Policy in effect as of 01/2023
We, LJUBICIC SPORT d.o.o., with our registered office located at Veli Lošinj, Šestavina 17A, OIB (Identification number) 85422457143 (hereinafter referred to as “Academy” or “Controller”), process the personal data of visitors frequenting this website.
2. What is personal data?
Personal data refers to information that can directly identify you (e.g., your name) or indirectly identify you (e.g., through an alias). It encompasses details such as your email address, home address, mobile phone number, personal identification number, and more.
Additionally, personal data may include numerical identifiers like your computer’s IP address, mobile phone, MAC address, or cookies.
3. Method of processing personal data
In this section we will present categories of data, purposes and legal basis for processing your personal data.
Please find more details below.
3.1. Whose data do we process?
The Academy processes personal data of the following individuals:
3.1.1. Persons who access the Academy’s website,
3.1.2. Potential clients of the Academy who contact us directly via email, by telephone, or visit our offices in person,
3.1.3. Recipients of the Academy’s newsletters.
As a data controller, the Academy is responsible for the processing of personal data in these instances. When visitors engage in the Academy’s services and complete the forms available on the website, additional data will be processed.
3.2. How do we collect personal data?
We collect your personal data through two main methods:
3.2.1. Direct Collection: We gather data directly from you in various instances, such as when you become our client, request an offer
from us, contact us by phone or visit our business locations, provide consent to receive our newsletter, or reach out to us via email for
complaints or to exercise your rights.
3.2.2. Automatic Collection: We also collect data automatically through our website. This may include information such as your IP address,
cookies, browsing activity, and device information. These automated processes help us enhance your website experience and provide relevant services.
By employing these collection methods, we ensure that we have a comprehensive understanding of your personal data while respecting your privacy and adhering to applicable data protection laws.
3.3. Why do we process your personal data?
The purposes and legal bases for processing your personal data vary depending on your activities when visiting our website. In general, we process your personal data to fulfil your requests, specifically by taking actions to enter into a contract, for our marketing efforts, and to pursue our legitimate interests in enhancing our business activities.
For more detailed information on the processing of specific data, including the legal basis and purpose, please refer to the section below which outlines the activities we engage in.
3.3.1. Sending a general inquiry regarding our services via e-mail or online form
When you have questions about our services, you can reach out to us by using our web form or sending an inquiry via email.
The data we collect through these channels is used solely for the purpose of processing your inquiry, enabling us to respond to you and establish communication regarding our services and potential contract arrangements.
The essential data we process includes necessary information to identify the sender of the inquiry and to establish appropriate communication. We request contact details to facilitate more efficient correspondence regarding inquiries. The processing of this data is conducted to fulfil actions based on your request prior to the finalisation of a contract.
3.3.2. Sending other messages
In addition to the option of sending a general inquiry regarding our services via the online forms on our website or via email, you also have the opportunity to send messages of other nature, such as expressing praise for our work or providing suggestions to enhance the content we offer.
We value the opinions of our current and potential clients, as well as our business partners, and we strive to respond to your messages. To effectively address your messages, it is necessary for us to process the content, which may include your personal data. Similar to the previous case, the processing of your basic data is carried out solely for the purpose of responding to your messages. In this instance, our legal basis for processing is our legitimate interest in improving our business and assisting you in utilising our services.
On our website, you have the option to subscribe to our newsletter, which allows us to regularly update you on our activities, events, and opportunities to participate in our programs, among other relevant information. Our newsletters are delivered directly to your email address.
To facilitate the sending of newsletters, it is necessary for us to process data pertaining to your email address. Regarding newsletters, the legal basis for processing your data is your consent. By subscribing to our newsletter, you provide us with your explicit consent to process your email address for the purpose of delivering newsletters to you. You have the right to withdraw your consent at any time, without incurring any charges. You can do so by clicking on the “Unsubscribe” link located at the bottom of each newsletter or by contacting us via email at [email protected].
3.3.4. Cookies and similar technologies
3.3.5. Completing online registration forms for the purpose of concluding a contract / sending an offer for Performance and Academy programs
When you request an offer for a service which is not available in our webshop, we may require additional information to tailor the offer according to your specific requirements and tennis skill level. The legal basis for processing this additional information is your explicit request to initiate actions that precede the conclusion of a contract.
If you decide to enter into a contract with us, the processing of data becomes necessary for the execution of the contract, in which you, as the client of the Academy, are a party. Prior to signing the contract, alongside the registration form that you complete for contract finalisation, a detailed notice on the processing of personal data will be provided to you. This notice explicitly outlines the necessity of processing each individual piece of data and the reasons behind it.
By providing this detailed notice, we aim to ensure transparency and inform you about the specific purposes and legal basis for processing your personal data in the context of the contract.
3.4. Who are the recipients of personal data?
Depending on the specific purpose for which we collect your personal information on this website or through direct communication, we may share it with relevant third parties who assist us in providing our services. These third parties may include:
3.4.1. Advertising and Marketing Agencies: We may collaborate with advertising and marketing agencies to promote our services, including advertising through digital media and social networks.
3.4.2. Technical Support Providers: We may engage third-party technical support providers to assist us in maintaining and improving the functionality of our website and resolving technical issues.
3.4.3. Payment Service Providers: When you make payments for our services, we may share your information with trusted payment service providers to facilitate secure and efficient payment processing.
3.4.4. Legal Representatives: In certain cases, we may need to involve legal representatives who provide advice and assistance in legal matters related to our services.
3.4.5. Competent Government Authorities: If required by applicable laws or regulations, we may be obligated to share your information with competent government authorities to fulfil our legal obligations.
When sharing your personal information with these third parties, we take appropriate measures to ensure the protection and confidentiality of your data. We carefully evaluate the privacy practices and policies of these third parties before engaging in any data sharing arrangements.
4. Duration of data retention
specific purpose for which it was collected, unless applicable regulations specify a longer retention period for a particular purpose.
4.1. The following criteria guide us in determining the storage duration:
4.1.1. Purpose of Data Collection: We consider the purpose for which your personal data was collected.
4.1.2. Legal Basis for Processing: We take into account the legal basis on which we process your data.
4.1.3. Duration Needed for Purpose Fulfilment: We assess the period for which we need to retain the data to fulfil the intended purpose.
4.1.4. Legal Obligations: If there are legal obligations requiring the retention of your personal data, we comply with the prescribed retention period.
If we use the same data for multiple purposes, we retain it until the longer retention period expires. However, we cease using the data for purposes with shorter retention periods, in line with the principles of personal data processing. Once the applicable retention period elapses, we securely delete or destroy the data.
4.2. The data retention periods are as follows:
4.2.1. Data Obtained Based on Consent (e.g., Newsletter Email): We retain this data only for as long as valid consent for processing exists.
4.2.2. Documents Kept for Accounting Regulations (e.g., Invoices): We retain such documents for 11 years in accordance with accounting regulations.
4.2.3. Data Used in Processing with Potential Compensation Claims: We retain this data for a maximum of 5 years, as required by statutory deadlines.
4.2.4. Visitors’ Messages (excluding inquiries or praise): We store these messages for the duration necessary to review the inquiry and respond, typically within approximately 10 working days. In the case of complaints, we retain such messages for 1 year from receipt, in compliance with consumer protection laws.
4.2.5. Official Procedures: In official or legal procedures, we keep the personal data required for the duration of the procedure. In cases of realised compensation claims, we retain personal data for 10 years from the final judgement or settlement, in accordance with the statute of limitations.
4.2.6. Personal Data with Tax Liability: If personal data is necessary for contract execution and there is a tax liability, we extend the retention period to 10 years. During this period, we process the data on a limited basis.
Please note that these retention periods are subject to change in accordance with any updates to applicable laws and regulations.
5. Security of personal data processing
We would like to inform you that we process your personal data within the European Economic Area (EEA). As part of our commitment to data security, we have implemented necessary organisational and technical measures to protect your personal data from loss, destruction, alteration, falsification, manipulation, and unauthorised access.
In the event of a data breach or any violation related to the processing of personal data, we will promptly notify both you and the competent authority, as required by applicable regulations.
The security and protection of your personal data are of utmost importance to us, and we continuously strive to maintain the necessary measures to ensure its confidentiality, integrity, and availability.
6. Links to third-party websites
If you visit other websites through links provided on our website, please be aware that those websites have their own privacy policies.
The Academy is not responsible for the processing of personal data that occurs on third-party websites. We encourage you to review the privacy policies of those websites before providing any personal information or engaging in any activities on those sites.
It is important to note that once you leave our website and navigate to another website, any information you provide is subject to the privacy practices and policies of that specific site. We recommend exercising caution and familiarising yourself with the privacy policies of any websites you visit.
7. Your rights
All of your rights are listed is sections below.
To exercise your rights, please contact us via this email address: [email protected].
We will process all of your requests as soon as possible and without any delay, in accordance with our legal obligations. We will also keep you informed about the measures we have taken in line with regulations. Please note that in order to process your request, we may need to verify your identity.
Furthermore, if you have any complaints regarding the processing of your personal data, you may file a complaint with the Agency for the Protection of Personal Data at Selska cesta 136, Zagreb, Croatia (https://azop.hr/kontakt/).
7.1. Right to withdraw consent for processing personal data
The right to withdraw consent for the processing of personal data is available to newsletter recipients when the processing is based on consent. You can exercise this right by following these steps:
7.1.1. Clicking on the ‘unsubscribe’ link provided at the bottom of the newsletter. This will allow you to opt-out of further communication and the processing of your personal data for newsletter purposes.
7.1.2. Sending a request to the email address [email protected] stating your intention to withdraw consent for the processing of your personal data. Make sure to provide the necessary details so that your request can be properly identified and processed.
Please note that withdrawing your consent does not affect the lawfulness of processing that was based on consent before you withdrew it. In other words, any processing that took place prior to your withdrawal of consent remains valid and lawful.
If you have any further questions or concerns regarding the withdrawal of consent or the processing of your personal data, feel free to reach out to the above provided email address.
7.2. Right of access
You have the right to exercise the right of access, which allows you to obtain confirmation from us regarding the processing of your personal data. This includes the right to receive a copy of your personal data and access to information about how it is being processed. The information you are entitled to includes:
7.2.1. The purpose of the processing: You have the right to know the specific purpose for which your personal data is being processed.
7.2.2. Categories of personal data: You can request information about the types or categories of personal data that are being processed.
7.2.3. Recipients: You have the right to know who receives or has access to your personal data, such as third parties or organisations.
7.2.4. Retention period: You can inquire about how long your personal data will be stored or the criteria used to determine the retention period.
To exercise your right of access, please contact us at the provided email address, [email protected].
We will respond to your request as soon as possible, providing you with the necessary information and a copy of your personal data if applicable.
7.3. Right to be forgotten
You have the right to exercise the right to be forgotten, which allows you to request the deletion of your personal data without undue delay if there is no legitimate reason for further processing. This means that if your personal data is no longer necessary for the purposes for which it was originally processed, you can request its deletion.
However, it’s important to note that the right to be forgotten is not an absolute right. There may be circumstances where we have a valid reason to continue processing your personal data or we are legally obliged to retain certain data. In such cases, we may refuse your request for deletion.
If we determine that there is still a legitimate reason for processing your personal data or if we are unable to fulfil your request for deletion, we will provide you with an explanation as part of our response to your request or inquiry. We will ensure transparency and communicate the reasons behind our decision regarding the deletion of your personal data.
If you have any concerns or questions regarding the processing of your personal data, please feel free to contact us at email address [email protected].
7.4. Right to rectification
You have the right to request the rectification of your personal data if it is inaccurate or incomplete. If you believe that your personal data we hold is outdated, incorrect, or incomplete, you have the right to request its correction or completion. We are obligated to rectify your personal data without undue delay.
To exercise this right, please contact us at the provided email address, [email protected], and provide us with the specific details of the personal data that requires correction or completion. We will review your request and make the necessary updates to ensure the accuracy and completeness of your personal data.
It’s important to consider the purposes for which your personal data is processed when requesting rectification. If there are additional details or information that needs to be added to your personal data to fulfil the processing purposes, you also have the right to provide an additional statement.
We will process your request for rectification promptly and in accordance with our legal obligations. If we determine that your personal data has been corrected or completed, we will inform you accordingly. If we are unable to fulfil your request, we will provide you with an explanation as part of our response. Please don’t hesitate to reach out to us if you have any questions or concerns regarding the accuracy or completeness of your personal data.
7.5. Right to object to processing
If the processing is based on the realisation of our legitimate interests, you have the right to object to such processing at any time in relation to your personal data. In this case, we will not process the data any further for the purpose to which the objection relates unless we can demonstrate compelling legitimate reasons that override your interests, rights, and freedoms, or if it is necessary for the exercise or defence of our legal claims.
7.6. Right to restriction of processing
You have the right to obtain from us the restriction of personal data processing if:
7.6.1. you dispute the accuracy of the data;
7.6.2. the processing is unlawful, and you object to its deletion;
7.6.3. you need it to establish, exercise, or defend legal claims, and we no longer need it for processing; you have lodged a complaint regarding the processing of your personal data and are awaiting confirmation.
7.7. Right to data portability
You have the right to receive data relating to you, which you have provided to us, in a structured, commonly used, and machine-readable format, and to transfer it to another service provider. In doing so, if technically feasible, you have the right to request direct data transfer from us to another data controller.
7.8. Right to information
7.9. Right to submit a complaint to AZOP
It is your fundamental right to lodge a complaint with the competent authority responsible for the processing of personal data, namely the Agency for the Protection of Personal Data, located at Selska cesta 136, Zagreb, Croatia (https://azop.hr/kontakt/).
If you believe that there has been a breach concerning your personal data, you are welcome to contact us to clarify the situation and prevent any violation of your rights.
8. Closing message
As the Data Controller, we assure you that all data is processed in full compliance with applicable regulations, and we are committed to handling your personal data responsibly. We want to emphasise that we will not misuse your personal data under any circumstances. You can reach us by mail at the address provided or by emailing us at [email protected].
We are available to address any concerns or inquiries you may have regarding the processing of your personal data. Thank you for placing your trust in us.