We are Altera Savjetovanje Ltd., a company registered in Croatia under number 28683219469 whose principal place of business is at Trg Nikole Šubića Zrinskog 9, 10 000 Zagreb, Croatia (“Altera savjetovanje”/“we”/“us”/”our”).

The website at www.alteracf.com (the “Website”) as defined in the Altera orporate Finance (“Terms of Use”).

By registering to use our Services, you consent to us processing your personal information in accordance with this Privacy and Cookie Policy (the “Policy”). This is the legal basis upon which we process your personal information as well as because it is necessary for the performance of our obligations under the Terms of Use. You may withdraw such consent at any time by letting us know at data.protection@alteracf.com.

At that time, you may also want to remove any cookies which have been placed on any device used to access the Website. Your withdrawal of consent will not affect the lawfulness of any processing carried out by us prior to such withdrawal.

We want you to obtain personalised experiences anytime, anywhere, on any device. This requires us to collect personal information from you. However, we want to put you in control of that personal information. We want you to be aware at all times where and how your personal information is being used. This is of paramount importance to us.

So, let’s describe what this Policy tells you. It explains:

what information we may collect about you; what we may do with the information we collect about you; whether we share your information with anyone else; the types of cookies we use and how you can reject these cookies; where we store your information; how we keep your information secure; and your rights in relation to your information.

At Pepermint we take your privacy seriously. We operate on the principle that your personal information belongs to you and only you can decide who you want to share it with and why. This is fundamental to the way we work and we’re committed to providing a secure environment for you to store your personal information and share it with others when you want to.

WHEN DOES THIS POLICY APPLY?

This Policy and the Terms of Use apply to your use of the Website and to your use of the Apps, Newsletters and the Services once you register to access the Apps and use the Services.

HERE IS THE INFORMATION WE MAY COLLECT ABOUT YOU

Information you voluntarily provide If you contact us (by email or through the Website or the Apps), we may keep a record of that correspondence for two years in case we need to contact you in relation to the issue for which you contacted us, for operational performance improvement and/or nuisance caller management. We will not use it for marketing purposes.

If you report a problem with the Website, the Apps, Newsletters and/or the Services, we may keep that information for two years in case we need to contact you in relation to the issue you for which you contacted us, for operational performance improvement and/or nuisance caller management. We will not use it for marketing purposes.

The information you give may include your name, address, telephone number and email address.

Information we collect about you and your device When you use the Website, the Apps, Newsletters and interact with our Services, we may use technology such as that provided by Google Analytics and/or Mailchimp to collect information about your visit to our Website and use of the App and/or Newsletters. In essence, these tools enable us to analyse how you and others interact with our Website, Apps and Newsletters. The information we collect may include:

your IP address; the type of browser you use (e.g. are you using the Chrome or Safari browser?); the number of sessions per browser on each device; the type of device (eg Samsung) and operating system (eg Android) you are using; referrer information; time zone; if you opened our newsletters; user preferences; and which pages you visited.

THIS IS WHAT WE DO WITH THE INFORMATION WE COLLECT ABOUT YOU

We use the information you provide to us to:

enable us to provide the Services; ensure that content from our Website, Apps and Newsletters is presented in the most effective manner for you and for your device to achieve the most user-friendly navigation experience; provide you with marketing information about us and our services; notify you about changes to the Website, Apps and Newsletters and the Services; carry out our obligations arising out of the Terms of Use; and/or defend our servers against malicious attacks. Where we propose using your personal information for any other uses we will ensure that we notify you first. You will also be given the opportunity to withhold or withdraw your consent for the use of your personal information for purposes other than those listed above.

OUR USE OF AGGREGATED AND ANONYMISED INFORMATION

We may share anonymised usage data which does not identify you specifically with third parties. We may combine your data with those of other users of our Website, Apps and Newsletters and share this information in aggregated and anonymised form with third parties to help us improve the design and delivery of our software tools, increasing the effectiveness for all users and to allow us to monetize our Website, Apps and Newsletters, which enables us to provide our Services to you.

THIS IS WHO WE SHARE YOUR INFORMATION WITH

We will only share your non-anonymised information with other organisations where we have your permission to do so in accordance with this Policy or where we believe it is necessary for a legitimate reason connected with the Website, Apps and Newsletters and/or our Services.

We work with analytics providers and we may receive information about you from them. Below is a non-exhaustive list of third parties we work with. We may work with third parties not listed below or stop working with the third parties listed below.

NAME OF THIRD PARTY WHY WE WORK WITH THEM

Google Analytics To monitor Website performance and user experience.

Google Apps for Work To process emails.

In addition, we may disclose your personal information to third parties:

if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request; to enforce or apply our Terms of Use and other agreements or to investigate potential breaches; and/or to protect the rights, property or safety of our Website, Apps and Newsletters our users.

OUR USE OF COOKIES, PIXELS AND LOCAL STORAGE

Cookies are small pieces of data that are stored on your computer, mobile phone or other device. Pixels are small blocks of code on web pages or emails that do things like allow another server to measure viewing of a web page or email and are often used in connection with cookies. HTML5 Local Storage is a small database located inside your browser which web pages can use to store data to speed up their processing. We may use all three technologies from time to time, to help improve your user experience.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, storing your preferences, and generally improving your experience of our Website, Apps and Newsletters. Cookies make the interaction between you and our Website, Apps and Newsletters faster and easier. We use cookies to distinguish you from other users of the Website, Apps and Newsletters and our Services. This helps us to provide you with a good experience when you use the Website, Apps and Newsletters and also allows us to improve the Website, Apps and Newsletters and Services. Cookies and other things like local storage also help us authenticate you to deliver personalised content to you.

Please refer to your device’s help material to learn what controls you can use to remove or block cookies. Please remember that if you do this, it may affect your ability to use the Website, Apps and Newsletters and/or the Services. As you use your device, you will encounter third parties that make use of cookies and similar technologies. We are not responsible for those third parties or what they may place on your device or in your browser.

THIS IS WHERE WE STORE YOUR INFORMATION

The information that we collect from you may be processed outside the European Economic Area (EEA), but we have ensured that there is an adequate level of protection for such information.

KEEPING INFORMATION SECURE

All information you provide to us is stored on servers owned and operated by Cloudways.com, Inc, unless it is shared with a third party such as Google Analytics (for instance, see the table of third parties we use above). More information on this provider is available at https://cloudways.com.

HERE ARE YOUR RIGHTS

We think it is important that you are able to control your personal information.

You have the right to ask us not to process your personal information for marketing purposes, with the exception of customer communication such as downtime, welcome emails and the like. You can exercise your right to prevent such processing at any time by contacting us at data.protection@alteracf.com.

The law gives you the right to request a copy of the personal information we hold about you. We first require you to prove your identity with 2 pieces of approved identification. We will supply, correct or delete personal information about you on our files. In addition, you may request rectification or erasure of personal information as well as the restriction of processing of your personal information. We will comply with your requests in accordance with the applicable law.

If you wish to complain about the processing of your personal information then please contact us first, but if we do not satisfactorily deal with your complaint, then you may contact the Information Commissioner.

If you want to stop using the Website, Apps and Newsletters and the Services, you may do so. If you do, you may also want to remove any cookies that we have placed on any device used to access the Website, Apps and Newsletters and the Services.

THIRD PARTY PROPERTIES ACCESSED FROM THE WEBSITE / APPS / NEWSLETTERS

Our Website, Apps and Newsletters and Services may contain links to and from the online properties of third parties. If you follow a link to any of these online properties, please note that these online properties have their own privacy policies which will govern use of any personal information that they process. Please check these policies carefully before you click on any links and/or submit any personal information to these online properties.

CHANGE OF CONTROL

If the ownership of our business changes, we may transfer your information to the new owner so they can continue to operate the Website, Apps and Newsletters and provide the Services. The new owner will be obliged to comply with this Policy.

CHANGES TO OUR POLICY

Any changes we may make to this Policy will be posted on this page. Where it makes sense because the changes are material, we will notify you by e-mail or in another appropriate manner such as when you next interact with the Website, Apps and Newsletters.

CONTACTING US IS EASY AND WE WANT TO HEAR FROM YOU

We really do welcome any questions, comments and requests you may have regarding this Policy. You can contact us by emailing us at data.protection@alteracf.com.