Privacy Policy
This Privacy Policy informs you about the nature, scope, and purpose of the processing of personal data (hereinafter "Data") by Empowered Products d.o.o., Pijavišće 17/G, 10000 Zagreb, Croatia (OIB: 081285408) (hereinafter "the Company" or "Controller") in connection with the website pinksensuals.eu.
1. Hosting and Data Infrastructure
Our website and its underlying databases are hosted on a dedicated server located in France (OVHcloud). This ensures that your personal data is stored within the European Economic Area (EEA), providing high levels of data sovereignty and security under the General Data Protection Regulation (GDPR).
2. Cookies and Tracking (The "No-Banner" Disclosure)
To ensure a user-friendly experience, we use only
strictly necessary functional cookies.
- The "Cart" Cookie: A persistent functional cookie used to remember your shopping cart contents. This is essential for the service you explicitly requested.
Legal Basis: Art. 6(1)(f) GDPR (Legitimate Interest) and Section 15(3) of the ePrivacy Directive. Because we do not use analytical, marketing, or third-party tracking cookies,
no cookie consent banner is required.
3. Collection and Purpose of Data
We process data only for the following purposes:
Order Fulfillment: When you make a purchase, we process names, addresses, and payment info to fulfill your order. (Legal Basis: Art. 6(1)(b) GDPR - Performance of a Contract).
Inquiries: Data from contact forms is used solely to respond to your specific request. (Legal Basis: Art. 6(1)(f) GDPR - Legitimate Interest).
Newsletters: If you opt-in to our mailing list, we process your email address to send updates. (Legal Basis: Art. 6(1)(a) GDPR - Consent).
4. Data Processing (Internal Systems, Logistics, & SendGrid)
For the management of customer relationships and the fulfillment of orders, we utilize the following partners:
- Internal Platform: Our secure management system ("Access") is hosted on our dedicated infrastructure in France.
- Logistics & Fulfillment: Order details (name, shipping address, contact info) are shared with our fulfillment partner in the Netherlands to process and ship your purchases.
- Email Delivery: We use SendGrid (Twilio Inc.) for transactional and marketing emails. We ensure data protection via Data Processing Agreements and Standard Contractual Clauses (SCCs).
5. No Sale or Third-Party Sharing
The Company maintains a strict "No-Share" policy. We do not sell, rent, or trade your personal information. Data is only disclosed to essential service providers (e.g., shipping carriers for delivery) or when legally mandated by public authorities.
6. Data Retention
We store your data only as long as necessary:
- Order Data: Retained for 10 years to comply with Croatian tax and commercial record-keeping laws.
- Contact Inquiries: Deleted once the inquiry is resolved, unless a business relationship follows.
- Newsletter Data: Deleted immediately upon your unsubscription.
7. Your Rights and Contact
Under the GDPR, you have the right to access, rectify, or erase your data, and the right to restrict or object to processing. To exercise these rights, please contact us at our Zagreb headquarters or via our contact page. You also have the right to lodge a complaint with the Croatian Data Protection Agency (AZOP).