Privacy Policy
If you are interested in the processing and protection of your personal data within the UNA d.o.o. company, WELCOME, this section is the right place for you!
We value your privacy and take special care of the security of your personal data. Precisely for these reasons, with this Privacy Policy, we want to inform you in a transparent and easy-to-understand manner about the collection, use, nature and extent of processing of your personal data by UNA d.o.o. str. Istarska 3, PIB: 02053489, which is in the position of controller of your personal data (hereinafter “Una” or “we”).
Here you can find information about all the data we collect about you, during various types of cooperation, especially the data we collect when you access our website www.una.me, when you register and create a profile or when you just decide to buy our products online as a guest.
Personal data is all data that directly or indirectly relates or can relate to you as a natural person. As the legal basis governing data protection and conditions for processing your personal data, we apply the Law on Personal Data Protection (“Official Gazette of Montenegro”, No. 79/08 of 23.12.2008, 70/09 of 21.10.2009, 44/ 12 of 09.08.2012), hereinafter “the Law”).
In the event that our site contains links to other websites, please familiarize yourself adequately with the privacy policies found on those websites and the manner in which those persons process your data. Please note that Una has no control over the content of other websites, and therefore we cannot be responsible for protecting your privacy when you visit other websites.
1. How do we collect your personal data and on what legal basis?
All the information we collect is obtained directly from you, when you order certain products or services, fill out a certain form or when we collect data through security cameras in our retail stores.
During your visit to the site, we may collect your personal data that is necessary to set up your account, for the purpose of billing or delivery of your goods. We use your personal data exclusively and only to enable us to provide you with the products and services you want in order to satisfy your requirements or to adapt our offer to you, i.e. to personalize it, improve the operation of the website, ensure the verification of administrative tasks, establish contact with you, improve our advertising and promotional results and improve our offer of products or services on the market, as well as for the purpose of cooperation with institutions responsible for law enforcement. We will never misuse your personal data under any circumstances. We may disclose your information to our business units and partners, which are part of this Privacy Policy.
All your personal information is treated as strictly confidential, and Una and/or our trusted partners store it adequately.
During your visit to the site, we may collect your personal data that is necessary to set up your account, for the purpose of billing or delivery of your goods. We use your personal data exclusively and only to enable us to provide you with the products and services you want in order to satisfy your requirements or to adapt our offer to you, i.e. to personalize it, improve the operation of the website, ensure the verification of administrative tasks, establish contact with you, improve our advertising and promotional results and improve our offer of products or services on the market, as well as for the purpose of cooperation with institutions responsible for law enforcement.
We do not sell or rent your personal data to third parties, for their marketing needs, without first giving you the opportunity to turn off that option. However, we may disclose your information to our business units and partners, which are part of this Privacy Policy. We will never misuse your personal data under any circumstances. In the following items, we will explain to you the ways and reasons for the possible provision of your information, for the purposes of the normal operation of the Web site.
It is mandatory to submit only those personal data that we collect for the fulfillment of certain legal obligations.
Providing personal data on all other legal grounds is voluntary, but please note that if you deny us this data, in certain situations we may not be able to provide you with certain services (such as for example delivery of products to your home address or sending a newsletter via e-mail addresses).
Please note that all of the aforementioned legal bases are applied depending on the purpose for which we collect your data, which we will inform you about in each specific case. You can see more about the purpose and type of data we collect in the section “What data do we collect from you?”
2. What data we collect from you
Una collects several categories of personal data, depending on the specific request of users/customers.
2.1. Purchase/order in Una store/website
Sale of goods through our online store www. una.me performs as part of the registered activities of the company Una d.o.o. Tivat, street: Istarska 3, PIB: 02053489.
The goods (services) that are sold through the website have the properties required for the regular use of that type of goods in accordance with its defined purpose. Conformity of the goods to the contract is determined EXCLUSIVELY according to the properties and purpose of the goods as defined by Una doo. When you make a purchase in the Una store, through the website, depending on the case, you may be asked to leave certain personal data that are necessary for the conclusion of the distance sales contract, the creation of an order or for the fulfillment of obligations from the sales contract – realization delivery, billing and receipt of goods.
In the case of purchases in Una stores, we need the following data for home delivery:
– name and surname;
– phone number;
– address (city, street and number, postal code, apartment number and floor)
When you use our online shopping services through the website, in addition to the above data, we additionally need information about your e-mail address, in order to confirm the purchase and send you the purchase order.
If you make an online payment, in order to ensure a safe purchase, we also collect data about the completed transaction.
You can make an online purchase even if you are not registered on the Una website, i.e. as a guest.
We use the data collected in this way exclusively for the purpose of concluding and executing distance sales contracts, which includes order management and monitoring, communication with you, as well as dealing with objections or warnings.
In order to ensure that the products you buy from us are delivered to the correct address, we share your data with our external partners in order to provide appropriate services (e.g. your name, delivery address). See more about our partners in the section “Who has access to your data?”
2.2. Complaints
According to the Law on Consumer Protection, Una is obliged to provide customers with the opportunity to file complaints on purchased products.
In that case, when filing a complaint, we can collect data from you as a customer about your name and surname, phone number, e-mail address and/or home address, if it is necessary to send the goods or going out into the field.
We use the data collected in this way exclusively for the purpose of solving and responding to your complaints.
2.3. Opening a user account on the Una page/application
When you decide to register on our site or to create your personalized profile, we collect the following data for this purpose:
- Mandatory data:
-first and last name;
– e-mail address;
– password;
– gender;
– date and year of birth;
– phone number;
- Additional data:
– City/place of residence;
– Street, number, floor and apartment number;
In the event that, as a registered user on your profile, you decide to purchase one of our products available on our website, and in accordance with our Terms of Business, in order to execute transactions and deliver goods, in addition to the information about you as a registered user, we may request additional information, such as that stated under point 2.1. of this Privacy Policy.
Please note that under no circumstances do we collect special categories of data, such as data relating to your racial or ethnic origin, political opinion, religious or philosophical belief or trade union membership, as well as the processing of genetic data, biometric data, data related to health condition, sex life or sexual orientation.
Given that we create the profile solely based on your consent, you can withdraw your consent at any time by deleting the profile, after which we will delete all the data we have about you.
2.4. Contacting Una – different types of inquiries (contact by e-mail, telephone, via social networks)
Depending on the way in which you contacted us, as well as the type of inquiry, we may collect your information about your name, surname, phone number, e-mail address, as well as other information that you exchanged with us, which are related to by your request.
You can also contact us when you want to make a purchase by phone. In this case, we process your data, as stated in section 2.1. of this Privacy Policy.
2.5. Marketing purposes – registration to receive notifications about current offers and promotions – Newsletter, Viber, SMS messages
There are several ways to sign up to receive promotional offers from Una:
- If you want to receive our notifications about current offers and promotions, you can leave the following information at the bottom of the page at any time on our website: • phone number – if it is a matter of notifications via viber or SMS, • e-mail address mail in the case of newsletter notifications.
- When you register or create a profile on the website, Una will offer you the service of sending notifications about current offers and promotions to mail, viber or SMS, and on this occasion, in addition to the information you leave during registration, you can additionally accept the sending of promotional offers.These fields are not mandatory, so it is possible to create a profile without accepting the sending of promotional offers.
- If you did not sign up for sending promotional offers during registration, you can access your profile at any time and in the “notifications” section mark that you want to receive notifications by mail, viber or SMS. If you want to receive our notifications related to special offers (e.g. Black Friday) or when you want to participate in a prize game, Una also offers temporary registration forms for promotional offers. On this occasion, depending on the form, you leave data only for this purpose, unless there is also an option to sign up for constant notifications via e-mail address or viber/SMS. In this case, your data will be saved for the stated purpose and after the purpose is fulfilled or in case of withdrawal of consent before the purpose is fulfilled, your data will be permanently deleted.
- If you start an interaction on Una live chat, there is also an option to sign up for the newsletter. This option is optional and you can interact with the Una team without signing up for the newsletter.
You can dispute your consent to receiving notifications about current offers and promotions at any time, in which case we will stop sending you promotional offers. Revocation of consent does not affect the admissibility of processing that was carried out on the basis of consent before the revocation.
Regardless of the way in which you signed up to receive notifications, you can revoke your consent via the unsubscribe option at the bottom of each email or directly via the Viber application or SMS message, if you have given your consent for this type of notification.
If you have created a profile on our website, you can revoke your consent through your created profile in the “notifications” section, by waiting for the option to send promotional offers. You can use the login and logout option on your profile at any time, and we will act in accordance with your requests.
We inform you that in the case of sending newsletters/viber/SMS, we engage external partners in order to perform these services, your data may be transferred to these persons (data on e-mail address and phone number). See more about our partners in the section “Who has access to your data?”
2.6. Promotional actions, prize games, sponsorships
For the purposes of participating in prize games, sponsoring or conducting promotional activities, we collect data in accordance with the rules for each individual activity.
To register as a participant, we need your first and last name, and depending on the specific rules of the game, your date of birth and home address. If the winner whose prize value exceeds the amount prescribed by tax regulations, we additionally need your JMBG. When collecting this data, in each specific case we will inform you about the type of processing of this data, as well as about your rights.
Given that when registering for a contest, prize game, etc., you agree to the rules prescribed by the organizer, we collect the above data solely on the basis of your consent.
The company Una d.o.o. as a seller of products and services on the website provides maximum protection to protect your privacy when you are “online” as a user. Your personal information is kept secure and confidential and processed lawfully in accordance with this privacy policy. We take appropriate technical and organizational measures to protect against unauthorized and illegal access and processing of your personal data, including encryption of your information. We will retain your information for as long as necessary to process your order, your payment, process a refund, respond to a complaint, or provide you with promotional information that you have signed up for.
2.7. Profiling
In cases where we send or display notifications or content that are personalized in nature, we may use certain processes that are labeled as “profiling” (that is, any form of automated processing of personal data consisting of the use of collected personal data in order to evaluate certain personal aspects related to a natural person, specifically, in order to analyze or predict aspects concerning the personal affinities of a specific natural person, his interest, economic position, behavior, location, reliability or movement).
Based on our analysis, we send or display notifications and/or content tailored exactly to your interests/needs.
We process this data solely on the basis of your consent.
2.8. Website visit
With your consent, we record your behavior as a user of our website www.una.me and newsletter. The assessment of user behavior includes, first of all, information about the sections you visit and the links you use there. In this way, we create personalized user profiles with your personal data and/or with information about your e-mail address in order to enable the creation of advertising offers by Una in the form of newsletters, on-site advertising and printed material, adapted to your personal interests and thereby improve our offer.
Una processes your data when visiting this website, when using applications and other platforms. On this occasion, various data are exchanged between your device and our server, which may include personal data. The data collected in this way is used, among other things, for the optimization of our website or for the purpose of displaying advertisements in the browser of your device.
When you visit our website, the browser you use on your device will automatically and without your activity send to the server of our website:
– the IP address of the device from which the request was sent and which has access to the Internet,
– date and time of access,
– name and URL of the downloaded file,
– the website from which it is accessed (referrer URL),
– the browser you use and, if necessary, the computer’s operating system that supports the Internet, as well as the name of your provider.
The server temporarily stores the above data in a so-called log file for the following purposes:
– ensuring the establishment of a smooth connection,
– ensuring comfortable use of our website/application,
– assessments of system security and stability.
If in your browser, in the operating system or in other settings of your device you have accepted the so-called geolocation, i.e. with your consent, we use this function to offer you individual services based on your current location (for example, the location of the nearest store). We process location data exclusively for the stated purpose.
The legal basis for the processing of the IP address is the legitimate interest, which derives from the above-mentioned purpose of data processing, since it is a technical condition for the functioning of the site. We do not transfer this data to third parties. The data is stored temporarily during the visit to the page, and then it is automatically deleted. After you leave our website, the geolocation data is deleted.
2.9. Use of cookies
We use so-called cookies on our website. Cookies are small files that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our website. Cookies do not contain viruses, trojans or other malicious software. Cookies store information obtained in connection with the device you are using. However, this does not mean that we are familiar with your identity. On the one hand, the use of cookies serves to make your visit to the website more pleasant. We use so-called session cookies to recognize that you have already visited certain parts of our site or that you are already logged in to your user account. They are automatically deleted after you leave our website. In addition, we also use temporary cookies that are stored on your device for a certain period of time. When you visit our website again, it is automatically recognized that you have already been on the page and what settings you have set up, so you will not have to repeat these actions.
On the other hand, we use cookies to statistically record the use of our website, in order to optimize the offer and display of information that is adapted to your interests. These cookies allow us to automatically recognize you when you visit our website again. These cookies are automatically deleted after 5 years, but you can always delete them manually on your computer.
Most browsers automatically accept cookies. However, you can adjust your browser so that cookies are not kept on your computer or that a message always appears before a new cookie is created. However, completely disabling cookies may mean that you cannot use all functions of our website.
You can read more about the use of cookies and how they are collected in our Cookie Policy.
2.10. Google Analytics
For the purpose of adjusting the design and constantly improving our websites, we use the so-called Google Analytics – a web analytics service provided by Google Inc. (“Google”). In this context, pseudonymized user profiles are created and cookies are used. Cookies generate the following information about your use of this website:
– browser type/version,
– the operating system used,
– referrer URL (previously visited page),
– hostname of the computer from which it is accessed (IP address),
– server query time
The data is used to evaluate the use of our website, to compile reports on the activities on the site and to provide other services related to the use of the site and the use of the Internet. The data is processed for the purpose of market research and adaptation of these websites. IP addresses are anonymized, so it is not possible to determine the identity (so-called IP masking). Under no circumstances will your IP address be linked to other Google data.
You can find more information about data protection in connection with Google Analytics on the Google Analytics website.
2.11. Social networks
Data on social networks is largely processed by the operator himself, and Una has limited influence on that part.
You can find more detailed information about the processing of data by the operators of social network platforms and about the possibilities of objection in their data protection rules:
- YouTube
We process data collected on social networks for the purpose of informing consumers about current promotions and offers, and in order to interact and improve relations with followers.
Data collected on social networks based on consent, such as comments, videos, images, likes is published by the operator. Una does not share this data with third parties and reserves the right to delete illegal content, hate comments, explicit content and data that constitute a criminal offense.
There is partly joint responsibility with the social network operator in accordance with the Law:
We and the operator are jointly responsible for the web tracking methods enabled by the operator of the social network platform. Web tracking can also occur regardless of whether you are logged in or registered on the social network platform. As we have already mentioned, unfortunately we can only have a limited influence on the operator’s web tracking methods, for example we cannot turn them off.
The legal basis for web tracking methods is a legitimate interest, which consists in optimizing the social network platform and the specific fan page.
2.12. Video surveillance
Una uses video surveillance in all its retail stores for the safety of its employees and property, and for the purpose of detecting criminal acts and other disputed situations. The video surveillance notice is located at the entrance to each of our retail facilities and is used in accordance with the Law on Private Security. We keep the information collected through video surveillance for a period of time that allows us to help regulatory bodies and law enforcement authorities, for a maximum of 30 days, after which all data is automatically deleted. This information is stored in a manner that ensures adequate protection of personal data and access is limited to qualified security personnel only.
3. Who has access to your data?
The protection of your personal data is extremely important at Uni, which is precisely why we take care that your personal data is not given to unauthorized persons. Within our company, access to the data, which you have made available to us, is only available to those sectors, i.e. those employees who need it to fulfill the purpose for which the personal data was collected, and whose job description includes the processing of personal data.
In addition to our employees, in order to provide certain services, we may transfer your data to third parties – our partners who provide services on behalf of Una (e.g. courier service, complaints service, IT partners who maintain our website/mobile application).
In all these cases, our relationship with external partners and the method of protection and handling of your personal data have been secured by contracts in accordance with the Law.
We do not transfer your data outside the territory of the Republic of Montenegro.
4. How long do we keep your data?
We keep personal data as long as it is necessary to fulfill the above purposes. In doing so, we take into account the legal obligations to store personal data.
In the case of creating a profile on our site or collecting data based on consent, personal data will be processed until the user profile is deleted or the given consent is withdrawn. The revocation of consent does not affect the admissibility of processing that was carried out on the basis of consent before the revocation.
Data collected on the basis of consent will be deleted even before the withdrawal of consent, if the purpose for which we collected the data has been achieved (as we do with participants of prize games).
When the basis of data collection is the conclusion and execution of a contract, we keep data on completed purchases and customers to the extent provided by tax regulations and regulations governing sales contracts. (e.g. data on filed complaints are kept as long as it is prescribed by the Consumer Protection Act).
After the expiration of the stipulated periods, or after the withdrawal of consent, if the data is processed on that basis, all customer data will be depersonalized, that is, deleted or destroyed.
Please note that when it comes to purchase data, each customer can depersonalize the data themselves even before the expiration of the prescribed deadlines. Depersonalization is done through a link that is delivered to the customer via a generic email when the purchase order is successfully created.
5. Data on minors
Una intentionally does not process personal data of minors under the age of 16.
In order to prevent the sale of products to persons under the age of 16, Una requires entering data on the year and month of birth as a mandatory field when making a purchase.
Persons under the age of 16 cannot create personalized profiles on our website.
Adults are recommended to properly supervise minors under their guardianship while browsing the Internet, especially when it is possible to leave personal information.
6. Security measures
In order to ensure the protection of personal data, Una has adopted a whole series of rules that regulate the processing and protection of personal data.
Different mechanisms have been implemented, such as mandatory training of all employees to handle confidential and personal data, access to personal data is allowed only to authorized persons, and in addition there are strong password policies. In addition to the above, Una has also appointed a person for the protection of personal data who helps in the process of protecting and ensuring the security of personal data and takes care of their compliance with the Law.
In addition to the above, Una has enabled its users to depersonalize data, the possibility to download all personal data found on the site (account data, orders, comments, wishes…), and a strong password policy on personal profiles (at least 6 characters, small and capital letters) , numbers and punctuation marks).
Una constantly monitors and, depending on the needs, improves security measures, all in order to prevent unauthorized access, loss or destruction of personal data.
7. What rights do you have as a data subject?
You can contact us at any time with any of the above requests:
- to provide you with access to your personal data, to answer for which purposes the data concerning you is used, as well as to access such personal data, to know the purpose of processing, the categories of your personal data that we keep, third parties, or categories of third parties with to which your personal data is shared, the period during which we retain the data.
- to request the correction of incorrect, incorrectly entered and/or outdated data;
- to request the deletion of your personal data if the processing is based on your consent, legitimate interest or if the personal data is no longer necessary to achieve the purpose for which it was collected;
- to request the restriction of the processing of your data, if you dispute the accuracy of the personal data within the period that allows the controller to verify the accuracy of the personal data, if you believe that the processing is illegal and you do not want the data to be deleted, if you have raised an objection or if you believe that Una no longer need your data;
- to submit an objection to the way we process your data, even in cases where it is not disputed that we process the data in accordance with the Law;
- to submit a complaint to the Commissioner for Personal Data Protection, in accordance with the Law.
8. Entry into force and changes to the Privacy Policy
This Privacy Policy enters into force on December 1, 2020.
The privacy policy may be amended or supplemented, depending on the needs and changes in processes at Una, changes in legal frameworks or at the request of the competent authority.
We reserve the discretion to amend this Privacy Policy at any time and for the amended text to become valid immediately upon its publication on the website.
Your continued use of the website after the changes implies that you accept all the terms of the Privacy Policy so changed. Therefore, we advise users to periodically re-read the information contained in the Privacy Policy in detail, in order to be informed about possible changes.
It is recommended that users regularly follow changes and additions to the Privacy Policy on Una’s website.