Privacy Policy

LAST UPDATED: August 10, 2024

INTRODUCTION

Company SATORIAS 2020 d.o.o., PIN: 94993953585, Ferenščica II. 32, Zagreb, Republic of Croatia (hereinafter referred to as “SATORIAS”) respects the privacy of its users and appreciates consumers of its services. Please note that data protection is of a particularly high priority for SATORIAS, and, for all the mentioned, SATORIAS has developed this privacy policy (hereinafter referred to as “Privacy Policy“).

The use of the SATORIAS's website is possible without registration and any particular indication of personal data; however, if a data subject wants to use special SATORIAS's services, processing of Personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

Please note that this Privacy Policy regards the SATORIAS's website having a front page at https://www.athlex.io (hereinafter referred to as “Site”). Subject Privacy Policy sets forth SATORIAS's policies aiming to protect personally identifiable information (hereinafter referred to as “Personal data”) relating to an individual's use of the Site by summarizing SATORIAS's procedures and practices regarding the Personal data collection and use.

This Privacy Policy details SATORIAS’s commitment to protecting the privacy of individuals who send their Personal data to SATORIAS in any form by which these individuals can be fully and/or partially identified.

Your use of this Site signifies your understanding and acceptance of the terms of this Privacy Policy.

Please read this Privacy policy very carefully to clearly understand the reasons for the collection, use, and disclosure of your data.

The processing of Personal data, such as the name, e-mail address, nationality, and year of birth of a data subject shall always be in line with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (Text with EEA relevance) OJ L 119, 4.5.2016, p. 1–88 (“GDPR”), and under Croatian applicable laws and regulations. By means of this Privacy Policy, we would like to inform the general public of the nature, scope, and purpose of the Personal data we collect, use, and process. Furthermore, data subjects are informed, through this Privacy Policy, of the rights to which they are entitled.

As the controller, SATORIAS has implemented numerous technical and organizational measures to ensure the most complete protection of Personal data processed through this Site. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer Personal data to us via alternative means, e.g., by telephone.

DEFINITIONS

Privacy Policy of the SATORIAS is based on the terms used by GDPR. Our data protection declaration should be legible and understandable for the general public, as well as our customers. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

a) Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

c) Processing

Processing is any operation or set of operations that is performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing

Restriction of processing is the marking of stored personal data to limit their processing in the future.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular, to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

f) Pseudonymization

Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for the processing

The controller or controller responsible for the processing is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processor

A processor is a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.

i) Recipient

Recipient is a natural or legal person, public authority, agency, or other body, to which the personal data are disclosed, whether a third party or not. However, public authorities that may receive personal data in the framework of a particular inquiry following Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall comply with the applicable data protection rules according to the purposes of the processing.

j) Third party

The third party is a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

k) Consent

Consent of the data subject is any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

NAME AND ADDRESS OF THE CONTROLLER

Controller for the GDPR, other data protection laws applicable in the European Union, and other provisions related to data protection is:

SATORIAS 2020 d.o.o. Ferenščica II. 32 10000 Zagreb, Republic of Croatia Phone: 385992001800 Email: [email protected] Website: www.athlex.io

The Data Protection Officer of the controller is:

Vjekoslav Tuta Dujmović

SATORIAS 2020 d.o.o. Ferenščica II. 32 10000 Zagreb, Republic of Croatia Phone: 38598217982 Email: [email protected] Website: https://www.athlex.io

Any data subject may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection.

COLLECTION OF GENERAL DATA AND INFORMATION

SATORIAS's Site collects a series of general data and information when a data subject or automated system calls up the Site. This general data and information are stored in the server log files.

Collected may be:

  • The browser types and versions used
  • The operating system used by the accessing system
  • The website from which an accessing system reaches our website (so-called referrers)
  • The sub-websites
  • The date and time of access to the Internet site
  • An Internet protocol address (IP address)
  • The Internet service provider of the accessing system
  • Any other similar data and information that may be used in the event of attacks on our information technology systems

When using these general data and information, SATORIAS does not draw any conclusions about the data subject. Rather, this information is needed to:

  • Deliver the content of our website correctly
  • Optimize the content of our website as well as its advertisement
  • Ensure the long-term viability of our information technology systems and website technology
  • Provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack

Therefore, SATORIAS analyzes anonymously collected data and information statistically, intending to increase the data protection and data security of our company and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all Personal data provided by a data subject.

CONTACT POSSIBILITY VIA SITE

SATORIAS's Site contains information that enables quick electronic contact with our company, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such Personal data transmitted voluntarily by a data subject to the data controller are stored for processing or contacting the data subject. There is no transfer of this personal data to third parties.

ROUTINE ERASURE AND BLOCKING OF PERSONAL DATA

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased following legal requirements.

RIGHTS OF THE DATA SUBJECT

Right of confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller confirmation as to whether or not Personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.

Right of access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

  • The purposes of the processing
  • The categories of Personal data concerned
  • The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
  • Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
  • The existence of the right to request from the controller rectification or erasure of Personal data, or restriction of processing of Personal data concerning the data subject, or to object to such processing
  • The existence of the right to complain with a supervisory authority
  • Where the personal data are not collected from the data subject, any available information as to their source
  • The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject

Furthermore, the data subject shall have a right to obtain information as to whether Personal data are transferred to a third country or an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.

Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate Personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete Personal data completed, including through providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of Personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed
  • The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing
  • The data subject objects to the processing under Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing under Article 21(2) of the GDPR
  • The personal data have been unlawfully processed
  • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject
  • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of Personal data stored by the SATORIAS, he or she may, at any time, contact any employee of the controller. An employee of SATORIAS shall promptly ensure that the erasure request is complied with immediately.

Where the controller has made personal data public and is obliged under Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. Employees of the SATORIAS will arrange the necessary measures in individual cases.

Right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data
  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use
  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims
  • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification of whether the legitimate grounds of the controller override those of the data subject

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the SATORIAS, he or she may at any time contact any employee of the controller. The employee of the SATORIAS will arrange the restriction of the processing.

Right to data portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used, and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent under point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract according to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability under Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

To assert the right to data portability, the data subject may at any time contact any employee of the SATORIAS.

Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to the processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

SATORIAS shall no longer process the personal data in the event of the objection unless we can demonstrate compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims.

Shall SATORIAS process Personal data for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the SATORIAS processing for direct marketing purposes, SATORIAS will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to the processing of personal data concerning him or her by the SATORIAS for scientific or historical research purposes, or statistical purposes under Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To exercise the right to object, the data subject may contact any employee of the SATORIAS. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

Automated individual decision-making, including profiling

Each data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by European Union or Croatian law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, SATORIAS shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the SATORIAS.

Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to the processing of his or her data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the SATORIAS.

DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF GOOGLE ANALYTICS (WITH ANONYMIZATION FUNCTION)

On this Site, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics is mainly used for the optimization of a website and to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

For the web analytics through Google Analytics, the controller uses the application "_gat._anonymizeIp". By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymized when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits to our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

Further information and the applicable data protection provisions of Google may be retrieved under http://www.google.com/analytics/terms/us.html and under https://www.google.com/intl/en/policies/privacy/. Google Analytics is further explained under the following link: https://www.google.com/analytics/.

LEGAL BASIS FOR THE PROCESSING

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data, or other vital information would have to be passed on to a doctor, hospital, or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations that are not covered by any of the above mentioned legal grounds, if processing is necessary for the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

LEGITIMATE INTERESTS PURSUED BY THE CONTROLLER OR BY A THIRD PARTY

Where the processing of personal data is based on Article 6(1) lit. f GDPR, our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After the expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

PROVISION OF PERSONAL DATA AS STATUTORY OR CONTRACTUAL REQUIREMENT

We clarify that the provision of Personal data is partly required by law (e.g., tax regulations) or can also result from contractual provisions (e.g., information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with Personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before Personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

EXISTENCE OF AUTOMATED DECISION-MAKING

As a responsible company, we do not use automatic decision-making or profiling.

CHANGES TO THE PRIVACY POLICY

SATORIAS is likely to make changes to the services it renders in the future and as a consequence will need to revise this Privacy Policy to reflect those changes. You will be informed when changes have been made to the Privacy Policy by referring to the “Last updated” legend at the top of this page. When we revise the Privacy Policy, SATORIAS will post the new Privacy Policy on its Site, so you should review the page periodically.

QUESTIONS OR CONCERNS

Should you have any questions regarding this Privacy Policy, your privacy as it relates to the use of SATORIAS's services, or the protection of the personal data we hold about you, please contact us via e-mail at [email protected]. We seek to promptly resolve any concerns you may have.