MELLIUS MAGNA Ltd. understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who uses Our Web site, Our Application and uses Our Program (“Our Services” or “Services”). We shall collect and use personal data only in the ways described here and in a way that is consistent with our and your obligations, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals in relation to processing of personal data and on the free movement of such data and on the repeal of Directive 95/46/EC (Official Journal of the European Union L 119, 4.5.2016, p. 1, hereinafter: General Data Protection Regulation), which applies from May 25, 2018 in the Republic of Croatia and all member states of the European Union, as well as the Act on the Implementation of the General Regulation on Data Protection (Official Gazette No. 42/18, hereinafter: the Act), i.e. in accordance with the legal framework for the protection of personal data in the Republic of Croatia and the European Union and the best European practice.

Before using Our Services, we kindly ask you to read the Privacy Policy with understanding. If you do not agree and accept this Privacy Policy, please do not access or use Our Website or Application.

MELIUS MAGNA Ltd. reserves the right to modify this Privacy Policy at any time. Please check this website (https://getfinup.com/) periodically for updates. We shall comply with relevant legal provisions to provide you with notice of changes to this Privacy Policy. Your continued use of the Website and Application following any such update constitutes your acceptance of such changes.

All terms not defined herein shall have the meaning assigned to them in our Terms of Service.

„Cookie” means a small text file that our site either places on your computer or device when you visit certain parts of our site and/or when you use certain features of our site. Details of the cookies used by our site are set out below.

„Customer " means any person who, after reviewing and selecting a product or service, has registered their data and ordered a product or service.

What is personal data?

Personal data is defined by the General Data Protection Regulation as "all data relating to an individual whose identity has been determined or can be determined ("the respondent"); an identifiable individual is a person who can be identified directly or indirectly, in particular with the help of identifiers such as name, identification number, location data, online identifier or with the help of one or more factors inherent to physical, physiological, genetic, mental , economic, cultural or social identity of that individual.

Personal data, in simpler terms, is all information about you that enables your identification. Personal information includes obvious information such as your name and contact information, but also covers less obvious information such as identification numbers, electronic location data and other online identifiers.

What does this policy cover?

This Privacy Policy applies only to your use of Our Website and Our Application and related services. Our Website and Application may contain links to other websites. Please note that we have no control over how your personal information is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any personal information to them.

The personal information we collect depends on the context of your interaction and use of Our Website or Application, services, and the choices you make regarding your privacy settings.

What data do we collect directly from you?

Typical categories of information we collect from users are: contact information, such as name, email address, postal address, or other information you provide when filling out forms on Our website, Our Application or information you communicate with us by phone or email.

What are my rights?

a) The right to be informed about our collection and use of your personal data.

b) The right to access the personal data we have about you.

c) The right to correct your personal data if any of your personal data we have is incorrect or incomplete.

d) The right to ask us to delete or otherwise dispose of any of your personal data that we have.

e) The right to limit (i.e. prevent) access to your personal data.

f) The right to file a complaint regarding the use of your personal data for a specific purpose or purposes.

g) The right to request the transfer of data to another processor (transferability of rights). This means that if you have directly provided us with personal data, we use it with your consent or to perform a contract, and the data is processed by automated means, you can ask us for a copy of that personal data for reuse with another service or company.

h) Rights related to automated decision-making and profiling. We do not use your personal data in this way.

For any query regarding our use of your personal data or the exercise of your rights as stated above, please contact us using the information provided on the Our Website or Application. Additional information about your rights can also be obtained from the office of the Privacy Commissioner. If you have any reason to object to our use of your personal data, you have the right to lodge a complaint with the Privacy Commissioner.

How do you use my personal information?

In accordance with the General Data Protection Regulation, we must always have a legal basis for using personal data because the personal data is necessary to provide our services to you, because you have consented to our use of your personal data, or because it is in our legitimate business interest to use your personal dana. It may be used for one of the following purposes in accordance with your consent or request:

a) Providing and managing your account on Our Website or Application;

b) Providing and managing your access to Our Website or Application and relevant services;

c) Managing Our Website or Application and providing services;

d) Respond to your inquiry and process your requests as efficiently as possible;

e) Sending materials, offers and contacts

f) Personalization and customization of Our Website or Application and our services at your request.

g) Analyzing your use of Our Website or Application and collecting feedback so that we can continuously improve Our Web site or Application, Services and your overall user experience.

With your permission and/or where permitted by law, we may also use your personal information for marketing purposes, which may include contacting you by email, telephone or text message with information, news and offers on Our Website or Application and services. No illegal marketing content or spam shall be sent to you. We shall always work to fully protect your rights and comply with our obligations under the General Data Protection Regulation and the Electronic Privacy and Communications Regulation (EC Directive) 2003.

Third parties whose digital tools are used on Our website or Application may use third-party cookies, as detailed below. See below for more information on cookie control. Please note that we do not control the activities of such third parties, or the information they themselves collect and use, and we advise you to check the privacy policies of such third parties.

How long do you keep my personal data?

We shall not keep your personal data longer than necessary. Your personal data shall therefore be kept for the following periods (or, if there is no specified period, the following factors shall be used to determine the length of data retention):

- As long as you remain subscribed to our e-mail list and want to receive our news and offers

- If this above is applicable, we shall keep your data for a maximum of two years after your first communication or application/submission of personal data

How and where do you store or transfer my personal data?

We store your personal data that we collect in a secure environment. Personal information is protected from unauthorized access, disclosure, use, modification or destruction by any third party. MELIUS MAGNA Ltd. may share your information with third parties, as set out below, some of which are located outside the European Economic Area. In such sharing, we shall apply certain safeguards to such transfers. We shall only transfer your personal data to countries that the European Commission considers to provide an adequate level of personal data protection.

We also use special agreements and standard contractual clauses with third parties approved by the European Commission for the transfer of personal data to third countries. These special agreements and standard contractual clauses ensure the same level of personal data protection that would apply under the General Data Protection Regulation.

Please contact us using the details provided on Our website (https://getfinup.com/) for further information on the particular data protection mechanism we use when transferring your personal data to a third country.

Data storage

All personal information you provide to use Our website or Application and services is stored on secure Google Cloud servers located in Europe and the USA.

All payment related transactions shall be encrypted using SSL technology. All payment information is stored by our payment processors and is never stored on our servers. Where we have provided you with (or where you have chosen) a password that enables you to access your account and product, you are responsible for keeping this password confidential. We recommend that you do not share your password and that you change it often.

Are you sharing my personal information?

We may sometimes enter into agreements with third parties to offer certain features of our Website, Application and Services. This may include payment processing, shipping and marketing. In some cases, these third parties may require access to some or all of your personal information that we hold.

If any of your personal data is required by a third party, as described above, we shall take steps to ensure that your personal data is handled securely and in accordance with your rights, our obligations and the third party's obligations under the law, as above described.

If any personal data is transferred outside the European Economic Area, we shall take appropriate steps to ensure that your personal data is treated as securely as it would be within the EU and under the General Data Protection Regulation, as explained above.

In some limited situations, we may be required by law to share certain personal information, if we are involved in legal proceedings or in compliance with legal obligations, a court order or instructions from a government authority.

How can I control my personal data?

Subject to your rights under the General Data Protection Regulation, when you submit personal data through Our Website or Application, you may be given the option to restrict our use of your personal data. In particular, we provide you with strong control over our use of your personal information for direct marketing purposes (including the ability to opt out of receiving our emails, which you can do by unsubscribing via the links provided in our emails, by providing your information at the time).

Can I refuse to provide information?

You can access certain areas of Our Website or Application without providing any personal information. However, in order to use all the features and functions available on Our Website or Application, you may need to submit or allow the collection of certain data in order for us to offer our relevant services.

You can limit our use of cookies. For more information, see How you use cookies.

How do you use cookies?

Cookie policy

In order to ensure the proper functioning of Our Website or Application, we sometimes store small data files known as cookies on your devices.

What are cookies?

A cookie is a small data file that is stored on your computer or mobile device when you visit a certain website. With the help of cookies, the website remembers your actions and preferences (such as username, language, font size and other preferences related to display) for a long period of time, so it is not necessary to re-enter them every time you return to the website or moving from one of its pages to another.

How do we use cookies?

Our Website or Application uses cookies that are not strictly necessary to display the website, but shall allow you to have a more pleasant browsing experience. You can delete or block these cookies, but if you do, some functions of Our website or Application may not work as intended. We use cookies on Our website or Application in the following way:

- cookie for defining the browser language,

- cookies for monitoring website visit statistics,

- user security cookies, which are used to prevent authentication abuse and to protect against CSRF hacker attacks.

- cookie for defining the display of a pop-up window at the bottom of the page and for activating or deactivating certain categories of cookies.

Cookies update

You can withdraw the consent you give us by clicking on a particular category of cookies at any time.

Third party cookies

Sometimes, for statistical purposes, we also use external services to monitor the use of the pages, such as Google Analytics. In this case, Google will send its cookies to your computer - the so-called third party cookies.

Targeting/Marketing cookies are used to track visitors across websites. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers. If you do not allow these cookies, you will experience less targeted advertising.

Personal data

Information associated with cookies does not serve to identify you, and information about browsing habits is solely under our control. We do not use cookies for any purposes other than those described here.

How are cookies controlled?

You can control and/or delete cookies as you wish. You can delete all cookies already stored on your device, and the settings of most browsers allow you to block the storage of cookies. If you block cookies, you may have to manually adjust some preferences each time you visit Our website, and certain services and functions may not be available. If you do not want to receive cookies on your computer, you can set your browser to notify you when it detects them or you can reject them all automatically. You can also delete any cookies you have already received. If you want to limit or block cookies that have already been installed, you can do so through your browser settings. In which way, find out through the "Help" function in the browser or on the page www.aboutcookies.org, where you can find detailed instructions related to different browsers.

How you can turn off third-party cookies and how to change your browser settings are described in the following links:

https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer

https://support.google.com/chrome/answer/95647?hl=en

https://support.apple.com/en-us/HT201265

How can I contact you?

To contact us about anything related to your personal data and data protection, including a subject access request, please use the following details:

Email address: [email protected]

Phone number: 0038514095810

Postal address: MELIUS MAGNA Ltd., Ulica Filipa Vukasovića 1, 10000 Zagreb

Changes to this Privacy Policy

We may change this Privacy policy from time to time. This may be necessary, for example, if the law changes or if we change our business in a way that affects the protection of personal data.

Any changes shall be posted immediately on Our website and you shall be deemed to have accepted the terms of the Privacy Policy when you first use Our website after the changes. We recommend that you check this page regularly to stay up-to-date.