This Privacy Policy is issued by Sport Vision doo, Croatia, Zagreb, Bani 75, OIB: 30098672140, (“Privacy Policy”).
1. Definitions, purpose and scope of application of the Privacy Policy
” Sport Vision ” or ” we ” means the company Sport Vision doo, OIB: 30098672140, with its registered office at Bani 75, 10000 Zagreb, Croatia, registered with the Commercial Court in Zagreb MBS 030126201.;
” Online Stores ” means the online stores operated by Sport Vision as part of its business activities, in particular www.buzzsneakers.hr/ and www.sportvision.hr/ , individually referred to as the “Online Store”;
” Websites ” means the Online Stores and other websites operated by Sport Vision to support the operations of the Online Stores, individually referred to as “Websites”;
” User “, ” You ” means you, the user of the Website (any natural person);
” Related Services ” means services or functionalities provided or shared by Sport Vision or third parties, including services provided under specific terms and conditions, that support Sport Vision’s core activities or facilitate users’ use of Sport Vision’s Services or functionalities, for example by providing same-day delivery or via parcels;
” GDPR ” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals 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);
” Agency ” means the Croatian Agency for Personal Data Protection (AZOP);
” personal data ” means all data relating to an identified or identifiable natural person, directly or indirectly (e.g. name, surname, date of birth, location data, IP address, etc.);
” processing of personal data ” means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automatic means, such as collection, recording, organisation, collection or structuring, storage, alteration, disclosure, use, reproduction, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (” processing” );
” profiling ” means any form of automated processing used to evaluate certain personal characteristics, in particular to analyze or predict the actions, economic situation, health, personal preferences, interests, reliability, behavior, location or movements of a natural person;
” data controller ” means the person who determines the purpose and manner of processing personal data;
” processor ” means any natural or legal person who processes personal data on behalf of the controller.
We care about the protection of your personal data and therefore ask you to read this Privacy Policy carefully to familiarize yourself with the method and scope of processing, what personal data we process, how we use it, for what purpose we process it, how long we keep it, and what rights are available to you in relation to the processing of personal data.
The purpose of this Privacy Policy is to determine the scope and legal basis for the processing of your personal data that we collect in connection with your use of the Website and Related Services, and to define the measures that Sport Vision takes to protect your personal data.
We receive your personal data from you when you create an account, in connection with your activities (including transactions) on the Online Stores, when viewing offers and in connection with updating your account information. The processing of personal data may also be associated with a number of other activities that you perform that are directly related to your use of the Websites and Related Services. We may receive information about your shipments directly from the carrier. If you use the Related Services, your personal data may also be provided to us by third-party suppliers that offer the Related Services.
This Privacy Policy applies only to the collection and processing of data through the Websites, as well as when you use our online services. In relation to the data that we collect and process in another way, please contact us by e-mail at online@sportvision.hr or by sending a written request to the address Sport Vision doo, Hrvatska, 10000 Zagreb, Bani 75.
We will not use or share your personal information for purposes unrelated to the purposes described in this Privacy Policy without notifying you and, if necessary, giving you the opportunity to decide whether we may use your personal information in that way.
You are responsible for the accuracy and truthfulness of all information you have provided or that you provide to us and you guarantee that you will manage your user account personally.
If you do not agree with our Privacy Policy, please stop using the Website immediately and do not provide us with your personal information.
In the event that the website contains links to other websites, please familiarize yourself adequately with the privacy rules contained on those pages and the way in which these persons process your data. Sport Vision has no control over the content of other websites and cannot be responsible for the protection of your privacy when visiting them.
Sport Vision, as the controller of personal data within the meaning of the GDPR, determines the purpose, basis and method of processing your personal data.
2. Scope, purpose and legal basis for processing personal data and retention period
The scope of personal data we process may vary depending on the services and functionalities of the Websites you use. To help you understand what personal data we process, we have provided information below on the types of data we process, categorised according to the functionalities and purposes of processing.
For each of the processing purposes, we have defined the legal basis for processing and the period for which we will retain your personal data. We will retain your personal data for as long as it is necessary for the purpose for which it is processed. Once the purpose has been fulfilled, we will permanently delete or make it inaccessible (i.e. anonymize) unless we are required to retain it by law or there is another applicable legal basis for further processing. The criteria for determining the period for which we retain your data are: (i) legal obligations and (ii) where applicable, criteria for implementing and resolving requests you have made to us.
For example, when you delete your user account, we will no longer process your personal data to provide services and functionality of the user account, but we will store your personal data for the period permitted by law to enable you to exercise your rights and to enable viewing of the transaction history between you and us.
In the event that the processing is based on your consent to the processing, and you withdraw your consent to the processing, we will permanently delete that personal data, unless we are required by law to retain it.
2.1 Visiting the Website
When visiting the Website, the browser you use on your device automatically and without your action sends to our website server: the IP address of the device from which the request was sent and which has access to the Internet, the date and time of access, the name and URL of the downloaded content, the website from which it is accessed (referrer URL), the browser you use and, if necessary, the operating system of the computer that supports the Internet, as well as the name of your service provider. This data is temporarily stored on the server in a so-called log file.
We process your personal data in accordance with the rules described in the table below regarding your access to the Website. Your personal data may also be processed for other purposes, which you will learn about in the further sections of this Privacy Policy .
| Data type | Purpose of processing | Legal basis for processing | Retention period |
|---|---|---|---|
| IP address | Establishing an uninterrupted connection and easier use of the website, and assessing the security and stability of the system. | Our legitimate interest arising from the purpose (Article 6..para.1., point f) GDPR) | During a visit to the website |
2.2. Establishment, use and defense of claims
We may process your personal data in connection with our right to establish, exercise or defend claims arising from a contract between you and us or related to your use of the services or functionalities we provide, Online Stores or Related Services. The scope and type of data may vary depending on the content of the claim.
We process your personal data in accordance with the rules described in the table below in relation to the establishment, use or defence of claims. Your personal data may also be processed for other purposes, which you will learn about in further sections of this Privacy Policy.
| Data type | Purpose of processing | Legal basis for processing | Storage period |
|---|---|---|---|
| Identification data, information about a specific order or offer, transaction details | Establishment, exercise or defense of a claim | Our legitimate interest in establishing, exercising or defending claims to which we are entitled (Article 6(1)(f) GDPR) | Generally, until the end of one year from the onset of the statute of limitations (5 +1 years), unless objectively necessary for a longer period (e.g. to continue legal proceedings) |
2.3. Data that we do not process
We do not intentionally process data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, biometric data for the purpose of uniquely identifying individuals, health data or data concerning sex life or sexual orientation.
If there is a need to process any of the above personal data, we will always need your explicit consent.
3. Cookies, technologies and profiling
3.1. Cookies
Many websites use small text files called cookies that can be stored on your device and your browser can store them.
4. Access and transfer of personal data
4.1. Persons with access to personal data
We consider your personal data to be a trade secret and as such we protect it in accordance with applicable legal regulations and best practices. We store it on servers within the European Union.
Within Sport Vision, access to the data you have made available to us is only available to those organizational units, or those employees who need it to fulfill the purpose for which the personal data was collected in order to perform their work tasks. Employees who have access to personal data are obliged to maintain the confidentiality of the data.
We process your personal data, while third parties have the right to access and process your personal data only to the extent necessary.
Third parties act on our behalf as processors. In these cases, third parties may use your personal data solely for the purposes set out above and solely in accordance with our instructions. In this case, only the data necessary to achieve the purpose of the contracted processing is provided to the processor, and the processor may not use it for other purposes. In these cases, the terms of data processing and the responsibility for data protection will be defined in the contract between us and the processor.
The persons who have access to your data are our business partners who help us in regular business, namely:
- providers of cloud IT platforms on which data is stored and partners in the maintenance and development of IT platforms who ensure the implementation of new functionalities on the systems and the proper functioning of the systems;
- partners engaged in data analysis for Sport Vision and within the business process for sending personalized offers, identification of target groups, etc.;
- communication service providers that enable the exchange of data through various communication channels (telephone, e-mail, social networks, etc.) with the aim of informing customers about the status of their order and sending marketing offers and notifications;
- partners who provide technical support in the Sport&Bonus loyalty program, who have access to the records of members of the Sport&Bonus loyalty program;
- the courier services that deliver our goods have access to the data necessary for delivery (name and surname, address, phone number);
- persons with whom we cooperate to protect our rights and interests (lawyers, accountants, insurance companies, advisors, etc.) have access to personal data only to the extent necessary to protect our rights;
- competent authorities when conducting supervision over the legality of business and actions, as well as other legal entities when it is necessary to fulfill some of our legal obligations, e.g. auditor. In that case, these legal entities process your personal data for the purpose assigned to them by law;
- other persons in connection with business transactions such as the sale of the company or a portion of the company, a reorganization, merger, joint venture or any other type of disposition of our company, assets or stock (including bankruptcy or similar proceedings);
- suppliers in situations where we cannot respond to your inquiry independently, and we need the supplier’s assistance, with your prior consent.
Third parties are limited in their ability to use your personal data for any purpose other than those listed above, and are required to protect and process your personal data in accordance with legal, regulatory and contractual obligations.
All legal entities we cooperate with are very carefully selected and are contractually obligated to maintain the confidentiality of personal data and adopt all other mandatory requirements, in accordance with Article 28 of the GDPR. We may also share your personal data with other members of the SV group of companies based on the legitimate interest of the SV group.
4.2. People with whom Sport Vision shares personal data
In principle, we do not transfer your data to third parties unless we have a legal obligation to do so (e.g. at the request of a criminal prosecution authority) or if we need your data to perform business activities or within the framework of the execution of a contract, as stated above. In all these cases, we strictly comply with the legal provisions. We may also share your personal data with other members of the SV group of companies based on the legitimate interest of the SV group. If you order a product, you will receive an order and delivery confirmation via your e-mail and/or phone number, as well as – depending on the transport service provider – a notification about the package and possible delivery options.
The legal basis for the transfer of your email and telephone number to the relevant parcel delivery service provider, as well as for their use, is the performance of the contract pursuant to Article 6(1)(b) GDPR based on your purchase – delivery of the ordered products, as well as our legitimate interest in maximally adapting shipping and delivery to customers pursuant to Article 6(1)(f) GDPR.
Data may also be transferred to other countries in which the above-mentioned contractual partners may have their headquarters or servers, i.e. process the data. These are exclusively European Union countries or countries that provide an adequate level of protection in accordance with European Union legislation or with companies with which we have concluded appropriate standard contractual clauses prescribed by the European Commission to ensure an adequate level of protection. We certainly implement appropriate security measures, including contracting provisions on the protection of personal data at the level of EU standards.
5. Personal data retention period
Personal data is stored for as long as necessary to achieve the purpose for which the personal data was collected, namely:
- for data for which there is a legal retention period, Sport Vision stores it for that period (e.g. generally 10 years in the case of accounting or tax documentation);
- data for which there is no defined legal retention period, Sport Vision stores it during the validity period of the contract in connection with which the data is processed, and after the termination of the contract, Sport Vision deletes the data within an additional period of one year after the statute of limitations for the relevant obligations, e.g. contracts for the sale of goods 5 years, bearing in mind that within an additional one year after the statute of limitations, Sport Vision may learn of the filing of a lawsuit;
- data that is processed on the basis of legitimate interest, Sport Vision keeps it as long as there is a legitimate interest, and deletes it after the end of the legitimate interest within a reasonable period not exceeding 6 months;
- data processed on the basis of consent, Sport Vision keeps them as long as it has consent, and in the event of withdrawal of consent, they are deleted within a reasonable period not exceeding 6 months or as otherwise prescribed by this Privacy Policy;
- data submitted when asking questions/inquiries via the website, via social networks or by email or telephone, are deleted or anonymized no later than one year after the final answer is given;
- In case of deletion of the user account, it will remain active for another 30 days, during which time it is possible to reactivate the account by entering the e-mail address and password. After this period, all data contained in the account will be automatically deleted.
After the purpose has been fulfilled, i.e. the expiration of the legally prescribed period for storing personal data, personal data will be permanently deleted.
6. Data on minors
Sport Vision does not intentionally process personal data of minors under the age of 16. In order to prevent the processing of personal data of minors under the age of 16, when creating a user account on the website, it is necessary to enter the date of birth.
We recommend that legal representatives/guardians of minors properly supervise minors under their guardianship or those they legally represent while browsing the internet, especially when personal information may be left behind.
If you believe that you have unintentionally provided personal information, please inform us of this and we will delete your personal information.
7. How we protect personal data
Some of the protective measures we implement are as follows:
- implementing database pseudonymisation whenever practical;
- modern ways of protecting and controlling access to sources containing personal data;
- restricting access to sensitive data, as well as limiting user accounts that can access certain data, by introducing a system of roles and authorizations that will ensure that only certain employees and controllers who need access to data to perform their work tasks can view and process the relevant data;
- continuous monitoring of all resources (physical spaces where your data is stored) used for processing personal data;
The purpose of implementing these measures is to prevent the risk of destruction, loss, alteration, unauthorized disclosure of or access to your personal data. By using appropriate protective measures in relation to your personal data, we also require third parties who have the right to access and process your personal data.
Please note that by accepting this Privacy Policy, you agree that Sport Vision cannot guarantee the absolute security, security integrity and confidentiality of personal data, and that, unless expressly required by law, we will not be liable for the loss/destruction/disclosure of personal data if we have taken all measures available to us at the time.
In addition, when registering a user account, we advise users not to disclose their password to other persons, as users are responsible for all actions performed through the user account. Sport Vision will not be responsible for the loss/destruction/disclosure of personal data in connection with the data stored in the user account. If you know or suspect that someone knows your password, you can reset your password yourself, and instructions for changing it will be sent to your e-mail address. If there is a suspicion of a security breach, we have the right to ask you to change your password or temporarily block your user account.
8. Rights of the data subject
If you decide to exercise one or more of the rights listed below, we have the right to verify your identity, all for the purpose of protecting personal data.
You can exercise your rights free of charge. Exceptionally, if your request is clearly unfounded or excessive (e.g. you are requesting personal data that you already possess), and especially if the same request is repeated frequently, we have the right to charge the necessary costs of processing your request or to refuse to process your request.
Please send all questions and requests related to your rights in writing and signed to the address dpo@sportvision.hr . We will respond to your request immediately, and no later than within 30 days, unless the exceptional complexity of the individual case requires an extension of the specified period. This period cannot exceed 90 days, and we will inform you about this separately. In order to protect you as the owner of personal data, it is necessary to identify you as the applicant in an appropriate manner, which will be a guarantee for Sport Vision to provide personal data to their owner.
If your request is clearly unfounded or repeated, we may refuse it or charge you for its implementation. We consider this to be a situation where you contact us with a request to exercise one of your rights five or more times, in which case we will only respond to your request if there is a legitimate reason for doing so.
In certain cases, conditions or restrictions under the GDPR may apply to your request (see Article 13 et seq.).
8.1. The right to be notified/informed about the processing
At the time of collecting personal data, we are obliged to inform you in a transparent manner about the type of data we collect, the purpose of the intended processing and the legal basis for the processing, the recipient of the personal data, whether we intend to transfer the personal data to another country or international organization, the data retention period, or if that is not possible, the criteria for determining that period, as well as your rights (right to access, rectify or delete your personal data, right to restrict processing, right to object and right to data portability, right to withdraw consent at any time, right to object and appeal to the Agency).
8.2. Right to access your personal data
You have the right to request information about whether we are processing your personal data, access to your personal data, the right to access information about the purpose of the processing, the types of personal data we process, to whom your personal data have been or will be disclosed, the envisaged storage period, or if that is not possible, the criteria for determining that period, the right to information that you have the right to request correction or deletion of your personal data, restriction of processing and the right to object to processing, the right to file a complaint with the Agency.
8.3. Right to obtain a copy
You have the right to request that we issue you with copies of the data we process, in written or electronic form.
8.4. Correction of inaccurate data, addition, deletion and restriction of the use of personal data
In the event of inaccurate data, you have the right to request that inaccurate data be corrected. We are obliged to correct such data without undue delay. If necessary to fulfill the purpose of the processing, you may request that your incomplete personal data be updated or supplemented, which we will record without delay. This does not apply to data stored in the user account that is automatically withdrawn by Sport Vision, as we do not have access to the user account, and you are solely responsible for the accuracy and up-to-dateness of such data.
8.5. Right to delete personal data
You have the right to request that we delete your personal data, as well as to stop and temporarily suspend the processing of your personal data.
8.6. Right to restriction of processing
You have the right to request that the processing of your personal data be restricted if: (i) you contest the accuracy of the personal data (within a period during which we are enabled to verify the accuracy of the personal data), (ii) you consider the processing to be unlawful (and you do not request the erasure of the data), (iii) we no longer need your personal data to achieve the purposes of the processing, but you have requested them for the establishment, exercise or defence of legal claims, (iv) you have lodged an objection to the processing (during the assessment of whether the legitimate grounds for the processing outweigh your interests). When processing is restricted, personal data whose processing is restricted may be further processed only on the basis of the consent of the data subject, except in cases provided for by relevant regulations. In the event of a restriction of processing, Sport Vision will be obliged to inform you of the termination of the restriction, before the expiry of the period for which the restriction was valid.
8.7. Transfer of personal data
You have the right to request the transfer of personal data from us to another controller, where technically feasible, or where the personal data that are the subject of the transfer request are in a structured, commonly used and machine-readable format, if these are data for which you have given consent to the processing of the data and if the processing is carried out automatically.
8.8. Right to withdraw consent
You have the right to withdraw your consent to the processing of your personal data at any time in writing and to request that your personal data that we have processed on the basis of your consent be permanently deleted. The withdrawal of consent does not affect the permissibility of the processing carried out before the withdrawal.
8.9. Objection to the processing or handling of your personal data
You have the right to object to the processing of your personal data, as well as to our actions regarding your personal data in general. Send us your request by e-mail to dpo@sportvision.hr , stating your objection to the processing in the subject line of the message, and explaining the reason for the objection and your request in the message itself.
Special notes on the right to object under Article 21 of the GDPR
You have the right to object to us at any time if you consider it justified and if you consider that our decision produces such legal consequences that may significantly affect your position. In that case, we will be obliged to stop such processing of personal data, unless we demonstrate that there are legitimate grounds for the processing which override your interests, rights or freedoms or are related to the establishment, exercise or defence of legal claims.
If your objection is directed against the processing of data for advertising purposes pursuant to Article 21(3) of the GDPR, we will immediately suspend the processing without further verification, including profiling.
8.10. Right to complain to the Agency
At any time, you have the right to file a complaint with the competent authority for personal data protection – the Personal Data Protection Agency (AZOP), whose contact details can be found here https://azop.hr/ .
9. Change of Privacy Policy
Sport Vision reserves the right to change this Privacy Policy at any time. Any changes will become effective upon their publication on the website or in another appropriate manner. In this regard, we recommend that you regularly check the Privacy Policy section to have the latest information.
10. Contact us
If you have any questions, comments or complaints regarding the processing of your personal data, please contact us by e-mail at dpo@sportvision.hr or by sending a written request to the address Sport Vision doo, Croatia, 10000 Zagreb, Bani 75.