Privacy Policy
This privacy policy (hereinafter: “Privacy Policy”) governs the processing of your personal data as
part of your visit to our website https://www.stem-parts.com/ (hereinafter: “Website”), your
communication with us via e-mail, telephone, fax and social media (hereinafter: “Social Media
Channels”; e.g. Facebook, LinkedIn, Google+, YouTube, Pinterest, Instagram, Snapchat, Twitter,
Whatsapp, Vimeo, etc.) and any order or purchase via our webshop.
Stem parts Europe d.o.o. is committed to protecting and respecting your privacy. We wish to be
transparent regarding how we process your personal information in accordance with the EU General
Data Protection Regulation (EU 2016/679) and the Data Protection Act 2018. It is the intention of this
Privacy Policy to explain to you our privacy management practices in relation to the personal
information that we collect and process.
In accordance with the EU GDPR (2016/679) and the Data Protection Act 2018, we are identified as
both a Data Controller, and Data Processor of personal information.
By willingly providing personal and other information, you consent to the terms and conditions of this
Privacy Policy. Please read this statement carefully, as this document sets out the basis on how we
collect and process the personal information that you provide to us.
NOTE: If you want information on how we process personal data via cookies, social plug-ins, pixels
and other types of tracking technology, you are kindly referred to our Cookie Policy .
1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?
Stem parts Europe d.o.o., Josipa Jurja Strossmayera 341, 31000 Osijek, Croatia with corporate registration number 030303042 is the
entity responsible for your personal data as covered in this Privacy Policy (hereinafter: “Stem parts
Europe”, “we”, “us, “our”.) This Privacy Policy may be changed from time to time, in order to ensure
that it remains accurate and in line with legislation. If this happens, you are kindly asked to take note
of the changes and to agree with them if you find them acceptable.
1.1 Your personal data are processed by Stem parts Europe d.o.o., Josipa Jurja Strossmayera 341, 31000 Osijek, Croatia with
corporate registration number 030303042 (hereinafter: “Stem parts Europe”, “we”, “us”, “our”). You
can contact us via e-mail at info@stem-parts.com .
1.2 Any notion starting with a capital shall be defined by explicit reference in this Privacy Policy.
Where possible given the context, singular words shall be interpreted as also including the plural and
vice versa.
1.3 Where reference is made to certain laws or regulations, such reference shall also include any
change, replacement or annulment of said laws or regulations, including any related executive
decisions.
1.4 Stem parts Europe reserves the right to modify, change or amend the Privacy Policy at its own
discretion and from time to time. Such modification, change or amendment shall be communicated
via the Website. If you do not accept the modifications, changes or amendments, you are to inform
us by sending an e-mail to info@stem-parts.com . If we do not receive such an e-mail from you within
three (3) business days after the changes to the Privacy Policy have been announced on our
Website, you will be deemed to have accepted unambiguously all such changes
2. WHICH CATEGORIES OF PERSONAL DATA DO WE PROCESS?
We process following categories of personal data: technical information associated with the device
you use, your browsing preferences, basic identity information you provide us with, the content of
your communication, the technical details of the communication, your preferences regarding
receiving our e-mail communications, publicly available information of your profile, any other
personal data you choose to provide to us, your order and the details pertaining to the order itself.
Most of the personal data we process, we receive directly from you. However, from time to time we
may receive personal data from third parties.
2.1 Whenever you use our Website, Webshop and Social Media Channels, we collect:
– technical information associated with the device you use, such as your IP address, browser type,
geographical location and operating system;
– information concerning your browsing behavior, such as how long you visit, what links you click
on, what pages you visit and how many times you visit a page.
2.2 When you fill out the contact form on our Website, use the chat function or contact us via e-mail,
telephone, fax or Social Media Channels, we collect:
– the basic identity information you provide us with, such as name, e-mail address, postal address,
telephone number, the company you work for, your function.;
– the content of your communication and the technical details of the communication itself (with
whom you correspond at our end, date and time, etc.);
– your preferences regarding receiving our e-mail communications, such as newsletters,
promotions, advertisements, etc., if you have chosen to receive such communications and you
have indicated your preferences in the Preference Center.
– publicly available information of your profile on Social Media Channels;
– any other personal data you choose to provide to us.
2.3 When you place an order on one of our Webshop, as customer or supplier, we collect:
– the basic identity information we require to process your order, such as your name, company,
function, postal address and telephone number;
– details pertaining to the order itself.
2.4 All of the personal data listed above, we receive directly from you. It may happen that we receive
additional information about your preferences and surfing behavior from partners such as Google,
Facebook, Yandex and AddThis/Oracle. If you require more information about the personal data
these parties process about you and make available to others, you are kindly requested to consult
their respective privacy policies:
– Google: https://www.google.com/intl/en/policies/privacy/
– Facebook: https://www.facebook.com/about/privacy
– Yandex: https://yandex.com/legal/privacy/
– AddThis/Oracle: http://www.addthis.com/privacy/
3. WHY DO WE PROCESS YOUR PERSONAL INFORMATION?
We process your personal data for several different purposes: to provide, improve and develop
services; for marketing purposes; to inform third parties; because we are legally required to do so or
to detect if you use our Website, Webshop, Social Media Channels or other communication
channels in any way that may harm Stem parts Europe or someone else, is illegal.
3.1 Stem parts Europe processes your personal data for marketing purposes, i.e. to provide you with
targeted communications, promotions, offerings and other advertisements of Stem parts Europe and
selected partners.
Unless you are an existing customer who has already purchased similar goods or services from us
and who we wish to target with our own marketing material, we will only send you communications,
promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person
electronic communications channels if you have explicitly consented to receiving such
communications, promotions, offerings, newsletters and other advertisements.
3.2 Stem parts Euroope processes your personal data to provide you in a personalized and efficient
way with the information, products and services you request via the Website, e-mail, telephone, fax,
Social Media Channels and Webshop.
3.3 Stem parts Europe processes your personal data to comply with legal obligations or to comply
with any reasonable request from competent law enforcement agents or representatives, judicial
authorities, governmental agencies or bodies, including competent data protection authorities.
Your personal data may be transferred upon our own initiative to the police or the judicial authorities
as evidence or if there are justified suspicions of an unlawful act or crime committed by you through
your registration with or use of the Website, Webshop, our Social Media Channels or other
communication with us.
3.4 We may be required to collect and transfer your personal data to the financial institution or
payment service provider to allow your financial institution and the payment service provider to
comply with their legal obligations, such as obligations under applicable anti-money laundering and
counter-terrorism financing legislation.
3.5 Stem parts Europe processes your personal data to perform statistical analyses so that we may
improve our Website, Webshop, products and services or develop new products and services.
3.6 We may process your personal data for informing any third party in the context of a possible
merger with, acquisition from/by or demerger by that third party, even if that third party is located
outside the EU.
3.7 We may process your personal data for the preservation of the legitimate interests of Stem parts
Europe, its partners or a third party if and when your registration with or use of the Website,
Webshop, Social Media Channels or other communication channels can be considered (a) a
violation of any applicable terms of use or the intellectual property rights or any other right of a third
party, (b) a threat to the security or integrity of the Website, Webshop, Social Media Channels or
other communication channels, (c) a danger to the Website, Webshop, Social Media Channels or
other communication channels or any of our or its subcontractors’ underlying systems due to
viruses, Trojan horses, spyware, malware or any other form of malicious code, or (d) in any way
hateful, obscene, discriminating, racist, slanderous, spiteful, hurtful or in some other way
inappropriate or illegal.
3.8 Stem parts Europe may process your personal data for the organization of trainings and for
carrying out certification.
4. WHAT MAKES THE PROCESSING OF YOUR PERSONAL DATA LEGITIMATE?
The law requires us to state precisely which legal basis we use to process your personal data. We
may process your personal data because you have given your consent to do so, it is necessary for
performing the agreement between you and us, we are obliged to do so by legislation or it is in our
legal interest to process your personal data.
4.1 For processing your personal data for the purposes outlined in clause 3.1 and 3.2, Stem parts
Europe as the responsible party asks for your consent.
4.2 The processing of your personal data for the purpose of fulfilling an order you have placed via
our Webshop is necessary for performing the agreement between you and Stem parts Europe.
4.3 The processing of your personal data for the purposes outlined in clauses 3.3 and 3.4 is
necessary to allow us to comply with its legal obligations.
4.4 The processing of your personal data for the purposes outlined in clauses 3.5, 3.6 and 3.7 is
necessary for the purpose of the legitimate interests of the Stem parts Europe, which are:
– continuous improvements to our Website, Webshop, Social Media Channels, products and
services to ensure that you have the best experience possible;
– keeping our Website, Webshop, Social Media Channels, products and services safe from misuse
and illegal activity;
– marketing and promotion of our products, services, brands an overall successful
commercialization of our products and services.
5. WHO RECEIVES YOUR PERSONAL DATA?
Our general approach is that we do not share your personal with third parties unless you consent to
it. However, sometimes it is unavoidable that third parties receive your personal data. Social media
providers, financial institutions, payment service providers, cloud providers, service providers that
help us with the maintenance of our Website and Webshop may receive and process your personal
data in some circumstances.
5.1 Stem parts Europe does not send your personal data in an identifiable manner to any third party
without your explicit permission to do so. You understand, however, that if you use our Social Media
Channels, your personal data is also processed by the social media providers. If you purchase
anything via our Webshop, a financial institution or payment service provider may also receive your
personal data in order to provide their services.
5.2 Stem parts Europe relies on third party processors to provide you the Website and Webshop as
well as to process your personal data on our behalf. These third party processors are only allowed to
process your personal data on behalf of Stem parts Europe upon explicit written instruction. Stem
parts Europe warrants that all third party processors are selected with due care and are obliged to
observe the safety and integrity of your personal data.
6. DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE THE EEA?
Yes, we transfer your personal data outside the EEA (i.e. the European Economic Area, consisting
of the EU and Norway, Liechtenstein and Iceland). Parties to whom we transfer your personal data
are foreign service providers. It goes without saying that your personal data are safe when we send
your personal data to countries outside the EEA.
6.1 Stem parts Europe processes your personal data first and foremost within the EEA. However, in
order to process your personal data for the purposes outlined in article 3 above, we may also
transfer your personal data to third parties who process on our behalf which are located outside the
EEA. Each entity outside the EEA that processes your personal data shall be bound to observe
adequate safeguards with regard to the processing of your personal data. Such safeguards will be
the consequence of:
the recipient country having legislation in place which may be considered equivalent to the
protection offered within the EEA; or
of a contractual arrangement between Stem parts Europe and that entity. All Stem parts Europe
entities are parties to a contractual arrangement based on the EC’s Standard Contractual Clauses
(controller-to-controller) (Commission Decision C(2004)5721
6.2 We may transfer anonymized and/or aggregated data to organizations outside of the EEA.
Should such transfer take place, we will ensure that there are safeguards in place to ensure the
safety and integrity of your data as well as all rights with respect to personal data you might enjoy
under applicable mandatory law.
7. WHAT ARE THE QUALITY ASSURANCES WITH REGARD TO YOUR PERSONAL
DATA?
We will not process more personal data than we need for the purposes we have communicated to
you. Additionally, we will only process your personal data for as long as needed to achieve the
purposes we have communicated to you or up until such time where you withdraw your consent for
processing them and no other legal ground applies that allows us to proceed in processing your
personal data. We also guarantee to keep your personal data safe.
Note that the withdrawal of your given consent may imply that you cannot longer use the whole or
part of the Website, Webshop, Social Media Channels and other communication channels.
We also make profiles about you based on preferences, surfing behavior and purchases so that we
may better target our marketing activities.
7.1 Stem parts Europe does its utmost best to process only those personal data which are
necessary to achieve the purposes listed under article 3.
7.2 Your personal data are only processed for as long as needed to achieve the purposes listed
under article 3 of this Privacy Policy or up until such time where you withdraw your consent for
processing them. Note that withdrawal of consent may imply that you can no longer use the whole or
part of the Website, Webshop, Social Media Channels and other communication channels. We will
de-identify your personal data when they are no longer necessary for the purposes outlined in article
3, unless there is:
– an overriding interest of Stem parts Europe, your financial institution, the payment service
provider, or any other third party in keeping your personal data identifiable;
– a legal or regulatory obligation or a judicial or administrative order that prevents us from de-
identifying them.
7.3 You understand that an essential aspect of our marketing efforts pertains to making our
marketing materials more relevant to you. This means that Stem parts Europe builds a profile of you
based on relevant characteristics as outlined in article 2 and then uses this profile to provide you
with communications, promotions, offerings, newsletters and other advertisements about products
and services that may interest you.
7.4 We will take the appropriate technical and organizational measures to keep your personal data
safe from unauthorized access or theft as well as accidental loss, tampering or destruction. Access
by our personnel or third party processors will only be on a need-to-know basis and subject to strict
confidentiality obligations. You understand, however, that safety and security are best efforts
obligations only which can never be guaranteed.
7.5 If you are registered to receive communications, promotions, offerings, newsletters and other
advertisements via e-mail or other person-to-person electronic communications channels, you can
change your preferences for receiving such communications, promotions, offerings, newsletters and
other advertisements by surfing to our preference center. The link to our Preference Center will be
made available in each e-mail or other person-to-person communication we send you.
8. WHAT ARE YOUR RIGHTS UNDER THIS PRIVACY POLICY?
As a data subject, you have several rights vis-à-vis the processing of your personal data. These
rights are the right of access, the right to rectification, the right to withdraw your earlier given
consent, the right to erasure, the right to oppose the processing of personal data and the right that
you receive from us in a structured, commonly used and machine-readable format all personal data
you have provided to us.
If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-
mail to info@stem-parts.com .
8.1 You have the right to request access to all personal data processed by Stem parts Europe
pertaining to you. Stem parts Europe reserves the right to charge an administrative fee for multiple
subsequent requests for access that are clearly submitted for causing nuisance or harm to us.
8.2 You have the right to ask that any personal data pertaining to you that are inaccurate, are
corrected free of charge. If a request for correction is submitted, such request shall be accompanied
of proof of the flawed nature of the data for which correction is asked.
8.3 You have the right to withdraw your earlier given consent for processing your personal data, in
which case clause 6.2 will apply.
8.4 You have the right to request that personal data pertaining to you be deleted if they are no longer
required in light of the purposes outlined in article 3 or if you withdraw your consent for processing
them. However, you need to keep in mind that a request for deletion will be evaluated by Stem parts
Europe against:
– overriding interests of the Stem parts Europe, your financial institution, the payment service
provider or any other third party;
– legal or regulatory obligations or administrative or judicial orders which may contradict such
deletion.
Instead of deletion you can also ask that Stem parts Europe limits the processing of your personal
data if and when (a) you contest the accuracy of that data, (b) the processing is illegitimate or (c) the
data are no longer needed for the purposes listed under article 3 but you need them to defend
yourself in judicial proceedings.
8.5 You have the right to oppose the processing of personal data if you are able to proof that there
are serious and justified reasons connected with his particular circumstances that warrant such
opposition. However, if the intended processing qualifies as direct marketing, you have the right to
oppose such processing free of charge and without justification.
8.6 You have the right to receive from us in a structured, commonly used and machine-readable
format all personal data you have provided to us.
8.7 If you wish to submit a request to exercise one or more of the rights listed above, you can send
an e-mail to info@stem-parts.com . An e-mail requesting to exercise a right shall not be construed as
consent with the processing of your personal data beyond what is required for handling your request.
Such request should clearly state which right you wish to exercise and the reasons for it if such is
required. It should also be dated and signed, and accompanied by a digitally scanned copy of your
valid identity card proving your identity. If you use the contact form, Stem parts Europe may ask you
for your signed confirmation and proof of identity.
Stem parts Europe will promptly inform you of having received this request. If the request proves
valid, we shall honour it as soon as reasonably possible and at the latest thirty (30) days after having
received the request.
If you have any complaint regarding the processing of your personal data by Stem parts Europe, you
may always contact us via the e-mail address listed in this clause 8.7. If you remain unsatisfied with
our response, you are free to file a complaint with the competent data protection authority.