Franck d.d. Vodovodna 20, VAT No.: 07676693758 (hereinafter referred to as Franck), as the controller, processes and protects personal data concerning the users of its services and visitors of www.franck.eu, www.shop.franck.eu and the related microsites in accordance with the regulations applicable to personal data protection.
Provided below please find information about the treatment of personal data collected from users of the website and webshop, consumers, job applicants, contractors and participants in prize contests, competitions and other similar activities, which we collect through this website or otherwise.
Access to our website is free and requires no registration. If you would like to receive a newsletter about our offerings, new contents of our website, prize contents or competitions, you can simply select to register your e-mail address using the relevant form and become duly subscribed. An e-mail confirmation of user’s subscription to the newsletter will be sent to the e-mail address registered by the data subject before the newsletter is sent for the first time, for double authentication purposes. Such confirmation is used to demonstrate whether or not the e-mail owner, being a data subject, agrees to receive the newsletter. The personal data collected as part of subscribing to the newsletter will only be used for the purposes of distributing our newsletter.
If you would like to receive any personalized content at your e-mail address, you can provide your personal data, i.e. give your consent to personalize the newsletter content based on your interests, age group and gender. For that purpose, you need to provide the following personal data: full name, date of birth, gender, and interests.
To manage newsletter subscriptions and distribution, Franck uses the Webpower Adria d.o.o. platform and services of 404 d.o.o., Radnička cesta 37a, 10 000 Zagreb, which acts pursuant to its contract with Franck as the processor, solely as instructed by us, and takes all necessary data protection measures. Mailchimp registers instances of newsletter opening and link clicks to offer statistical information on which contents are interesting to newsletter subscribers.
You can opt out of the newsletter at any time by selecting the option of withdrawing your consent within the newsletter received or by using the email@example.com contact address provided for privacy and personal data protection matters. If you withdraw your consent, this shall not affect the lawfulness of the processing completed prior to such withdrawal. Receiving of the newsletter is voluntary and the data subject shall not be responsible for any adverse consequences if he denies or withdraws his consent.
In case you withdraw your consent, you will no longer receive our newsletter and the canceled e-mail addresses will remain on our unsubscribe list for up to 5 years following the opt-out date to demonstrate Franck’s compliance with the obligations imposed on it under the applicable law.
Buyers’ personal data provided at the time of purchasing shall be processed for the purpose of performing the contract, including prior verification of the conditions precedent to entry into the contract, and for the purpose of conducting the payment transaction and delivering the product.
Personal data shall also be processed for the purpose of preventing any abuse, fraud, and for the purpose of informing buyers of news and offerings, subject to Seller’s legitimate interest and in compliance with the Electronic Communications Act.
Buyers are required to provide accurate, current and complete personal data. In case this obligation is violated, Franck may deny such user access to or refuse to supply him with all or part of the services and products offered by it. The provision of the service is conditional upon the processing of personal data for contract performance purposes, which may as such not be restricted or revoked. In case the buyer refuses to provide his personal data, which are marked as mandatory, he shall not be able to enter into contract or make any purchase.
The Seller shall not disclose or transmit any buyers’ personal data except for the purpose of performing the product purchase contract (which pertains to financial institutions through which payments are made, suppliers of the purchased product for accounting, supply and delivery purposes, and persons responsible for maintaining the IT system used to conduct purchase transactions), protecting buyers’ interests, and to prevent any abuse. Such personal data shall also be provided to the competent authorities if so required by them by operation of the law. Personal data shall be retained for the period defined by the applicable law, which is presently up to 11 years following the expiry of the year in which the transaction is performed.
For any questions or complaints regarding the webshop, buyers may contact the Contact Center at firstname.lastname@example.org or at 01 3710 300.
The legal ground for data processing is a legal obligation because Franck is required to communicate with its consumers and respond to complaints and instructions in accordance with the applicable law. In case you refuse to provide your information, we will not be able to handle your complaint or query. Personal data shall be retained for up to 5 years following their receipt date.
4. Queries and complaints
Our website contains forms and information that will allow you to contact us quickly and you can also communicate directly with us using the 0800 33 44 33 toll free line every day between 8 a.m. and midnight or contact us at email@example.com.
Our contact center partner Margon Media d.o.o., Avenija Većeslava Holjevca 60, 10 000 Zagreb, is responsible for such direct communication and provision of information and this company acts as the processor under its agreement with Franck, acts solely as instructed by us and takes all necessary data protection measures.
If a user contacts the controller or processor by e-mail or using a contact form, the personal data submitted by him will be automatically stored and processed exclusively for the purpose of providing the requested information. The legal ground for data processing is a legal obligation because Franck is required to communicate with its consumers and respond to complaints and instructions in accordance with the applicable law. In case you refuse to provide your information, we will not be able to handle your complaint or query.
The personal data necessary to resolve a complaint shall be retained for up to 5 years following their receipt date, in compliance with the regulations applicable to consumer rights.
5. Open job applications
Franck receives open job applications through its e-mail address specified on the website. For this purpose, the processing involves the personal data of a job applicant which he voluntarily specified in the application and CV (full name, date of birth, contact particulars, prior work experience, professional qualifications, education degree, photograph). The same e-mail address is used to receive job applications from students for job vacancies advertised via the Student Service.
Such open applications are received by an employee of the Human Resources Department who saves them in the relevant folders within the information system. Only authorized persons and processors authorized by Franck for providing IT support are allowed access to open job applications.
The data you send us through open job applications are processed based on legitimate interest and solely for the purpose of recruiting new employees, and are retained for 12 months.
6. Job vacancies
In the course of the recruitment process, the job description is defined and a job vacancy is published using the relevant service providers for the purpose of recruiting new employees. Depending on the job description, job vacancies are advertised through different facilities. All data are collected and processed in TalentLyft.
Franck receives job applications and, for this purpose, the processing involves the personal data of a job applicant which he voluntarily specified in the application and CV (full name, date of birth, contact particulars, prior work experience, professional qualifications, education degree, photograph). Depending on the job description, Franck also conducts professional and psychological tests and interviews for the purpose of selecting job applicants.
Such data are retained until the job vacancy is finalized, but no more than one year following the finalization date of the job vacancy, provided that if a candidate’s data are desired to be retained for another job vacancy, consent must be obtained from such candidate. Participation in job vacancies is voluntary and candidates’ data are processed as activities preceding the execution of an employment contract.
If a candidate gives his consent to the retention of his data after the job vacancy is completed, such data may be retained for up to 2 years. If a candidate voluntarily provides his data for future job vacancies, he may at any time withdraw his consent without suffering any adverse consequences. Such withdrawal of consent does not affect the lawfulness of the processing completed up to the time of such withdrawal.
Only authorized persons are allowed access to data concerning job applicants. Psychological tests are conducted by a person duly licensed to conduct psychological tests and the interview with the psychologist and psychological tests are conducted in accordance with the applicable law.
7. Promotional prize contests and prize competitions
We occasionally organize prize contests and prize competitions. We only process the personal data collected as part of this for the purpose of conducting such contest or competition (e.g. publication of the winners’ names for the purpose of contacting them, delivering the prizes, etc.). To allow you to participate in a prize contest or competition, we need your full name, e-mail address, contact phone, and your address for prize delivery. If necessary, we may request further information as defined by the rules of the prize contest or competition (e.g. your account number). Participation in such prize contests and competitions is voluntary. If a participant refuses to provide his personal data, he will not be able to participate in the prize contest or competition.
The participant may withdraw his consent to participate. Such withdrawal of consent will not affect the lawfulness of the processing completed up to the time of such withdrawal.
We will erase the data collected 12 months after the prize contest or competition is completed. We retain the information and written report concerning the winners in accordance with the relevant accounting regulations (we are presently allowed to retain them for 11 years following the end of the relevant year). We forward such data to our processors with whom we have processing contracts in place and to postal service providers.
In all prize contest or prize competition rules we explain in detail how personal data are processed and the participant is invited to consult the privacy policies of the social networks where a particular prize competition is announced.
If you agree to receive our newsletter in a prize contest or competition registration form, you can opt out of the newsletter at any time by selecting the option of withdrawing your consent within the newsletter received or by using the firstname.lastname@example.org contact address provided for privacy and personal data protection matters.
8. Data tracking – Cookies and web analytics
Franck stores “cookies” in your computer, which contain information about the user and are used to save user’s time while using Franck’s website and for the purpose of tracking and directing user’s interests and providing services adapted to each user.
Many cookies contain the so-called cookie ID. Such cookie ID is a unique identifier of the cookie. It comprises a series of characters whereby websites and servers may be assigned to a specific web browser in which the cookie is stored.
By using cookies, Franck is able to provide users of its website with a user-friendly experience that would not be possible to achieve without using cookies. Once the user accesses the website, the cookie is stored in the user’s computer system.
Necessary cookies (e.g. cookies used to register a product in the cart) are stored for the purpose of providing a service at user’s request, whereas the storage of any unnecessary cookies (e.g. cookies for advertising and analytics or functional cookies) requires data subject’s consent which may be given using the cookie management window.
Below please find a description of the cookies we use on the website:
|Name of cookie||Duration of cookie||Purpose||More information||Website / microsite||Classification|
|_ga||2 years||User by Google Analytics to differentiate users.||Google Analytics Cookie Usage||.franck.eu; .jubilarna.franck.eu||Statistics|
|_gat_UA-56115183-11||2 minutes||User by Google Analytics to differentiate users.||Google Analytics Cookie Usage||.franck.eu||Statistics|
|_gat_UA-56115183-1||1 minute||User by Google Analytics to differentiate users.||Google Analytics Cookie Usage||.franck.eu||Statistics|
|_gat_UA-56115183-12||2 minutes||User by Google Analytics to differentiate users.||Google Analytics Cookie Usage||.franck.eu||Statistics|
|_gat_UA-56115183-13||2 minutes||User by Google Analytics to differentiate users.||Google Analytics Cookie Usage||.franck.eu||Statistics|
|_gid||24 hours||Used for user identification.||Google Analytics Cookie Usage||.franck.eu; .jubilarna.franck.eu||Statistics|
|csrftoken||xx||xx||xx||bianka.franck.eu; capsules.franck.eu||Mandatory cookies|
Depending on the user's settings, Google services via YouTube may also use other cookies, such as the VISITOR_INF01_LIVE cookie for advertising.
The user may at any time disable cookies on our website by selecting the relevant setting of the web browser being used, and may thus permanently disable cookies. Furthermore, enabled cookies may be erased at any time using the web browser or other software. If the user disables cookies in the web browser used, all functions on our website may not be fully available.
Please note that you can disable Google Analytics for advertising on the display network and adjust ads for Google Display Network using the Ad Settings Manager tool (http://www.google.com/settings/ads).
Franck collects information that does not identify a specific end user, including the URL (Uniform Resource Locator) of the page visited by the user after leaving Franck’s website, the type of browser used by the user, and anonymized user’s IP address (Internet Protocol Address). Authorized service providers and advertisers may automatically collect such information when you visit Franck’s website or by using cookies or other tools. Franck only uses such information for problem solving, to administer its website, to analyze trends, to collect demographic information, to analyze its compliance, or in cooperation with the relevant law enforcement authorities. Personal data is transferred outside the EU/EEA based on standard contractual clauses for the transfer of personal data to third countries approved by the European Commission.
9. Social networks
10. Business cooperation
Franck processes personal data of its business partners and personal data provided to Franck by its business partners, which are necessary for the uninterrupted conduct of daily business, invoicing and performance of legal and contractual obligations (e.g. directors’ and contact persons’ names, IBAN, PIN).
Franck processes data for the purpose of undertaking its commercial activities, selecting contractors and entering into and performing contracts. Data will be processed for the purpose of performing legally defined obligations (including tax and accounting obligations, obligations arising from public tendering or occupational safety regulations, for supplier qualification purposes), for contract administration, for receiving goods and/or services, for the conduct of judicial proceedings, for internal audit purposes (security, productivity, product quality, preservation of financial integrity), for management control purposes, and for certification purposes. The processing of data for such purposes requires no consent from the data subject because the legal ground for such personal data processing is a contractual obligation/pre-contractual measures. Such collection of data is required because otherwise Franck will not be able to enter into contract or duly perform its relevant obligations.
11. Recording or photographing of events
Subject to legitimate interest, we record and photograph public events we organize or participate in as a sponsor. For such purpose, we publish on our website and social networks photographs and recordings of people participating in such events. For the purposes of such recording and photographing, we engage processors acting as instructed by us.
No consent is required for this purpose because such photographing and recording does not override data subjects’ rights and freedoms, for example, if no publicly exposed person is involved, if a person is photographed merged in a group of other people, and certain photographs may be blurred or trimmed to achieve a balance between our legitimate interest in promoting our events and data subjects’ rights.
12. Data export
Franck forwards personal data to its processors. Franck conducts investigations in the process of selecting its processors and checks that they use adequate controls to protect personal data. Franck enters into a processing contract with each processor. Data are exported from the EU/EEA with the conclusion of standard data protection clauses approved by the European Commission.
Such personal data may, subject to the purposes specified above, be disclosed to:
- entities that need them to fulfill an order, deliver a parcel, send mail and e-mail, analyze data, process payments, or provide customer services, being our consultants;
- processors providing or maintaining IT solutions;
- law enforcement authorities and other public authorities if required by the applicable law or in good faith (e.g. to inform them of our compliance with the relevant legislation, to protect and defend our rights or property; or to have them act to protect service users’ personal safety in an emergency).
- Cloudinary platform for saving and processing images for websites. Images are stored on Amazon servers owned by Cloudinary. Personal data is transferred outside the EU/EEA based on standard contractual clauses for the transfer of personal data to third countries approved by the European Commission.
- Google for the purpose of updating and enabling Google fonts on the page in case a certain font is not stored locally on our server. For this purpose, Google processes certain data, such as the IP address of the user of the site and makes requests from third parties on the site. Personal data is transferred outside the EU/EEA based on standard contractual clauses for the transfer of personal data to third countries approved by the European Commission.
13. Personal data protection measures
Franck implements appropriate technical and security measures for the purpose of ensuring the security and confidentiality of personal data and to prevent any unauthorized access to or unauthorized use of personal data or any technical equipment used by Franck. In case of a security incident, which is considered to be a personal data breach under the General Data Protection Regulation, Franck will conduct a risk assessment and, based on its results, take the necessary actions and notify the supervisory authority and data subjects.
To be able to take the necessary technical and integral data protection measures in our business, we:
- ensure, based on advice from our data protection officer, that only the personal data necessary for each purpose are processed according to the relevant settings;
- check whether or not the processing may represent high risk to data subjects’ rights and freedoms and, if necessary, conduct a data impact assessment;
- control the export of data from the EU to be able to adopt the appropriate security measures;
- verify processor’s technical and organizational measures; and
- analyze the risk of personal data breach and act in compliance with the General Data Protection Regulation (notification of the supervisory authority and data subjects).
14. Data subject’s rights
The data subject may at any time request from us information about the processing of his personal data and may, subject to the applicable law, request to exercise the following rights:
- right of access to personal data;
- right to rectification or supplementation of personal data;
- right to data erasure;
- right to restriction of personal data processing, for example, if the accuracy of the personal data is challenged and verification is necessary;
- right to withdraw consent to data processing;
- right to object to the processing of his personal data; and
- right to lodge a complaint with the Personal Data Protection Agency at www.azop.hr.
15. Applicable law and transfer of assets