Care for our clients is the guiding light of all our visions for future development, while the feelings of trust and security we aim to impart are continuously added on and improved. This guarantees the market reputation we are building. EU data protection regulation has enabled us to develop an uncompromising system of careful custody over information with which our clients have entrusted us. You can rest assured that our Privacy Policy means your data is looked after in accordance with the very highest standards of security and expertise. Please take a moment to familiarize yourself with our new Privacy Policy: LET’S BUILD TRUST TOGETHER.

Through this Internet Privacy Policy Tommy d.o.o. based in Split, 93 Domovinskog rata (also: Tommy) protects the privacy of its clients and expresses care for their personal information as per the General EU Data Protection Regulation 2016/679/EU (also: Regulation) and the Croatian General Data Protection Regulation Implementation Act NN 42/2018. This Internet Privacy Policy is Tommy’s transparent and public declaration of the manner of personal data processing strictly in accordance with the Regulation. The privacy of our clients and the protection of their personal information are our guiding principles. We adhere to the following principles in order to protect your privacy:

• We collect no more information than is necessary,
• We only use your information for the purposes declared,
• We store your information no longer than needed, and for as long as we have a legitimate interest in doing so,
• We never sell, loan, distribute or publicize your personal information,
• We allow no third party to access your information without informing you
• We do not use profiling as part of our automated data processing, nor does that processing include analytical and predictive techniques regarding your preferences and behavior,
• We do not transfer your personal information outside the EU,
• We make every reasonable effort to ascertain that your personal information is stored securely.

It is important that you read and understand our Internet Privacy Policy, and we hope you will spare us your time and attention. We have made efforts to declare everything as clearly as possible, wishing to be fully understood by all, and hoping to retain your full confidence regarding the actions we take with your personal information.

According to the Regulation, personal information is any and all information pertaining to an individual whose identity is or can be determined, whereas this “Individual” is defined by the Regulation as any person identifiable directly or indirectly.

According to the Regulation, processing means any action or set of actions performed on personal information and sets thereof, whether automated or non-automated, such as gathering, record keeping, organization, structuring, storage, adjusting or changing, archival browsing, querying, investigating, use, discovery via transfers, publishing or otherwise making available, coordinating or combining, limiting, erasure and deletion.

Tommy gathers personal information which you make available to us of your own volition. The information is gathered through Internet newsletter sign-up forms, as well as support staff contact forms. The information is gathered for the purpose of contact initiation and for other purposes for which you have given us express consent. A part of the information is gathered automatically through the use of web cookies, explained in detail below.

Your personal information is used for the purposes listed above. Our processing involves sharing your information with renowned outside processors, who have brought their operations fully in line with the Regulation. To give you a better user experience, we partner with the Remake marketing agency, as well as Google and Facebook.

We use web cookies on our Internet pages. These represent information stored onto a personal computer or mobile device as you browse our pages. Their purpose is to customize our pages in order to give you the best user experience possible, and to enable our pages to function as an effective source of useful information. The cookies we use fall into two basic categories:

• functional cookies which enable the customization of your browser interface—fully anonymously,
• additional cookies which enable the customization of our marketing activities—used exclusively following your express consent.

Having obtained your consent, we aim to learn the interest of Tommy website visitors for the purposes of tracking client interest in certain services. This enables us to present you with marketing messaging tailored to your interests. Additional cookies we use are Google AdWords and Facebook cookies. We restrict ourselves to using only aggregated data. Additional information regarding web cookies can be found at the address https://www.aboutcookies.org.uk/ You can disable cookies at any time by adjusting the settings of your browser software.

Your personal information will be stored and processed in accordance with the Regulation. Tommy continues to take all reasonable technical and organizational steps to maintain the security of your information, and the same expectation is placed before all external processors. Access to your personal information is limited in order to prevent unauthorized access, tampering or abuse.

We strive to enable you to make decisions regarding the processing of your personal information. You retain the following rights:

You have the right to know whether we are processing your information and, if so, obtain access to this information. In case we are processing a large amount of information about you, we may ask you to specify which group or groups of information you wish to access.

In case you notice we are processing your personal information which is incorrect or incomplete, you have the right to ask that we correct or complete this information. To ensure we always process correct and up-to-date personal information, please let us know of any changes therein without delay.

You may ask us to delete your personal information, for example if you have withdrawn your permission for this information to be gathered and processed, or if your personal information is being processed in an unlawful manner, or when your information is no longer necessary relating to the purposes for which it was gathered or processed, regardless of methods used. However, please consider that we may not be able to comply with your information deletion request if your information is needed to fulfill legal or contractual obligations, or if we have another legitimate interest for retention as per the General Data Protection Regulation.

You have the right to limit the processing of your personal information, which you can exercise if, for example, you object to this processing, or if you doubt the accuracy of the information being processed, or in the lawfulness of this processing, but you do not wish the information deleted, or you still need the information for legal purposes.

If processing is based on your consent or is performed for the purpose of executing a contract you have made while being fully automated, you have the right to receive in return all personal information we have gathered about you. At your request we will transfer your personal information directly to an outside processor if this is technically feasible.

At all times you retain the right to object to the processing of your personal information, resulting in limitations on this processing. This also means that we will delete and stop processing your information, unless if we can prove a justified legitimate interest for the retention and further processing of this information. Additionally, you may at any time object to your personal information being processed for the purposes of direct marketing. Following your objection, your personal information will no longer be used for this purpose.

If you feel the processing of your personal information is contrary to the General Data Protection Regulation, you have the right to file a complaint with the appropriate regulatory body. In the Republic of Croatia this body is the Personal Information Protection Agency (Croatian, Agencija za zaštitu osobnih podataka) with its seat at 136 Selska cesta, 10000 Zagreb, Croatia, website: https://azop.hr, telephone: +385 1 4609 000.

If your personal information is processed on the basis of freely given consent, you have the right to withdraw this consent at any time, with no consequences whatsoever. This right can be exercised by:

Registered mail labeled “Data protection”, or

In person during business hours of 8 AM to 3 PM on weekdays at

Tommy d.o.o.

93 Domovinskog Rata

21000 Split

Croatia

Additional information regarding your rights concerning personal information may be obtained by emailing:

zastita-podataka@tommy.hr

Note: the identity of a person making such requests must be ascertained.

if using registered mail, please attach a legible copy of your identification documents, as well as a letter of authority if applicable

if you are coming in person, please have identification documents with you, as well as a letter of authority if applicable

Identification documents are necessary to protect you as the owner of your personal information.

Any additional queries may be sent by regular mail to the address:

Tommy d.o.o.

93 Domovinskog Rata

21000 Split

Croatia

Labeled “Data protection”

Document updated December 1, 2019.