Politici privatnosti

We undertake to provide protection of personal data customers, in a way that we collect only necessary, basic data on customers/users who are necessary for the fulfilment of our obligations; We inform customers about the use of collected data, we regularly give customers choices about the use of their data, including the opportunity to decide whether or not to remove their name from the list used for marketing campaigns.

All users are strictly stored and are available only to employees whose data are necessary to do the job. All our employees and business partners are responsible for complying with the principles of privacy protection.

If you communicate with us, for example by e-mail or our customer service, here you will find information on data processing in communication.

Data Protection Officer

We, Cinemart Motion Picture d.o.o., Bujska 20, 51000 Rijeka, Croatia (furtheron as “Cinemart”) as a General Data Processing as per General Data Protection Regulation (furtheron as “GDPR”) we take very seriously the protection of your personal information and respect Legal regulations on data protection.

Cinemart.tv and online services

Below we want to inform you about which information we collect about you when you visit us on our website on Cinemart.tv (including integrated pages) or use our online services and for which we use your data.

About visiting internet pages in general

We collect and use the personal data of our users as a rule only if it is necessary to provide a functional website as well as our content and services. The collection and use of personal data of our users regularly take place only on the basis of the contract concluded with the user or after the previous benefit of the user. The exception applies in cases in which the acquisition of adequate reasons is not possible or data processing is allowed on the basis of other legal regulations.

Providing internet pages and creating data records

At each visit of our website, our system automatically collects data and information of the computer system from which the page is visited.

The following information is collected:

  • request (title of the requested file), (for example: www.example.eu/index.html)
  • type/version of the browser
  • Browser language (e.g. Croatian)
  • operating system used
  • internal resolution of the browser window
  • screen resolution
  • Javascript activation
  • Java on/off
  • cookies included/excluded
  • color depth
  • content reference locator, ie. referrer URL (address of the previously visitited web page)
  • IP address (anonymized)
  • access time
  • clicks
  • eventual forms content
  • ev. access place (e.g. when using a page with a contact form, category, search, Home page / Customer Service…).

The specified data is stored in the records of our system. Analyses of these data set in record files in anonymized form serve faster error detection and their removal as soon as possible. In this way, we can also manage the capacity of our servers and continue to improve our service. We use IP addresses exclusively in exceptional cases for the purpose of analyzing abuse. These purposes contain our legitimate interest in data processing according to Art. 6. st. 1. f) of GDPR which is the legal basis for processing. Data analysis for marketing purposes is not implemented in this context.

Use of cookies and other technologies

Our websites in multiple places use cookies and other technologies. The so-called cookies are small text files that are saved on your computer and which your browser can store. The data from these files will not be connected to other data sources, except when it serves the contract that has been concluded when you explicitly approved or if there is a legal basis or other justified reason. If the user opens a website, then the cookie can be stored in the browser on the user’s device. This cookie contains a characteristic order of characters that allows unambiguous identification of the browser when reopening the website.

Most cookies we use are the so-called “session cookies” that are deleted as soon as you leave the page. In addition, there are a few long-lived cookies with which we recognize you again as a visitor. Cookies will not cause any damage to your computer and do not contain viruses.

The following information is stored and processed in cookies:

  • application functionality (Log-in), service life: one session
  • ev. reduction of the load, service life: one session
  • basket functionality, service life: 30 days after the last visit

In addition, we use monitoring measures to ensure compliance of our web page to the user’s needs and their continuous optimization. Monitoring measures also apply for the purpose of collecting statistical data on the use of our website and for analysing the optimization of our offer for you. If you have registered ‘My Account’, the information we collected about you is used to make your ‘My Account’ more precise and better and adapted to your needs, and personalize it to provide you with information that you might be interested in. For more information about your ‘My Account’ option can be found here

Detailed information about cookies and other technologies we use, also on options to select and deselect can be found below and in our consent management.

You can manage your consent in the cookie settings.

Technically necessary technologies

These technologies enable the basic functions and are necessary for the proper operation of our website.

Statistics

The statistical technologies are stored in form of anonymized information that helps us understand how to use our websites and applications ‘My Account’ in order to continuously optimize our offer. These technologies are used only if you have given your consent. The legal basis is your consent in accordance with Art. 6. st. 1. a) GDPR. Your consent is voluntary, and it is possible to revoke it at any time that will affect future management through consent management.

Marketing

The technologies listed below help us understand what content is relevant to you and help us in the future on our website and on websites of third parties to address you according to your interests.

The technologies below apply if you are using our tools to manage consent give your consent in accordance with Art. 6. st. 1. a) GDPR. Your consent is voluntary and you may at any time revoke the effect on future management through the consent management.

Facebook Pixel

Facebook Pixel is especially used for ad serving aligned with the interests ( “Ads”) of users of our web pages during their visit of social networks Facebook (and associated social network Instagram) on Facebook, Instagram and on advertising network Facebook (Audience Network), respectively, and to other Internet pages, as well as for the purpose of measuring and optimizing the impact of the ads displayed in terms of conversion. We also use Facebook’s function Custom Audience based on visits to the website in order to share target groups with interested partners. In doing so, we share only the name and size of the target group in order to ensure ads are aligned with the interests. We do not share any personal data and/or statistics with the partners.

For this purpose, the website cinemart.tv has implemented a Facebook label. Through the said label, during the visit of the certain website establishes a direct connection with the servers of Facebook, and the Facebook server is transferred that you visited this web page and how you used it. Facebook assigns this information to your personal account on Facebook. When visiting social networks, Facebook and Instagram or page of Audience Network of Facebook’s partner Facebook’s, there might display personalized ads that match your interests. Depending on the specific purpose of processing between us and Facebook there are various relations with regard to the regulations governing data protection:

  • Company Facebook Ireland is our executor for the processing of personal data related to events with service of measurement and analysis.
  • Company Facebook Ireland and we are joint Data Management Officers in the processing of personal data about events that are used purpose of target groups to contact, the delivery of commercial information or information on transactions, personalization features and content as well as in order to improve the security of Facebook’s products. In the context of joint processing of your personal data we have with Facebook agreed that Facebook is primarily responsible to provide you with information about the processing of data and provide you with the exercise of rights you may have in accordance with the GDPR. You will, moreover, find more information on the processing of personal data by Facebook, among other things, information on the legal basis of data processing and the way in which you will with ask Facebook to exercise your rights.
  •  In the remaining part of Facebook Ireland, we are separately responsible for the processing of personal data.

Advertising through Google and Conversion Tracking

Track conversions through Google’s analytical services of Google Ireland Limited.

If through ads on Google, visit our website, Google sets a cookie for conversion (Conversion Cookie) on your device. It doesn’t serve personal identification. If you visit certain pages and the cookie on our pages has not yet expired, we and Google can see that someone has clicked on the ad and is thus directed to our website. Each customer of Google Ads (advertising customized by interests) gets a different cookie. Therefore, cookies can not be tracked through the websites of Google Ads customers.

Information collected by the conversion cookie is used to produce statistics on conversions for Google Ads customers who opted for conversion tracking. We, as a buyer of Google Ads, find out the total number of users who clicked on the ad and are taken to a page that is marked with conversion tracking. However, we do not get any information through which it was possible personal user identification.

Advertising through Google and remarketing

We use technology for re-marketing of the company Google Ireland Limited in order to be on the network pages of Google’s partners through advertising in line with interests and that could address people who have already visited our website.

By using cookies we can analyze your interests during the visit of our web pages, and then use them for advertising relevant products. If they match your interests, our ads will be shown not only when you visit our website, but also on a Google website or the website of the network of Google’s partners. In this case, Google we transfer Google relevant information. The ads/means of advertising may contain e.g. products that you have previously accessed on our website.

If you have given consent to Google to connect your history log and search, and that information from your Google account may be used to personalize ads, Google will use this information for re-marketing on all your devices. If you’re in that case during his visit to our web sites logged into Google, Google will use your information together with the user data on Google to develop and define lists of target groups for remarketing on all devices that you use. Google will also use your personal available data short link to the user data on Google for the purpose of making the target groups.

Cookies and other technologies, cancellation and objection

Detailed information about cookies and other technologies we use, also on options to select and deselect can be found below and in our consent management.

You can manage your consent in the cookie settings.

Additional options for deactivation can be found below:

  • In the appropriate settings of your browser you can define the desired cookies and tracking by yourself.
  • Information and options regarding the deactivation of personalized advertising with Google can be found here. In doing so you must be logged in to Google. 
  • Users can also completely or partially deactivate Google ads for certain browser and device.
  • You can also deactivate Facebook’s function of re-targeting. Information on options for deactivation with Facebook you can find here  below the re-targeting function “Custom Audiences”. In doing so you must be logged in to Facebook.

Delivery

In the case of delivery, your e-mail address can also use our service provider for delivery.

Social networks buttons, videos on Youtube

Description and scope of data processing

On our website are integrated buttons of social networks (e.g. Facebook, Instagram, YouTube, TikTok). These buttons take you directly to our pages on social networks. In addition, on various places are included YouTube videos. 

They are on our website included only as a link to the appropriate services. After clicking on integrated graphics or video, you will be redirected to the appropriate network location of the service provider, i.e. only then will the user data be transferred to an appropriate service provider.

Legal basis for the processing / deleting data

Based on our legitimate interest we process your data in accordance with Art. 6. st. 1. f) of the GDPR so that we can provide this functionality.

Other services

Description and scope of data processing

Web page Cinemart.tv gives you the opportunity to visit our other pages.

Please also pay attention to our legal information such as Privacy Policy, General Terms and similar.

The legal basis of data processing

Based on our legitimate interest we process your data in accordance with Art. 6. st. 1. f) of the GDPR so that we can provide this functionality.

The legal basis of data processing

Your personal data is safely transferred by coding. We use the SSL system. We provide technical and organizational measures by our website and other systems from loss, destruction, access, amendments or distribution of your data by unauthorized persons.

Categories of recipients, transmission to third countries

We generally do not transmit your data to third parties, unless we are legally mandatory (for example by a call from criminal persecution bodies) or if our third parties are needed to implement business processes or provide us with data processing contracts. These are, for example, package delivery service providers, payment service providers, service processing providers, internet hosting providers, communication agencies, external call centres or also providers of IT services. In all cases, we strictly respect the legal regulations. The mentioned context is possible to transfer data to other countries in which the above contractual partners may have their attendant or process data. These are primarily the European Economic Area (EEA) and in individual countries outside EEA, which may be different or provide a lower level of protection against the regulations from the European Union. The consequence of the mentioned may be for example, that your data can be processed by the state bodies for the purpose of control and supervision, perhaps without the possibility of legal protection. In the event that personal data is processed outside the European Union, and there is no decision of the European Commission on the appropriate data protection, we implement appropriate protection measures, including the contracting of standard EU data protection clauses.

The text of the standard contractual clauses on the protection of the EU data can be found on the European Commission’s website available here.

Respondents’ rights and data protection officer

Respondent’s rights

In general

Our visitors are entitled to information on personal data relating to them, the right to data transfer, as well – if applicable – right to deletion, correction, processing limitation and/or processing, as well as the right to submit a complaint with the Croatian Supervisory Body

Croatian Personal data protection agency
Selska cesta 136
10000 Zagreb
Phone: 00385 (0)1 4609-000
e-mail: azop@azop.hr

More about your rights

You have the right:

  • in accordance with Art. 15. of GDPR to request information on personal data relating to you, which we process. In particular, you can request information on processing purposes, the category of personal data, the categories of the recipients whose data is revealed, or will be revealed, the planned keeping time, right to correction, deletion, constraining the processing or appeal, right to appeal, right to the origin of data weren’t collected by us, as well as existence of automatized decision-making, including the production of profiles and, if applicable, meaningful information on the details of the profile.
  • in accordance with Art. 16. GDPR promptly request a correction of incorrect or incomplete personal data relating to you and which are stored by us
  • in accordance with Art. 17. GDPR request a deletion of the stored personal data by us that relate to you, unless processing is not necessary for the purpose of exercising the right to freedom of expression and information, for the purpose of fulfilling the legal obligation due to the public interest or due to the exercise, execution or defense of legal requirements
  • in accordance with Art. 18. GDPR require the restriction of personal data processing if you dispute the accuracy of data, if processing is illegal, but you disapprove its deletion, where the data is no longer needed to us, but they are needed to you to carry out, execute or defend legal requirements or you are in accordance with Art. 21. of GDPR invested in an objection to processing
  • in accordance with Art. 20. GDPR to obtain personal information that relates to you, which you submitted to us, in a structured, common and machine-readable format or request that they are transferred to another data processing officer 
  • in accordance with Art. 7. st. 3. GDPR at any time to the consent you gave. Due to that in the future, we must no longer implement processing of data that is based on that privileges 
  • in accordance with Art. 77. GDPR submit a complaint to the supervisory body.

Special information with the right to submit complaints in accordance with Art. 21 GDPR

Based on your specific situation, at any time you have the right to file an objection to the processing of personal data that relate to you, and are processed in accordance with Art. 6. st. 1. f) GDPR (data processing for the purpose of protection of legitimate interest). This also applies to the creation of profiles based on the same legal basis (Art. 4, item 4 of the GDPR).

If you make an objection, we will no longer process your personal information unless we can prove that there are convincing and justified reasons that go beyond your interests, rights and freedoms or the processing serves to establish, realize or defend the legal requirements. If your objection is about processing your data for advertising purposes based on Art. 6. 1. f) GDPR, we will terminate processing without delay and without further verification. This is also applied to the preparation of the profile that comes in such circumstances.

Data Protection Officer

All inquiries associated with data protection or your personal information can be referred to our data security officer

through e-mail to: zastitapodakataka@cinemart.tv

or by land post

 CONEXUS d.o.o., Bujska 20, 51000 Rijeka, Croatia

For communication with us, you can also use our contact form

You can find answers to frequent questions below: 

What measures do we use to protect your personal information? 

Cinemart as a data protection officer in processing personal data undertakes all the measures to protect personal data from the violation of personal information, including all legitimate, technical, personnel and organizational measures of personal data protection, that data protection from any unauthorized processing, either external (by subcontractor, suppliers, other users of services, unauthorized third parties), either internal, including that they will fully abide by the requirements and principles of the GDPR.

For what purpose do we do the processing of your data and what is the legal basis for processing?

Your personal information we process include information such as name, surname, personal id number (OIB), email address, home address, mobile phone number, and in special cases and photos, video and audio, usernames, etc.

For each processing of personal data, we will clearly point to you on the legal basis and the legality of processing as specified.

Depending on the processing of data purpose, the legal basis for processing your data may be one of the following:

  1. The regulation commits us to data processing
  2. Execution of a contract or conclusion of a contract
  3. Your consent – the consent of respondents
  4. Our legitimate interest that is based on the need to improve our products and services, with a view to better understanding of your needs and expectations and the protection of assets and persons as well as to prevent fraud and embezzlement, to ensure the safe and proper functioning of the devices/websites/applications and their improvement.

Who do we forward your personal information to?

Your data, such as your first name, address, phone number, mail address, we can get primarily from you at the time you access the company for any reason or contact us by phone, mail, post or in any other way, and depending on your query towards the company we take information from you to answer, for example, at the request for a claim, complaint, a product purchase request, a request for business cooperation in any form, a donation/sponsorship request or a request for employment, application for participation in our prize contests, application for inclusion to the loyalty program, if available etc. 

In each of these cases, we process the data to respond, for which the legal basis is our legitimate interest in viewing that you have directly addressed or otherwise the purpose of collecting data to conclude the contract or take actions that are necessary before the conclusion of the contract. 

In some cases, we can ask you for further information such as gender and date of birth that is necessary to determine and prevent, both misuse and because of the fulfilment of our legal obligations imposed by positive regulations, above all the identification. 

We do not deliver your personal information to other recipients unless you authorize us or have to submit to us to meet the contractual or legal obligation we have towards you or the competent authorities. We ensure that our partners handle personal data in a manner consistent with legal regulations and powers for the purpose of fulfilling the contract or purpose in which personal data are given and for our legal obligations to prevent illegal procedures. 

Only if you are in a voluntary and undoubted way, you have given us the consent for the purpose of direct marketing, your personal information is processed by the third data protection officer in accordance with its own terms and conditions and privacy rules. 

Carefully read the third party rules before the consent of disclosing information about yourself. 

Your personal information may be processed by reliable third service providers. 

Trusting third parties, we entrust a part of the business tasks they are doing on our behalf. We only provide the information needed to execute the contract service and require that they do not use your personal information for any other purposes. We have taken all appropriate measures to determine that third parties protect your personal information. 

Following the above-mentioned processing of your personal data we can trust:

  • subcontractors, due to fulfilment of the package delivery
  • third persons that help us provide technical support such as platform service providers or hosting service providers, support and maintenance of the databases, as well as software and application that could contain your data (such services sometimes imply allowed access to your data in order to be performed justified tasks)
  • in certain cases data could be forwarded to our lawyers, revisers, security service company in limited scope in order to perform the orders they were given to.

In any case, with the recipients of the data, we carefully contract a minimum of data that is necessary to execute their job.

How do we collect your information?

We collect your data via our phone, websites, e-mail, forms, applications, devices, or other ways when you address us.

Your information can also provide us with a third person who entrusted us to execute a particular job. Then we are required to process your information in accordance with the privacy rules of persons who have given us data on processing.

How long have we preserved your information and how do we decide on keeping time?

We will keep your personal information in all the time of the contractual relationship or in accordance with the regulations for storing some documentation or while it lasts (exists) our legitimate interest, i.e. until the respondent cancels the application to the newsletters or by the passage of inactivity periods.

In case your data is on our property because they are treated in the proceedings before the competent bodies, we will keep them to finality in the procedures that are initiated, in which the data was used as evidence collected by the supervisory device of the data protection officer or to the limitation period started relative to the stated proceedings.

The data protection officer will make a copy of personal data that has been submitted to the procedure before the competent authorities as evidence in the proceedings.

After the expiration of the deadline, we will destroy the data collected in the most appropriate way: by deleting it from the media or by destroying the data media as provided by the law by the authorized person or the data will be anonymous so that respondents cannot be identified.

After the expiration of the deadline determined to keep your data, the same will be deleted, i.e. anonymized in an appropriate manner.

Last change: January 2022