Privacy policy

The protection of our customers` personal data is one of the fundamental principles and key priorities of InClouds, craft for services and trade, Kašinska cesta 31, 10 360 Zagreb, Croatia, PIN (VAT ID): 24036673173 (hereinafter: “Seller”). In accordance with the General Data Protection Regulation (EU) 2016/679 (hereinafter: “GDPR”) and the Croatian Act on the Implementation of the General Data Protection Regulation, the Seller has adopted this Privacy Policy, which regulates the procedures for collecting, processing, using, and protecting personal data of customers collected during regular business operations.

This Privacy Policy applies to all customers with the aim of ensuring clear, transparent, and comprehensive information about how the Seller, as the data controller, processes their personal data and about the rights that belong to them in this regard. The Privacy Policy also includes the Cookie Policy (section 8).

The policy is based on the following principles of personal data processing:

• Lawfulness, fairness, and transparency – personal data is processed lawfully, fairly, and in a transparent manner;
• Purpose limitation – data is collected solely for specific, explicit, and legitimate purposes;
• Data minimization – only those data necessary for fulfilling each specific purpose of processing are collected;
• Accuracy – personal data must be accurate and, where necessary, kept up to date;
• Storage limitation – data is stored only for as long as necessary for fulfilling each specific purpose of processing;
• Integrity and confidentiality – personal data is processed in a manner that ensures adequate security, including protection against unauthorized or unlawful processing;
• Accountability– the Seller ensures a high level of accountability in the protection of personal data through the application of appropriate technical and organizational measures.

The Seller consistently applies these principles in everyday operations, thereby ensuring the highest level of protection and security of personal data for its customers. 

Personal Data
Any information relating to an identified or identifiable individual (“data subject”); an identifiable individual is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, network identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that individual. 

Data Subject
An individual (natural person) whose identity is established or can be established - customer. 

Data Controller
A natural or legal person, public authority, agency, or another body that alone or jointly with others determines the purposes and means of processing personal data - Seller.

Processing of Personal Data
Any operation or set of operations performed on personal data or sets of personal data, whether by automated means or not, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction. 

Personal Data Breach
A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored, or otherwise processed. 

Data Protection Officer
A person whom the data subject can contact regarding all matters related to the processing of their personal data or for exercising their rights regarding the protection of personal data - email: hello@incloudsjournal.com. 

The Seller collects your personal data either based on legitimate interest or on given consent or for the purposes of fulfilling the Seller`s legal obligations or when entering into a contract with the Seller, and for the purpose of fulfilling contractual obligations as well as obligations arising from applicable regulations of the Republic of Croatia.

The personal data collected during interactions with the Seller via email and the website include: 

• Name and surname
• E-mail address
• Phone number
• Delivery address
• Any other data you voluntarily provide.

These interactions during which personal data is collected include: 

• when you, as a potential buyer, contact us for information and for the purchase of products. The basis for the processing of your personal data is the execution of this contract, i.e., taking pre-contractual actions;
• when you contact us for information or assistance regarding your rights as a data subject in accordance with applicable legal frameworks, where the basis is fulfilling our obligations to you and under applicable regulations;
• when you place an order and make payment for products, during the processing of such order by us or payment by us or our contractual partners, where the legal basis for processing is compliance with legal obligations and the performance of the purchase contract;
• when you give explicit consent for a specific purpose or purposes, such as marketing, sending personalized content, surveying, etc., according to the content of the consent itself;
• when you exercise rights based on liability for material and legal defects or from a commercial warranty (if applicable) or other rights specified in accordance with the General Terms and Conditions, where the basis for processing is contractual;
• if you contact us directly through our website to request information or an offer, via a contact form, where the basis for processing is contractual;
• in case of your response to our direct marketing campaigns (i.e., by filling out a form on the website), in which case the basis is legitimate interest;
• if you participate in prize contests or promotional activities that we organize, where the basis for processing is acting in accordance with legal obligations and/or executing obligations from the mentioned prizes or promotions.

We may share your personal data with other parties (recipients) in the cases and situations listed below and when positive regulations require it:  

• Service providers for authorized services in case of exercising customer rights regarding material defects, or when it is not covered by them, for the purpose of performing necessary actions to eliminate the defect;
• Service providers for the distribution (delivery) of goods when fulfilling the Seller`s obligations;
• Payment Gateways (PayPal and/or Shopify Payments) – for processing payment transactions;
• Relevant auditing bodies regarding the Seller`s legal consolidated and unconsolidated financial statements, as legal and contractual obligations of the Seller.

(i) Right of Access to Your Personal Data

You have the right to obtain confirmation of whether your personal data is being processed, which category of personal data it concerns, for what purpose, the recipients or bodies with which we may share your personal data, the retention period, and the source of data in the case of indirect collection.

At the same time, you have the right to access the data we hold about you and a copy of part o all of it.

(ii) Right to Rectification

If you believe that some personal data is incorrect or needs to be updated, you have the right to request rectification or removal at any time.

(iii) Right to Erasure (“Right to be Forgotten”)

You have the right to obtain the erasure of your personal data held by the Seller, if:

• the personal data is no longer necessary for the purpose for which it was collected;
• you have withdrawn your consent as the basis for collection and processing; the processing is unlawful;
• erasure is in accordance with a legal obligation of the Seller arising from national law or EU law;
• you have lodged an objection (Article 21 of the GDPR), and there are no overriding legitimate interests.

(iv) Right to Restrict Processing

You have the right to restrict processing if:

• you contest the accuracy of the personal data, during the period in which the data controller is allowed to verify the accuracy of the same;
• the processing is unlawful and you oppose the erasure of the personal data and instead request restriction of its use;
• the Seller no longer needs the personal data, but you require it for the establishment, exercise or defense of legal claims;
• you have lodged an objection (Article 21 of the GDPR) and are waiting for confirmation whether this outweighs legitimate interests.

(v) Right to Object

You have the right to object to any processing of your personal data. The Seller may no longer process personal data unless it demonstrates compelling legitimate grounds for processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.

You can contact us for any questions related to the processing of your personal data or exercising your rights for the protection of personal data at the following email:hello@incloudsjournal.com.

We will respond to your objection within the legal deadline of 30 days.

(vi) Right to Data Portability to Another Data Controller

If the processing of your personal data is based on consent or on a contract or is carried out automatically.

(vii) Right to Lodge a Complaint with the Data Protection Agency

You have the right to lodge a complaint with the relevant authority for the protection of personal data - the Personal Data Protection Agency (www.azop.hr) regarding the processing and protection of your personal data.

The Seller does not store or process your personal data longer than necessary to fulfil the purposes of processing your personal data as set out in this Privacy Policy or in accordance with any of our legal obligations.

Therefore, your personal data will be deleted immediately upon withdrawal of consent, or as soon as possible after the termination of the contractual relationship, and no later than upon the expiry of all legal obligations related to the retention of personal data.

The Seller uses various categories of cookies on its website (subject to your consent where necessary) on your device to recognize your device`s browser as long as the respective cookie is valid. This Cookie Policy applies to every product or service that contains a link to this Privacy Policy or that includes it by reference.

The operator and website manager are specified in section I of this Privacy Policy.

Please carefully read this Privacy Policy and the Cookie Policy, as an integral part of it, before using this website. It explains how we use cookies and how you can manage them.

A “cookie”means a small file that our Website requests your browser to store on your device (computer, smartphone, tablet, etc.) when you visit this Website. The term “cookie”, in this document, also refers to other digital measurement technologies, such as web beacons.

Cookies allow us to tailor the Website to your needs and improve your user experience. We also use third-party cookies for advertising and marketing purposes. Some cookies are necessary for the functionality of the website, while others help provide services and features tailored to you.

The first time you access the Seller`s website, you are notified via a corresponding cookie notice about the use of cookies and the category of the respective cookies.

You can access our cookie management tool to manage your cookie settings for each category of cookies (except necessary cookies, which cannot be disabled in our system) by clicking the appropriate button in the cookie notice.

In the following section, we will inform you about the cookies used on our website. If you disagree with the settings of individual cookies, you may disable the respective cookie by clicking the displayed link. If there are no direct links to disable certain cookies, you can restrict cookie usage in your browser settings.

Some cookies are provided by authorized third parties; however, we do not allow cookies to be used for purposes other than those described in this Privacy Policy.

By visiting and using this website, you agree to the use of cookies, which can also be blocked.

If you disable them through your internet browser settings, you will still be able to browse the website, but some functionalities may no longer be available to you.