing. For any questions, requests or complaints related to the application of this Policy or the exercise of your rights based on this Policy, you can reach the Contact person for Personal Data Protection: Email address: info@intercosmeticeurope.rs

Our Website smorodinacosmetics.rs respects your privacy. Regardless of whether you are a customer, user, member of the public, etc., you have the right to protect your personal data: name, address, telephone number, email address and other data such as IP address, geolocation data, etc. Our General Privacy and Personal Data Protection Policy of the smorodinacosmetics.rs website ("this Policy") describes how we collect your personal data and for what purposes, how we use it, with whom your personal data is shared, how we protect it and what rights and capabilities you have regarding your personal data protection. This Policy applies to the processing of your personal data within the framework of various services, tools, applications, websites, portals, (online) promotions, marketing events, sponsored social media platforms, etc., which are provided or operated, or managed by us or third parties on our behalf. This Policy provides general rules and explanations. For certain services, tools, applications, websites, portals, (online) promotions, marketing events, sponsored social media platforms, etc., offered by the smorodinacosmetics.rs website or operated and managed by third parties on behalf of the smorodinacosmetics.rs website, this Policy may be supplemented with special privacy notices. We will duly notify you of these special privacy notices each time we collect your personal data from interaction with you within the aforementioned activities (for example, on websites, portals, certain communication services, e-news, reminders, surveys, offers, events, etc.).

Key principles:

We appreciate the trust you place in us by entrusting your personal data to us, and we are committed to always processing it honestly, transparently and securely. The basic principles that smorodinacosmetics.rs adheres to when processing personal data are the following:

Lawfulness:

We will collect personal data in an honest, legal and transparent manner.

Minimum amount of personal data (data minimisation):

We will limit the collection of personal data only to those that are relevant and necessary for the purposes for which they were collected.

Purpose limitation:

We will collect personal data only for specific, explicit and legal purposes and will not process them in a manner incompatible with these purposes.

Accuracy:

We will ensure that your personal data is accurate and up-to-date.

Security and protection of personal data:

We will take technical and organisational measures to ensure an appropriate level of data protection, taking into account, among other things, the nature of your personal data that must be protected. These measures include the prevention of any kind of unauthorised disclosure or access, accidental or intentional destruction or accidental loss or alteration, and other illegal forms of processing.

Access and corrections:

We will process your personal data, respecting your right to require the manager to provide access to your personal data, to correct or delete it, the right to restrict processing, the right to object, the right to complain to the Authorised person and the right to transfer data in accordance with the Law.

Data retention period limitation (Storage limitation):

Your personal data will be stored in accordance with the legislation in force on the protection of personal data and only for the time necessary to achieve the purpose for which they were collected, except in cases where you prematurely submit a request for deletion or withdraw your consent to processing. In this case, the provision of personal data is not a legal or contractual obligation, and this is a necessary condition for concluding a contract.

Protection in case of international transfer:

We will ensure that your personal data, if transferred to countries outside the European Area, is transferred in accordance with the law and is adequately protected during the transmission.

Protection of personal data when transferring to third parties:

We will ensure that personal data transfer to third parties and processing by third parties complies with legislation in force and relevant contractual protection measures.

Legality of direct marketing and cookies:

Promotional materials will be sent and Cookies will be installed in accordance with legislation in force.

Processing of your personal data:

What data do we collect and on what legal basis:

It will always be clearly stated what personal data we collect. This information will be provided to you in a separate privacy notice that will be included in certain services.

In accordance with legislation in force on the protection of personal data, we may process your personal data if:

• you have consented to certain processing purposes (as indicated in the privacy notice regarding specific processing). You have the right to withdraw your consent at any time with no explanation; or
• the processing of your personal data is necessary to fulfil the terms of the contract to which you are a party; or
• such processing follows legitimate interests, for example, smorodinacosmetics may process certain personal data in order to prevent abuse or fraud, determine warranty rights, and in some cases measure your satisfaction with its products and services. We will disclose our legitimate interests in a privacy notice related to this particular case of processing; or
• this is necessary to fulfil our legal obligations, for example, regarding the purchase you have made (payment, place of receipt and reception date, etc.), or while handling complaints, returning goods purchased at a distance, servicing, exercising other consumer rights related to defects or warranty.

The purposes of processing your personal data and profiling

We process your personal data only for specific, explicit and legal purposes and will not process it in a manner incompatible with these purposes.

Keeping your personal data accurate and up-to-date

It is important to us that your data is always accurate and up-to-date. Please inform us of any changes or errors in our records of your personal data by contacting us through the Personal Data Protection Contact person. We will take reasonable measures to delete or rectify all incorrect or expired personal data.

Access to your personal data

You have the right to access your personal data that we process, and if your personal data is incorrect or incomplete, you can request to correct or delete your personal data.

Data retention period

We store your personal data in accordance with the legislation in force on the protection of personal data. Your personal data is stored only for the time necessary to achieve the purpose for which we process your personal data, for the period prescribed by law or for the period necessary to fulfil the terms of the contract, including warranty requirements and other possible requirements. The personal data that we process on the basis of your consent is stored permanently, until you withdraw your consent, except in cases where the purpose for which your personal data was collected was achieved earlier.

Protection of your personal data

We implement technical and organisational security measures to protect your personal data from illegal or unauthorised access or use, as well as from accidental loss or destruction. These measures are implemented based on our IT infrastructure, the potential impact on your privacy and the cost of implementation, as well as in accordance with current standards and practices in the field of data protection. We entrust the processing of your personal data only to Authorised persons (third parties) who comply with the aforementioned technical and organisational measures for the protection of personal data.

Ensuring data protection means preserving the confidentiality, integrity and availability of your personal data.

• a) Confidentiality: We will protect your personal data from unacceptable disclosure to third parties.
• b) Integrity: We will protect your personal data from alteration by unauthorised third parties.
• c) Availability: We guarantee that only Authorised persons can access your personal data when necessary.

Our security procedures include:

access protection, backup systems, monitoring, audits and maintenance, security incident management and continuous operation, etc.

Transfer of personal data

With regard to the purposes of collecting your personal data, we may transfer, disclose or provide access to the categories of users listed below who process this data in accordance with the purpose in question. We require that they always comply with legislation in force, personal data protection rules and pay special attention to the confidentiality of your personal data.

A separate interaction with sellers and service centres

If you contact an authorised service centre or importer directly about the product that you purchased from us, or thereby transfer your personal data to them, a separate relationship is established between you and this importer or service centre. In this case, these authorised merchants or service centres become the processors of your personal data. If you have any questions or requests regarding the use of your personal data collected for this purpose by an authorised importer or service centre, please contact them directly.

Social media use

If you log into smorodinacosmetics tools (website, portal...) through social media (for example, using your Facebook account), smorodinacosmetics will record your personal data available on these social networks, and your use of these networks means that you explicitly agree to the transfer of your personal data that was recorded by smorodinacosmetics using its tool. These social networks have their own terms of use that you must follow while using them.

Your capabilities and rights

We want to be as transparent as possible, so we offer you the opportunity to choose how to use your personal data.

Your options for choosing the contact method

You have various options to choose the way you want us to contact you (for example, by email, mail, social media, phone, etc.). You will be able to make a choice by leaving your contact details in the corresponding form, setting up privacy settings on your device, or updating your user profile or account by following the opt-out instructions provided in the notification. If you have left several contact details without explicitly choosing the method of communication, you will receive our promotional and other communications in the usual manner for publication, to the extent permitted by law.

Your personal data

You can always communicate with us by reaching the Contact person for Personal Data Protection (see section 3 "Who can you contact if you have questions or requests?"), if you want to know which of your personal data we process and its source. Under certain conditions, you have the right to receive the personal data that you have provided to us in the most common structured readable form, as well as the right to transfer this personal data to any third party of your choice.

Corrections

If you find an error in your personal data or if it seems to you that your data is incomplete or inaccurate, you can make a request to have your data rectified or complemented.

Limitation of processing

You have the right to request a restriction on the processing of your personal data.

Your objections

You can object to the processing of your personal data for direct marketing purposes (if you want, you can tell us through which channel and how often you want us to contact you) or to the transfer of your personal data to third parties for these purposes. Your consent can be revoked by a written statement or notification that you send to us by e-mail to the Personal Data Protection Contact person or by using a different method of communication indicated on smorodinacosmetic_rs. Refusal or withdrawal of consent to the processing of your personal data does not carry negative consequences or sanctions and is completely voluntary. However, after withdrawing your consent to the processing of your personal data, smorodinacosmetics may not be able to provide the user with one or several of its services, which cannot be provided without the use of personal data. You also have the right to file a complaint with the Authorised Person in accordance with the law.

Data deletion

You can also request that we delete all your personal data (except in certain cases, for example, to prove a transaction or if it is needed to comply with the law).

Legal information:

The provisions of these rules supplement and comply with the legislative provisions in the field of personal data protection. In case of inconsistency between the provisions of these rules and the legislative provisions in the field of personal data protection, the legislative provisions apply despite these rules. smorodinacosmetics.rs has the right to change these rules at any time. You can check these rules on our website and thus find out about the changes made.