Cookie Policy

Personal Data Processor

The data processor under this policy is ŠPICA INTERNATIONAL d.o.o., Pot k sejmišču 33, 1000 Ljubljana.

Scope of use

This policy applies to the following websites ("Website"):

www.spica.si

www.spica.hr

www.spica.rs

www.spica.me

www.spica.com.mk

www.spica.com

katalog.spica.si

katalog.spica.hr

support.spica.com

forpartners.spica.com

This Policy applies to the use of cookies in combination with pixels, local storage objects and similar devices, and technologies (collectively "Cookies") that we or our permitted service providers may use in connection with your interaction with our websites and communications ("Website") to enable our Website to function effectively and efficiently.

This Policy explains how we use Cookies, when your consent is required, how they are used on the Website, and provides you with information on how you can exercise your rights in relation to Cookies. You can read more about the processing of personal data in relation to Cookies in the Špica Privacy Policy .

Cookies and how we use them

Cookies use unique codes that act as identifiers and can be treated as personal data under European data protection law. This is because they can enable the user of a device to be uniquely recognised as the same user, even if their 'true' identity is unknown.

Cookies are often used in combination with other identifiers, such as the IP address of your device, which is automatically assigned to your computer by your internet service provider and shared by your device when online content is requested and displayed. IP addresses can be logged automatically in our server log files whenever our website, applications or online content are accessed, and can be associated with Cookies unless separate IP anonymisation features are enabled (see 'Our use of Google Analytics' below).

Our website contains essential and non-essential cookies. Essential cookies are required for our website to function. We do not require your consent for the operation of essential cookies on the website. However, we require your consent to use non-essential cookies. You are not required to allow non-essential cookies to visit our website. However, enabling non-essential cookies can allow for a more personalised browsing experience.

We are the data controller for the processing of personal data in relation to Cookies and tracking used on the website.

Some Cookies are deleted as soon as you close your browser. These cookies are called session or temporary cookies, as they only last for the duration of a single session and are no longer stored after the session ends. These cookies usually only contain an identification code that can only be recognised by the website that installed the cookies. Some cookies have a certain lifespan or validity period and are used to identify that you have already logged in to a particular website or to store information about certain settings, such as language preference.

You can also control the installation of cookies on your device using the settings in your browser. In the event the terms and conditions governing cookies are amended, all previous cookies managed by us will be deleted and set again according to the newly published terms and conditions. We cannot delete cookies that have been installed on our website and are managed by others. You can do so yourself in your browser settings.

Please read the instructions on the links below on how to control cookies using browser settings:

Internet Explorer 9 - click HERE for instructions

Internet Explorer 7 and 8 - click HERE for instructions

Google Chrome - click HERE for instructions

Mozilla Firefox - click HERE for instructions

Opera - click HERE for instructions

Safari - click HERE for instructions

For more information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org .

Below is a description of the tools we use in connection with our use of Cookies:

a) Google Analytics

For all our websites, we use Google Analytics to perform web analytics. It is operated by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA ("Google").

Google will use this information on our behalf for the purpose of measuring your activity on our website, compiling statistical reports on your overall interaction with the content, and providing other services relating to website activity and internet usage.

Špica has activated the IP anonymisation with Google Analytics; as a consequence, Google will truncate/anonymise the last octet of the IP address for the Member States of the European Union. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there, in which case the transfer of this information is subject to a legal basis as described at https://policies.google.com/privacy/frameworks?hl=en-US .

You can prevent the collection of data generated by the cookie, as well as the processing of this data by Google, by downloading and installing a browser plugin that sets the opt-out cookie, or by selecting the appropriate setting in your browser software.

For further information, please see Terms of Use and Privacy Policy https://marketingplatform.google.com/about/analytics/terms/us/ .

b) Google reCAPTCHA

To ensure an adequate level of data security during data entries on our website, in certain cases, we use the Google reCAPTCHA service ("reCAPTCHA") provided by Google.

This is primarily used to distinguish whether an input on our website (e.g. via a contact form) is made by a human or if there has been abuse through automated or automatic input. The service includes the transmission of IP addresses and all other data required by Google for the reCAPTCHA service (e.g. information about which pages you viewed, the time you viewed them and what you clicked on).

The analysis by reCAPTCHA takes place entirely in the background. Visitors to the website are not informed that this analysis is taking place. You can find out more about reCAPTCHA and the Google Privacy Policy at: www.google.com/recaptcha/intro/v3beta.html and policies.google.com/privacy?hl=en .

The legal basis for the processing of data by reCAPTCHA is Article 6(1)(f) of the GDPR. As a website operator, we have a legitimate interest in our online offer being protected from malicious automated input and unsolicited email (SPAM).

c) Google AdSense

We use Google AdSense, an ad serving service provided by Google Inc.

Google AdSense also uses cookies stored on your computer that enable user analysis. In addition to cookies, Google AdSense uses small Web Beacons to record additional information about user traffic on our website. Both the information collected by cookies and the information collected by counters are stored on a Google server in the USA for future evaluation of your usage patterns. In addition, Google's contractors may have access to the evaluation and, consequently, to your data. Google will not combine your IP address with other data stored about you.

You can disable the use of these cookies by using a setting on your browser software. This may interfere with the operation of some of our website services.

Google AdSense cookies are stored on the basis of Article 6(1)(f) of the GDPR. We have a legitimate interest in analysing user behaviour on our website in order to optimise both our offer and our advertising.

d) Google Remarketing

Our websites use the Google Analytics remarketing feature in conjunction with Google AdWords and DoubleClick or Google Ads. This service is provided by Google. This allows advertising to be displayed based on your personal interests, which are determined by your previous usage and browsing history on one device (such as your mobile phone), on other devices (such as your tablet or computer).

Once you have given your consent, Google will associate your web and app browsing history to your Google Account for this purpose. This way, any device that logs into your Google Account can display the same personalised promotional message. If you have this feature enabled, Google Analytics collects advertising IDs that are temporarily linked to our Google Analytics data to identify and create cross-device ad audiences.

You can permanently disable cross-device remarketing/targeting by turning off personalised advertising in your Google Account. Follow this link: adssettings.google.com/authenticated?hl=en .

The collection of data in your Google Account is based solely on your consent, which you may give or withdraw from Google pursuant to Article 6(1)(a) of the GDPR. For data collection that is not aggregated in your Google Account (for example, because you do not have a Google Account or have objected to it), data collection is based on Article 6(1)(a) of the GDPR.

For more information and to view the Google Privacy Policy, please visit: policies.google.com/technologies/ads?hl=en .

e) Google AdWords and Google Conversion Tracking (Google Ads)

We use Google AdWords or Google Ads provided by Google. It is used to record visits to the website for advertising purposes (remarketing) on Google and the Display Network. Your browser stores cookies when you visit a website, allowing it to recognise you as a visitor again when you open websites that are part of the Google advertising network. These pages may then present you, as a visitor, with adverts that relate to content you have previously viewed on other websites that use Google remarketing feature.

You can opt out of data logging by Google AdWords at https://adssettings.google.com/authenticated?hl=sl .

We use Conversion Tracking within Google AdWords to produce Conversion statistics that measure the effectiveness of our online advertising campaigns. The Conversion-Tracking cookie is installed when a user clicks on an ad turned on by Google.

If you do not wish to participate in tracking, you can object to this use by deactivating the Google Conversion-Tracking cookie in your web browser settings.

You can find out more about Google AdWords and Google Conversion Tracking and the Google Privacy Policy at

policies.google.com/technologies/ads?hl=en and policies.google.com/privacy?hl=en .

Google AdWords and Google Conversion Tracking cookies are stored based on Article 6(1)(f) of the GDPR. We have a legitimate interest in analysing user behaviour on our website in order to optimise both our offer and our advertising.

f) MS Clarity

We use the Microsoft Clarity analytics tool, provided by Microsoft Corporation, a company based in the USA, on our websites.

In addition, we use this data for website optimisation, fraud/security purposes and advertising. For more information about how Microsoft collects and uses your data, please visit the Microsoft Privacy Statement HERE .

This tool allows us to analyse user interactions on our website. It provides insights into how users navigate our website and engage with our content. MS Clarity collects data such as clicks, scrolls and form submissions to give us an overview of the user experience on our website.

Website usage data is captured using first-party and third-party cookies and other tracking technologies to determine products/services popularity and online activity.

MS Clarity uses device identifiers to process technical information stored on your mobile device, such as device type, operating system, provider name, as well as events that occur on our website (e.g. viewing certain pages, time spent on the page, interactions with page elements).

We have signed the EU Standard Contractual Clauses (SCC) with the company, which provide specific safeguards for the transfer of personal data outside the EU. You can read more about it at: https://learn.microsoft.com/en-us/compliance/regulatory/offering-eu-model-clauses

You can prevent the collection of data generated by Microsoft Clarity, as well as the processing of this data by Microsoft, by installing the appropriate add-on in your browser or by selecting the appropriate setting in your browser software.

For further information, please see the Microsoft Clarity Terms of Use and Privacy Policy: https://clarity.microsoft.com/terms .

g) Segment

We use the Segment analytics tool provided by Segment.io, Inc.

Segment collects data from a variety of sources, such as device identifiers, i.e. unique identifiers associated with your device, including IDFA (Identifier for Advertisers) for Apple devices or AAID (Google Advertising ID) for Android devices; technical details about your device, such as device type (e.g. iPhone 6), operating system (e.g. iOS 8.4), and the name of your mobile service provider (e.g. Vodafone); and app usage data, which includes information on how you interact with apps, such as events like starting and stopping timekeeping, generating reports, and utilizing other app functionalities.

We use the data collected by Segment to analyse how users use our apps, to identify areas for improvement and develop new features, to personalise the user experience, and to send targeted ads and promotions.

We have entered into EU Standard Contractual Clauses with Segment.io, Inc. concerning the transfer of personal data outside the EU. You can read more about the international transfers HERE . You can find out more about the Segment Privacy Policy at https://segment.com/docs/legal/privacy/ . By using our services, you consent to the processing of data by Segment in the manner described above.

The use of Segment services is carried out on the basis of Article 6(1)(f) of the GDPR. We have a legitimate interest in optimising the performance of our services or in better managing our customer relationships. We need your consent to collect your personal data through cookies.

h) Hotjar

On our websites, we use the Hotjar online marketing tool provided by Hotjar Ltd, Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta ("Hotjar"). It is an analytical tool that helps us monitor your use of our website, e.g. to see how you navigate our website. The aim is to optimise your experience as a guest of our website and make our offer even more attractive. Hotjar uses cookies. For further information regarding the cookies used by Hotjar, please visit: www.hotjar.com/cookies .

In addition, we have implemented a Hotjar-tracking-code on our website that allows us to collect the following information: (i) device-specific data (IP address of your device - which is collected and stored in an anonymous way, device screen size, device type (unique device identifiers) and browser information, country as a geographic location, selected language for displaying the website and (ii) login data (relating to the domain, pages visited, country as a geographic location, selected language for displaying the website, date and time of website visits). In general, your data will only be collected in an anonymous form, no personal associations will be made. If you register with our services, your Hotjar data will not be associated with your personal data. Hotjar also uses third-party services such as Google Analytics and Optimizely.

For further information regarding the Hotjar Privacy Policy, please visit: www.hotjar.com/privacy . In the future, you can opt-out of any collection and storage of your data by Hotjar at: www.hotjar.com/opt-out .

Hotjar cookies are stored on the basis of Article 6(1)(f) of the GDPR. We have a legitimate interest in analysing user behaviour on our website in order to optimise both our offer and our advertising.

i) Intercom

We use the Intercom tool provided by Intercom Inc. 98 Battery Street, Suite 402, San Francisco, CA 94111, USA to send email messages and for Live-Chat functionality regarding our Cloud Services and to manage customer relationships on websites.

We transmit the following data:

your email address,

your name and surname,

your phone number,

contact details of technical contacts.

We have concluded EU Standard Contractual Clauses with Intercom Inc. for international data transfers from outside the EU to the USA. For more information, please click HERE .

You can learn more about data processing at: https://www.intercom.com/help/en/articles/1385437-how-intercom-complies-with-gdpr .

You can find out more about the Intercom Privacy Policy at https://www.intercom.com/terms-and-policies#privacy .

Intercom also uses cookies stored on your computer that enable user analysis. The cookie-based data about your last visit to our cloud platform is transferred to Intercom's servers in the USA and stored there. Intercom will not combine your IP address with other data stored about you.

The data of interested parties who contact us via Live-Chat is completely deleted after 9 months. Any interested party who contacts us after their data has been deleted is considered a new interested party.

You can disable the use of these cookies by using a setting on your browser software. This may interfere with some of our website services (e.g. Live-Chat).

The use of the Intercom service is carried out on the basis of Art. 6(1)(f) of the GDPR. We have a legitimate interest in optimising the performance of our services or in better managing our customer relationships. However, your consent is required to install Intercom cookies.

j) ActiveCampaign Marketing Automation System

On our websites, we use the ActiveCampaign platform provided by ActiveCampaign, 1 N, Dearborn, Chicago, IL 60607, USA, for sending newsletters, where the following data is stored: email address and first and last name. This data is stored by ActiveCampaign on its servers in the USA.

ActiveCampaign strives to ensure the highest level of security for the data we store through various physical, technical and organisational measures, such as encrypting online connections, preventing unauthorised access, using secure passwords and preventing intrusions. The ActiveCampaign service monitors the delivery performance of sent emails by collecting data on open rates, link clicks, email clients and browsers, approximate location, IP address, logins and unsubscribes, and failed email deliveries. This data will be kept for a maximum of 6 months after unsubscribing from receiving emails.

The ActiveCampaign Privacy Policy is available here https://www.activecampaign.com/privacy-policy/ .

We have concluded EU Standard Contractual Clauses (SCC) with ActiveCampaign. We have signed a contract with ActiveCampaign on the processing of personal data, in which the latter undertakes to process the users' data in accordance with our instructions and not to disclose it on to third parties.

The implementation of the newsletter is based on your consent in accordance with Article 6(1)(a) of the GDPR. The use of the ActiveCampaign service is based on Article 6(1)(f) of the GDPR.

We have a legitimate interest in choosing technology providers that offer tools that help us optimise our business and also offer a user-friendly way of sending newsletters that also meets your expectations.

AC MAS will store a cookie on your computer's hard drive to track your activity and site usage, but it will not store or collect personal data. You can prevent the storage of cookies at any time by configuring your internet browser so that cookies from the "trackcmp.net" domain are not accepted. However, we would like to point out that in this case you may not be able to take full advantage of all the features of this website.

ActiveCampaign cookies are stored on the basis of Article 6(1)(a) of the GDPR, i.e. your consent.

k) Social plugins - Meta, X and Linkedin

We have implemented social plugins from social networks so you can easily share what interests you with your colleagues and connections on social media. Our website may contain social plugins for external social networking websites such as Facebook, Instagram (collectively: "Meta"), x.com ("X") and LinkedIn.com ("LinkedIn").

Each time you visit our website containing the plugin, your browser will establish a direct connection to Meta, X and LinkedIn servers. In this process, the servers of Meta, X and LinkedIn will recognise which of our websites, apps or content you are currently visiting.

If you are a member of Meta, X and/or LinkedIn and you are logged in while visiting our website, Meta, X and/or LinkedIn will assign this information to your personal user account. By interacting with one of the plugins, e.g. by clicking the like button and/or the X button, this information will be sent directly via your browser to Meta, X and/or LinkedIn, where it will be stored in your personal user accounts. The information you share from our website will be shared with Meta, X and LinkedIn.

We would like to emphasize that, as the provider of this website, we have no knowledge of the content of the transferred data or its use by Meta, X and Linkedin. We also have no control over the data collected by Meta or LinkedIn through the plugin, nor the extent of such data collected by Meta or LinkedIn. We also have no knowledge of the content of the data provided to Meta or LinkedIn.

Please see their privacy policies for details of their data collection practices and your rights and preferences.

l) Youtube

We use plugins from YouTube, which are managed by Google. The operator of the website is You Tube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. If you visit our website that contains the YouTube plugin, a connection is established with the YouTube servers. YouTube is thereby informed about the website you have visited.

If you are signed in to a YouTube account, YouTube allows you to link your browsing behaviour directly to your personal profile. You can prevent this by logging out of your YouTube account.

YouTube helps us make our website attractive. This is a legitimate interest under Article 6(1)(f) of the General Data Protection Regulation ("GDPR"). Further information on the handling of user data is available in the YouTube Data Protection Statement:

https://www.youtube.com/static?template=privacy_guidelines .

m) Snitcher

To track the business usage of our website, we use the Snitcher tool operated by Snitcher B.V., Deventerstraat 21, 7311 BH Apeldoorn, The Netherlands. This service shows us the names and addresses of companies based on the IP addresses of our visitors. We transmit the following data:

your IP address,

information about page visits (pages viewed, referral source, time of visit).

Snitcher collects data about visitors to our website on its infrastructure hosted on AWS (Amazon Web Services) located in Frankfurt, Germany (eu-central-1). All data collected is encrypted both during transmission and during storage. Our legal basis for using personal data is in accordance with Article 6(1)(a) of the GDPR.

You can learn more about data processing at: https://help.snitcher.com/en/articles/7237945-security .

Snitcher processes your IP address and compares it to its own database to verify the company behind the visit and their geographic location. All visitor data is then aggregated at the company level. Snitcher does not share visitor IP addresses and only provides customers with publicly available corporate data that complies with GDPR exemptions.

n) Calendly

We use Calendly, a service provided by Calendly, LLC based in the USA, to conduct online meetings and arrange appointments. Calendly and related companies that operate a global server infrastructure. The data processed when using the Calendly service may be transferred outside the European Economic Area and is subject to the laws of the country where Calendly servers are located. Calendly processes meeting participant data based on the type of participation and use of the service.

Calendly is certified under the EU-U.S. Data Privacy Framework (EU-U.S. DPF ).

We have entered into a personal data processing agreement with Calendly, which commits Calendly to comply with EU data protection rules. The data collected by using the services is described HERE .

The use of Calendly services is based on Article 6(1)(f) of the GDPR. We have a legitimate interest in optimising the performance of our services or in better managing our customer relationships.

o) Stripe

Payments for products and services offered on the website are made through Stripe, Inc., 354 Oyster Point Boulevard, South San Francisco, California 94080, USA. If you purchase our products or services, your purchase will be made through an SSL encrypted website operated by Stripe and the data provided will be stored on Stripe servers in the USA.

For international transfers from outside the EU to the US, we have concluded EU standard contractual clauses with Strike. For more information, please click HERE . You can read more about the Stripe Privacy Policy at

https://stripe.com/en-si/legal/privacy-center and https://stripe.com/legal/dpa .

The use of Stripe services is based on Article 6(1)(f) and Article 6(1)(b) of the GDPR. We have a legitimate interest in optimising the performance of our services or in making payment for our services.

International transfers of personal data

If we transfer your personal data outside the European Economic Area, we will do so after carefully reviewing the appropriate legal bases and safeguards as described here:

https://www.ip-rs.si/fileadmin/user_upload/png/infografike/Prenos_osebnih_podatkov_v_dveh_korakih.png

The rights of the data subject

Please note the following rights regarding your personal information that you may exercise by sending an email to gdpr@spica.com :

request access to your personal data and information relating to our use and processing of your personal data;

request correction or deletion of your personal data;

request that we restrict the use of your personal data;

request your personal data that you have provided to us in a structured and machine-readable format (for example, an Excel spreadsheet) and the right to have this personal data transferred to another personal data controller;

object to the processing of your personal data for certain purposes (for further information, see the section below entitled "Your right to object to the processing of your personal data for certain purposes"); and

withdraw your consent to our use of your personal data where we rely on your consent. If you withdraw your consent, this will not affect the lawfulness of our use and processing of your personal data based on your consent prior to the date on which you withdraw your consent.

You also have the right to file a complaint with the supervisory authority (in the Republic of Slovenia: the Information Commissioner). Their contact details are available here: www.ip-rs.si/ .

For further information on your rights in relation to your personal data, including certain limitations that apply to some of these rights, please see Articles 12 to 23 of the GDPR available here: www.eur-lex.europa.eu/legal-content/SL/TXT/?uri=CELEX:32016R0679 .

You have the following rights in relation to your personal data, which you can exercise in the same way as in the previous section (your rights in relation to your personal data):

object to the use or processing of your personal data if we process your personal data for our legitimate interests, including profiling (e.g. predicting your behaviour based on your personal data) on the basis of any of those purposes; and

object to the processing of your personal data for direct marketing purposes (including any automated assessment we make of you or any of your characteristics as a person, if this is related to such direct marketing).

Changes to our Cookie Policy

We may change our Cookie Policy from time to time. If we make any changes, we will notify you. If you continue to access our website on or after this date, you agree to be bound by the new version of our policy.

Ljubljana, 17/06/2024