We respect your privacy and therefore Tink Things is committed to protect information that identifies or is capable of identifying an individual (“personal data”), which it collects, uses and/or has access to.

How personal data is collected, used and shared depends on how you interact
With this Privacy Policy we want to ensure that you receive adequate information about our collecting and processing of your personal data, including such information we are obliged to inform you about according to applicable personal data protection regulation incl. the EU Regulation No. 2016/679 the General Data Protection Regulation (“GDPR”). 

This Privacy Policy may be supplemented by other information received from us and other terms and conditions applicable to this website, or which you have agreed to as part of interacting with us.

How we use cookies and your personal data
We use cookies to improve your user experience on our website, to store the choices you make when you use our website, and to help us make ongoing improvements in the content and functions you encounter on our website. We also use cookies to target our marketing to your need and to generate usage statistics for our website.

When you interact with us we will collect personal data about you, and use it for various purposes, such as operating this website, enabling you to make use of our various services, including our online shop, signing up for Newsletters, creating accounts with us, contacting our Customer Service representatives etc. We also use your personal data to evaluate and assess your personal interests and preferences in order to personalise your website experiences and improve our services and offer you services better customised to your interests and preferences. 

If you are asked to provide information, then it is optional for you to disclose such information. The information might, however, be needed for statutory, contractual or practical reasons. We will always clearly indicate whether the information is mandatory. If you refrain from disclosing information which we deem as mandatory, as a consequence it may be that we will not be able to provide you with the services you have requested (e.g. signing up for a newsletter, creating an account or making a purchase through our online shop etc.).

To help personalise and continuously improve our services and communication with you, for instance through our newsletters, we may upon occasion ask you for information on your personal interests, demographic data or your experience of our products and services. This supplementary information is always voluntary, but we appreciate your support in providing it

How we collect and use your personal data depends on how you interact with us, and which services you make use of.

What is a Cookie?
A cookie is a small text file that stores Internet settings. Almost every website uses cookie technology. The cookie is downloaded by your Internet browser the first time you visit a website. The next time you visit this website from the same device, the cookie and the information in it are either sent back to the originating website (first-party cookies) or to another website to which it belongs (third-party cookies). By that, the website can detect that it has already been opened using this browser, and in some cases it will then vary the content it shows.

Some cookies are extremely useful because they can improve your user experience when you return to a website you have already visited. This assumes that you are using the same device and the same browser as before; if so, cookies will remember your preferences, will know how you use the website, and will adapt the content you are shown so that it is more relevant to your personal interests and needs.

Cookies on this website that do not require approval (Strictly necessary cookies)
Cookies that are essential, also known as ‘strictly necessary’ cookies, enable features without which you would not be able to use the website as intended. (These cookies are used exclusively by this website and are therefore known as first-party cookies.) They are only saved on your computer while you are actually browsing the website. Strictly necessary cookies are used to ensure that what you see on screen corresponds to the data volume which your current Internet connection can handle. These cookies also facilitate the switch from http to https when you change pages, so that the security of data transmitted is maintained. Furthermore, a cookie of this kind is used to store your decision about the use of cookies on our website. Your consent is not required for the use of strictly necessary cookies.

First-party cookies on this website that require consent
Cookies which, in strictly legal terms, are not absolutely essential in order to use this website, do nevertheless fulfil important functions. Without these cookies, features that enable our website to be used easily, such as pre-completed forms, will no longer be available. Settings you make, such as language choices, will no longer be saved, so you will be asked about them every time you change pages. As well as that, we will no longer have a way of presenting offers to you that are tailored to you personally.

We use Google Analytics remarketing codes to log when users view specific pages or take specific actions on a website. This allows us to provide targeted advertising in the future. If you do not wish to receive this type of advertising from us in the future you can opt out using the DoubleClick opt-out page or the Network Advertising Initiative opt-out page.”

Third-party cookies on this website that require consent
This website has integrated content belonging to third parties. These third-party providers can place cookies while you visit the website, and in doing so can obtain information about the fact that you have visited the website. Please visit the websites belonging to those third-party providers if you need more information about how they use cookies. If you have decided not to provide your consent to the use of cookies that require it, or if you have revoked that consent, then you will only be provided with website features whose use does not require such cookies. Areas of the website that can potentially incorporate content from third parties, and which therefore place third-party cookies, will not be available to you if that is the case. If you do not want to accept cookies at all, then you can also configure that in your browser.

Your consent applies to the following domain: www.tinkthings.com

You have the opportunity to sign up to receive information by e-mail about Tink Things’s products, services, contests and promotions from us (“Newsletters”). We will only send you newsletters and other marketing material, if you have specifically consented to receive newsletters from us.

If you sign up to receive Mailings either through our website, in person at a trade show or in another manner (for example, via social media channels), then you will be asked to provide certain basic information about yourself. The mandatory personal data includes your first and last name and e-mail address (“Newsletter Registration Data”), which will be used for the purpose of your registration, checking the validity of the e-mail and providing you with relevant Newsletters. We cannot sign you up for Newsletters, unless you provide us with the mandatory information. 

We may also give you the opportunity to provide us with other supplementary data other than the data that we clearly have indicated as mandatory, such as gender, phone number, birthdate, interests. It is your own choice whether you provide such supplementary data to us. If you provide us with the supplementary data, it will help us improve our services and offerings to you. 

The Legal basis for sending you Newsletters is GDPR art. 6(1) a) namely the consent you have granted, when signing up to receive Newsletters. 

You can always withdraw from a consent to receive Newsletters and unsubscribe from an e-mail list by following the instructions in any e-mail or other communication you receive from us. Please also refer to section 5 (Your rights and how to withdraw consents and unsubscribe).

Our Newsletters contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, we may see if and when an e-mail was opened by the recipient, and which links in the e-mail were called up by the recipient (“Newsletter-Tracking Data”). Such Newsletter-Tracking Data are used by us to perform general marketing research and to optimise the distribution and use of Newsletters. The legal basis for this is GDPR art. 6(1) f) our legitimate interest namely in understanding customer behaviour and interests and ensuring effective marketing and advertisement of Tink Things products and services.

We will also use the Newsletter Registration Data, supplementary data and Newsletter-Tracking Data to perform general marketing research and to tailor or improve our websites and our service offerings. We may also link this data to other personal data about you for profiling purposes in order to be able to personalise your website experiences, adapt the content of future Newsletters to better suit to your interests and to provide you with personalised offerings. Please also refer to section 2.8 (Profiling for marketing purposes).

If you create an account with us in our webstore, then you will be asked to provide certain basic information in order to create and operate the account. The mandatory personal data includes your first and last name, gender, e-mail address, and password (“Account Registration Data”). The purpose is to create your account and make it available to you. We cannot create an account and make it available to you, unless you provide us with the mandatory information.

We may also give you the opportunity to provide us with other supplementary data than the data which we have clearly indicated as mandatory. Such supplementary data might include your age, birth date, family information, shipping and billing address and other demographic information or information about your interests and purchasing preferences. We might also give you the opportunity to submit personal data about other people (e.g. information about your kids, spouse, friends etc.). If you submit personal data about other persons, you warrant that you have informed such other persons about the submission and have obtained their prior consent hereto and to our use hereof in accordance with this Privacy Policy. 

It is your own choice whether you will provide such Supplementary Data to us. 

You can use your account at www.tinkthings.com to manage your account data and provide us with supplementary data, which will help us improve our services and offerings to you. You will also have access to certain transactional data about your previous purchases, returns etc. To provide you with an increased level of security online, access to your personal data on certain parts of our websites may be protected with a password that you have selected. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication.

The legal basis for the processing described above in this section is GDPR art. 6(1) a) namely the consent you have granted when creating the account. You can manage and delete your tinkthings.com account by logging into the account to administer it.

We will also use your personal data for performing general market research and analysis in order to tailor and improve our websites and service offerings. We may also link your tinkthings.com account data to other personal data about you for profiling purposes in order to be able to personalise your website experiences and to provide you with personalised offerings (e.g. special birthday vouchers, offers that relate to your previous purchases, country of residence, etc.). 

Newsletter subscription
Please be informed that we will not use your e-mail etc. to send you Newsletters, unless you have explicitly consented to receive such Newsletters. 

If you make or take steps to make a purchase on this website, we process your personal data including your name, e-mail, shipping and billing address, details of the purchased items and other information necessary for the purpose of completing the purchase and delivery of the purchased items to you (“Online Transactional Data”).  The Legal basis for this processing is GDPR art. 6(1) b) namely that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract. 

If you have signed up to receive Newsletters, then we will also use your personal data in order to adapt the content of Newsletters to better suit your interests and to provide you with personalised offerings. The Legal basis for this is GDPR art. 6(1) a) namely the consent you have granted, when signing up to receive Newsletters. 

If you disagree and want to object to this, please contact us in accordance with the section 1 “Our Contact Details”, and we will then cease to use your personal data for profiling for marketing purposes.

How we’re sharing your personal data
In order to make our services available to you, provide you with requested services and support and in general to operate our business, we will have to disclose and transfer your personal data to certain departments within our company as wel as to third parties, such as IT suppliers, marketing agencies, logistics service providers, payment service providers, etc. 
Please be ensured that we will never sell or rent your personal data to third parties for them to be able to use your personal data for their own direct marketing purposes, unless we have your consent to do so. When using data processors to process your personal data on our behalf, we require that they only process your personal data in accordance with our instructions. We also require that the data processors signs relevant contracts providing sufficient guarantees to implement appropriate technical and organisational measures in such a manner that the data processing will meet the requirements of the applicable data protection regulation and ensures an appropriate protection of your rights.

In case we disclose your personal data to a third party who will not be acting as a data processor under our instructions, but as an independent data controller, then we shall do our best to ensure that they are trustworthy and have implemented appropriate technical and organisational measure to protect your data, and provide us with clear commitments to comply with applicable data protection regulation and not to use the personal data received from us for other purposes, than providing agreed services and making statistical analysis in an anonymous manner.

The main categories of potential recipients of your personal data are:
A. Service Providers
We may share your personal data with our trusted third party service providers, who, on our behalf, operate, maintain, and/or support our IT systems and IT infrastructure, our websites, manage our payment solutions, perform statistical analysis, sending newsletters, deliver goods you have purchased from us, provide customer support and perform other important services for us.
B. Legal Successors
A transfer of your personal data to another legal entity may occur as part of a transfer of our business or parts thereof in form of a reorganization, sale of assets, consolidation, merger or similar.
C. Other disclosures
In addition to where you have consented to a disclosure of the personal data or where disclosure is necessary to achieve the purpose(s) for which it was collected, personal data may also be disclosed in special situations, where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users, or anyone else who could be harmed by such activities, or otherwise where necessary for the establishment, exercise or defense of legal claims.

How we retain and delete your data
Your personal data will be held by us and kept in a form, which permits identification of you for no longer than is necessary for the purposes for which the personal data is collected and legitimately processed. This implies that we will keep and process your personal data as long as we are providing services to you and also keep it afterwards for as long as would be needed for the settlement of any potential disputes that may be raised afterwards or as long as the law otherwise provides for. Thereafter, we will either delete your personal data or anonymise it so that it no longer can be used to identify you. We will delete any information, which according to our reasonable assessment seems to be inaccurate or out of date by reason of the time elapsed since it was collected or by reason of any other information in our possession.

If you provide us with a written request, we will also erase or anonymise your personal data without undue delay, unless we have a valid legal ground to continue to keep your personal data. Please also refer to section 5 (Your rights and how to withdraw consents and unsubscribe).

Withdrawing consents
You have certain rights according to the applicable data protection regulation. Some of the rights are rather complex and include exemptions, accordingly you are recommended to read relevant laws and guidance from the regulatory authorities for full explanation of these rights. However, you can find a summary of your rights, if you unfold below sections. You have a right to obtain the confirmation as to whether or not your personal data are being processed by us. In addition, you have a right to obtain more detailed information about the personal data kept and the processing undertaken by us and under certain circumstances the right to receive a copy of this personal data.

You have the right to have inaccurate personal data about you rectified, and, taking into account the purpose of the processing, to have incomplete personal data completed. In some cases, you have the right to erasure of your personal data without undue delay. Those circumstances include; i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; ii) you withdraw consent to consent-based processing; iii) the processing is for direct marketing purposes and iv) the personal data has been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary; i) for the exercising the right of freedom of expression and information; ii) for compliance with legal obligation; or iii) for the establishment, exercise or defense of legal claims. In some cases, you have the right to restrict the processing of your personal data. Where processing has been restricted, we may continue to store your personal data. However, we will only otherwise process it i) with your consent; ii) for the establishment, exercise or defense of legal claims; iii) for the protection of the rights of another natural or legal person; or iv) for reasons of important public interest.

To the extent the legal basis for the processing is your consent, and such processing is carried out by automated means, you have the right to receive your personal data in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

You have the right to object to the processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for i) the performance of a task carried out in the public interest or in the exercise of any official authority vested in Tink Things and Benussi & the Fish j.d.o.o.) the purpose of legitimate interests pursued by us or a third party. In such case we will cease processing the personal data, unless we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.

You also have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

To the extent that the legal basis for the processing is your consent, you have the right to withdraw from that consent at any time. 
In case you withdraw from a consent given, then we will cease to process your personal data, unless and to the extent the continued processing is permitted or required according to the applicable personal data regulation or other applicable laws and regulations. The withdrawal from your consent will in no event effect the lawfulness of processing based on consent before its withdrawal.

If you refrain from providing required consents, or later on withdraw from the consents, it might have as a consequence that you may not be able to benefit from some of the service offerings provided by us. 

We do our best to ensure that we protect your personal data, keep you informed about how we process your personal data and comply with the applicable data protection regulation. In case you are not satisfied with the processing and protection of your personal data or the information you have received from us, then we urge you to inform us in order for us to improve. Please also do not hesitate to contact us, if you want to make use of your rights.

Please contact us through the points of contact listed in section 1 (Our Contact Details). Please also provide us with relevant information to take care of your request, including your full name and email address so that we can identify you. We will respond to your request without undue delay.

You can always withdraw from a consent to receive newsletters etc. and unsubscribe from an e-mail list by following the instructions in any e-mail or other communication you receive from us. 
If you have created an account with us, then you can also manage and delete your account by logging into the account and administer your account.

Links to other websites
We may provide links to third party websites. These linked websites are not under our control, and we therefore cannot accept responsibility or liability for the conduct of third parties linked to our websites. Before disclosing your personal data on any other website, we advise you to examine the terms and conditions of using that website and its privacy policies.