PRIVACY STATEMENT

GENERAL INFORMATION

‍
Televizija Classicum LLC, seated in Zagreb, Šoštarićeva 10, PIN: 04702559401 ("Company", "Controller", "we", "us", "our") collects and processes certain personal data about you, in accordance with this Privacy Statement.

With this Privacy Statement, with the aim of ensuring a fair and transparent processing, the Company wishes to provide its service users with clear information about the use and protection of their personal data and enable an easy control and managing of their personal data and consents.

The Company is committed to protecting the privacy and personal data.

If you have any questions regarding the protection of your personal data, please contact our person responsible for personal data protection via email at: zorislav@klasiktv.com.

We reserve the right to change this Privacy Statement at any time, for whatever reason. In the event that any changes are made, the users will be informed about it on the website www.doxtv.rs ("Website").

We may remind you periodically of the Privacy Statement text via e-mail, while you can always find the current version of the Privacy Statement on the Website.

‍

PRINCIPLES FOR PROCESSING OF PERSONAL DATA

‍
The Controller processes the personal data of the Website visitor and newsletter recipient ("Data Subject", "you", "your") by adhering to the following personal data processing principles:

Lawfulness, fairness and transparency - The Company processes the personal data lawfully, and offers the Data Subject easily accessible and understandable information and communication regarding personal data processing;

Purpose limitation - The Company collects and processes personal data only for a specific and legitimate purpose, and does not process the data any further in a way that is not in line with the purpose for which they were collected;

Data minimization - The Company uses only the data of Data Subjects that are adequate, relevant and limited to what is necessary in order to achieve a specific lawful purpose;

Accuracy of personal data - In order to ensure a fair and transparent processing of personal data, and prevent possible misuse, the personal data must be accurate, complete and up-to-date. It is very important to us that the Data Subject notifies the Controller of any changes to their personal data immediately or as soon as possible;

Storage limitation - The Company stores the Data Subject's personal data in an identifiable format only for a period of time needed for processing purposes, and, when that period has expired,  deletes them from all records, i.e. applies anonymization and/or pseudonymization;

Integrity and confidentiality - The Company processes personal data in a way that ensures appropriate personal data protection, including the protection against unauthorized or unlawful processing, and against accidental loss, destruction or damage (for instance, only authorized persons, whose job necessitates it, have access to personal data of Data Subjects).

‍

PERSONAL DATA PROCESSED AND THE USE OF PERSONAL DATA

‍
This Privacy Statement explains several concepts, principles, and privacy and protection policy:

Types of personal data the Controller collects about you;

The manner in which the Controller obtains your personal data;

The manner in which the Controller uses your personal data;

The purpose based on which the Controller uses your personal data;

The third parties with which the Controller shares your personal data;

How the Controller protects your personal data; as well as

Whether the Controller shares your personal data outside the European Union and why.

TYPES OF PERSONAL DATA THE CONTROLLER COLLECTS AND PROCESSES
The Controller collects only those personal data necessary to achieve certain legitimate processing purposes.

The Controller may collect your personal data for the purpose of conducting its business, including the instances when you are addressing the Controller, asking for information from the Controller or using the Controller's services.

The personal data of the Data Subjects that the Controller collects and processes include:

Personal identification information: name and surname;

contact details: e-mail address;

technical data (the number of Data Subject's Website visits, or receipt and use of materials and communications sent by the Controller to the Data Subject electronically) collected through cookies;

and other information about the Data Subjects that they may provide to the Controller (for instance, by contacting the Controller via e-mail, phone etc.)

The Controller does not process special types of personal data of Data Subjects which may reveal racial or ethnic background, political orientation, religious or philosophical beliefs, trade-union membership, genetic data, biometric data, health-related data or data concerning the Data Subject's sex life or sexual orientation, nor personal data regarding criminal convictions and offences.

MANNER OF COLLECTING PERSONAL DATA
The Company collects personal data of Data Subjects in various ways, which include:

the Data Subject's subscription to the newsletter on the Company's Website;

during direct communication with the Company, when the Data Subject delivers information, including personal communication with the Company staff and online communication via the Website and e-mail;

during the Controller's Website visits, including pages and e-mail communication directed to and from the Company;

as part of business processes of the Company with its business partners.

When the Controller collects personal data of Data Subjects in any of the aforementioned manners, it uses them exclusively for the purpose specified to the Data Subject at the moment of the collection of such data.

‍

PURPOSE AND PERIOD OF PERSONAL DATA STORAGE

‍
When the Controller collects and processes personal data of the Data Subject, it does so in order to:

fulfill contractual obligations with the Company's business partners; offer services of the Company and/or its affiliates on the market, including sending of publications and newsletters to Data Subjects;

perform Website analysis and administration, including the monitoring of Website usage;

make available the data requested by the Data Subject.

A. FULLFILMENT OF CONTRACTUAL OBLIGATIONS
The Controller, as a service provider to its business partners, collects the following personal data about its Data Subjects: name, surname and e-mail address.

The stated personal data are being collected for the purpose of concluding and executing agreements by the Controller, as a service provider, and conducting business processes which include solving possible disputes with business partners.

To the extent that is reasonably necessary for the provision of Company's services, it is possible that the Controller will have to share personal data with third parties. Please see the Subsection "Third parties with whom we share the Data Subjects' personal data".

The personal data collected for this purpose shall be deleted from all data-keeping systems of the Controller and its data processors (if applicable) not later than 8 days after the business relationship between the Company and its business partner has ended, but longer if the Controller is obliged by law to store the aforementioned data further.

B. MARKETING, DEVELOPMENT AND IMPROVEMENT OF THE COMPANY'S SERVICES
The personal data delivered to the Controller by the Data Subject (specifically: name, surname and e-mail address), the Controller may use in order to find out whether:

the Data Subject is reading e-mails or other materials of the Company, including the newsletter, by opening attachments or clicking on the links sent;

the Data Subject is opening web, unsubscribe or event links included in the e-mails and marketing materials of the Company;

the Data Subject is visiting the Website and how, after clicking on the links provided by the Company. This is done by using software which stores cookies on the Data Subject's device, which then track this activity and record it. Please see the Cookie Usage Notice, which is part of this Privacy Statement.

Some of the aforementioned Data Subjects' data, the Controller also uses for the purpose of sending out marketing messages, newsletters and information about the Company's services via e-mail, in order to promote the Company.

If you no longer wish to receive these marketing messages, newsletters or e-mails about the Company's services, you can unsubscribe at any moment by sending an e-mail to: marketing@dox-tv.com.

The personal data collected for this purpose are stored permanently, or up to the moment the Data Subject unsubscribes, as described in the previous paragraph.

THE LEGAL BASIS FOR PROCESSING OF PERSONAL DATA
The Controller processes personal data of Data Subjects on the following legal basis:

Unconditional consent, given out of Data Subject's free will, to receive marketing messages, newsletters and e-mails about the Company's services;

The conclusion or execution of agreements of the Company, as a service provider, or other agreements concluded between the Company and its business partners;

The legitimate interest of the Controller in processing for a specific purpose: sharing of personal data with third parties, as it is specified in detail in this Privacy Statement.

THE THIRD PARTIES WITH WHOM THE CONTROLLER SHARES YOUR PERSONAL DATA
The Company may share the Data Subject's personal data with third parties - business partners of the Controller - in accordance with contractual obligations it has with them. The aforestated represents a legitimate interest of the Controller.

The Company may use the services of other vendors for the purposes of newsletter performance analysis, such as Google, Facebook, MailChimp, which may store your e-mail address when used, according to their service terms and conditions. The Company does not share the Data Subject's e-mail address directly with the aforementioned vendors.

The Controller may share the personal data with supervisory authorities, courts or authorized institutions when such data sharing is necessary, including abiding by all laws and regulations. Unless prohibited by law, we will make all reasonable efforts to inform you of such a disclosure of your personal data carried out by the Company.

The Company does not allow Data Subject's personal data to be made available to third parties for the purpose of offering third-party products and services, unless the Data Subject has given his/her explicit consent for that purpose.

‍

PROTECTION OF YOUR PERSONAL DATA

‍
The Company takes personal data protection seriously and has taken various precautions to protect your personal data.

In accordance with applicable law on the protection of personal data, the Company uses technical and organizational measures to protect personal data against unauthorized access, use, disclosure or destruction.

In order to protect the personal data of Data Subjects and their privacy, the Company carries out appropriate physical, technical and organizational protection measures. Maintenance and safety testing is carried out on an ongoing basis. The Company restricts access to the data of the Data Subjects by allowing access only to authorized persons for whom that is necessary in order to perform duties defined in their job description. In addition, the Company continuously trains its personnel on the importance of confidentiality and maintaining of privacy and personal data security and engages partners with whom it contracts appropriate protection measures.

‍

RIGHTS OF THE DATA SUBJECT

‍
Right to Object - The Controller seeks to ensure the highest standards in processing of personal data and approaches every complaint of Data Subjects and their resolution seriously. In case you consider that the processing of personal data performed by the Controller is contrary to personal data protection regulations, please notify us in writing to the Controller’s address or via e-mail address: info@dox-tv.com. Your objection can also be addressed to the Supervisory Authority - Personal Data Protection Agency, Zagreb, Martićeva 14 and, from May 25 2018, you may also refer to the supervisory authority within the EU.

Right of Access: Every Data Subject has the right to request details of personal data processed by the Controller in relation to him/her, and the manner in which they are processed.

Right to Rectification and Amendment: If your personal data the Controller processes is incomplete or inaccurate, you can request a correction or amendment of such data from the Controller at any time. Please notify us of any changes to your personal data via e-mail: zorislav@klasiktv.com in order for us to update your data.

Right to Erasure ("Right to be Forgotten"): You may request that the Controller delete your personal data if they have been processed unlawfully or if the processing represents disproportionate interference with your protected interests. Please note that there are reasons that prevent instant deletion, for example, in case of archiving obligations required by law.

Right to Restriction of Processing:

You may request a restriction of processing from the Controller:

if you dispute the accuracy of the data for a period that enables the Controller to verify the accuracy of such data;

if the processing was unlawful and you refuse the deletion of your data and request the restriction of processing instead;

if the data is no longer needed for the purpose of data processing, but you require it to assert legal claims; or

if you have filed an objection to the processing of such data.

Right to Data Portability: You can request the data you have entrusted to the Controller to be delivered to you in a structured form, and readable format:

if this data is processed based on a consent you have given and which you can withdraw or for the execution of an agreement, and

if the processing is performed using automated processes.

Under certain circumstances, each Data Subject is also entitled to request the termination of any unauthorized transfer of his/her personal data to third parties and to demand that the Controller does not deliver personal data which concern him/her to third parties.

Exercising Rights: If you wish to exercise any of these rights, please contact us using our contact information: Televizija Classicum d.o.o., Zagreb, Šoštarićeva 10, or the e-mail address: zorislav@klasiktv.com.

Misuse of Rights: If you use any of these rights with an obvious intent to misuse them, the Controller may charge an administrative fee or decline to process your request.

When you object to the processing of your personal data by the Controller or when you withdraw consent, there is a possibility that the Company will not be able to achieve the processing purpose specified in this Privacy Statement or that you will not be able to use our services. Withdrawal of a given consent does not affect the legitimacy of processing of data that was based on the consent given prior to the withdrawal.

When you object to the processing of your personal data by the Controller or when you withdraw consent, it is important that you understand that the Company has a legal basis to continue to process your personal data to the extent required or otherwise permitted by law.

CONSEQUENCES OF PERSONAL DATA DENIAL AND MANAGEMENT OF CONSENTS
If you notify the Company that you no longer wish to receive marketing messages, newsletters or direct e-mails about Company services, we shall no longer send you marketing messages, newsletters nor direct e-mails about Company services.

You may withdraw a consent you have given to the Company for a particular processing purpose at any time. In that case, your personal data collected on the basis of this consent will no longer be used for the purpose mentioned.

You can change the consent on the Website or by sending an e-mail to the e-mail address: zorislav@klasiktv.com.

‍

COOKIE USAGE NOTICE

‍
We inform you that the Company uses cookies on its Websites.

Cookies are text files stored on the Website visitor's device. We use cookies to ensure the functionality of all Internet portal functions that are necessary for the optimal functioning of the Website or without which the access to the Website is not possible. Such Cookies cannot be excluded nor deleted because the pages would not function properly without them. However, it is important to stress that the mentioned cookies do not collect nor store any personal data, but only the technical information necessary for the correct operation of the Website.

You may also find third-party cookies (such as Google Analytics, Facebook, etc.) on the Website, as well as advertising cookies and similar links, which may also collect certain personal data about you. These cookies are not set up or controlled by the Company. For more information on how a third party uses cookies and how you can manage them, please visit the appropriate third-party websites. The third-party cookies used on the Website are: Facebook and Google Analytics - a service for measuring website traffic.

Analysis cookies, third-party cookies, advertising cookies, and similar cookies can be stored on your device only with your explicit consent. You can either disable or delete such cookies by selecting the appropriate settings of your browser.

Most web browsers accept cookies, but you can usually change your browser settings to reject new cookies, disable existing ones, or simply notify you when new cookies are sent to your device. The third-party cookies used on the Website are: Google Analytics - a service for measuring website traffic, and Facebook pixel.

To set up your browser to refuse cookies, see the instructions in the help section of your browser (usually found under "Help", "Tools" or "Edit").

Please note that certain page functionality may be lost if you decline or disable cookies. In addition, disabling cookies or cookie categories does not delete the cookie from your browser. You have to do this yourself manually in the browser menu. By adjusting the browser settings you can manage the cookie policy on your device. You can always withdraw your cookie consent in the same way, by adjusting your browser settings.

Your personal data collected through cookies is not shared with third parties without your explicit consent.

You can find the rights of the Data Subject and other information regarding the personal data that is collected by cookies in the Privacy Statement.

Should you have any questions regarding privacy, or objections or questions regarding this Statement, please contact us via e-mail at: zorislav@klasiktv.com.

‍