This Cookie Policy, together with the General Terms and Conditions and Privacy Policy, governs the relationship between you and HAM d.o.o., with registered address and business address at Gerbičeva ulica 102, 1000 Ljubljana, Slovenia (“HAM”) in relation to the use of cookies and similar technology, such as pixels and tags, (collectively, “Cookies”) to recognise you and obtain information from you when you visit the Website when accessing and using the https://spinalis-ml.neagencija.eu/ website and any subpages of this website (the “Website”).

1. What are cookies?

Cookies are small text files that are placed on your computer or other device when you visit our website. Cookies are placed on your device by us (“first-party cookies”) or by third parties (“third-party cookies”). By placing cookies, we collect or store a wide variety of information about you, your device and how you use the website. This information is then used for a number of different purposes, for example to remember products in your shopping basket or to show you advertisements tailored to your interests on other online platforms. Depending on the purpose for which the information collected by each cookie is used, we distinguish between four types of cookies; essential or technical cookies, functionality cookies, maintenance and improvement cookies and advertising cookies.

2. What types of cookies do we use and why?

2.1. Strictly necessary cookies

Strictly necessary cookies are technical cookies that are essential for the operation and use of the website. They enable us to ensure the technical functioning of the website, its accessibility and security.

We use essential cookies:

• to enable you to access the website,
• to ensure your safe use of the website and to detect and prevent security threats and malicious activity,
• to authenticate your access to the website,
• to display pop-up notifications on the website,
• to increase the speed of the website; and
• to remember the products you have added to your shopping basket.

How to reject them?

These cookies are essential for the website to function and you cannot refuse them. You can block or delete the use of essential cookies in your browser settings. In this case, some of the website’s features and services may not function properly or may be disabled.

2.2. Functionality cookies

We use functionality cookies to recognise you and remember your choices and preferences when you return to our website.

We use functional cookies:

• to remember which cookies you have accepted and which you have rejected,
• to remember your language preferences.

How to reject them?

As cookies are not necessary for the functionality of the website itself, you can refuse their use by selecting the appropriate option in our cookie management tool below. In addition, you can refuse certain types of cookies in your browser settings. You can find out more about these alternative options for refusing cookies in the section “How to accept or refuse cookies” below.

2.3. Cookies for maintenance and improvement

Maintenance and improvement cookies measure how often you visit our website, collect information about how you move around our website and how you use it. They show us aggregate statistics about the use of our website based on information about the number of visits to the website, the locations from which users access our website, the time of access and the total time spent using the website. They also help us to identify which parts of the website are of most interest to our users and which products are most frequently viewed by our visitors.

We use cookies for maintenance and improvement or analytical cookies:

• to analyse and understand the use of our website,
• to improve the design, performance and efficiency of the website,
• to provide our users with new content and products that match their interests and habits; and
• to understand the effectiveness of our ads.

How to reject them?

As cookies are not essential for the maintenance and improvement of the website itself, you can refuse their use by selecting the appropriate option in our cookie management tool below. In addition, you can refuse certain types of cookies in your browser settings. You can find out more about these alternative options for refusing cookies in the section “How to accept or refuse cookies” below.

2.4. Advertising cookies

Advertising cookies help us understand you, your preferences, interests and choices by helping us to recognise you, to recognise what you like and to remember your online habits and activities. By accepting the use of advertising cookies, you are giving us permission to collect information about you (e.g. unique user identification or user ID), your device (e.g. IP address, browser information), and how you use our website (e.g. We use the information we collect in this way to prevent the repetition of advertisements that are shown to you and to ensure that our advertisements are displayed correctly. In addition, we use the information obtained through advertising cookies to create an advertising profile of you and others with similar interests, which we use to select and serve ads to you and others that are relevant to your interests, preferences and web browsing patterns.

We use advertising cookies to:

• To show you ads tailored to your interests and preferences, for example to show you ads about new products that are similar to the ones you’ve viewed,
• to serve ads to social network users with interests similar to yours,
• to prevent repetition of adverts,
• to ensure that your adverts are displayed correctly,
• to measure the effectiveness of ads.

How to reject them?

As advertising cookies are not essential for the operation of the website itself, you can refuse their use by selecting the appropriate option in our cookie management tool below. In addition, you can refuse certain types of cookies in your browser settings. You can find out more about these alternative options for refusing cookies in the section “How to accept or refuse cookies” below.

3. What information do we collect through cookies?

Cookies help us and our partners to collect information about you, your devices and your use of our website. Some of this information gives us and our partners insight into your use of the website, your choices and preferences, and technical specifications without identifying you directly or indirectly, while through others we can identify you, either directly or by combining several pieces of information collected (“personal data”).

We collect the following categories of personal data using cookies:

• personal identifiers, e.g. your unique User ID, cookie or pixel identifier, IP address,
• Device information, e.g. device type, device identifier and information about the browser used,
• information about your browsing behaviour and browser usage, e.g. information about your visits to the website, information about the products you have viewed on our website and information and other types of activity on our website,
• your geographical location.

4. Who all has access to the (personal) data obtained through cookies?

To enable additional features and functionalities on the website, such as displaying interactive content via YouTube and Facebook interfaces, website analytics or advertising, we enable the use of certain additional cookies when you use the website, both by ourselves and with the help of third parties. As some of the additional website features and functionalities are provided by our business partners, the data collected via cookies when using the website may be directly transferred to the business partner that provides the specific additional website feature and functionality.

The third parties that provide such additional facilities and functionalities of the website and to whom the data obtained through cookies is provided are:

• our related companies,
• providers of analytics and conversionservices, e.g. Google Analytics, Google Optimize, Hotjar, Facebook and others,
• partners providing interactive content on the website, e.g. YouTube and Facebook,
• providers of targeted and personalised advertising, e.g. Google Ads, Facebook, Pinterest and others.

5. Which cookies exactly are we talking about?

The cookies (“first-party” and “third-party”), categorised by cookie type, are listed and explained in the table below. The table also contains a link to our partners’ websites where you can read more about their use of cookies placed when using the website.

6. How long do we store the data collected through cookies?

We usually delete data collected through cookies that is not personal data after the cookie expires, unless the purpose for which such data was collected still exists. In this case, we will delete the data as soon as the purpose for which the data was collected ceases to exist.

We retain personal data obtained through the use of cookies for as long as necessary to fulfil the purposes for which the personal data was obtained or until the consent to the processing of the personal data is withdrawn, if the personal data was obtained on the basis of the data subject’s consent. We retain personal data for longer where required to do so by our obligations under applicable law and where it is necessary for the protection of our legitimate interests and rights. When the business need for the use of personal data ceases or when the obligations imposing mandatory retention of personal data on us cease to exist, we delete or, if deletion is not possible or is necessary for statistical purposes, anonymise the personal data.

7. How do you accept and reject cookies?

You can choose whether to accept cookies that are not strictly necessary for the operation of the website and allow information to be collected using them, or to refuse them. Necessary cookies are mandatory for the proper functioning of the website and cannot be refused.

You can manage the installation and use of cookies that are not strictly necessary for the functioning of the website in our cookie management tool, which is located in the cookie notice that appears when you access the website and in the section below. The cookie management tool allows you to accept or reject the use of each type of cookie we use. Your settings in the cookie management tool apply only to the cookies uploaded or used when you access our website and only to the device on which you have edited the cookie settings in the cookie management tool. Your settings or changes to the settings in the cookie management tool apply only to the future use of cookies on our website.

In addition to using the cookie management tool, you can also manage cookies by using the settings in your web browser, where you can accept or reject a particular type of cookie in general for all websites. If you wish to change the cookie settings in your web browser, we recommend that you consult the “help” tab of your web browser for information on this, as the settings of each web browser vary depending on the type of browser. If you refuse cookies in your web browser’s cookie settings, the website may not function properly or some of the website’s functionality may be limited.

You can refuse third-party advertising cookies universally for all websites by visiting one of the following websites and selecting the appropriate choice: the Digital Advertising Alliance website, the Network Advertising Initiative website, or Your Online Choices website (for visitors from the EU).

8. Cookie management tool

Your choices in the cookie management tool only apply to the future use of cookies on our website and to the placing or accessing of cookies on the device you are using to access and modify the cookie settings below.

☒ ESSENTIAL COOKIES

Strictly necessary cookies enable the basic functions of a website to work, such as technical website functionality, accessibility and security. These cookies are essential for the functioning of the website and cannot be disabled.

☐ FUNCTIONALITY COOKIES

Functionality cookies allow us to recognise and remember your preferences and choices. If you disable these cookies, some or all of these features may not work properly.

☐ COOKIES FOR MAINTENANCE AND IMPROVEMENT

Maintenance and improvement cookies help us to improve our site by collecting information about your visits to and use of the Little Heroes site. We use this information to optimise the look, feel, performance and efficiency of the site, thereby improving the user experience.

☐ ADVERTISING COOKIES

Advertising cookies collect information about your visits to our website and other information about you and your devices, such as which browser you use and your IP address, so that we can build advertising profiles based on your preferences, preferences and habits. This allows us to show you and others personalised content and ads that are relevant to you.

9. Forwarding of personal data obtained through cookies to third parties

We may share your personal data with the categories of persons set out in the section “Who all has access to personal data obtained through cookies?”. We may also disclose your personal data upon request to regulatory authorities responsible for overseeing the proper implementation of the provisions of the personal data law and other law enforcement authorities, which shall duly specify and justify their request. We transfer personal data outside the European Economic Area (“EEA”) in certain cases, but only on the condition that such transfer of personal data is permitted by European data protection law, i.e. when the transfer of personal data takes place between EEA countries and a third country which the European Commission has decided ensures an adequate level of data protection, or when the transfer of personal data takes place with the application of appropriate safeguards, or in the case of other transfers of personal data outside the EEA permitted by the General Data Protection Regulation.

10. Rights you have to protect and preserve the integrity of your personal data

You may exercise a number of rights in relation to our use of your personal data, namely the right to request access to your personal data held by us, the right to rectification of your personal data, the right to erasure of your personal data, the right to request the restriction of the use of your personal data and the right to request that we directly transfer your personal data to another controller. You can find out more about your rights in relation to our use of your personal data in our privacy policy.

If you believe that our use of your personal data does not comply with the provisions of the General Data Protection Regulation and other provisions of applicable law, you have the right to lodge a complaint with the Information Commissioner, Dunajska cesta 22, 1000 Ljubljana, Slovenia.

11. Additional information

If you have any questions about our use of cookies and other similar technologies, you can contact us at info@spinalis.si.

©HAM d.o.o. (Ljubljana, May 2021)