Privacy Policy Effective Date: March 3, 2023
1. General Gepek d.o.o. (with registered address at M.Krleže 15, 44320 Kutina), as the controller, is dedicated to protecting and respecting your privacy. This policy (“Privacy Policy”) is designed to inform you of our practices regarding the collection, use, and disclosure of information you provide to us through our platform (“Platform”) accessed through Google Play or IOS. This Privacy Policy (together with our Terms and other documents referred to therein and our Cookie Policy) sets out the basis on which we will process data collected from you or that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
2. What information do we collect from you and for how long? We may collect and process the following from you:
2.1. Information you provide to us You may provide information to us, including information that serves to identify you (“Personal Data”) when you use our platform, fill in forms on our platforms (e.g. registration forms), when you sign up for any contests, promotions or surveys, when you communicate with us by phone, email or otherwise, and when you report a problem with our platform. Information you provide to us may include: •
2.1.1. Required information for signing up for our services on our platform or for accessing other services we provide, which includes your name, email address, date of birth, and when creating an account, a password. All of these fields are mandatory. Gepek will not be able to provide you with services offered on our platform if you do not provide us with the requested information or, where applicable, register for a user account on our platform; •
2.1.2. Photograph; •
2.1.3. Address; •
2.1.4. Your telephone number; •
2.1.5. Vehicle information; •
2.1.6. Short biography, your gender when you agree to provide such information.
2.1.7. Record of correspondence between you and Gepek; we may also record and/or listen to phone calls between you and Gepek (for example, with agents from our Community Relations service). We give you the option to object to the processing at the beginning of the call;
• 2.1.8. Record of reservations or trips related to ads you have placed on or through our platform;
• 2.1.9. Data on accounting or financial transactions, including transactions you have conducted through our platform or otherwise. This may include information such as data on your bank or credit card, bank account, trips or travel shares you have booked or offered through our platform;
• 2.1.10. Information about your visits to our platform and the sources you access;
• 2.1.11. Your responses to surveys and questionnaires, such as descriptions of trips you have made through our platform. This information may be used for analytical purposes and to understand our users;
• 2.1.12. Information we may request from you when you report a problem on our platform or with our services, such as the subject of your support request;
• 2.1.13. Location data, when you give your consent for the collection of data and processing of such data so that we can respond to your travel search in your vicinity; and
• 2.1.14. A copy of your passport, driver’s license, ID card, and similar documents if you have agreed to provide them to us.
2.2. Information we collect automatically
2.2.1. If you log in using social media authentication, Gepek will have access to certain personal data (such as your name, picture, and email address) on your social media account in accordance with the applicable terms of use of those social media platforms. Some of your personal data may also be collected during your interactive use of third-party social media features, such as when you select “Like.”
2.2.2. Regarding your visits to our platform, in accordance with applicable legislation and when necessary, with your consent, we may collect information about the devices you use and the networks to which you are connected when using our services. These may include the following information: your IP address, login data, browser type and version, type and version of your browser plug-ins, operating system and platform, information about visits including URL clickstream for various pages on our platform, content you have viewed and searched for, search terms used, download errors, duration and visits to specific pages, advertising identifier of your device, interaction on pages, and all phone numbers used to contact us. We collect this information using various technologies, including cookies (for detailed information, please refer to our Cookie Policy).
2.2.3. In addition, we collect information about your overall activity on our platform (e.g., the number of rides offered, the number of responses to your ads, etc.), including data about your usage of our services, your search and browsing history, and your preferences and settings. This information is collected using various technologies.
2.3. Data retention
In accordance with your rights as a data subject, we will store your data in compliance with applicable regulations, where the retention periods may depend on fulfilling certain obligations based on specific legislation.
In any case, when it is determined that your data is no longer needed and the legal retention periods for such records and data have expired, we will delete your personal data.
How we use the information we collect from you?
We will use the information we collect for the following purposes:
3. PURPOSE LEGAL BASIS
3.1 fulfilling all obligations arising from the contracts we have mutually concluded or those that you have concluded with our business partners, providing information, and providing services that you request; This processing is necessary for the performance of our mutual contractual obligations.
3.2 sending information related to services via email and/or SMS and/or any other communication means (e.g. your reservation confirmations); This processing is necessary for the performance of our mutual contractual obligations or is carried out with your consent.
3.3 collecting payments from you or transferring to you all payments we collect on your behalf; This processing is necessary for the performance of our mutual contractual obligations.
3.4 enabling the personalization of your user profile on our platform; This processing is carried out with your consent.
3.5 improving our Community Relations service and training our customer agents by recording your phone calls with us. This processing is based on our legitimate interest (to provide you with high-quality customer support / to improve our customer support).
3.6 ensuring compliance with (i) applicable laws, (ii) our terms of use, and (iii) our Privacy Policy. Some violations that we consider inappropriate may result in the suspension of your account on our platform. For this purpose, we may use technologies to automatically analyze your use of our platform, including the content of your posts, in order to detect any behavior that may be interpreted as a violation on your part. This processing is necessary (i) for the performance of our mutual contractual obligations, (ii) to comply with our legal obligations based on your consent, or (iii) to establish, exercise, or defend against claims.ased on specific legislation.
3.7 We will send you advertising materials and information, in accordance with applicable laws and with your consent, that are necessary for the provision of our services or reservations, and to suggest and recommend products and services related to our services that may interest you. We also use your data to show you our ads on social media platforms or third-party websites. For more information on how these features work and what data we collect, please refer to the relevant sections on social media platforms or pages. This processing is carried out with your consent if required by law or as part of our legitimate interest (i.e., content advertising).
3.8 We will inform you of changes related to our services. This processing is necessary (i) for the performance of our contractual obligations, (ii) to comply with our legal obligations, or (iii) to establish, exercise, or defend against claims.
3.9 We will verify the information provided in your passport, driver’s license, ID card, and other identification documents that we collect during registration or at any time while using our platform. This processing is carried out (i) with your consent, (ii) to comply with our legal obligations, or (iii) as part of our legitimate interest.
3.10 We will administer our platforms and internal operations, including problem solving, data analysis, testing, research, and analytical and survey purposes. This processing is based on our legitimate interest (i.e., ensuring the security of our platform and improving their features).
3.11 We will improve our platform to ensure that content is displayed in the most effective way for you and your device. This processing is based on our legitimate interest (i.e., providing meaningful content).
3.12 We will allow you to participate in interactive features of our service when you choose, such as searching for nearby travel based on your location. This processing is necessary (i) for the performance of our contractual obligations or (ii) with your consent if required by law.
3.13 As part of our efforts to make our platform safe and secure. This processing is carried out (i) based on our legitimate interest (ensuring the security of our platform), (ii) to establish, exercise, or defend against claims, or (iii) to comply with our legal obligations.
3.14 We will measure and understand the effectiveness of the advertising we offer and send relevant advertising materials to our users. This processing is carried out (i) based on our legitimate interest (i.e., measuring and optimizing the effectiveness of our advertising campaigns) or (ii) with your consent if required by law.
4. Who are the recipients of the information we collect from you and for what purposes?
4.1. When you use our services, some information about you is shared with members of our communities, either on your public profile or when you make a reservation (for example, we provide your phone number to members with whom you will share a ride).
4.2. We may receive and send your data, including personal data, to other Gepek entities or affiliated companies for the purposes stated in this Privacy Policy.
4.3. In addition, we work closely with third parties who may be recipients of your personal data, such as: • business partners who are social media platforms and who can provide you with connectivity services, such as connecting information from your Gepek profile to their platforms on ours;
• business partners whose services may be advertised on our platform and which you may choose to sign up for. These services may include insurance services, banking services, rental services, etc.;
• business partners who may advertise our services on their websites;
• our external collaborators on services such as technical services, payment services, identity verification, delivery or analytics.
4.4. Information you provide to us, including your personal data, will not be disclosed to the third parties listed in section 4.3 except:
4.4.1. when it is necessary to engage a third party to perform mutual obligations in order to ensure or expand the provision of our services (e.g., in the context of payments made on our platform);
4.4.2. as part of the reservation process and in order to provide requested services, information such as your name, photo, and/or email address may be displayed on the platform and/or forwarded to another member;
4.4.3. as part of our rating system, the ratings you write are published on our platform. Ratings, together with your abbreviated name and picture, are visible to all visitors to the platform.
4.4.4. In order to improve and optimize our platforms, we use analytical services and search engines; 4.4.5. If you explicitly request it (e.g. when using authentication methods on social networks, subscribing to a service from one of our partners, requesting participation in an offer or promotion from one of our partners);
4.4.6. We may distribute parts of our platform (and trips you have posted) for publication on the websites of our business partners, via APIs or widgets. In such cases, some information from your public profile may be displayed on those websites;
4.4.7. If required by law or if we believe in good faith that it is necessary (i) to respond to a lawsuit filed against Gepek, (ii) to comply with legal regulations, (iii) to implement agreements with our users, such as the terms of use and the Privacy Policy, (iv) in an emergency that represents a danger to public health, death or bodily injury to individuals (v) as part of an investigation or (vi) to protect the rights, property or personal safety of Gepek, its members and others;
4.4.8. In the event of our sale or purchase of a commercial company or asset, we may disclose your personal information to the future seller or buyer of the commercial company or asset and
4.4.9. If Gepek or part or all of its assets is acquired by a third party, the personal data that the company has about its members becomes transferable property in that case.
4.5. In accordance with applicable laws and where required by your consent, we may combine information about you, including personal data and cookie data, that we send or receive from our business partners. We may use this and combined information for the purposes previously mentioned.
4.6. We would like to draw your attention to the fact that if you choose to share information, including personal data, with us through connection services provided by our business partners, their privacy policies and/or notices may also apply to you in addition to this Privacy Policy. We do not control the collection and/or final processing of your data carried out by our business partners on their platforms.
5. How do we use and modify your messages?
5.1. We may read the messages you exchange with other members of the community on our platform in order to prevent fraud, improve the service, provide assistance to users, and implement agreements concluded with our members (e.g. terms of use). For example, in order to prevent circumvention of our online reservation system, we may scan and analyze messages sent through our platform to check for any contact information or references to other websites, and where applicable, messages may be blocked and fully or partially filtered.
5.2. We will never scan or analyze the messages you exchange with other members of the community for commercial or advertising purposes
6.Targeted advertising and our communication via email and/or SMS messages
In accordance with applicable laws and where required by your consent, we may use the information you have provided us on our platform for the purpose of direct electronic marketing (e.g. (i) receiving our newsletters, (ii) receiving invitations to our events and other forms of communication that may interest you, or (iii) sending targeted advertising materials to third-party social media platforms or websites based on your profile and interests). For communication through electronic marketing: you can withdraw your consent at any time by (i) unchecking the relevant checkbox on your account, (ii) clicking on the unsubscribe link we send in each personally addressed communication, or (iii) contacting us using the contact details provided in chapter 13 below.
For targeted ads and content: on social media (e.g. Facebook): you can reject them at any time by configuring the settings related to direct advertising through your social media account, or by contacting us in accordance with article 13 below;
on third-party websites: please refer to our Cookie Policy to learn how to reject advertising.
7.Does your information get transferred, how and where?
In principle, we store personal data we have about you in the European Union (“EU”). However, as some of our service providers operate in countries outside the European Union (“third countries”), we also transfer some of your data to third countries. This may include third countries for which the European Commission has not yet made a decision that such third country has an adequate level of protection. In that case, we ensure that the transfer is carried out in accordance with applicable legislation and apply appropriate safeguards (especially standard contractual clauses adopted by the European Commission) to ensure an adequate level of protection of privacy and fundamental rights of individuals. By sending a request to the data protection officer of the group (info@theGepek.com), we can provide you with details of such appropriate safeguards (e.g. standard contractual clauses adopted by the European Commission).
8.What are your rights regarding your personal data?
8.1. You have the right to obtain a copy of your personal data that we hold (your right to access data).
8.2. You can request the deletion of personal data or correction of inaccurate personal data (your right to erasure and rectification). Please note that we may retain certain data relating to you, in accordance with the law, or if we have a legal basis for doing so. For example, if we believe you have committed fraud or violated our Terms and Conditions, and we want to prevent you from circumventing the rules applicable to our community.
8.3. You have the right to object at any time to (i) the processing of your personal data for direct marketing purposes, or (ii) any other processing of your personal data based on our legitimate interest (your right to object to processing).
8.4. You have the right to restrict the processing of your personal data (your right to restrict processing). Please note that this only applies if you have (i) contested the accuracy of your personal data, and we are verifying the accuracy of the personal data; (ii) exercised your right to object, and we are still considering, in accordance with applicable law, whether our legal reasons outweigh yours; or (iii) we have processed your personal data unlawfully, and you request the restriction of their processing, rather than their deletion; or (iv) we no longer need personal data for processing purposes, but they are still needed for you to establish, exercise, or defend legal claims.
8.5. You have the right to data portability, i.e., the right to receive personal data that you have provided to us in a structured, commonly used, and machine-readable format and the right to transfer that data to another controller (your right to data portability).
8.6. You also have the right to lodge a complaint with the relevant data protection supervisory authority or seek a legal remedy through the courts if you believe that your rights have been infringed.
8.7 To exercise your rights, please contact the Data Protection Officer of the Group using the contact details provided in Article 13 below.
Cookies and similar technologies
We use cookies to be able to further improve the platform, in order to improve the user experience. We will not use cookies together with your personal data without your prior consent.
Our data processing is based on the legal provisions of Article 96, act 3 TKG i article 6. act 1. (consent), same as recital 47 (legitimate interest) of the General Data Protection Regulation (GDPR).
Cookies are small text files that are placed on your device to store data that can be recalled by the web server in the domain that set the cookie. We use cookies and similar technology to track and remember your activity on the platform, to store your preferences and settings, and to apply them for logins, enable online advertising, combat fraud, analyze platform performance, and other legitimate purposes. We may also use web beacons to deliver cookies and collect usage and performance data. Our websites may include web beacons, cookies, or similar technology from third-party service providers.
If you do not enable cookies, you will still be able to use our pages, but certain functionalities may be disabled. Most web browsers allow the use of cookies in their settings, but you can change these settings in your web browser settings (on your computer, tablet, or other mobile device).
Cookies cannot harm your computer. We never store personally identifying data, such as your credit or debit card data, in cookies, but we use encrypted and anonymized data we collect from cookies to improve our website – for example, to identify and fix errors that sometimes occur on web pages.
Cookies are not computer programs and cannot read other information stored on your computer. They cannot be used to transmit computer viruses or to obtain user data such as email addresses, etc. It is possible that we have an agreement with carefully selected and monitored suppliers who, in a small number of cases, may set cookies during your visit to our website for remarketing purposes – to show you products and services based on your presumed interests and preferences. Please note that we are not responsible for the content of websites that are not ours or that we do not control.
Our cookies do not contain personal information such as your name or surname, or payment information – they only contain a ‘key’ that is linked to such information once you log in to your user account.
If you want to limit, block, or delete cookies from any website that is under our control, you can do so in your web browser settings. Each web browser is different, so we suggest looking for these options in the ‘Help’ section of your web browser. You should be aware that such action may cause certain functionalities of the platform.
If you need additional information about cookies, please visit www.allaboutcookies.org.
This is a list of the cookies we use and the purposes for which we use them:
Category: Necessary
Necessary cookies help create a website by enabling basic functions such as page navigation and access to secure areas of the website. The website cannot function properly without these cookies. The following indicates the cookie name, cookie provider, cookie type, and cookie expiration:
Cookie Name: PHPSESSID Applies to: thegepek.com/hr/ Duration: until the end of the session on the website Purpose: technical, saves user data through page requests. Source: thegepek.com/hr/
Category: Statistics
Statistical cookies help website owners understand how visitors interact with websites by collecting and reporting data anonymously. The following indicates the cookie name, cookie provider, cookie type, and cookie expiration:
Cookie Name: _ga Applies to: thegepek.com Duration: 2 years Purpose: uses Google Analytics to distinguish users. Source: thegepek.com
Protection of confidentiality of your password
When you choose to use a password to access your account on our platform, you are responsible for keeping your password confidential. Please do not share your password with anyone.
Links to other websites and social media
Our platform may occasionally 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 they have their own data protection policies and we do not accept any responsibility or liability for these policies. Before submitting any personal data to these websites, please check their policies.
Changes to our Privacy Policy
Any changes we may make to our Privacy Policy in the future will be posted on this page. When appropriate, we will notify you and request your consent. Please check our Privacy Policy frequently to ensure that you are aware of any updates or changes.
Right to lodge a complaint
You have the right to lodge a complaint with a supervisory authority for data protection and privacy. In Croatia, this is the Agency for the Protection of Personal Data, which can be contacted as follows:
Agency for the Protection of Personal Data
Martićeva ulica 14
HR – 10 000 Zagreb
Tel. 00385 (0)1 4609-000
Fax. 00385 (0)1 4609-099
E-mail: azop@azop.hr
Web: www.azop.hr
Contact and Data Protection Officer
If you wish to exercise any of the rights listed or withdraw your consent (where consent is the legal basis for processing your personal data), please contact us. Please note that we will keep a record of our communication with you so that we can address any disputes in a timely manner.
You can contact us at any time using the following details:
Gepek d.o.o
Ulica Miroslava Krleže 15
Kutina
E-mail: info@theGepek.com