Last update on June 14, 2022.
At Cobalt Hills Tech Ltd ("Company", "we", "us" or "our"), we are committed to affirming the principles of legal, fair and transparent processing of personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the Protection of natural persons 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) and the current laws of the Republic of Croatia governing the area of personal data protection.
We are dedicated to the protection of personal data of our employees, customers, users, business partners, or other persons with whom we are cooperating. We collect only necessary, basic data that is necessary for the fulfilment of our obligations, regularly inform about the usage of collected data, and give you the option of choosing the way your personal data will be used including the decision whether or not you want your name removed from lists used for marketing campaigns. All user data is safely stored and is available only to employees who need this data to perform their work. All employees of Cobalt Hills Tech Ltd, and business partners are responsible for respecting the principles of privacy protection.
You guarantee that the information you provide is accurate, complete and up-to-date. By accepting this Privacy and Cookie Policy, you confirm that you agree with the use of your personal data for the above-mentioned purposes. All communication related to the order process and conclusion of the sales contract is carried out via e-mail and/or telephone number that you provide.
In the event of a dispute before the court, the court of actual jurisdiction is in Rijeka, Republic of Croatia, on whose territory the Company's headquarter is located.
Personal data is any data relating to an individual whose identity is known or can be determined. An identifiable individual is a person who can be identified directly or indirectly, especially with the help of identifiers such as a name, personal identification number, location data and network identifier. They can be identified with the help of one or more factors inherent in the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
We collect information about you that allows us to ensure the smooth operation of our website and to provide you with the best possible experience on our website. Generally speaking, we distinguish between (a) personal data that you provide to us, (b) personal data that we collect automatically and (c) personal data that we receive from another source.
For example, we collect data that you provide when you visit our website, when you request our newsletter, or when you order one of our services - in such cases, you fill in certain fields or click on a certain button and thereby possibly provide us with your personal data. We also collect data through surveys, when you contact our customer service or when you participate in a prize game or competition that we organise.
When you provide us with service feedback or complain about a particular service, it is also possible (or likely) that we will collect some personal information from you. We collect all this data when you give us your consent for such collection or for the reason that we need such data to fulfil our contractual obligation (for example when we have to respond to a specific complaint related to the service), and for the purposes of this Privacy and Cookie Policy, we consider them Personal data that you give us.
Each user gives their Consent to the collection of their personal data. In the form where personal data is entered, a notice appears that the data is collected in a precisely defined scope, for a precisely defined purpose and where this data is stored. If the same data will be used for multiple purposes, we ask for clear consent for each of those purposes (boxes in which you can independently put a checkmark).
There is also Personal Data that we collect automatically. This is data that we record when you use our websites or when you use some of our services. Whenever you use our websites or, for example, when you read one of our e-mails, certain information (which is not necessarily personal data) is created and automatically collected.
We collect such data to pursue a legitimate interest, and for this Privacy and Cookie Policy, we consider them to be Personal Data that we collect automatically.
To improve the quality and constantly improve the user experience, this website saves small text files called cookies on your computer when you visit it. Through cookies, we collect information about the use of the site to improve the quality and constantly improve the user experience. Examples of information about the use of the site include the most visited and most viewed pages and links on our website, the number of completed forms, time spent on the page, the most popular keywords that lead users to our site, IP address, data of the device from which they access the site such as hardware settings, system activities, browser types, etc.
The directive of the European Union dated May 26, 2012, obliges website owners to request user's consent before storing cookies. By clicking on the "I agree" button, you give your consent to the use of cookies. By clicking on the "See more about cookies" button, you can view the Privacy and Cookie Policy.
We use cookies to be able to make further improvements to this site, to improve your browsing experience on this site and to make your user experience as positive as possible. We will not use cookies together with your personal data without your prior consent. Our data processing is based on the legal provisions of valid positive regulations.
Cookies are small text files placed on your device to store data, which can be recalled by the web server in the domain that placed the “Cookie”. We use cookies for enabling online advertising, fighting fraud, analysing the performance of our services and for other legitimate purposes. We may also use web trackers to deliver cookies and collect usage and performance data. Our websites may include web companions, cookies, or similar technology from third-party service providers.
If you wish to, you can block cookies and continue browsing the site, which may lead to the fact that some functions of the website can no longer be fully used. Under no circumstances will the people behind the data be identified or personal data be collected, following the Data Protection Regulation.
To order service on our website, you should enable the use of cookies. If you do not enable cookies, you will still be able to use our pages, but certain functionalities may be disabled. Most web browsers enable the use of cookies in their settings, but you can change these settings in the settings of your web browser (on a computer, tablet, or other mobile devices).
Cookies cannot damage your device. We never store personal information, such as your debit/credit card information, in cookies, but we do use the encrypted and anonymized information we collect from cookies to improve our website - for example, to detect and fix errors that sometimes occur on websites.
Cookies are not computer programs, they cannot read other information stored on your device. They cannot be used to transmit computer viruses or to obtain user data such as e-mail addresses, etc. We may have an agreement with carefully selected and monitored suppliers who, in a small number of cases, may set cookies during your visit to our website, and use the same for re-marketing purposes - that is, to show you services based on your assumed interests and preferential selections. Please be sure to take into account that we are not and cannot be responsible for the content of websites that are not ours or that we do not control. Our cookies do not contain personal information, such as your first or last name, or payment information. If you want to limit, block or delete cookies from any website under our control, you can do so in your web browser settings. Every web browser is different, so we suggest you look for such options in the 'Help' section of your web browser. You must be aware that by doing so, you may cause certain functionalities of our website to not work. If you need more information about cookies, please visit allaboutcookies.org.
When you visit our website, cookies are used to generate data that Google collects and processes. You can prevent this by downloading and installing the Google Analytics Opt-out Browser Add-on.
You can find more information about the processing of user data by Google Analytics in Google Analytics' privacy policy.
There are currently several websites that can be used to disable the storage of cookies for different services. You can get more information at the following links:
Finally, it is possible for us to receive personal data about you from another source. For example, we can receive information about you via 'social networks', in case you 'like' our page on Facebook or start following us on another 'social network'. Then we may receive personal data about you through those pages, and we will use them exclusively to achieve some legitimate interest, and for the purposes of this Privacy and Cookie Policy, we consider them as Personal data that we receive from another source.
If you 'share' content with friends or 'like' or 'follow' Cobalt Hills Tech Ltd via a social network that we use, for example, Facebook, it is possible that cookies will be sent to you from one of these websites. We have no control over the settings of these cookies, but we suggest you check the 'Privacy Policies' of these third-party websites.
Facebook:
For more information on the purpose and scope of data collection, further processing and use of data by Facebook, as well as your related rights and setting options to protect your privacy, please see Facebook's privacy policy.
Instagram:
Further information on the scope and use of Instagram data and related rights can be found in Instagram's privacy policy.
LinkedIn:
Further information on the scope and use of LinkedIn data and related rights can be found in LinkedIn's privacy policy.
GitHub:
Further information on the scope and use of GitHub data and related rights can be found in GitHub's privacy policy.
We use the obtained user data for one or more of the following purposes:
Only when it is necessary, we will share your personal data with the following categories of recipients:
Our website may contain links to other websites. This Privacy and Cookie Policy applies only to websites managed by Cobalt Hills Tech Ltd, so when you click on a link that takes you to other websites, you should read their rules and privacy policies.
To protect the personal data, we receive through the website, we use physical, technical, and organisational security measures. We are constantly upgrading and testing our security technology. We limit access to personal information to only those employees who need to know that information to provide benefits or services.
In addition, we educate our employees about the importance of data confidentiality and the preservation of privacy and the protection of your data.
Personal data that is exchanged between you and us through our website is transmitted using the most modern connections. All used IT systems are protected against unauthorised access to security systems, and employees are obliged to keep data confidential. However, Cobalt Hills Tech Ltd has no effect on the transmission of data over the Internet and therefore cannot exclude misuse of third-party access.
If you want to know whether we own and process your personal data, or if you want to access your personal data, you can contact us at dpo@cobalt-hills.tech.
You may also demand the following information: the purpose of data processing, categories of personal data under processing, who else outside of our company has received personal data from us, who is the source of the personal data (if not directly provided to us) and how long we will keep the data. You have the right to correct the personal data we have if it is incorrect. You can also, with certain exceptions, request that we delete the data or stop processing it. You may ask us to stop using personal data for direct marketing purposes.
If it is technically feasible, we will, based on the request, send personal data to you or transfer them directly to another data controller.
If you submit a request to dpo@cobalt-hills.tech to send you your personal data, we will comply with that request within a reasonable period of 14 working days. If we cannot comply with the request within a reasonable time, we will inform you of the date when we will comply with the request. If for some reason we cannot fulfil that request, we will send an explanation of why we did not fulfil your request.
Based on the General Data Protection Regulation, you have the following rights:
The right to object
This right allows you to object to the processing of your personal data, in those cases where we process your personal data on one of the following legal bases:
The right to withdraw consent
In cases where we have obtained your consent for certain actions, you are entitled to withdraw the given consent at any time and we will stop using your personal data for this purpose unless we believe that there is an alternative legal basis that would justify the further processing of your personal data for this purpose, in which case we will inform you about it.
The right of access
You can also request information about the purpose of the data processing, the categories of personal data being processed, who else outside of our company has received personal data from us, and what is the source of the personal data (if you have not provided it directly to us) and how long we will keep the data.
If it is technically feasible, we will send you personal data based on your request or transfer them directly to another data controller.
At any time, you are authorised to ask us for a copy of the information we have about you, as well as to ask us to modify, update or delete this information. We may ask you for additional information about your request. If we provide you with access to the data we hold about you, we will do so free of charge, unless the processing of the request is manifestly unfounded or excessive. In case you request additional copies of this data from us, a proportionate administrative fee may be charged. Your request may be denied in cases where this is legally permitted.
The right to deletion
In certain circumstances, you are authorised to request that we "delete" your personal data. For example, you have this right in the following cases:
The right to rectification
You have the right to correct the personal data we hold if it is incorrect. You can also, with certain exceptions, request that we delete the data or stop processing it. You can ask us to stop using personal data for direct marketing purposes.
You have the right to request the correction of any inaccurate or incomplete information we have about you. In the event that we have shared your data with third parties, we will notify them of the correction, unless this is not possible or would cause disproportionate difficulties. You are also authorised to request information about third parties to whom we have provided incorrect or incomplete personal information. In the event that we consider that it is not reasonably possible to act on your request, we will inform you about this and we will explain the reasons for such a decision.
The right to transfer
If you wish, you are authorised to request the transfer of your personal data to another data controller. This right actually means that it is possible to request that your personal data be transferred to a third party. In order to enable you to do this, we will transfer your data to you in the usual, machine-readable form so that you can transfer your personal data to a third party. This right is applicable if it concerns: (i) data that we process automatically (without a human factor); (ii) if it is about data that you have given us; and (iii) if it is data that we collect and process based on your consent or to fulfil the contract.
Following your rights as a data subject, we will store the data in accordance with the relevant regulations, whereby the storage periods may depend on the fulfilment of some of our obligations based on a certain regulation. In any case, when it is determined that we no longer need your data and that the legal deadlines for keeping such records and data have passed, we will delete your personal data.
If you wish to exercise one of the aforementioned rights or withdraw your consent for the processing of your personal data (in cases where consent is the legal basis for the processing of your personal data), please contact us. Please note that we will keep a record of our communications so that we can resolve any disputes on time.
You can contact us at any time in the following way:
In the event of a personal data breach, we will notify those whose data is at risk and the competent supervisory authority by e-mail within 72 hours about the extent of the breach, the data covered, the possible impact on our services, and our planned measures to secure data and limit any adverse effects by individuals.
We reserve the right to change this Privacy and Cookie Policy in accordance with changes in legal provisions, business policies of the Company, or other circumstances that affect the area of data protection. In case of changes, we will inform you about it on the website and update the date of modification of the Privacy and Cookie Policy.
We regularly review this Privacy and Cookie Policy and, if necessary, supplement them with additional information because we care about your privacy.
At any time, you can send a complaint to the supervisory authority regarding the collection and processing of personal data. In the Republic of Croatia, you can file a complaint to
Agency for the Protection of Personal Data (AZOP)
Selska cesta 136, 10 000 Zagreb, Croatia
Tel. 00385 (0)1 4609-000, Fax. 00385 (0)1 4609-099
E-mail: azop@azop.hr, Web: www.azop.hr