Privacy and personal data protection

JADRAN – GALENSKI LABORATORIJ d.d., Svilno 20, 51000 Rijeka (hereinafter: “JGL d.d.”) processes personal data of its service users and visitors of the website rhinnovate.com in accordance with applicable regulations that govern the protection of personal data (EU Regulation 2016/679). JGL d.d. collects and processes personal data in a lawful, fair and transparent manner, in accordance with applicable regulations.

INTRODUCTORY PROVISIONS

JGL d.d. protects the personal rights of every individual whose data it processes, including employees, clients, suppliers and other contract partners, interested parties, etc., regardless of the manner or method by which such personal data is acquired. For this reason, JGL d.d. has defined security standards for processing, storage and transfer of personal data in order to ensure adequate protection of personal data and rights of all data subjects.

The data collected for specified, explicit and legitimate purposes will be collected solely to the extent necessary, and processed in a manner consistent with those purposes. The collected data will be retained as long as necessary for the purpose for which it is collected and will be deleted upon fulfilment of the purpose.

All employees of JGL d.d. have been informed of the data confidentiality policy. Only those authorised to process certain data may process it and they shall not make it accessible to any unauthorised person. Unauthorised persons are also considered to be employees who do not require access to this data to fulfil their duties.

Personal data is stored according to applicable laws and regulations, and it is deleted as soon as the purpose for which it is collected is fulfilled, or at the request of the user.

We expressly state that JGL d.d. shall not sell, share or in any way make the user’s data available to third parties, other than as stated in this Policy. A user’s personal data will occasionally be provided to third parties, which are hired to provide certain services on behalf of or for JGL d.d. or in relation to other business operations of JGL d.d., for further processing whose purpose is in line with the original purpose of collecting data, such as delivering services to users, service analyses, and technical support. These service providers are contractually obligated to use the personal data only for the purposes defined in the contract and expressly state that they shall not sell the personal data nor make it available to other third parties, unless in situations when this is required under legal provisions. In the event that user data is provided to third parties, JGL d.d. will take every measure necessary to ensure that the data is processed only for the purposes that are in line with the purpose of its collection, and within the scope it was initially collected in, with the user’s consent.

There are two additional cases when personal data may be provided to third parties: 1) if the business activity of the company that manages this website and the user data stored on it is sold, assigned or transferred to third parties, in which case the buyer, the successor, or the person to whom the business is being transferred are obligated to handle the personal data in accordance with this Policy; 2) when there are legally binding conditions, a court order, or requests from government authorities, i.e. if disclosing the data is necessary for the purpose of legal proceedings or criminal investigations.

The user has the right to verify whether their data that is stored on this website is up to date and correct. The user also has the following rights: the right to access the data relating to the user, the right to rectification of personal data or to have incomplete personal data completed, the right to erasure of personal data, the right to restriction of personal data processing, the right to withdraw consent to personal data processing, the right to data portability, and the right to lodge a complaint with a competent authority, i.e. the Personal Data Protection Agency.

If at any point you wish to exercise any of the above-mentioned rights, please send an email to osobni-podaci@jgl.hr. State the address of the website where you provided your personal data in your email, and mark the right you would like to exercise and the personal data it relates to. In accordance with the applicable legal regulations governing the protection of personal data, each request/inquiry will be resolved as soon as possible. When contacting us and making the above requests, we will make reasonable efforts to verify your identity and prevent unauthorised processing of personal data. On your request, we will also notify you within the appropriate period whether we collected your personal data during your visits to our website, as well as which data was collected. Requests to delete data are subject to applicable laws and regulations and ethical standards regarding storage, reporting, and recording personal data.

We apply security technologies and procedures required by law to protect the safety and confidentiality of the user data we collect, and all of the data is also password protected. When we process data, we take all necessary precautions to protect personal data from loss, misuse, unauthorised access, transfer, modification or destruction, as well as all necessary security measures to protect personal data from these risks.

JGL d.d. may collect and process anonymous data regarding access to its website or searches performed by visitors to the site. Such anonymous data is used to improve stored content, i.e. to collect aggregate statistical data on visitors and use it for internal market research. To this end, the JGL d.d. website uses cookies that collect data on the user’s email address and domain name (e.g. “bigmail.com” from the email address john@bigmail.com), as well as on the date and time of accessing the site. Cookies set up by our network server cannot be used to identity individual users. A cookie is a small text file that the website server sends to the user’s browser and stores on the user’s computer hard drive. Cookies do not damage the computer.

Browser settings can be adjusted to inform the user of sending cookies, and the user can then decide whether or not they will accept them. With the user’s consent, JGL d.d. may occasionally hire third parties to help them with data collection and processing as specified in this Article, in which case the third parties undertake the responsibilities under Article 1. JGL d.d. may occasionally use network tags (i.e. digital images known as action labels, single-pixel GIFs, pure GIFs, invisible GIFs, and 1×1 GIFs) to help deliver cookies, or in other words, to deliver services of other advertising companies. These tags are placed on online ads that lead users to the JGL d.d. website. The tags are used to count the number of users accessing our website and generate statistical data on the efficiency of our promotional campaigns (including counting the instances of access to individual pages, collecting information on content viewed, etc.). Due to cookies and network tags placed on the user’s computer, our third-party advertising partners can also collect anonymous, aggregate statistical data on visitors accessing other websites.

We expressly state that JGL d.d. will not use the cookies and network tags to collect personal data that can be used to directly identify a user, such as name, postal address, email address and phone number, without the user’s prior consent. For additional information on network tags and cookies used for online advertising, or to opt out of targeted online advertising, please visit the Network Advertising Initiative website.

COLLECTION AND USE OF USERS’ PERSONAL DATA

JGL d.d. may, at its sole discretion and without prior notice, change, modify, amend, remove, or otherwise update this Data Protection Policy. Any changes that we make will be published on this website to fully inform the users of the type of personal data that is being collected, the way the data is used, and the conditions under which the data can be accessed. If any amendments are made to the Policy, you will be notified of it on this page, and the revision date will be updated.

WHAT IS PERSONAL DATA?

For the purpose of this Data Protection Policy, the term “personal data” means any data, such as name and surname, email address, IP address, etc., in other words, any data relating to an identified or identifiable individual. JGL d.d. normally does not process personal data without the user’s consent. However, JGL d.d. reserves the right to perform additional data processing in exceptional circumstances, in the scope allowed or stipulated by law, i.e. as part of legal proceedings or criminal investigations. A detailed explanation of how and when user data is collected is provided below.

DATA PROCESSING PRINCIPLES

JGL d.d. collects and processes personal data solely in accordance with the core principles of EU Regulation 2016/679 (hereinafter: “GDPR” or “Regulation”), which includes:

• Lawful, fair and transparent processing of personal data;
• Collection of personal data exclusively for specified, explicit and legitimate purposes;
• The adequacy of personal data and its relevance in relation to the purpose for which it is processed;
• Accurate and, if necessary, up-to-date personal data; every reasonable step must be taken to delete or correct inaccurate, incomplete data, given the purposes for which it was collected or for which it is further processed;
• Keeping personal data in a form that ensures that the data subject can only be identified for as long as necessary for processing;
• Processing personal data in a manner that ensures an appropriate level of data security.

DATA SUBJECT RIGHTS

The data subject, who is the subject of data processing activities, has the following rights regarding their personal data in accordance with legal provisions.

• Right of access;
• Right to rectification and erasure;
• Right to restriction of processing;
• Right to data portability;
• Right to object.

You have the right to file a complaint with the competent supervisory authority regarding the processing of your personal data.

DATA COLLECTION AND PROCESSING WHEN VISITING OUR WEBSITE

No login/registration is required to access most of our services so our website can be used without revealing the users’ identity. However, some services do require the user to login/register. Certain fields need to be filled during the login process (some are mandatory, others optional). If a user decides to withhold the necessary personal data in such cases, they will not be able to access the requested sites, and JGL d.d. will be unable to respond to their query/request. Personal data is processed only for the purpose for which it is collected, of which the user is informed and for which they gave their consent at the time of collection. For example, JGL d.d. may collect and use personal data from users for the purpose of informing them of products and services, of sending marketing messages on other products and services the user might be interested in, and of communicating with users.

When you visit our website solely for informational purposes, or if you do not register or otherwise provide your information, we only collect the personal data that your browser sends to our server, which is technically necessary for us to be able to offer our website and guarantee its stability and security.

COOKIES

STRICTLY NECESSARY COOKIES

Strictly necessary cookies enable basic functionalities. Without these cookies, the website cannot function properly, but they can be switched off by changing the settings in your web browser. Cookies of this type are considered strictly necessary in the context of the Privacy Directive 2002/58/EC and they require the user’s consent.

Legal basis: Art. 6(1)(f) of the GDPR (Legitimate Interest)

ANALYTICAL COOKIES

Analytical cookies help us improve the website by collecting and analysing usage data. We record clicks and movements on our website to understand which areas of our website attract user interest the most. The outcome of the analysis is content customisation of our site according to user needs. Your computer’s IP address transmitted for technical reasons is automatically anonymised and does not allow us to draw conclusions about individual users. You can customise your consent to the use of analytical cookies at any time via the LINK (Cookie Settings).

Legal basis: Art. 6(1)(a) of the GDPR (Consent)

MARKETING COOKIES

We use marketing cookies to increase the relevance of the ads you see. They record visits to websites for the purpose of showing ads tailored to your interests. They are also used to limit the number of ad impressions and measure the effectiveness of ad campaigns. Marketing cookies come from a third party and are used to collect information about websites that the user has visited in order to create targeted advertising for the user. You can customise your consent to the use of marketing cookies at any time in Cookie Settings. 

Legal basis: Art. 6(1)(a) of the GDPR (Consent)

WEBSITE ANALYTICS

GOOGLE ANALYTICS

We use the Google Analytics service to rationalise our website: (i) by optimising Internet traffic, i.e. visits to the company website and connections to other websites in our business system, and, when necessary, (ii) by integrating the contents and optimising our web pages. Google Analytics is a service provided by Google Inc. It includes detailed statistical data on visits to web pages and on locations users are visiting from, and it measures conversion and sales results. Google Analytics uses cookies stored on your computer to analyse the way our website is used.

Algorithms that guarantee user anonymity are applied to the usage data of our website, including your IP address, which is collected using cookies, and the data is sent to Google’s servers in the USA.

Google Analytics has been expanded on this website to include the code “gat._anonymizeIp ();” in order to ensure anonymous recording of IP addresses (so-called “IP masking”). Due to the anonymisation of IP addresses on this site, Google has shortened your IP address in the EU and member states of the European Economic Area. Only in exceptional circumstances is the complete IP address transmitted to a Google server in the USA and shortened there.

Google will process the data collected using cookies for us in order to evaluate usage methods and create reports on activities on our website, which they will deliver to us for analysis. Google has the right to forward this data to third parties in accordance with legal obligations or in case analysis is being performed by a third party on behalf of Google. Google will in no way connect or associate your IP address with other data they have at their disposal. You can disable the cookie download and storage features in your browser settings. Please note that by doing so, you will not be able to make use of all the functions that are available on our website. By using our website, you agree that Google may collect and process your personal data in the above manner and for the purposes described above. Data processing by Google may be further restricted by using a browser add-on available at Google Analytics Opt-out Browser Add-on Download Page.

Since data transfer to third countries is possible, appropriate protection is used in the form of a standard contractual clause in accordance with Art. 46 of the GDPR. For more information on the topic please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_en.

GOOGLE TAG MANAGER

We use Google Tag Manager, which allows you to manage web page bookmarks through a specific interface. Google Tag Manager only uses tags, which means that no cookies are used and no personal data is collected. Google Tag Manager launches other tags that collect data as necessary, but it does not retrieve that data. If deactivation is performed at the domain or cookie level, it remains valid for all tracking tags if it is implemented with Google Tag Manager. Data transfer to third countries is possible.

GOOGLE ADSENSE

We use Google AdSense to provide advertising services to provide a better and more targeted type of ad serving, but also to limit the impressions of certain ads. For more information on the Google AdSense service, visit the official website and privacy FAQ.

Legal basis: Art. 6(1)(a) of the GDPR (Consent)

GOOGLE ADS & DISPLAY AND VIDEO 360 (doubleclick)

We use Google Ads to draw your attention to our offer with the help of ads we place through the Google Ads platform. Google delivers ads through so-called “ad providers”, and we use ad server cookies to measure ad performance for this purpose. Google Ads stores cookies on devices, and we have no influence over the extent or subsequent use of data collected by Google. We invite you to read more on the purpose and scope of Google’s collection and processing of data in Google’s Privacy Policy at: https://policies.google.com/privacy?hl=en. Transfers to third countries are possible. As an appropriate protection of the standard contractual clause, we apply Art. 46 of the GDPR. For more information on the topic please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_en.

You can manage your cookie consent rules by adjusting cookie settings accordingly.

Legal basis: Art. 6(1)(a) of the GDPR (Consent)

FACEBOOK PIXEL 

Where Facebook Pixel is used, your browser automatically establishes a direct connection with the Facebook server after you agree to the use of cookies that require consent. By integrating the Facebook Pixel tool, Facebook receives information that you have referred to a website that matches ours or that you have clicked on our ad. If you are registered as a Facebook user, Facebook may link your visit to your account. 

Processing this data by Facebook takes place in accordance with the Facebook Data Protection Policy. Specific information and details about the Facebook Pixel tool and its functionality can be found in the Facebook Help Center – https://www.facebook.com/business/help/742478679120153?id=1205376682832142  

You can manage your cookie consent rules by adjusting cookie settings accordingly. 

Legal basis: Art. 6(1)(a) of the GDPR (Consent) 

YOUTUBE VIDEOS

We have embedded video content stored on the YouTube platform in certain parts of the website. Data transfer takes place the moment you click on a video to start playing it. JGL d.d. has no control over this data transfer. Further information on the purpose and scope of YouTube’s data collection can be found in the YouTube Privacy Policy.

NEWSLETTER

JGL d.d.’s newsletter contains offers, news and other information. Users can subscribe to the newsletter by entering their email address on the website and by giving their consent for the use of the email address for the purpose of sending personalised information of the JGL d.d. Group.

We distribute our newsletter through the Webpower system of the company WebPower Adria d.o.o., Ulica grada Vukovara 284, Zagreb, Croatia. WebPower is adapted to the Privacy Shield data protection agreement, and must comply with EU privacy rules. WebPower will not contact you directly or use your data. The data will not be forwarded to third parties. The data used by WebPower includes a “web beacon” that sends information on opening the newsletter and/or activating links within the newsletter. As part of this process, information about your Internet browser, your IP address and your location will be sent to WebPower. If you no longer wish to receive the newsletter, you can unsubscribe at any time. Click on the link contained in each newsletter.

Legal basis: Art. 6(1)(a) of the GDPR (Consent)

CAPTCHA VERIFICATION

In certain cases, our website uses Google’s reCAPTCHA service to prevent automated bots from using text fields. We use reCAPTCHA to improve the security of our website and to avoid unwanted content for users.

You can find out more in Google’s Privacy Policy at: https://policies.google.com/privacy.

Legal basis:

Art. 6(1)(c) of the GDPR (Data Processing for Compliance with a Legal Obligation)

Art. 6(1)(f) of the GDPR (Data Processing in Accordance with the Above-mentioned Legitimate Interests)

PRIZE DRAWS/COMPETITIONS

If you participate in prize draws or competitions, we use the personal information you provide to conduct the contest. You are not required to provide your personal information. If your data has not been submitted, you cannot participate in the prize draw or competition, and additional information on the purpose, data retention period and method of deletion can always be found in the rules governing the prize draw or competition.

Legal basis: Art. 6(1)(a) of the GDPR (Consent)

SOCIAL MEDIA AD-ONS

On this website, you can share (click on the “Share” button) certain content via social media, such as Facebook, Twitter and LinkedIn. Information on data collection by these social media platforms is available below:

• Facebook (Meta) Hacker Way Menlo Park, California 94025: http://www.facebook.com/help/186325668085084, http://www.facebook.com/about/privacy/your-info-on-other#applications, and http://www.facebook.com/about/privacy/your-info#everyoneinfo
• Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA; https://twitter.com/privacy.
• LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA; http://www.linkedin.com/legal/privacy-policy.

CONTACT FORM

If you contact us by email or via the contact form on our website, the information you provide will be stored and processed in order to respond to your questions and requests or for the purpose of business correspondence. We delete the data when it is no longer needed, unless there are legal obligations to retain it or restriction deadlines must be met.

In this case, we have a legitimate interest in processing the data in accordance with legal requirements, for internal verification or in accordance with the relevant communication requirement.

Legal basis: Art. 6(1)(a) of the GDPR (Consent)

UNDERAGE USERS

Most of the services available on the JGL d.d. company website are aimed at persons over the age of 18. Persons requesting information on medication for use in children must be older than 18. We will not knowingly collect, use, or share personal data of persons under the age of 18 without prior consent from their parent or guardian. We will 1) inform the parents of the type of personal data that is being collected from individuals under the age of 18 and 2) offer them the option to revoke their consent to collect, use or share their children’s personal data with third parties. JGL d.d. strictly complies with all laws and regulations regarding the protection of minors.

Data Storage Period

JGL d.d. will retain the user’s personal data for as long as necessary for the provision of products or services; as long as necessary in accordance with this Policy or the collection period; as long as necessary to fulfil our legal obligations, resolve disputes and enforce our contracts; or to the extent permitted by law.

To determine the data retention period, we follow the following guidelines:

• If the user participates in an organised promotional competition, we store their data for the duration of the competition as foreseen in the rules governing the prize draw or competition;
• If we receive a request from the user, we store personal data for a period necessary to process the request;
• If the user gives their consent to receive the newsletter, we store the data until the moment they unsubscribe from the newsletter or after a period of prolonged inactivity;
• If cookies are stored on the user’s computer and/or mobile device, we store them while they serve their purpose.
• Once the retention period expires, JGL d.d.  will delete the personal data in a manner that ensures that it cannot be reconstructed or read.

The default cookie storage periods are provided below:

If you have any questions or complaints regarding this Data Protection Policy, or if you would like to share your comments and recommendations for improvement, please email us at osobni-podaci@jgl.hr.

Last updated: 6. 4. 2022.