E-Glas Privacy Policy

Note: For E-Glas d.o.o. we differ between two addresses:

Office & Mailing Address: Rubeši 18B, 51215 Kastav, Croatia, European Union

Headquarters: Ratka Petrovića 54, 51000 Rijeka, Croatia, European Union

Protecting the privacy on the Internet is crucial to the future of Internet-based business and Internet economy. E-Glas d.o.o., Ratka Petrovića 54, 51000 Rijeka, Croatia, European Union, VAT No. HR 01085855307 (hereinafter referred to as “Company”) has created this Privacy Policy to demonstrate commitment to the individual`s right to data protection and privacy. This Privacy Policy outlines how Company handles information that can be used to directly or indirectly identify an individual ("Personal Data").

1. General information

When does this Privacy Policy apply?

This Privacy Policy applies to Personal Data that you provide to Company or which is derived from the Personal Data as outlined below.

Data controller and DPO

Company is the data controller of www.eglas.hr, www.kokolingo.com, www.kokolingo.hr app.us.kokolingo.com, app.kokolingo.co.uk and app.kokolingo.hr (hereinafter referred to as “Company Websites”).

Company’s data protection officer (DPO) is Mr. Marijan Pap, attorney-at-law (privacy@eglas.hr).

What does Company do with my Personal Data?

Company will process the Personal Data provided hereunder only as set out in this Privacy Policy. Further information can be found in Sections 2 and 3 below. Where the processing of your Personal Data is based on a statutory permission, you can find information on which Personal Data Company is processing or using for which purposes in Section 2 below. Where consent for the processing of your Personal Data is required you can find further information in Section 3 below.

Duration of processing of Personal Data

Company will store your Personal Data:

• Only for as long as is required to fulfil the purposes set out below or
• Until you object to Company’s use of your Personal Data (where Company has a legitimate interest in using your Personal Data) or
• Until you withdraw your consent (where you consented to Company using your Personal Data). However, where Company is required by mandatory law to retain your Personal Data longer or where your Personal Data is required for Company to assert or defend against legal claims, Company will retain your Personal Data until the end of the relevant retention period or until the claims in question have been settled.

Why am I required to provide Personal Data?

As a general principle, your granting of any consent and your provision of any Personal Data hereunder is entirely voluntary; there are generally no detrimental effects on you if you choose not to consent or to provide Personal Data. However, there are circumstances in which Company cannot take action without certain Personal Data, for example because this Personal Data is required to process your orders or provide you with access to the Company software or a web offering or newsletter. In these cases, it will not be possible for Company to provide you with what you request without the relevant Personal Data.

Where will my Personal Data be processed?

Company has affiliates and third-party service providers within the European Economic Area (the “EEA”) and in the United States of America. Company’s servers are located in Amazon AWS CloudFront zone us-east-1 in Virginia for US users and Amazon AWS CloudFront zone eu-central-1 in Frankfurt, Germany for EU and all other users.

Whenever Company is using or otherwise processing your Personal Data for the purposes set out in this Privacy Policy, Company may transfer your Personal Data to other countries within the EEA.

What are your rights?

• Right to access Personal Data - You have right to access the data collected on you by Company. Company will respond to that request within 30 days.
• Right to rectification - You have right to request modification of your data, including the correction or errors and the updating of incomplete information.
• Right to erasure - You have right to stop all processing of your data and request your Personal Data be erased.
• Right to restrict data processing - You, under certain circumstances, have right to request that all processing of your Personal Data be stopped.
• Right to be notified – You have right to be informed about the uses of your Personal Data in a clear manner and be told the actions that can be taken if you feel your rights are being impeded.
• Right to data portability – You have right to request that your Personal Data file be sent electronically to you or a third party. Data will be provided in a commonly used, machine readable format, if doing so is technically feasible.
• Right to object - If your request to stop data processing is rejected by Company, you have right to object.
• Right to reject automated individual decision-making – You have right to refuse the automated processing of your Personal Data to make decisions about you if that significantly affects you or produces legal effects.

If Company uses your Personal Data based on your consent or to perform a contract with you, you may further request from Company a copy of the Personal Data that you have provided to Company. In this case, please contact the email address privacy@eglas.hr and specify the information or processing activities to which your request relates, the format in which you would like this information, and whether the Personal Data is to be sent to you or another recipient. Company will carefully consider your request and discuss with you how it can best fulfill it.

Furthermore, you can request that Company restricts your Personal Data from any further processing in any of the following events:

• You state that the Personal Data Company has about you is incorrect, (but only for as long as Company requires to check the accuracy of the relevant Personal Data).
• There is no legal basis for Company processing your Personal Data and you demand that Company restricts your Personal Data from further processing.
• Company no longer requires your Personal Data but you claim that you require Company to retain such data in order to claim or exercise legal rights or to defend against third party claims.
• In case you object to the processing of your Personal Data by Company (based on Company’s legitimate interest as further set out in Section 2 below) for as long as it is required to review as to whether Company has a prevailing interest or legal obligation in processing your Personal Data.

Right to lodge a complaint

If you believe that Company is not processing your Personal Data in accordance with the requirements set out herein or applicable EEA data protection laws, you can at any time lodge a complaint with the data protection authority of the EEA country in which you live or with the data protection authority of the country or state in which Company has its registered seat (Croatia).

Use of Company Websites by children

Company Websites are intended for use by children and minors under age of 16 only in the presence of an adult – parent, guardian or speech therapist.

You are advised to use child’s nickname instead of real name during registration on Company Websites and in correspondence with Company as there is no need or requirement for Company to collect or process any Personal Data of children such as their real names to offer its services.

Links to other websites

Company Websites may contain links to external websites. Company is not responsible for the privacy practices or the content of websites outside Company. Therefore, Company recommends that you carefully read the privacy statements of such external websites.

Data breach procedures

If you believe that the processing of personal data that Company carries out is contrary to the regulations on personal data protection, please inform the Company’s Data Protection Officer at the email address privacy@eglas.hr.

In the event of a personal data breach, Company will notify you and the supervisory authority by email within 72 hours, describing the extent of the breach, data covered, possible impact on Company’s services, Company’s planned data protection measures and limiting any adverse effects on you.

At any time, you can send a complaint to the supervisory body of the Personal Data Protection Agency of Republic of Croatia (AZOP) regarding Company’s collection and processing of your Personal Data. AZOP’s contact details are: Selska cesta 136, 10 000 Zagreb, Croatia, Tel: +385 1 4609 000, fax: +385 1 4609 099, Email: azop@azop.hr, Web: https://azop.hr/naslovna-english/ .

2. Where Company uses my Personal Data based on the law

In the following cases, Company is permitted to process your Personal Data under the applicable data protection law.

Providing the requested software or services

If you order software or services from Company, Company will use the Personal Data that you enter into the order or registration form (usually a subset of) your name, email address, postal address and telephone number. If payment is to be made to Company - IBAN number, credit or debit card number or other bank details may be needed to process your order or to provide the requested software or service. This may also include conversation data that you may enter via the chatbot or chat functionalities on Company Websites, contact forms, emails, or telephone conversations. In this Privacy Policy, “software and services” include (access to) Company Websites, applications, other content, non-marketing related newsletters, whitepapers, tutorials, trainings and events.

If you participate in tutorials or trainings provided by Company, Company may also track your learning progress in order to make this information available to you. Furthermore, Company communicates on a regular basis by email with users who subscribe to Company’s services, and Company may also communicate by phone to resolve your complaints or investigate suspicious transactions. Company may use your email address to confirm your opening of an account, to send you notice of payments, to send you information about changes to Company’s software and services, and to send notices and other disclosures as required by law. Generally, users cannot opt out of these communications, which are not marketing-related but merely required for the relevant business relationship. With regard to marketing-related types of communication (i.e. emails and phone calls), Company will:

• Where legally required only provide you with such information after you have opted in.
• Provide you the opportunity to opt out if you do not want to receive further marketing-related types of communication from us.

Ensuring compliance

Company and its software, technologies, and services are subject to the export laws of various countries including, without limitation, those of the European Union and its member states, of the United Kingdom and of the United States of America. You acknowledge that, pursuant to the applicable export laws, trade sanctions, and embargoes issued by these countries, Company is required to take measures to prevent entities, organizations, and parties listed on government-issued sanctioned-party lists from accessing certain products, technologies, and services through Company Websites or other delivery channels controlled by Company. This may include:

• Automated checks of any user registration data as set out herein and other information a user provides about his or her identity against applicable sanctioned-party lists;
• Regular repetition of such checks whenever a sanctioned-party list is updated or when a user updates his or her information;
• Blocking of access to Company’s services and systems in case of a potential match; and
• Contacting a user to confirm his or her identity in case of a potential match.

Furthermore, you acknowledge that any information required to track your choices regarding the processing or use of your Personal Data or receipt of marketing materials (that is to say, depending on the country in which the Company operates, whether you have expressly consented to or opted out of receiving marketing materials) may be stored and exchanged between members of the Company’s group or larger business entity as required to ensure compliance.

Company’s legitimate interest

Each of the use cases below constitutes a legitimate interest of Company to process or use your Personal Data. If you do not agree with this approach, you may object against Company’s processing or use of your Personal Data as set out below.

Questionnaires and surveys. Company may invite you to participate in questionnaires and surveys. These questionnaires and surveys will be generally designed in a way that they can be answered without any Personal Data. If you nonetheless enter Personal Data in a questionnaire or survey, Company may use such Personal Data to improve its software and services.

Creation of anonymized data sets. Company may anonymize Personal Data provided under this Privacy Policy to create anonymized data sets, which will then be used to improve its and its affiliates’ software and services.

Recording of calls and chats for quality improvement purposes. In case of telephone calls or chat sessions, Company may record such calls or chat sessions in order to improve the quality of Company’s software and services.

In order to keep you up-to-date/request feedback. Within an existing business relationship between you and Company, Company may inform you, where permitted in accordance with local laws, about its software or services (including webinars, seminars, conferences, workshops or events) which are similar or relate to such software and services you have already purchased or used from Company. Furthermore, where you have attended a webinar, seminar, conference, workshop or event of Company or purchased software or services from Company, Company may contact you for feedback regarding the improvement of the relevant webinar, seminar, conference, workshop, event, software or service.

You may object to Company using Personal Data for the above purposes at any time by unsubscribing by sending email to privacy@eglas.hr. If you do so, Company will cease using your Personal Data for the above purposes (that is to say, under a legitimate interest set out above) and remove it from its systems unless Company is permitted to use such Personal Data for another purpose set out in this Privacy Policy or Company determines and demonstrates a compelling legitimate interest to continue processing your Personal Data.

3. Where Company uses my Personal Data based on my consent

In the following cases Company will only use your Personal Data as further detailed below after you have granted your prior consent into the relevant processing operations. If you re-open this Privacy Policy after you have initially one or more consents granted you will not only see the information related to the consents you have granted but the full privacy statement.

News about Company’s services

Subject to a respective provision and your consent, Company may use your name, email and postal address and telephone number as well as an interaction profile based on prior interactions with Company (prior purchases, participation in webinars, seminars, conferences, workshops or events or the use of (web) services displayed on the relevant Company Websites) in order to keep you up to date on the latest software-related announcements, software updates, software upgrades, special offers, and other information about Company’s software and services (including marketing-related newsletters and blogs) as well as events of Company and in order to display relevant content on Company Websites. In connection with these marketing-related activities, Company may provide a hashed user ID to third party operated business and social networks or other web offerings (such as Facebook, Instagram, Twitter, Google (YouTube) or LinkedIn) where this information is then matched against the social networks’ data or the web offerings’ own data bases in order to display to you more relevant information.

Please refer to the privacy guidelines of the respective social network for information regarding the purpose, duration and scope of the data collection, the further processing and use of your data, your respective rights, and setting options to protect your privacy:

• Facebook: http://www.facebook.com/policy.php
• Instagram: https://help.instagram.com/519522125107875
• Twitter: https://twitter.com/privacy?lang=de
• Google (YouTube): https://policies.google.com/privacy?hl=us
• LinkedIn: https://www.linkedin.com/legal/privacy-policy

Creating user profiles

Company offers you the option to use its web offerings including blogs and networks (such as Company’s business and social networks) linked to Company Websites that require you to register and create a user profile. User profiles provide the option to display personal information about you to other users, including but not limited to your name, photo, social media accounts, postal or email address, or both, telephone number, personal interests, skills, and basic information about your company.

These profiles may relate to a single web offering of Company may also allow you to access other web offerings of Company or any of these (irrespective of any consent granted under the section “Forwarding your Personal Data to other Company partner and supplier companies.” below). It is, however, always your choice which of these additional web offerings you use and your Personal Data is only forwarded to them once you initially access them. Note that without your consent for Company to create such user profiles Company will not be in a position to offer such services to you where your consent is a statutory requirement that Company can provide these services to you.

Event profiling

If you register for a webinar, seminar, conference, workshop or event of Company, Company may share basic participant information (your name and email address) with other participants of the same webinar, seminar, conference, workshop or event for the purpose of communication and the exchange of ideas.

Forwarding your Personal Data to other Company partner and supplier companies

Company may transfer your Personal Data to other entities. In such cases, these entities will then use the Personal Data for the same purposes and under the same conditions as outlined in this Section 3. above.

Revocation of a consent granted hereunder

You may at any time withdraw a consent granted hereunder by unsubscribing by sending email to privacy@eglas.hr. In case of withdrawal, Company will not process Personal Data subject to this consent any longer unless legally required to do so. In case Company is required to retain your Personal Data for legal reasons your Personal Data will be restricted from further processing and only retained for the term required by law. However, any withdrawal has no effect on past processing of personal data by Company up to the point in time of your withdrawal. Furthermore, if your use of a Company offering requires your prior consent, Company will not be (any longer) able to provide the relevant service, offer or event to you after your revocation.