I. Processor Details
Altonomic d.o.o. (hereinafter “Altonomics” or “we” or “us”) is the responsible party for the processing of personal data collected through your use of our website https://nearbalkans.org/ and mobile platform as per the applicable data protection laws, in particular the European General Data Protection Regulation (GDPR).
We have our registered domicile at Putine 25, 10090 Zagreb, Croatia.
For any queries regarding your personal data, please contact us at the following address: firstname.lastname@example.org .
II. How we process your personal data
We only process your personal data if this is necessary to provide a functional website or to provide you with our contents and services. The processing of personal data only takes place based on the appropriate legal basis and as permitted by law.
Legal Basis for Processing under GDPR
Insofar as we are required to obtain the consent of the data subject for the processing of personal data, we will obtain your prior consent and Art. 6 para. 1 lit. a GDPR serves as the legal basis for the processing of the corresponding data.
If the processing of personal data required for the performance of a contract to which you are a party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual services or measures.
Insofar as the processing of personal data is required to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis.
In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6 para 1lit. d GDPR serves as the legal basis.
If processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 para. 1 lit. f GDRP serves as the legal basis.
Duration of Processing
We only store your personal data for as long as necessary to serve the purpose of the processing and we delete personal data or block access to it as soon as such purpose ceases to apply.
Furthermore, personal data may be stored if this has been provided for by the applicable law (for example for book keeping or mandatory archiving purposes). The data will also be blocked or deleted if a storage period prescribed by the applicable law expires, unless there is a need for further storage of the data for the conclusion or fulfilment of a contract.
III. Website Access and Logfiles
Automated Data Processing
Every time you visit our website, our system automatically collects data and information about the computer system you used to access our website.
The following data is collected:
Browser information (type and version)
Your internet service provider
Your IP address
Date and time of access
Websites from which your system reaches our website
Websites accessed by the user’s system via our website
The data is also stored in the log files of our system. This data is not stored together with your other personal data.
For data processing subject to GDPR, the legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f GDPR.
Cookies, tracking and technologies relating to the use of our website
In addition, we also use temporary cookies that are stored on your end device for a specified period of time to optimize user-friendliness. If you visit our site again to use our services, it will automatically recognize that you have already been with us and what entries and settings you have made so that you do not have to enter them again.
Within the scope of the GDPR, the data processed by cookies for the aforementioned purposes is justified in order to protect our legitimate interests and those of third parties pursuant to Art. 6 para. 1 sentence 1 letter f GDPR.
Most browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or a message always appears before a new cookie is created. However, the complete deactivation of cookies can lead to the fact that you cannot use all functions of our website.
We use Google Analytics on our websites. These are services provided by third parties, which may be located in any country (in the case of Google Analytics, Google LLC is based in the US but Google Ireland Ltd. is the data controller for customers based in the EU and Switzerland, for more information visit https://policies.google.com/?hl=en) and allow us to measure and evaluate the use of our website (without identifying individuals). Permanent cookies, which are placed by the service provider, are also used for this purpose. Although such service providers do not receive personal data from us (and do not retain any IP addresses), they may track your use of the website, combine this information with data from other websites you have visited, which are also tracked by service providers, and use this information for their own purposes (e.g. to manage advertising). If you have registered with the service provider concerned, the service provider will also know your identity. The service provider concerned will then be responsible for processing your personal data in accordance with the applicable data protection provisions. Service providers only provide information on how a particular website is used (but not any personal details).
Purpose of Processing
The data is stored in log files to ensure the functionality of the platform. In addition, the data serves us to optimize the website and to ensure the security of our information technology systems.
For data processing subject to GDPR, these purposes are our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR.
Duration of Processing
The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. If the data is stored in log files, deletion occurs after seven days at the latest. Further storage is possible. In this case, the IP addresses of the users are deleted or anonymized.
The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility of objection on your part.
IV. Your Rights
You have the following rights under the applicable data protection laws:
Right of Information
You can request us to confirm whether personal data concerning you is being processed by us
If such processing has taken place, you can request the following information from us:
The purposes for which the personal data are processed;
the categories of personal data being processed;
the recipients or categories of recipients to whom the personal data concerning you have been or are still being disclosed;
the planned duration of the storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage period;
the existence of a right to rectification or deletion of personal data concerning you, a right to limitation of processing by the controller or a right to object to such processing;
the existence of a right of appeal to a supervisory authority;
any available information on the origin of the data if the personal data are not collected from the data subject;
if the processing is subject to GDPR, the existence of automated decision-making including profiling in accordance with Art. 22 para. 1 and 4 GDPR and – at least in these cases – meaningful information on the logic involved and the scope and intended effects of such processing for the data subject.
You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate guarantees in connection with the transmission.
Right to Rectification
You have a right of rectification and/or completion if the personal data processed concerning you are incorrect or incomplete. We shall make the correction without delay.
Right of Restriction
Under the following conditions, you may request that the processing of your personal data be restricted:
if you dispute the accuracy of the personal data concerning you for a period that enables us to verify the accuracy of the personal data;
the processing is unlawful and you refuse to delete the personal data and instead request that the use of the personal data be restricted;
we no longer need the personal data for the purposes of the processing, but you do need them to assert, exercise or defend legal claims; or
if you have filed an objection to the processing pursuant to Art. 21 para. 1 GDPR and it has not yet been determined whether the legitimate reasons of the person responsible outweigh your reasons.
If the processing of personal data concerning you has been restricted, such data may only be processed – apart from being stored – with your consent or for the purpose of asserting, exercising or defending rights or protecting the rights of another natural or legal person or on grounds of an important public interest.
Right to Deletion
a) Obligation to Delete Personal Data
You may request us to delete the personal data relating to you without delay and we are obliged to delete this data without delay if one of the following reasons applies:
The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
You revoke your consent, on which the processing was based pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR, and there is no other legal basis for the processing.
You file an objection against the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate reasons for the processing, or you file an objection against the processing pursuant to Art. 21 para. 2 GDPR.
The personal data concerning you have been processed unlawfully.
The deletion of personal data relating to you is necessary to fulfil a legal obligation to which we are subject.
The personal data concerning you were collected in relation to information society services offered pursuant to Art. 8 para. 1 GDPR.
If we have made your personal data public and are obliged to delete it pursuant to Art. 17 para. 1 GDPR, we shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform those responsible for data processing who process the personal data that you as the data subject have requested the deletion of all links to this personal data or of copies or replications of this personal data.
The right to deletion does not exist insofar as the processing is necessary
to exercise freedom of expression and information;
for the performance of a legal obligation required for processing under the applicable law or for the performance of a task in the public interest or in the exercise of official authority conferred on the controller;
for reasons of public interest in the field of public health pursuant to Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR;
for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 para. 1 GDPR, insofar as the right mentioned under a) is likely to make it impossible or seriously impair the attainment of the objectives of such processing, or
to assert, exercise or defend legal claims.
Right to Notification
If you have exercised your right to have us correct, delete or limit the processing, we are obliged to inform all recipients to whom the personal data concerning you have been disclosed of this correction or deletion of the data or restriction on processing, unless this proves impossible or involves a disproportionate effort.
You have the right to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format. In addition, you have the right to pass this data on to another person in charge without obstruction by us, provided that
processing is based on consent pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. GDPR or on a contract pursuant to Art. 6 para. 1 lit. b GDPR and
processing is carried out by means of automated methods.
In exercising this right, you also have the right to request that the personal data concerning you be transferred directly from us to another data controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.
Right to Objection
You have the right to object at any time, for reasons arising from your particular situation, to the processing of your personal data based on Article 6 para 1 lit. e or f GDPR; this also applies to profiling based on these provisions.
In such case we shall no longer process the personal data concerning you, unless we can prove compelling reasons worthy of protection for the processing, which outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling, insofar as it is associated with such direct marketing. If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
Right to Withdraw Consent
You have the right to revoke your declaration of consent at any time. The revocation of consent shall not affect the legality of the processing carried out on the basis of the consent until revocation.
Right of Appeal to Supervisory Authority
Without prejudice to any other administrative or judicial remedy, you have the right of appeal to a supervisory authority, if you believe that the processing of personal data concerning you is contrary to the applicable law.
This document informs Users about the technologies that help this Website to achieve the purposes described below. Such technologies allow the Owner to access and store information (for example by using a Cookie) or use resources (for example by running a script) on a User’s device as they interact with this Website.
For simplicity, all such technologies are defined as “Trackers” within this document – unless there is a reason to differentiate.
For example, while Cookies can be used on both web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile apps as they are a browser-based Tracker. For this reason, within this document, the term Cookies is only used where it is specifically meant to indicate that particular type of Tracker.
Some of the purposes for which Trackers are used may also require the User’s consent. Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document.
This Website uses Trackers managed directly by the Owner (so-called “first-party” Trackers) and Trackers that enable services provided by a third-party (so-called “third-party” Trackers). Unless otherwise specified within this document, third-party providers may access the Trackers managed by them.
The validity and expiration periods of Cookies and other similar Trackers may vary depending on the lifetime set by the Owner or the relevant provider. Some of them expire upon termination of the User’s browsing session.
In addition to what’s specified in the descriptions within each of the categories below, Users may find more precise and updated information regarding lifetime specification as well as any other relevant information – such as the presence of other Trackers – in the linked privacy policies of the respective third-party providers or by contacting the Owner.
Activities strictly necessary for the operation of this Website and delivery of the Service
This Website uses so-called “technical” Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of the Service.
Other activities involving the use of Trackers
This Website uses Trackers to provide a personalized user experience by improving the quality of preference management options, and by enabling interaction with external networks and platforms.
Interaction with external social networks and platforms
This Website uses Trackers to measure traffic and analyze User behavior with the goal of improving the Service.
Analytics services managed directly by this Website
Targeting & Advertising
This Website uses Trackers to deliver personalized marketing content based on User behavior and to operate, serve and track ads.
Remarketing and behavioral targeting
How to manage preferences and provide or withdraw consent
There are various ways to manage Tracker related preferences and to provide and withdraw consent, where relevant:
Users can manage preferences related to Trackers from directly within their own device settings, for example, by preventing the use or storage of Trackers.
Additionally, whenever the use of Trackers is based on consent, Users can provide or withdraw such consent by setting their preferences within the cookie notice or by updating such preferences accordingly via the relevant consent-preferences widget, if available.
It is also possible, via relevant browser or device features, to delete previously stored Trackers, including those used to remember the User’s initial consent.
Other Trackers in the browser’s local memory may be cleared by deleting the browsing history.
Locating Tracker Settings
Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses:
Microsoft Internet Explorer
Users may also manage certain categories of Trackers used on mobile apps by opting out through relevant device settings such as the device advertising settings for mobile devices, or tracking settings in general (Users may open the device settings and look for the relevant setting).
How to opt out of interest-based advertising
Notwithstanding the above, Users may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.
The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.
Owner and Data Controller
10090 Zagreb, Croatia
Owner contact email: email@example.com
Since the use of third-party Trackers through this Website cannot be fully controlled by the Owner, any specific references to third-party Trackers are to be considered indicative. In order to obtain complete information, Users are kindly requested to consult the privacy policies of the respective third-party services listed in this document.
Given the objective complexity surrounding tracking technologies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of such technologies by this Website.