Privacy Policy

Last updated: November 27th, 2022

GENERAL

Venator d.o.o. ("we", "us", or "our"), located at Drenovac 8, 10000 Zagreb, Croatia, is committed to protecting and respecting your privacy. This privacy and cookie policy ("Policy"), together with our Terms of Use located at https://www.venator.dev/terms-of-use, will detail what personally identifiable information ("Personal Data") we collect and what we use it for when you access and use https://www.venator.dev website as well as any other media form, media channel, mobile website or mobile application related, linked, or otherwise connected thereto (collectively, the "Site").

Please read this Policy carefully. You agree that by accessing the Site, you have read, understood, and agreed to be bound by all of this Policy. If you do not agree to this Policy, please do not access or use this Site.

For the purposes of EU data protection laws and any applicable national implementing laws, regulations and secondary legislation relating to the processing of personal data (together "Data Protection Law"), the data controller is Venator d.o.o.

DATA WE COLLECT

We collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

  • Identity Data: includes first name, maiden name, last name, company name;
  • Contact Data: includes billing address, delivery address, home address, email address and telephone numbers;
  • Financial Data: includes bank account;
  • Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from us;
  • Technical Data: includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Site;
  • Usage Data: includes information about how you use our Site, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); products or services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
  • Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences;
  • Aggregated Data: we also collect, use and share statistical or demographic information for any purpose. This Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this information will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined information as Personal Data which will be used in accordance with this Policy.

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

HOW WE COLLECT DATA

We use different methods to collect data from and about you including via:

  • Direct Interactions: you may give us your Identity, Contact and Financial Data when you fill in forms or correspond with us by post, phone, email or otherwise. This includes Personal Data you provide when you register to receive our newsletter, subscribe to use our services, request marketing to be sent to you, search for a service or product, enter a competition, promotion or survey, attend a conference or webinar, give us feedback or contact us and when you report a problem with our Site or services;
  • Purchases: if you make purchases via our Site, or register for an event or webinar, we may require you to provide your Identity, Contact, Financial and Transaction Data;
  • Automated Technologies or Interactions: as you interact with our Site or emails, we automatically collect Technical Data about your device, browsing actions, patterns and Usage Data. We collect this Personal Data by using cookies, server logs, web beacons, pixels, and similar technologies about your device, and your use of our Site and services. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see the Cookie section below for further details.

DATA WE RECEIVE OR SHARE WITH THIRD PARTIES

We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive or share the following Personal Data about you:

  • Technical Data: from analytics providers, advertising networks and search information providers, Google (https://policies.google.com/privacy);
  • Email, Communications and Contact Data: from providers of email communications service providers, Google.

DATA WE COLLECT FROM OTHER SOURCES

We also collect Personal Data about you from publicly available sources. We may combine this information with Personal Data provided by you. This helps us update, expand, and analyse our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you. We also use this for the purposes of targeted advertising, delivering relevant email content, event promotion and profiling, determining eligibility and verifying Contact Data. The Personal Data we collect includes:

  • Identity and Contact Data: from publicly available sources such as Companies House and Securities and Exchange Commission;
  • Identity, Contact and Profile Data: that is published about you on social media profiles such as LinkedIn, Facebook, Twitter etc.

HOW WE USE DATA

We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing
To register you as a new customer.Identity
Contact		Performance of a contract with you.
To process and deliver your order including:
(a) Manage payments, fees and charges;
(b) Collect and recover money owed to us.		Identity
Contact
Financial
Transaction
Marketing and Communications		(a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to recover debts due to us).
To manage our relationship with you which will include:
(a) Notifying you about changes to our Terms, this Policy, the Site or services;
(b) Asking you to leave a review or take a survey.		Identity
Contact
Marketing and Communications		(a) Performance of a contract with you;
(b) Necessary to comply with a legal obligation;
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services).
To enable you to partake in a survey.Identity
Contact
Usage
Marketing and Communications		(a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to study how customers use our products and services, to develop them and grow our business).
To administer and protect our business and the Site (including troubleshooting, data analysis, testing, system maintenance, support, updates, reporting and hosting of information).Identity
Contact
Technical		(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise);
(b) Necessary to comply with a legal obligation.
To deliver relevant Site and services content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.Identity
Contact
Profile
Usage
Marketing and Communications
Technical		Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve our Site and services, marketing, customer relationships and experiences.Technical
Usage		Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about goods or services that may be of interest to you.Identity
Contact
Technical
Usage
Profile
Marketing and Communications		Necessary for our legitimate interests (to develop our services and grow our business).
To display personal testimonials (success stories) of satisfied customers on our Site in addition to other endorsements.IdentityYour prior consent. Consent can be withdrawn to the publication of a testimonial by sending us an email.

We will not sell or rent your Personal Data to anyone.

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may combine data we receive from other sources with data you give to us and data we collect about you. We may use the data we receive from other sources and the combined data for the purposes set out above (depending on the types of data we receive).

DISCLOSURE OF DATA

We do not share or otherwise disclose your Personal Data for purposes other than those outlined in this Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide us:

  • to any member of our group, which means our subsidiaries, and our ultimate holding company and its subsidiaries;
  • to business partners, suppliers, and sub-contractors for the performance of any contract we enter in to with them or you to provide services such as IT and system administration services, email communications, hosting services, backup services, credit card processing, research, development, marketing and customer support;
  • to analytics and search engine providers that assist us in improving and optimizing our Site;
  • to credit reference agencies, for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
  • to professional advisors acting as service providers to us in relation to the Site or our services including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services;
  • to tax authorities, regulators and other authorities who require reporting of processing activities in certain circumstances;
  • in the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets;
  • if Venator d.o.o., or substantially all of its assets, is acquired by a third party, in which case Personal Data held by it about its customers will be one of the transferred assets;
  • if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, and/or any other agreements; or to protect our rights, property, safety, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

WHERE WE STORE DATA

Our services are global and your Personal Data may be stored and processed in any country where we have operations, our staff are located or where we engage service providers engaged in, among other things, the fulfilment of your order, the processing of your payment details or the provision of support services. This will involve a transfer of your Personal Data to countries outside of your country of residence, where data protection rules are different from those of your country of residence.

If you are a resident of the European Economic Area ("EEA"), in order to provide our Site, products, and services to you, we may send and store your Personal Data outside of the EEA, including to the United States.

We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Policy. In particular this means that your Personal Data will only be transferred to a country that provides an adequate level of protection (for example, where the European Commission has determined that a country provides an adequate level of protection) or where the recipient is bound by standard contractual clauses according to conditions provided by the European Commission ("Standard Contractual Clauses").

DATA SECURITY

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. For example, all data you provide to us is stored on our secure servers.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Site. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

DATA RETENTION

We retain Personal Data for as long as necessary for the relevant activity for which it was provided or collected including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

For customers who have not purchased our products or services or started a conversation with our support, this period will be no more than one (1) year. For customers or persons who have purchased a product or a service or contacted our support team we will retain Personal Data for as long as we provide access to our services to you or any period set out in any relevant contract you have with us. After you have ceased using our services we will delete your Personal Data within one (1) year.

We may retain your Personal Data for a longer period in the event of a complaint, if we reasonably believe there is a prospect of litigation in respect to our relationship with you, to comply with law enforcement requests, maintain security, prevent fraud and abuse, resolve disputes, enforce our legal agreements, or fulfil your request to "unsubscribe" from further messages from us.

We may retain your Personal Data for a longer period in the event of a complaint, if we reasonably believe there is a prospect of litigation in respect to our relationship with you, to comply with law enforcement requests, maintain security, prevent fraud and abuse, resolve disputes, enforce our legal agreements, or fulfil your request to "unsubscribe" from further messages from us.

We will retain some anonymised information after your account has been closed and we may use this for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Please note that after you have closed your account or ceased using our services, any data you have shared with others will remain visible. We do not control data that other users may have copied from the Site or services. Your data may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

LEGAL BASIS FOR PROCESSING DATA

If you are from the EEA, our legal basis for collecting and using the Personal Data described in this Policy depends on the Personal Data we collect and the specific context in which we collect it. We may process your Personal Data because:

  • we need to perform a contract with you;
  • you have given us permission to do so;
  • the processing is in our legitimate interests and it's not overridden by your rights;
  • we need it for payment processing purposes;
  • we need to comply with applicable law.

YOUR RIGHTS UNDER THE GENERAL DATA PPROTECTION REGULATION (GDPR)

If you are located in the EEA, you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at

In certain circumstances, you have the following data protection rights:

  • the right to access, update, or delete your Personal Data;
  • the right of rectification. You have the right to have your Personal Data rectified if that data is inaccurate or incomplete;
  • the right to object. You have the right to object to our processing of your Personal Data;
  • the right of restriction. You have the right to request that we restrict the processing of your Personal Data;
  • the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
  • the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely upon your consent to process your Personal Data.

Please note that we may ask you to verify your identity before responding to such requests. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further data in relation to your request to speed up our response.

If you wish to exercise any of the above rights, please contact us. We will respond to such queries within 30 days and deal with requests we receive from you, in accordance with the provisions of applicable data protection law. Occasionally it could take us longer, if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You will not have to pay a fee to access your Personal Data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. Our local data protection authority who deals with all EU complaints is: The Croatian Personal Data Protection Agency (Agencija za zaštitu osobnih podataka).

"DO NOT SELL MY PERSONAL INFORMATION" NOTICE FOR CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

Under the CCPA, California consumers have the right:

  • to request that a business that collects a consumer's Personal Data disclose the categories and specific pieces of Personal Data that a business has collected about consumers;
  • to request that a business delete any Personal Data about the consumer that a business has collected;
  • to request that a business that sells a consumer's Personal Data, not sell the consumer's Personal Data.

If you make a request, we have 30 days to respond to you. If you would like to exercise any of these rights, please contact us at .

THIRD-PARTY LINKS

Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. We strongly advise you to review the privacy policy of every site you visit.

COOKIES

We use cookies on our Site to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve the Site.

WHAT ARE COOKIES

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of websites. Cookies are sent to your browser from a website and stored on your device.

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain parts of our Site. You can find more information about cookies at https://www.allaboutcookies.org and https://youronlinechoices.eu.

PERSISTENT COOKIES

Persistent cookies are stored on a user's device in between browser sessions which allows the preferences or actions of a user across the website, or in some cases across different websites, to be remembered.

SESSION COOKIES

Session cookies allow a website to link your actions during a browser session. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the website or close your browser.

WHICH COOKIES WE USE AND WHY

Our Site uses 3rd party cookies (which are set by third parties). The table below explains the cookies we use and why we use each of them.

CookieTypePurposeDuration
Google AnalyticsTrackingThese cookies are used to collect information about how visitors use our Site. We use the information to compile reports and to help us improve the Site. The cookies collect information in an anonymous form, including the number of visitors to the Site, where visitors have come to the Site from and the pages they visited. If you do not allow these cookies we will not be able to include your visit in our statistics. You can read the full Google Analytics privacy policy at: https://www.google.com/policies/privacy/.Up to 2 years

DO NOT TRACK

We do not support Do Not Track ("DNT").

Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the "Preferences" or "Settings" page of your web browser.

MARKETING

We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. We call this marketing.

PROMOTIONAL OFFERS FROM US

We will send you marketing emails if you "opt in" to receive marketing emails when registering on our Site, or if you have enquired about, or purchased any of our goods or services from us and you have not opted out of receiving such marketing.

THIRD PARTY MARKETING

We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.

NEWSLETTERS

From time to time, we may provide information to our customers in the form of electronic newsletters. When you subscribe to our newsletter you will be added to our mailing list and will receive emails about our products, offers, and feedback. The emails will come from us, not from third parties. They will be sent directly to the email address that you provide when you subscribe.

OPT OUT

Please note that, if you change your mind about being sent marketing emails or our newsletter you can "opt out" at any time by clicking the "unsubscribe" link at the bottom of any marketing email or newsletter. Once you "opt out", you will no longer receive any marketing emails or newsletter from us. We will continue to communicate with you regarding your service billing and support via email and where we send push notifications from time to time in order to update you about any service updates, events and promotions we may be running. If you no longer wish to receive these communications, please disable these in the settings on your device.

CHILDREN'S PRIVACY

The Site and any product or service are intended for adults. We do not knowingly collect Personal Data from children under the age of 13. If we are made aware that information is, or has been, submitted by or collected from a child under the age of 13, we will promptly delete this information.

CHANGES

We reserve the right, in our sole discretion, to make changes or modifications to this Policy from time to time. We will alert you about any changes by updating the "Last updated" date of this Policy, and you waive any right to receive specific notice of each such change. Please ensure that you check the applicable Policy every time you use our Site so that you understand which Policy applies. You will be subject to, and will be deemed to have been made aware of and to have accepted, the changes in any revised Policy by your continued use of the Site after the date such revised Policy is posted.

CONTACT

Please send your comments and questions regarding this Policy to the following address:

Venator d.o.o.
Drenovac 8
10000 Zagreb, Croatia
Email: