Privacy Policy

1. Who We Are

This Website and online store are operated by:

For the purposes of applicable data-protection law, including the EU General Data Protection Regulation, Torp d.o.o. is the controller of the personal data described in this Privacy Policy.

In this Policy, “Torp,” “we,” “us,” and “our” refer to Torp d.o.o.

2. Scope of This Policy

This Privacy Policy applies when you:

• visit or use our Website;
• purchase a product through our online store;
• create or use a customer account;
• contact us through a Website form, email, telephone, or social-media channel;
• subscribe to newsletters or marketing communications;
• submit a review, survey response, photograph, video, or other content; or
• otherwise interact with us in connection with the Website or an order.

The Torp App, Dealer Platform, recruitment processes, formal product-recall programmes, and warranty procedures may be covered by separate or additional privacy notices. Where another privacy notice is presented for a particular service, that notice applies to the relevant processing together with this Policy.

3. Personal Data We Collect

Depending on how you interact with us, we may collect the following categories of personal data.

3.1 Identity and contact information

This may include your:

• name;
• company name;
• billing and delivery address;
• country;
• email address;
• telephone number;
• VAT or tax identification number; and
• other contact information you provide.

3.2 Order and transaction information

This may include:

• products ordered;
• order number and date;
• purchase price, discounts, currency, and tax information;
• billing and invoice information;
• payment method and payment status;
• delivery method, tracking number, and delivery status;
• return and refund information; and
• communication relating to the order.

Complete payment-card details are normally collected and processed directly by the selected payment provider. Torp does not normally receive or store your complete payment-card number or security code.

3.3 Customer account information

This may include:

• account identifiers;
• login credentials stored in protected form;
• saved addresses;
• order history;
• preferences;
• communication settings; and
• account-security information.

3.4 Communication and customer-support information

When you contact us, we may process:

• the contents of your message;
• previous correspondence;
• order and product information;
• photographs, videos, attachments, and documents you provide;
• product model and serial number;
• installation or configuration information; and
• other information reasonably necessary to answer your request.

Where a formal warranty, conformity, safety, or recall procedure applies, additional information may be processed under the notice or documentation applicable to that procedure.

3.5 Marketing information

This may include:

• newsletter subscription status;
• marketing preferences;
• consent records;
• email delivery and interaction information; and
• information about campaigns or promotions with which you interact.

3.6 Website, cookie, and device information

This may include:

• IP address;
• browser and device type;
• operating system;
• approximate location derived from your IP address;
• language and time-zone settings;
• referring website;
• pages viewed;
• date and time of access;
• session and cookie identifiers;
• shopping-cart activity; and
• security and error logs.

3.7 Content you voluntarily submit

This may include reviews, comments, testimonials, survey responses, photographs, videos, suggestions, social-media handles, or other content you choose to provide.

Please do not send sensitive personal data unless it is genuinely necessary and we have specifically requested it.

4. How We Collect Personal Data

We collect personal data:

• directly from you;
• automatically through your browser or device;
• from payment providers, couriers, fulfilment providers, and other companies involved in completing your order;
• from an authorised Torp dealer or distributor where that party is involved in your purchase or support request;
• from security and fraud-prevention providers; and
• from publicly available sources where reasonably necessary to prevent fraud, protect our rights, or comply with law.

Where another person places an order for you or provides your information to us, that person is responsible for ensuring that they are authorised to do so and that the information is accurate.

5. Why We Process Personal Data

5.1 To process and fulfil orders

We process identity, contact, order, payment-status, billing, and delivery information to:

• process and confirm orders;
• receive and administer payments;
• issue invoices;
• deliver products;
• provide delivery updates;
• process cancellations, returns, and refunds; and
• communicate with you about your order.

The legal basis is the performance of a contract or taking steps at your request before entering into a contract.

5.2 To provide customer support

We process contact, order, product, and communication information to answer questions, provide technical assistance, investigate reported issues, and manage customer requests.

The legal basis is performance of a contract, compliance with legal obligations, or our legitimate interest in providing effective customer support.

5.3 To comply with legal obligations

We may process and retain personal data to comply with:

• tax and accounting requirements;
• customs and import requirements;
• consumer-protection obligations;
• product-safety obligations;
• regulatory requests;
• court orders; and
• other legal obligations applicable to Torp.

The legal basis is compliance with a legal obligation.

5.4 To protect the Website, Torp, and other users

We process account, transaction, communication, and technical information to:

• protect the Website and our systems;
• prevent fraud and unauthorised transactions;
• investigate misuse or security incidents;
• enforce our contractual rights;
• preserve evidence; and
• establish, exercise, or defend legal claims.

The legal basis is our legitimate interest in operating a secure and lawful business.

5.5 To improve the Website and our services

Where permitted, we may analyse Website usage, orders, errors, and customer interactions to improve Website performance, product information, customer service, and business operations.

Where optional analytics technologies are used, they will be activated only after consent where consent is legally required.

5.6 To send marketing communications

We may send newsletters, product announcements, promotions, and similar communications where:

• you have given your consent; or
• another legal basis permitted by applicable marketing law applies.

You may unsubscribe at any time by using the unsubscribe link in the message or contacting us at info@torp.hr.

Withdrawal of consent does not affect processing that took place before consent was withdrawn.

5.7 To administer reviews, promotions, and submitted content

Where you submit a review, testimonial, photograph, video, competition entry, or other content, we may process that content to administer, moderate, and publish it.

Where required, we will obtain separate permission before using identifiable customer content in advertising or promotional campaigns.

6. Information Required to Complete a Purchase

Certain information is necessary to:

• process an order;
• accept payment;
• issue an invoice;
• deliver a product;
• comply with customs or tax requirements; or
• answer a customer request.

Required fields will be identified during the relevant process. If you do not provide required information, we may be unable to accept or complete your order or provide the requested service.

7. Cookies and Similar Technologies

The Website may use cookies, local storage, pixels, scripts, and similar technologies.

7.1 Strictly necessary technologies

These technologies may be used without consent where legally permitted because they are necessary to:

• operate the shopping cart and checkout;
• maintain Website security;
• prevent fraud;
• remember privacy preferences;
• enable account login;
• maintain Website availability; or
• provide another service expressly requested by you.

7.2 Optional technologies

Analytics, advertising, remarketing, personalisation, and social-media technologies will be activated only in accordance with your consent choice where consent is required.

You can accept, reject, or change your choices through Cookie Settings.

Cookie Settings shows the current list of:

• cookies and similar technologies;
• providers;
• purposes;
• categories; and
• retention periods.

Withdrawing consent will not affect processing that took place before withdrawal.

8. Who Receives Personal Data

Where necessary, we may share personal data with:

• Website-hosting and cloud-service providers;
• e-commerce and customer-account providers;
• IT, cybersecurity, backup, and technical-support providers;
• payment service providers and financial institutions;
• couriers, freight forwarders, customs agents, fulfilment providers, and postal operators;
• email, newsletter, and customer-communication providers;
• customer-support and business-management providers;
• accountants, auditors, insurers, lawyers, and other professional advisers;
• authorised Torp dealers, distributors, or service partners involved in a relevant transaction;
• analytics, advertising, or social-media providers where the required consent or legal basis exists;
• courts, regulators, customs authorities, tax authorities, police, and other public bodies where legally required; and
• prospective purchasers, investors, or advisers in connection with a merger, restructuring, financing, or transfer of all or part of our business.

Some recipients, including payment providers, couriers, and public authorities, may process personal data as independent controllers. Their own privacy policies apply to that processing.

We do not sell personal data as a standalone commercial product.

9. International Data Transfers

Some service providers may process personal data outside the European Economic Area.

Where personal data is transferred to a country that has not been recognised as providing an adequate level of protection, we use an appropriate transfer mechanism where required, such as:

• European Commission standard contractual clauses;
• another legally approved transfer mechanism; and
• supplementary technical or organisational safeguards where appropriate.

You may contact us for additional information about the safeguards used for a particular transfer.

10. Data Retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected.

Retention periods are determined by considering:

• the duration of the customer relationship;
• the time necessary to complete an order or request;
• applicable tax, accounting, customs, consumer, and product-safety requirements;
• applicable limitation periods;
• the need to prevent fraud or protect account security; and
• the need to establish, exercise, or defend legal claims.

In general:

• order, invoice, tax, and accounting information is retained for the period required by applicable law;
• account information is retained while the account remains active and for a limited period after closure;
• customer correspondence is retained for as long as reasonably necessary to resolve and document the matter;
• marketing information is retained until consent is withdrawn or you object;
• a minimal suppression record may be retained to ensure that marketing is not sent after you opt out;
• cookie and analytics information is retained for the period shown in Cookie Settings; and
• security information may be retained for a longer period where it relates to an investigation, suspected fraud, or legal claim.

When personal data is no longer required, it is deleted, anonymised, or securely archived where continued retention is legally required.

11. Your Data-Protection Rights

Subject to applicable legal conditions and exceptions, you may have the right to:

• obtain information about our processing of your personal data;
• request access to your personal data;
• request correction of inaccurate or incomplete data;
• request deletion of personal data;
• request restriction of processing;
• receive certain personal data in a structured, commonly used, machine-readable format;
• request transmission of eligible data to another controller;
• object to processing based on legitimate interests;
• object at any time to direct marketing;
• withdraw consent at any time; and
• lodge a complaint with a competent data-protection authority.

Requests may be sent to info@torp.hr.

We may request information reasonably necessary to verify your identity and protect personal data against unauthorised disclosure.

You may lodge a complaint with the Croatian Personal Data Protection Agency (AZOP). Where applicable, you may also contact the data-protection authority in the country where you live or work or where you believe an infringement occurred.

12. Automated Decision-Making

We do not currently use solely automated decision-making that produces legal or similarly significant effects for Website customers.

Automated systems may be used to identify potential payment fraud, account misuse, cybersecurity threats, or technical errors. Where required by law, a decision that materially affects you will be subject to appropriate human review.

13. Children

The online store is not intended for children to place orders independently.

Orders must be placed by a person legally capable of entering into a binding contract or by a parent or legal guardian.

We do not knowingly collect personal data from children where parental or guardian authorisation is legally required.

14. Data Security

We use appropriate technical and organisational measures designed to protect personal data against:

• accidental or unlawful destruction;
• loss;
• alteration;
• unauthorised disclosure; and
• unauthorised access.

However, no website, electronic transmission, or storage system can guarantee absolute security.

Customers are responsible for keeping account credentials confidential and should contact us promptly if they suspect unauthorised access to their account.

15. Third-Party Websites and Services

The Website may contain links to websites, applications, payment services, social-media platforms, or other services operated by third parties.

Torp is not responsible for the privacy practices of independent third parties. You should review the relevant third party’s privacy information before providing personal data.

16. Changes to This Policy

We may update this Privacy Policy when our Website, business processes, service providers, or legal obligations change.

The current version will be published on the Website with a revised “Last updated” date.

Where a change materially affects how we process existing personal data, we will provide additional notice where required by law.

17. Contact

For questions or requests concerning this Privacy Policy or our processing of personal data, contact: