This is the Privacy Statement and Policy (“Privacy Statement”) for IMELUM LLC (“IMELUM”).
IMELUM understands that your privacy is important and is committed to protecting your privacy and personal information you provide or as you access and use materials on www.imelum.com (the website), including the subscription pages or other websites or apps that post a link to this Privacy Statement. In addition, information that you submit to IMELUM in response to an email request for information will be treated in accordance with this Privacy Statement.
IMELUM may, in its discretion, amend this Privacy Statement from time to time. To ensure you are able to remain informed about the information we collect and how we use it, material changes to our statement will be reflected here. This website may contain links to external websites which are not governed by this Privacy Statement. IMELUM does not take responsibility for the privacy practices of any third party websites to which we link. We encourage you to review the privacy policies of any such websites before you submit information there.
YOUR ACCEPTANCE OF THIS PRIVACY STATEMENT
Please read this Privacy Statement carefully. By browsing our website and expressly consenting where required (for instance, when subscribing to our newsletters), you agree to be bound by this Privacy Statement.
INFORMATION THAT WE COLLECT AND HOW WE USE IT
What information do we collect?
IMELUM collects information from you when you create your account for the website, subscribe for email newsletters and seek additional information regarding our services. If you do not provide such information, you will not be able to create an account for the website, subscribe for email newsletters and seek additional information regarding our services.
Personal information that we collect includes: names, addresses, e-mail addresses, phone numbers, unique personal identifiers, financial information, subject areas of interest and/or demographic information.
In addition, we sometimes aggregate demographic information and the types of systems and browsers of users IMELUM also may conduct user surveys on the website or use technologies to provide IMELUM with information on a number of areas, such as user identity, user viewing habits, whether or not users found what they were searching for, whether the Website content is relevant to user needs, and the like.
How do we use personal information?
The purposes and uses of your personal information will depend on the use of the website and the personal information provided. We process your personal information:
(i) for the purposes of safeguarding the legitimate interests pursued by IMELUM. This includes:
– Informing you about updates to the service and notifying you about other services offered by IMELUM that may be of interest to you, including information regarding publications
– Tailoring your experience at the website with relevant IMELUM materials
– Understanding the website’s user population, identifying subject areas of interest, and determining whether the Website is designed to work with the computer settings of a majority of our – visitors
– Measuring and improving the effectiveness of IMELUM marketing programs.
– Improving our web content and navigation.
(ii) on the basis of your consent. Insofar as you have granted us consent to the processing of personal information for specific purposes (for example, you have subscribed to our free newsletter), the lawfulness of such processing is based on your consent. You may withdraw your consent at any time.
(iii) for compliance with a legal obligation.
We will not sell, share, or rent or otherwise make available your personal information to other parties, except that we may disclose the information to third parties who perform services on our behalf and have a need to access the information in connection with those services. Any third parties will only process this information to the extent to which and within the limits that IMELUM itself is permitted to process that data.
HOW WE MIGHT SHARE YOUR INFORMATION
The third parties with whom we may need to share personal information to help us provide services and products to you and to run our website include:
our third party service providers who process information on our behalf to help run some of our internal business operations including email distribution, IT services and marketing and events services;
law enforcement bodies in order to comply with any legal obligation or court order
Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.
We hold the following information about you within our EMS system:
– Name and surname
– Email address
– I.P address
– Subscription time and date
This also includes third parties located outside the European Economic Area (EEA). These arrangements, for example, involve your personal information being located in the USA where our EMS provider is based. We will only ever use providers based in the USA if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the European Union and the USA. We will only transfer your personal data to countries outside the EEA or USA where the European Commission has deemed any such countries provide an adequate level of protection of personal data. In addition, this website may be viewed and accessed anywhere in the world including countries that may not have laws regulating the use and transfer of personally identifiable information. By using the website, submitting information through this website, or submitting personal information to IMELUM through other means you voluntarily consent to such international transfer and hosting of such information to those countries and parties.
RETENTION OF YOUR PERSONAL INFORMATION
IMELUM retains your personal information for so long as is necessary to fulfil the purpose for which it was collected. We may retain your personal information for longer if they may be the subject of a legal claim, or may otherwise be relevant for future litigation.
If, at any time, you prefer not to receive further communications from us in any or all forms you will have the ability to unsubscribe from such communications by means of a link provided in every e-mail that is sent to you by us. When subscribing to IMELUM e-mail newsletters, you are given the opportunity to select which promotions, news, and information you would like to receive at the time of sign up, and you will have the opportunity to unsubscribe from such communications.
COOKIES AND OTHER TRACKING TECHNOLOGIES
We use the following types of cookies:
“persistent cookies” to improve your experience when using the website.
“session cookies” to enable your use of our website and to remember your settings. Session cookies are deleted automatically at the end of your visit.
“web analytics cookies”. These cookies are used by us or third-party providers to analyse how the Website and our services are used, including the following types:
Web beacons. IMELUM includes a web beacon, which is a graphic image, in a majority of the HTML email messages we send. IMELUM uses web beacons, alone or in conjunction, with cookies to compile information about your usage of our website and interaction with emails from IMELUM. We use the capability to determine whether or not an email has been received, opened, or when an URL has been clicked inside of an email that directs you to one of IMELUM’s website. These web beacons are used to: (i) operate and improve our website, services, and email communications, (ii) send emails in a format users can read and (iii) track the aggregate number of emails opened. The web beacon does not collect your personal information, however the information compiled by the web beacon allows us to tie a user to information IMELUM has collected in data collection processes as set out in this Privacy Statement. You may refuse the use of web beacons by selecting the appropriate settings on your email program to disable image and refraining from clicking on any links in email messages.
By continuing to browse or use our website and services, you agree that we can store and access cookies and other tracking technologies as described herein.
IMELUM has in place appropriate technological and operational security processes designed to protect personally identifiable information from loss, misuse, alteration or destruction. Only authorised employees and contractors will have access to any data provided by you, and that access is limited by need. Each employee or contractor having access to any personally-identifiable information is obligated to maintain its confidentiality. Although we take steps that are generally accepted as industry standard to protect your personally-identifiable information, IMELUM cannot guarantee that your personally-identifiable information will not become accessible to unauthorised persons and IMELUM cannot be responsible for any actions resulting from a breach of security when information is supplied over the internet or any public computer network.
LINKS TO OTHER WEB WEBSITES
This website contains links to other websites not operated by IMELUM.
IMELUM is not responsible for the privacy practices or the content of any non-IMELUM websites to which we link from the website. We are not responsible for the protection and privacy of any information you provide whilst visiting other websites and websites not governed by our Privacy Statement. We cannot control the content or security of such websites. We cannot be held responsible for any loss or damage incurred by a user as a result of visiting such websites. No links are intended to be, nor should be construed as, an endorsement of any kind by us of that other website.
COMPLIANCE WITH LAW
IMELUM complies with all applicable privacy laws and regulations. IMELUM may be compelled to surrender personal user or customer information to legal authorities if presented with a court subpoena or similar legal or administrative order, or as required or permitted by the laws, rules and regulations of any nation, state or other applicable jurisdiction.
In accordance with the GDPR, you have a right to request a copy of the personal information we hold about you and details of how we use that information. If any of the information held about you is incorrect or out of date, you have the right to amend or rectify it. As your privacy is important to us we encourage you to ensure the data you provide us is correct and current. Please follow the process outlined below and we will amend our records where appropriate. You also have the right to require us to erase your personal data, stop processing your personal data, restricting the processing of your personal information, right of portability of your personal information and/or to withdraw your consent to processing. This may not apply if there are other legal justifications to continue processing. If you think we may have incorrect personal information, or would like a copy of the personal information we hold on you, or to exercise any other data protection right, please contact us here: email@example.com. Please note that we need you to prove who you are before we can provide you with any information.
You also have a right to lodge a complaint with the Croatian Personal Data Protection Agency (AZOP) here. We would however appreciate the opportunity to first resolve any data protection issues you may have with us. We therefore encourage you to contact IMELUM in the first instance if such matters arise.
IMELUM understands the importance of protecting children’s privacy, particularly in their online interactions. This Website is not designed for and does not intentionally target or solicit to children 18 years of age and younger.
Zagreb, December 2018