PRIVACY POLICY

Last Updated: June 15, 2025

INTRODUCTION

This Privacy Policy explains how your personal information is collected, used, and disclosed by Byblos V d.o.o. and ShiftOneZero d.o.o. (collectively referred to as "we," "our," or "us") when you access or use the Byblos application on the clubin platform (the "App").

We respect your privacy and are committed to protecting your personal information. Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it.

WHO WE ARE

Both entities are data controllers for the purposes of applicable data protection laws and are jointly responsible for the collection and processing of your personal information through the App.

INFORMATION WE COLLECT

We collect several types of information from and about users of our App, including:

Personal Information

Usage Information

Technical Information

HOW WE COLLECT YOUR INFORMATION

We collect information directly from you when you:

We also collect information automatically when you:

HOW WE USE YOUR INFORMATION

We use the information we collect about you for various purposes, including to:

LEGAL BASIS FOR PROCESSING YOUR INFORMATION

We process your personal information based on:

DATA SHARING AND DISCLOSURE

Joint Use by Byblos and ShiftOneZero d.o.o.

Both Byblos and ShiftOneZero d.o.o. have access to and can use the data collected through the App to provide services, improve user experience, and for marketing purposes. We maintain appropriate safeguards to ensure the security of your data.

Third-Party Service Providers

We may share your information with third-party service providers who perform services on our behalf, such as:

These service providers are contractually obligated to use your information only for the purposes of providing services to us and in accordance with this Privacy Policy.

Important Limitations on Data Sharing

We do not sell, rent, or otherwise share personal information that directly identifies you with third parties for their own marketing purposes without your consent.

Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

Business Transfers

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you of any change in ownership or uses of your information.

With Your Consent

We may share your information with third parties when you have given us your consent to do so.

DATA RETENTION

We will retain your personal information only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider:

DATA SECURITY

We have implemented appropriate technical and organizational measures to protect the security of your personal information. However, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure.

YOUR RIGHTS

Depending on your location, you may have certain rights regarding your personal information, including:

To exercise any of these rights, please contact us using the contact information provided below.

ACCOUNT DELETION

You have the right to delete your account at any time. When you delete your account through the in-app "Delete Account" feature:

For more information about account deletion, please see our Account Deletion page within the App.

CHILDREN'S PRIVACY

The App is not intended for individuals under the legal drinking age (18 years in Croatia). We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us, and we will take steps to delete such information.

INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in countries other than the country in which you reside. These countries may have different data protection laws than your country of residence.

We have implemented appropriate safeguards to ensure that your personal information remains protected in accordance with this Privacy Policy when transferred internationally.

CHANGES TO OUR PRIVACY POLICY

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Last Updated" date, and the updated version will be effective as soon as it is accessible. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

CONTACT US

If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us at:

ShiftOneZero d.o.o.
Kobiljačka cesta 120, 10361 Sesvetski Kraljevec
[email protected]

Byblos V d.o.o.
Zelena laguna 1, 52440 Poreč - Parenzo
[email protected]

SUPERVISORY AUTHORITY

If you are located in the European Economic Area and believe we are processing your personal information unlawfully, you have the right to lodge a complaint with your local data protection supervisory authority. In Croatia, this is the Croatian Personal Data Protection Agency (AZOP).