Privacy Policy Effective as of September 1, 2023

Welcome to our website and online store, available at www.rockors.rs or www.rockors.com!

TwogNation d.o.o. Beograd-Rakovica, with its registered office at 12V Patrijarha Dimitrija Street, Rakovica, Belgrade, Serbia, company registration number: 21653659, and tax identification number (PIB): 112338373, as the owner of the Website and the data controller responsible for processing personal data, is fully aware of the importance of personal data protection and takes this responsibility very seriously. We understand how important the protection of your personal data is to you. Therefore, as the data controller, we have prepared this Privacy Policy to ensure that the processing of your personal data is transparent and easy to understand. This Privacy Policy explains how we collect and use your personal data and how you can exercise your rights regarding the protection of your personal data.

We hereby inform you that our Websites are created, supported, and operated using solutions provided by www.shopify.com. For this reason, your personal data may be disclosed to Shopify by us, and Shopify International Ltd. may act as a data processor. Its address is: Attn: Data Protection Officer, c/o Intertrust Ireland, 2nd Floor, 1–2 Victoria Buildings, Haddington Road, Dublin 4, D04 XN32, Ireland. We therefore recommend that you familiarise yourself with Shopify’s Privacy Policy at https://www.shopify.com/legal/privacy, or visit www.shopify.com to find any other official privacy policy of this legal entity that may apply to you. We recommend that you monitor any changes to the privacy policy of this recipient and/or processor of your personal data, as the links and information concerning this legal entity provided herein were accurate at the time this Privacy Policy was adopted and may subsequently change. We accept no responsibility for such changes.

This Privacy Policy applies to every person who accesses or uses our Website. Please read this Privacy Policy carefully, as it forms part of the complete agreement applicable to you, together with our Terms of Use and Business Terms and Cookie Policy. Please note that the Cookie Policy forms an integral part of this Privacy Policy. If you do not agree with our Privacy Policy and Cookie Policy, please stop using our Website immediately. All provisions of this Privacy Policy also apply to matters covered by the Cookie Policy, unless the Cookie Policy provides for additional or different terms.

Terms that are not defined in this Privacy Policy but are used herein with an initial capital letter shall have the same meaning as the terms defined in the “Definitions” section of our Terms of Use and Business Terms, which you can access here.

If you have any questions regarding this Privacy Policy, please contact us at master@rockors.com.

We primarily collect personal data directly from you when you communicate with us or interact with other users, contact us for support or any other reason, register an account, or purchase and/or order products and/or services from us, or in connection with such purchases or orders. These circumstances are described in detail below.

You are not required to provide us with your personal data. However, if you choose not to do so, you may be unable to use some or all of the services available on our Website. If you do not provide the personal data we require, TwogNation cannot guarantee that any purchase and/or order of products and/or services from us will fully meet your needs.

Your personal data is treated as strictly confidential, and each method of data collection has a specific purpose and a legal basis under applicable law. Depending on how you use our Website, the information we may collect about you includes the following.

Information that you voluntarily choose to share through the Website or in connection with the services you use and the products you purchase through our Website may contain your personal data and the personal data of others, including information shared:

• When communicating with us via email at master@rockors.com, through any other email address or telephone number available on the Website, or through any other form of communication with us;
• When communicating with manufacturers, retailers, suppliers, delivery providers, or any third parties involved in facilitating the sale of products and/or services purchased through our Website, as well as any related or ancillary activities necessary to fulfil the rights and obligations assumed by the contracting parties;
• When communicating with other users through messages, submitting reviews, entering text, or using any other communication feature available on the Website;
• When publishing posts or providing any other information through the Website.

The information that we or the third parties mentioned above receive in this way depends entirely on you and is provided voluntarily. Providing this information is not mandatory, nor is it a condition for using the Website. If you choose to share such information with us, you will be deemed to have given your explicit consent to its processing. If you share another person's personal data, you will be deemed to have obtained that person's explicit consent to its processing or to have another valid legal basis for sharing that data.

You may withdraw your consent to the processing of the above-mentioned personal data at any time by sending an email to master@rockors.com or by writing to our registered office address, specifying the personal data for which you wish to withdraw your consent.

To place an order, which is necessary for you to receive an order confirmation, i.e. confirmation that your order has been accepted or rejected, for the purpose of concluding a Sales Agreement with us, ensuring that the purchased product is delivered to your desired address, and enabling us to exercise all our rights and fulfil all our obligations in connection with your order and purchase through our Website, you, as a Website User, are required to provide the following personal data:

After registering or updating your account, or when placing an order, you may be offered the option to consent to our use of your email address to send you our newsletters. These newsletters constitute commercial communications and may contain information intended to promote goods, services, or the business reputation of TwogNation and third parties that are our partners in projects conducted through our Website. This includes, but is not limited to, marketing, sales, and other campaigns carried out by TwogNation independently or in cooperation with third-party partners.

Every Website User may consent to receiving notifications from us. If you do so, we will collect the identification number or identifier of the device you use to visit our Website to ensure that notifications are delivered to that device. Notifications also constitute commercial communications and may contain information intended to promote goods, services, or the business reputation of TwogNation and third parties that are our partners in projects conducted through our Website. This includes, but is not limited to, marketing, sales, and other campaigns carried out by TwogNation independently or in cooperation with third-party partners.

You may withdraw your consent to receiving newsletters and notifications as commercial communications at any time, whether you wish to receive only certain types of information or no commercial communications from us at all. You can do so by sending an email to master@rockors.com or by writing to our registered office address, specifying which newsletters or notifications you no longer wish to receive and to what extent. You may also unsubscribe from our mailing list using the unsubscribe option included in the newsletters we send you, or disable notifications through the relevant settings on your device.

On our Website, certain personal data is collected with your consent. For this reason, please refer to the table below to see which personal data we process on the basis of your consent.

You have the right to withdraw your consent at any time. However, withdrawing your consent does not affect the lawfulness of any processing of your personal data carried out before the withdrawal.

You may withdraw your consent by:

• Sending an email to master@rockors.com or writing to our registered office address;
• Using the unsubscribe option included in the newsletters you receive from us;
• Disabling notifications through the relevant settings on your device.

Individuals aged 15 or older may independently provide consent to the processing of their personal data. If you are under 15 years of age, consent to the processing of your personal data must be provided by your parent exercising parental responsibility or by your other legal representative.

If you believe that TwogNation has collected personal data belonging to a person under the age of 15 without obtaining consent from their parent exercising parental responsibility or another legal representative, please notify us at master@rockors.com or by writing to our registered office address.

We will use your personal data only with your explicit consent or where another lawful basis for processing applies.

Your personal data will not be stored or used for any purpose other than the one for which it was originally collected.

We process your personal data in accordance with applicable law and this Privacy Policy.

We do not retain your personal data for longer than necessary to fulfil the purpose for which it was collected, or beyond the period for which we have your consent.

If you have given your consent to the processing of your personal data, withdrawing that consent will result in the deletion of the relevant data. This does not affect the lawfulness of any processing carried out before your consent was withdrawn.

Where personal data is processed for the purpose of entering into or performing a contract, it will be retained for as long as necessary to fulfil the specific contractual right or obligation for which the data was collected, after which it will be deleted.

As an individual whose personal data we collect, you have the following rights, which you may exercise by contacting us as the data controller:

• The right to be informed about the collection and processing of your personal data;
• The right to request access to your personal data;
• The right to request the rectification of personal data if it is incomplete or inaccurate;
• The right to erasure (the “right to be forgotten”), meaning you may request that we delete the personal data we hold about you;
• The right to restrict the processing of your personal data;
• The right to object to the processing of your personal data where there are no legitimate grounds for such processing;
• The right to data portability;
• The right to lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection;
• The right to withdraw your consent to the processing of your personal data for a specific purpose.

If we obtain your personal data from a source other than you, you also have the right to know the source from which we obtained your data and, where applicable, whether the data came from publicly available sources, in addition to all the rights listed above.

To exercise any of these rights, please contact us at master@rockors.com or write to us at our registered office address.

Below, we explain how you can exercise certain rights in more detail.

You have the right to ask us whether we process your personal data and to request access to that data. You also have the right to obtain information about the purpose of the processing, the types of personal data we process, the recipient or categories of recipients to whom your personal data have been or will be disclosed, particularly recipients in other countries or international organisations, and the intended period for which your personal data will be stored or, if this is not possible, the criteria used to determine that period.

As the data controller, we are also responsible for enabling you to exercise your rights to request the rectification or erasure of your personal data, to restrict processing, and to object to processing. You also have the right to lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection, to obtain information about the source of your personal data if the data were not collected directly from you, and to be informed about the existence of automated decision-making, including profiling. In such cases, you are entitled to meaningful information about the logic involved, as well as the significance and expected consequences of such processing for you.

You have the right to receive a copy of all personal data we process about you.

You can find all this information, along with further details, in this Privacy Policy. Alternatively, you can contact us by email at master@rockors.com or write to us at our registered office address.

You have the right to have inaccurate personal data concerning you rectified without undue delay. Depending on the purpose of the processing, you also have the right to have incomplete personal data completed, including by providing a supplementary statement.

You have the right to request that we erase your personal data if:

• The data are no longer necessary for the purposes for which they were collected or otherwise processed;
• You have withdrawn your consent to the processing;
• You have objected to the processing on the grounds that we have no legitimate interest in processing your data, or where the data are processed for direct marketing purposes, including profiling to the extent that it is related to such direct marketing;
• Your personal data have been processed unlawfully;
• We are legally required to erase your personal data;
• You provided your personal data as a minor over the age of 15 while using our Website.

We reserve the right to refuse your request, but only where there is a lawful basis for doing so.

You may request the restriction of the processing of your personal data in the following circumstances:

• While we verify the accuracy of your personal data following your objection to their accuracy, or while we assess your objection that there are no legitimate grounds for processing;
• Where the processing of your personal data is unlawful;
• Where you need the data to establish, exercise, or defend a legal claim, and there are no grounds for further processing.

When processing is restricted, we may not process your personal data without your further consent, except where permitted by law. We will inform you before the restriction is lifted, once the reason for the restriction no longer applies.

If we rectify or erase your personal data, or restrict the processing of such data, we will notify all recipients to whom the data have been disclosed. You have the right to request information from us about all recipients of your personal data.

As previously explained, our Websites are created, supported, and operated using solutions provided by Shopify. Consequently, your personal data may be disclosed to Shopify International Ltd., which may act as the processor of your personal data. Its contact details are as follows:

Shopify International Ltd.
Attn: Data Protection Officer
c/o Intertrust Ireland
2nd Floor, 1–2 Victoria Buildings
Haddington Road, Dublin 4
D04 XN32, Ireland

We would also like to inform you that, according to official information, this legal entity is based in Dublin, Republic of Ireland. Ireland is included on the official list of countries, territories or specified sectors within countries, and international organisations that are considered to provide an adequate level of protection for personal data.

As previously explained, we may disclose the personal data listed in Section 1.2 of this Privacy Policy to recipients such as manufacturers, retailers, suppliers, delivery providers, or any other third parties engaged by us in any capacity to facilitate the sale of products or services. This excludes your password and the information you enter when making online payments, which we neither collect nor use.

Such recipients may also be located outside the territory of the Republic of Serbia, but only in countries included on the official list of countries, territories or specified sectors within countries, and international organisations that are considered to provide an adequate level of protection for personal data.

Since these recipients may be different entities located in different countries, depending on the specific circumstances, we will inform you of the recipient’s identity and the country in which they are located immediately before disclosing your personal data to that recipient.

We do not make decisions based on the automated collection of your personal data.

We do not share your personal data with third parties unless: we have your consent to do so; or we are legally required to disclose certain information, including your personal data, to parties such as public authorities. In such cases, we are not required to obtain your additional consent.

We reserve the right to update this Privacy Policy from time to time to reflect changes in legislation and technological developments. Any changes to this Privacy Policy will take effect upon publication on our Website. We therefore recommend that you review our Privacy Policy periodically to stay informed of any changes.

We will seek your consent to any changes to this Privacy Policy where and to the extent required by applicable data protection laws.