PRIVACY POLICY

RIGHTS HOLDER: Bracopone d.o.o.
BRAND NAME: Copone Digital Media
MEDIA: The Sports Ground (tsgnews.co), Vibecovery (vibecovery.com), Crotional (crotional.com), Noatte Photo and Video Agency (noatte.com)
ADDRESS: Ul. grada Chicaga 7, Zagreb, Croatia
CHIEF EDITOR: Ivan Brajković
CONTACTS: +385 99 2410609, info@bracopone.com

GENERAL SECTION

These Privacy Rules apply to all online media operating under the Copone Digital Media brand. Their purpose is to protect your privacy and ensure transparency in the collection, use, and storage of personal data of our digital platform users.
The rights holder is Bracopone d.o.o., the parent Company that owns all media under the Copone Digital Media brand. Bracopone d.o.o. manages all intellectual and ownership rights related to the content, design, and functionalities of the Copone Digital Media online media and ensures the lawful and transparent operation of all affiliated digital platforms. Bracopone and the Copone Digital Media brand take your privacy seriously.
The Privacy Policy clearly describes the reasons why we collect your data, how we use and protect it, with whom we share it, and how you can contact us regarding the protection of your privacy and compliance with GDPR. Our goal is to provide you with complete transparency and security when using our online media.
Bracopone and Copone Digital Media collect data and information about you in various ways. Please be careful when sharing your data and avoid giving or entering inaccurate and/or sensitive information to protect your privacy and security.
When there is a legitimate reason for collecting your data, we do not need to request your consent. In cases where there is no clearly expressed legitimate interest or any doubt regarding it, we will always obtain your consent before using your data and using it exclusively for the purpose you have agreed to. This ensures maximum transparency and respect for your privacy rights.
Bracopone and Copone Digital Media will try to collect accurate data, which will be corrected, deleted, or updated as necessary or upon the data subject’s request. Collected data will be stored only as long as needed, considering the purpose for which it was collected, i.e., by applicable regulations.
It is noted and emphasized that activities include photography, video recording, graphic design, as well as digital services and products. This includes managing social and digital media and networks, digital advertising, content creation and publishing on media and networks, website and application development and maintenance, as well as all aspects related to digital services, including advertising.
It is challenging to satisfy everyone, but our goal is to present our Privacy Policy transparently and clearly. Most users prefer concise and easily understandable information. Although we would like to summarize everything you need to know, our legal regulations require us to detail all essential aspects to ensure full compliance with our obligations.

LEGAL BASIS FOR PROCESSING PERSONAL DATA

We collect, process, and use personal data for the purposes for which it was collected, including but not limited to the following:

• Processing is necessary to comply with the company’s legal obligations,
• Processing is necessary for the performance of a contract to which the user is a party and/or to take steps at the request of the client and user before entering into a contract and/or framework agreement,
• Processing is necessary for the legitimate business interests of the company or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require protection of personal data,
• Based on the explicit consent of the user.

Personally identifiable data may include your name, email address, and other information that specifically identifies you. We use these data in various ways depending on the nature and purpose of the data.

However, your data are not collected unless you voluntarily provide them to us, except for specific data collected through information systems and software used on our website, where transmission is necessary for the use of internet communication protocols.

• Suppose you visit the social media channels of any of our media outlets under the Copone Digital Media brand and contact us. In that case, we will process your data to respond to you. In this case, the legal basis for processing is our legitimate interest in responding to your message. We do not store your data separately,
• If you participate in one of our promotional or prize games, we process your data to organize the promotional/prize game and award prizes. The legal basis for processing is our legitimate interest as the organizer of the game you registered for, and the promotion of that event and online media under the Copone brand. Additionally, explicit consent is required if we wish to publish recordings of your participation or prize handover,
• If you send us a complaint, a request related to a product or service fault, or a cancellation request regarding a purchased service, we process your data to verify the nature of your request. The legal basis in this case is our legitimate interest as a seller of goods or services. If necessary, we forward your request to the product or service manufacturer, with the legal basis being our legitimate interest in contacting the manufacturer to fulfill contractual warranties and to address your request. Our legal obligation toward you as a consumer also serves as the legal basis for processing,
• If you submit an open job application or apply in response to a recruitment advertisement, we process your data for recruitment and selection purposes. The legal basis for this is either our legitimate interest as an employer or your explicit consent, depending on the circumstances. This includes verification of prior work experience and educational qualifications through authorized bodies, with your consent,
• If you are identified as a supplier, customer, business partner, or their contact person, your data is processed for the purchase and sale of goods and services (orders, delivery, collection, invoicing, complaints, sending or preparing offers). The legal basis is our sales contract and/or legitimate interest in business cooperation with your employer,
• Suppose you work for the media, not part of Copone Digital Media, or report independently on behalf of third parties. In that case, we process your data for various professional publications based on our legitimate interest through business collaboration,
• If you request information about your rights, we will process your data to respond accordingly. The legal basis is our obligation to enable you to exercise your rights concerning your data,
• In the event of a security incident or suspicion thereof, we process data to investigate the incident, take appropriate measures, and inform you as necessary. The legal basis is our legitimate interest in protecting data and our legal obligation to notify you in case of a privacy breach,
• For audits or reviews of our data processing and business operations, we process personal data based on our legitimate interest in demonstrating the lawfulness of our activities,
• In the event of disputes or legal proceedings, we process data as necessary, based on our legitimate interest as a party to such proceedings,
• We process personal data for internal analysis and reporting based on our legitimate business interest.

We do not process any special categories of personal data about you (such as racial or ethnic origin, religious or philosophical beliefs, sexual life or orientation, political opinions, trade union membership, health data, genetic and biometric data), nor do we collect data about criminal convictions and offenses.

COLLECTION OF PERSONAL DATA

We may collect your data in the following ways:

• Directly from you, for example, data provided for concluding or performing a contract, visiting the Company’s premises, submitting your CV, attending one of our or our clients’ events, telephone conversations with an individual, participating in a prize game or competition, and similar situations,
• Indirectly, from publicly available sources on websites not owned by the Company, such as posts on social media, open forums, and data obtained through the use of cookies, links, and similar technologies.

REFUSAL OF CONSENT FOR DATA COLLECTION

We require specific data to support the operation of our services and products. Other data are optional, but their absence may affect the quality of your experience.

The data we must provide is used to improve our services and products. This includes personalized features, content, and recommendations.

Any specially protected data you choose to provide will be used for these purposes only, but not for displaying unnecessary information or data.

VISITORS

Suppose you visit any of our business premises (office space, logistics center, etc.). In that case, we process the personal data you provide at the entrance as well as video footage of your entry and exit. This data includes: your full name, ID card number, purpose of your visit, contact person at Bracopone and Copone Digital Media, and video recordings.

Before entering our business premises, you will be explicitly informed that our premises are under video surveillance.

PERSONAL DATA WE RECEIVE

When interacting with Bracopone, we may request certain information in the following ways:

• By submitting your CV,
• By subscribing to our newsletters,
• Through business contacts and cooperation, we may learn certain information about business partners or their employees for professional activities and to establish close business relations,
• When you visit us at a public event such as a celebration or event, or participate in one of our surveys, competitions, or prize games, we may request information such as your business card, name, surname, contact details, interests, and preferences,
• By participating in a public event, we may photograph or record you,
• When using our online services, we may receive content you choose to share, such as comments, photos, forum posts, or details about your interests and preferences,
• Representing our clients in conducting their marketing activities based on a contractual relationship,
• Establishing employment relationships by applicable regulations.

DATA COLLECTION THROUGH WEBSITES

As our website is one of the largest platforms for collecting personal data, Bracopone understands that our clients and visitors value their privacy. We want to reassure you that we are committed to protecting and respecting your privacy.

This Privacy Policy explains what you can expect from us regarding your data when you visit our website, contact us, or use any of our services, so please read it carefully.

Bracopone and Copone Digital Media act as data controllers under the General Data Protection Regulation (GDPR) and are responsible for processing personal data collected on or through this website.

If we collect your data through the website, we use it only for the following purposes:

• To improve the performance of our website and ensure its content is relevant to you,
• To ensure that content is displayed as effectively as possible for your browser settings,
• To administer our website for internal operations, including troubleshooting, data analysis, research, testing, statistics, and surveys,
• To provide you with the requested information.

When you use some of our social, digital, and online media applications or websites, we may receive information related to your social media accounts, for example:

• We may receive essential information from your social media profile if you log into our website using your social media account. The vital data we receive depends on your social media privacy settings, but may include your social media ID, full name, profile picture, gender, and language data. We may also receive additional information from your profile if you grant us access.
• We may track your interactions if you click “like” or a similar link on our website. Additionally, the content you view may be published on your profile or your social media newsfeed. We may receive information about further interactions with that published content (e.g., if your contacts click a link in the published content), which we may link to data we store about you.
• Click “like” or similar links on our pages hosted on social network websites or media. We may receive information about your social media profile depending on your account privacy settings.
• Details about the content you view.

TYPES OF COOKIES

Cookies are small text files that websites store on a visitor’s computer or mobile device to collect certain information about the user and enhance the browsing experience on the website.

Although cookies can improve user experience on the website, it is important to note that Bracopone may collect private information about users through cookies.

For this reason, Bracopone respects all privacy regulations to ensure users have the right to be informed about and give consent to the use of cookies.

The types of cookies we use include:

• Essential (Functionality) Cookies
  These cookies are crucial for enabling browsing and navigation of our website, as well as using its features. Without these cookies, the website cannot function properly.
• Statistical Cookies
  These collect information about how you use our website — for example, which parts of the site you visit most often. This data helps us optimize our website, facilitate navigation, and improve functionality. We do not collect any personally identifiable data through these cookies. All information collected by these cookies is anonymous.
• Functional Cookies
  These cookies allow our website to remember your browsing preferences (such as text size, fonts, language, location, and other customizable website elements). We do not collect any personally identifiable information through these cookies and cannot track your activity on websites outside of ours.

We also use Google Analytics, which collects analytical cookies to help us understand how you use the website and improve its functionality. You can learn more about how Google uses your personal data here: https://www.google.com/intl/hr/policies/privacy/. You can also opt out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

DATA COLLECTED THROUGH NEWSLETTER

If you have consented, we will send you a newsletter (approximately once a month) to keep you informed about our activities and help you discover our products and services.

For newsletter delivery, we use data processors including HubSpot and Mailchimp. For more information, please see the Privacy Policies of HubSpot and Mailchimp.

If you wish to stop receiving our newsletter, you can unsubscribe using the link provided in every newsletter email we send or send a removal request via email.

Please note that updating all our systems may take a few days. We appreciate your patience. While your request is being processed, you may still receive newsletters from us.

LINKS TO OTHER WEBSITES

Our website may contain links to other websites that we do not control. If you click a third-party link, you will be redirected to that third party’s website. We recommend reviewing the privacy policies of each website you visit.

When third parties act as data processors, they process your data in accordance with our instructions. When third parties act as independent data controllers, we cannot influence their behavior.

We regularly review our business partners to ensure your rights are respected.

We have no control over the content, privacy policies, or practices of any third-party websites or services and accept no responsibility for them.

DATA PROTECTION

We take multiple measures to protect your data from unauthorized access and misuse, for example:

• Access to your data is limited only to our employees who need it to carry out our business activities,
• We store data in specially separated folders (dedicated folders on personal computers, secure locked cabinets), with clearly defined access rights,
• We have implemented appropriate technical and organizational measures to prevent the loss, alteration, theft, or unauthorized third-party access to your data,
• We have ensured adequate physical, electronic, and management systems to protect and preserve data collected via the internet.

AUTOMATED DATA PROCESSING AND DATA PROFILING

Your data may be used for profiling in direct and targeted advertising.

THIRD-PARTY DATA PROCESSORS

We use third parties to process personal data on our behalf (e.g., cloud service providers based in the United Kingdom for website hosting), all of which are carefully selected and comply with applicable data protection laws.

Your data is stored within the European Union. In exceptional cases, your data may be transferred to third countries (outside the EU). Such transfers occur only based on a European Commission adequacy decision or after the recipient in the third country commits to comply with valid standard contractual clauses approved by the European Commission.

For marketing campaigns or sending notifications, we may use MailChimp and HubSpot, which are based in the United States. You can read more about how they process your data in their Privacy Policies available through their websites. We only provide them with your email address.

Additionally, depending on specific situations, Bracopone members operating in third countries may have access to your data.

Some of our data processors include Google, Mailchimp, and HubSpot.

DATA COLLECTED DURING BUSINESS RELATIONSHIPS WITH CUSTOMERS

In business relationships with partners, legal entities, and individuals (often with you personally), we often develop friendly and collegial contacts where we may learn personal information such as your date of birth to send you birthday or holiday greetings, gifts, invitations to our parties and other events, and more generally to socialize both professionally and personally.

By providing your data (such as your date of birth), you consent to us congratulating you on your birthday and presenting you with a symbolic gift. You may always withdraw your consent to personal data processing without any negative consequences, as described in this Privacy Policy.

Suppose you are assigned to us as a supplier or as a contact person at a supplier with whom we cooperate. In that case, we process the personal data provided by you or your employer that is necessary for ordering goods/services, delivery, collection, payment, or handling complaints. This includes: full name, supplier name, supplier address, your location, email address, and phone number.

Suppose you are assigned as a customer or contact person at a customer with whom we cooperate. In that case, we process the personal data provided by you or your employer that is necessary to sell services, deliver them, invoice, and/or collect payment. These data include your full name, customer name, address, location, email address, and phone number.

To minimize data processing, we remind suppliers and customers to use only official addresses, email addresses, and phone numbers when entering contact persons. In such cases, your data processing may not even occur.

If you work for a media outlet with which we regularly cooperate and you are our designated contact person, or if we work directly with you for publishing business information, we process your data to contact you regarding various professional publications. These data include your full name, media or platform name, profile, location, email address, and phone number.

We intend to use these data as long as you do not withdraw your consent. We wish to continue doing business and celebrating successes with you as long as it suits you.

DATA COLLECTED DURING RELATIONS WITH MEDIA AND JOURNALISTS

When you communicate with the Chief Editor, editors, or journalists, we use your data, including your name, place of residence, personal identification number (OIB), date of birth, email address, and phone number, to ensure the quality and efficiency of our communication.

We will keep and use the contact database for professional purposes until you withdraw your consent to its use. This way, we achieve mutual professional benefit.

DATA COLLECTED DURING EMPLOYMENT

We highly value the privacy of all our employees and do not collect their data without legitimate authorization. Whenever an employee’s or their child’s data is required for exercising certain rights, we always obtain prior consent from the employee, unless we have a legitimate interest or a legal basis to process the data without it.

Employees are required to provide data as specified by regulations governing record-keeping within their area of work, as well as other applicable regulations. If any initially provided data changes, employees must promptly update and provide accurate information. Failure to do so may result in adverse consequences for the employee.

Employee personal data may be collected, processed, used, and disclosed to third parties if necessary to exercise rights and fulfill obligations arising from or related to the employment relationship. For this purpose, data will be collected, processed, used, and shared with third parties by regulations on accounting, pension and health insurance, occupational safety rules, and laws enacted to implement the Labor Law.

We do not transfer employee data to other parties without the employee’s explicit written consent, except where required by law or necessary to fulfill contractual obligations with the employee.

Employee data is retained only as long as there is a legal obligation to do so and is deleted and/or destroyed once the legally prescribed conditions for deletion are met.

DATA COLLECTED AT ORGANIZED EVENTS

If you participated in one of our events, we processed the personal data you provided during registration and upon arrival.

Our events may be recorded, including video and photography. You will be separately informed about this in the event invitation and upon entering the event venue. The purpose of recording is to promote the event and Bracopone, as well as Copone Digital Media. The recordings may be published on websites, social media, and social networks.

Suppose you were a panelist, speaker, or host at our event. In that case, we may publish your name, surname, profession, position, and experience in the event announcement, event report, and recordings from the event.

CHILDREN’S PRIVACY

Children are all natural persons under the age of 18.
Our Services are not intended for children, and you must not use our Services if you are under 18 years old. You must also be sufficiently old to consent to the processing of your data. We do not collect personal data from children without the written consent of their parents and/or guardians.
If we become aware that such data has been provided to us without parental or legal guardian consent, we will delete it as soon as possible, guided by the instructions you, as a parent or legal guardian, have provided.
Parents or guardians have the same rights regarding the processing of their children’s data as adults do.

YOUR RIGHTS

You have many rights concerning your data, including but not limited to:

• You can withdraw your consent to any marketing communication or other processing at any time. If you withdraw your consent or if our legal basis for processing ends, or in any other case provided for by the General Data Protection Regulation (GDPR), you have the right to request the deletion of your data,
• You have the right to be informed about how your data is used,
• You have the right to request confirmation about data processing details (purpose, source, categories of personal data, recipients or categories of recipients, transfer locations, intended storage period, use of automated decision-making and profiling),
• You have the right to access the personal data we hold about you,
• You have the right to request correction and/or completion of inaccurate personal data,
• When we process your data based on your consent or a contract concluded with you, you have the right to request proper data portability,
• You have the right to request deletion of your data or cessation of processing or collection under certain circumstances,
• You have the right to opt out of receiving direct marketing messages,
• Suppose you dispute the accuracy of your data or in other circumstances permitted by the GDPR. In that case, you have the right to request a restriction on data processing until the issue is resolved.
• You have the right to request the transfer of your data to you or another service provider,
• You have the right to object to further or excessive processing of your data,
• You have the right to request an explanation of any automated decision-making process that affects you,
• You can request the transfer of your data to another controller,
• You can exercise your rights easily by unsubscribing from our mailing list, contacting us at info@bracopone.com, or reaching out directly to our Data Protection Officer,
• You have the right to complain at any time to the relevant data protection authority – the Croatian Personal Data Protection Agency (AZOP). Their website is www.azop.hr.

Your rights are free of charge. However, suppose you frequently (e.g., within 6 months of the previous request) or excessively (e.g., requesting a comprehensive set of your data in writing) request access or portability. In that case, we reserve the right to charge you for our costs before processing such requests.

We will consider every request in full compliance with applicable favorable data protection laws. We reserve the right to charge for processing unreasonable requests. Responses will be provided within 30 days from receipt of the request.

If you are an authorized representative of a client and want to request access, modification, or deletion of your or others’ data, you may also contact us in writing. We may request additional information to verify your identity.

We serve clients in Croatia, EU member states, and worldwide, providing privacy tools and controls to all users, regardless of their location. Your experience may differ slightly from that of users in other countries, but to ensure that Bracopone and Copone Digital Media comply with local requirements, we commit to respecting privacy by the laws of the country where the client is located.

DATA RETENTION PERIOD

We retain your data for the period necessary to fulfill the purpose for which it was collected, plus a reasonable amount of time afterward needed for deletion. The retention period depends on the purpose of processing, the sensitivity of the data, our legal obligations, and the legal basis for processing.

• For processing based on your consent, we keep your data for the duration of the consent or until you withdraw it. We delete data within 90 days of receiving a withdrawal of consent,
• For processing under our contract, we retain data during the contract term and for an additional five-year statute of limitations period. We delete it within one year after the limitation expires,
• For processing based on legal obligations, we retain data as long as the obligation remains in effect and delete it within one year after the legal responsibility has ended,
• For processing based on legitimate interests, we retain data as long as the legitimate interest lasts; we review the existence of that interest annually. Data is deleted within one year after the legitimate interest ends.

CHANGES TO OUR PRIVACY POLICY

From time to time, we may update these Privacy Rules to reflect changes in how we process your data.
We will not provide explicit notifications of these changes to our customers or website users. Instead, we recommend that you periodically review the policy for updates. You can do this by visiting our page.

SECURITY AND SECURITY PRACTICES

We are committed to taking reasonable steps to ensure the security of your data. To prevent unauthorized access, maintain data accuracy, and ensure appropriate use of information, we have implemented suitable physical, electronic, and administrative procedures, as well as technical and organizational measures to protect and secure personal data collected by any means, including via our website.
Due to the open nature of the internet, we cannot guarantee that communications between you and us, or information stored on our website or servers, will be completely free from unauthorized third-party access.

JURISDICTION, OVERSIGHT, AND COMPETENT AUTHORITIES

All matters related to our Privacy Policy are governed by Croatian law.
By using our services, you agree that courts in the Republic of Croatia will have exclusive territorial jurisdiction over any proceedings related to this Policy.

We may share your data in the following cases:

• To prevent or detect criminal offenses,
• For arrest or criminal prosecution of offenders,
• For tax or customs assessments or collection,
• By court order or as required by law.

RIGHT TO FILE A COMPLAINT WITH A SUPERVISORY AUTHORITY

At any time, you may file a complaint regarding the processing of your data if you believe we have violated Croatian or European data protection laws. Complaints can be submitted to the relevant supervisory authority, the Croatian Personal Data Protection Agency (Agencija za zaštitu osobnih podataka – AZOP), or, in the event of changes to applicable legislation, to any other competent authority that assumes jurisdiction. Since September 1, 2020, you may also complain to a supervisory authority within the EU.

DISCLAIMER

Suppose any provision of this Privacy Policy is found to be criminal, harmful, or unenforceable. In that case, such a provision will apply only to the extent it is not null, invalid, or unenforceable, provided that this does not affect the validity of the remaining provisions of this Privacy Policy.
Although we take available technical, organizational, and personnel measures to protect personal data against accidental or intentional misuse, destruction, loss, unauthorized modification, or access, we cannot guarantee that any personal data collected will never be accidentally disclosed in violation of this Privacy Policy.
To the maximum extent permitted by law, we exclude liability for damages caused to users or third parties by accidental disclosure of personal data.
Since we do not control personal data you provide when accessing or using other portals, or directly to third parties (e.g., in participation in sponsored activities), we exclude liability to the maximum extent permitted by law for any damages that may arise to you or third parties due to providing personal data.

CONTACTS AND HOW TO CONTACT US

If you have any questions or feedback about this Privacy Policy, wish to exercise any of your rights listed herein, or have a complaint, please do not hesitate to contact us—we will be happy to assist you.
You can contact us via our contact form, email, or postal address.
Bracopone contact details are:

• Email: info@bracopone.com
• Postal address: Bracopone d.o.o., Ul. grada Chicaga 7, 10000 Zagreb, Republic of Croatia.