Statement on Personal Data Protection

Date of Last Amendment: 01/07/2025

1. Terms and Introduction

• Fairy Latina, Sole proprietorship, owned by Lauro Portada, OIB: 74619539427, Paških rektora 8, 23250 Pag, Republic of Croatia (hereinafter: “the Trade”),
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• Statement on Personal Data Protection (hereinafter: “the Statement”),
• The website www.city-unlock.com and associated pages (hereinafter: “the Website”),
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• Website visitors, buyers, and users of the Website in every sense, especially in terms of using the Website for information and/or purchasing digital products on the Website (hereinafter: “the Buyers”).

The Trade values its Buyers and is committed to the security of their personal data.

With this Statement on Personal Data Protection, the Trade expresses its dedication to protecting the privacy of Buyers, in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Law on the Implementation of the General Data Protection Regulation (Official Gazette 42/2018).

This Statement transparently presents how the Trade collects, uses, processes, and protects the personal data of Buyers when they use the Website or purchase a digital product through the Website.

Use of the Website is permitted exclusively to persons over the age of 16. By using the Website and accepting the Terms of Use and this Statement on Personal Data Protection, Buyers are considered to confirm that they are over 16 years of age. Otherwise, Buyers are kindly requested to immediately stop using the Website and all associated digital products.

1. Personal Data and Processing

Personal data includes all information that can be associated with Buyers as individuals – such as name, email address, or IP address. The processing of this data encompasses all actions we take to enable the use of our digital products – including storing data, sending activation codes, and generating invoices. All data is processed in accordance with Regulation (EU) 2016/679 (GDPR) and the applicable laws of the Republic of Croatia.

The Trade collects and processes the data of its Buyers exclusively for the purpose of enabling the delivery of purchased digital products, ensuring the functionality of the system, and improving the user experience during the purchase and use of the content.

1. Data Collected When Visiting the Website

When visiting the website www.city-unlock.com, we collect basic technical data about the Buyers’ device — IP address, time zone, operating system, browser type, and information via cookies.

We use this information to:

• reduce the risk of abuse and fraud attempts

• understand Buyer behavior and improve system functionality

• resolve technical issues and errors

• analyze website traffic and optimize content

How we collect data:

• through cookies, web beacons, tags, and pixels used by the Trade, as well as third-party tools such as Google Analytics, Facebook Pixel, Hotjar, and similar

• through browser headers, e.g., data about IP address and device type

• through internal logs that record basic user actions on our pages

How long we store the data:

Data is stored permanently, exclusively for statistical and technical purposes, without linking it to the identity of the Buyers.

Who we share it with:

We share it with trusted analytics services (e.g., Google Analytics, Meta/Facebook, Hotjar) for the purpose of analyzing Buyer behavior and optimizing the experience. We do not share Buyers’ names, surnames, email addresses, or other personal data.

Why we process this data:

We process the listed data in order to resolve issues and inquiries from Buyers as quickly as possible and to provide prompt responses to their requests.

1. Personal Data During Purchase

During the purchase of a digital product, we collect the Buyer’s email address solely for the purpose of delivering the activation code. This data is not used for analytics or any marketing purposes.

Payment data:

Payments are processed via Stripe, a globally recognized and secure payment processor. The Trade does not store card data; it is entered directly into Stripe’s secure interface via an SSL connection. The Trade has access only to the last four digits of the card number and the cardholder’s name for identification in case of inquiries or payment issues.

Storage duration:

The Buyer’s email address and transaction-related data are stored for 12 years, solely for fiscal and legal record-keeping purposes.

Data sharing:

We share Buyer data only with:

• Stripe – for payment processing,

• state authorities – if required by law (e.g., for fiscalization, audits, or inspections),

• accounting service – which processes invoices on our behalf, if applicable.

1. Sharing Buyer Data and Purpose

Buyer data is never sold or given to third parties for marketing purposes. All data we collect is used solely for completing the purchase, issuing the invoice, and sending the activation code for the digital product.

Data is accessible only to:

• authorized personnel of the Trade who manage orders, issue invoices, and provide support,

• Stripe – as an external payment processor, for secure transaction execution,

• accounting service – for processing and storing invoices in accordance with the law,

• state authorities – if requested, based on legal authority (e.g., tax inspection).

All data is stored on protected servers with restricted access and is used solely for the purposes stated above.

1. Use of Cookies

To ensure proper website functionality and improve the Buyer’s user experience, the Trade and the Website use cookies.

We use two types of cookies:

• Essential cookies – necessary for the technical operation of the website, such as remembering login sessions and activation codes.

• Analytical cookies – anonymously track website usage, help us understand what interests Buyers, and allow us to continuously improve content and features. For this purpose, we use tools such as Google Analytics and Facebook Pixel.

Buyers can delete or block cookies at any time through their browser settings. More information about cookies and how to manage them can be found at www.aboutcookies.org.uk.

1. Buyer Rights

In accordance with the General Data Protection Regulation (GDPR), Buyers have the right to:

• Access data – request information on whether we process their personal data and access that data.
• Rectification – request correction or update of data that is incorrect, incomplete, or outdated.
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• Erasure (“right to be forgotten”) – request deletion of their data if it is no longer necessary, if consent has been withdrawn, or if the data has been processed unlawfully. Data will not be deleted if we are legally or contractually required to retain it.
• Restriction of processing – request that data processing be limited, e.g., if the accuracy or lawfulness of the processing is contested.
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• Data portability – obtain their personal data in a structured, commonly used, and machine-readable format or request the transfer to another controller, where technically feasible.
• Object – object at any time to the processing of their data, especially in the case of direct marketing.
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• Withdraw consent – if the processing is based on the Buyer’s consent, they may withdraw it at any time, without affecting the lawfulness of the processing carried out before the withdrawal.

To exercise any of the above rights, Buyers may contact us at support@city-unlock.com. We will respond within 30 days at the latest.

If Buyers believe that we have violated their rights, they have the right to file a complaint with the Croatian Personal Data Protection Agency (AZOP): www.azop.hr.

1. Information via Newsletter

We send newsletters solely based on consent, which Buyers can withdraw at any time.

If Buyers have given us their consent to receive the newsletter, from time to time (never more than once a week), we will send short updates about new tours, games, promotions, interesting facts, and benefits that may be useful or interesting.

Our goal is to send only quality and relevant content – without spam.

Buyers can unsubscribe at any time by clicking the link at the bottom of each newsletter.

1. Data Storage and Locations Outside Europe

Most Buyer data is stored on secure servers within the European Union through our hosting partner.

Some data collected via external services (such as Google Analytics, Gmail, Mailchimp, and others) may be stored on servers outside the EU, depending on their physical locations. All such services we use are fully compliant with European data protection laws (GDPR).

1. Security and Protection of Buyer Data

Buyers’ personal data is stored with the application of modern security measures – we regularly perform backups, access to databases is strictly limited, and all systems are protected according to the latest security standards.

However, no online platform is entirely immune to unforeseen situations such as technical malfunctions or hacker attacks. Therefore, we recommend that Buyers also protect their device and browser as best as possible.

In the event of any security incident involving Buyer data – we will immediately notify Buyers so they can take the necessary steps.

1. Contact and Exercising Buyer Rights

If Buyers have any questions, requests, or complaints regarding their personal data – they may freely contact us via email at: info@city-unlock.com

For security reasons, when exercising rights (e.g., requests for deletion, modification, or access to data), we will request identification to ensure the data is being modified by its rightful owner.

If Buyers believe that the processing of their data is not in accordance with the General Data Protection Regulation (GDPR) and we are unable to resolve the issue directly, they have the right to contact the competent authority: Croatian Personal Data Protection Agency (AZOP), Martićeva 14, 10000 Zagreb, www.azop.hr, +385 1 4609 000.

1. Updates to This Statement

This Privacy Statement may be updated from time to time. All significant changes will be published on our website.