Privacy policy of Marton Koncept d.o.o.
1. Preamble
Marton Koncept d.o.o. (hereinafter referred to as “DINOPARK FUNTANA”) is pleased that you are visiting our website and would like you to feel secure when visiting our website with regard to the protection of your personal data. We take the protection of your personal data very seriously. It goes without saying that we comply with the provisions of the Federal Data Protection Act and the General Data Protection Regulation. We would like to inform you at this point which of your personal data we collect in relation to your visit to our website and for what purposes it is used. Since changes in the law or changes in our business processes may make it necessary to adapt this data protection declaration, we ask you to read it regularly.
2. Scope of application
This data protection declaration applies to the Internet offer of Marton Koncept d.o.o., which can be accessed under the domains “www.dinopark.hr” and the various subdomains (hereinafter referred to as “our website”). 3.
3 Name and address of the responsible person
The responsible party within the meaning of the EU General Data Protection Regulation (hereinafter: DSGVO) and other national data protection laws of the member states as well as other data protection regulations is:
Marton Koncept d.o.o..
Ul. Matije Gupca odv. 1
HR- 49282, Konjščina
Croatia
Phone: +385 (0) 52445327 (during business hours, Mon-Fri 9am-6pm).
E-mail: info@dinopark.hr
3. Name and address of the data protection officer
If you have any other questions or suggestions regarding data protection in our company or regarding this information on data protection, please contact our data protection officer directly:
Marton Koncept d.o.o.
Ul. Matije Gupca odv. 1
HR- 49282, Konjščina
Croatia
4. Principles of data processing
Personal data is any information relating to an identified or identifiable natural person. This includes, for example, information such as your name, age, address, telephone number, date of birth, e-mail address, IP address or user behaviour. Information where we cannot (or can only with a disproportionate effort) establish a link to your person, e.g. by anonymising the information, is not personal data.
The processing of personal data (e.g. collection, retrieval, use, storage or transmission) always requires a legal basis or your consent.
Processed personal data will be deleted as soon as the purpose of the processing has been achieved and there are no longer any legally required retention obligations.
If we process your personal data for the provision of certain offers, we will inform you below about the specific processes, the scope and purpose of the data processing, the legal basis for the processing and the respective storage period.
5. Individual processing operations
5.1 Provision and use of the website
a) Type and scope of data processing
When you call up and use our website, we collect the personal data that your browser automatically transmits to our server. This information is temporarily stored in a so-called log file. When you use our website, we collect the following data, which is technically necessary for us to display our website to you and to ensure its stability and security:
– IP address of the requesting computer
– Date and time of access
– Name and URL of the file accessed
– Website from which access was made (referrer URL)
– Browser used and, if applicable, the operating system of your computer, as well as the name of your access provider.
b) Legal basis
Art. 6 para. 1 lit. f DSGVO serves as the legal basis for the aforementioned data processing. The processing of the aforementioned data is necessary for the provision of a website and thus serves to protect a legitimate interest of our company.
c) Storage period
As soon as the aforementioned data is no longer required to display the website, it is deleted. Further storage may take place in individual cases if this is required by law.
5.2. Newsletter
a) Type and scope of data processing
On our website, you have the option of subscribing to a free newsletter. In order to be able to send you the newsletter regularly, we need the following information from you:
– E-mail – address
Optionally, you can provide further information, such as title and name, postal address, mobile number and date of birth.
When sending our newsletter, we work together with the service provider Klaviyo (125 Summer St, Floor 6, Boston, MA 02111, USA), which processes your data on our behalf and ensures that the e-mails are sent correctly. Your data will not be passed on to third parties in connection with the sending of newsletters.
In this context, personal data may be transferred to countries outside the EU/EEA, in particular to the USA. In order to be able to guarantee adequate protection of your personal data in the event of the transfer of personal data to such so-called third countries, we have concluded so-called EU-US standard contractual clauses with Klaviyo. The USA is assessed by the European Court of Justice as a country with an inadequate level of data protection according to EU standards. Due to the lack of an adequacy decision and without appropriate safeguards, there is a particular risk that your data may be processed by US authorities for control and monitoring purposes, possibly also without any legal remedy. Furthermore, we are in constant exchange with the service provider to ensure the protection of your personal data with any additional measures that may be necessary.
Further information on data protection can be found on the website of the service provider: https://www.klaviyo.com/privacy.
For sending the newsletter, we use the so-called double opt-in procedure, i.e. we will only send you the newsletter if you first confirm your registration via a confirmation e-mail sent to you for this purpose by means of a link contained therein. In this way, we would like to ensure that only you yourself, as the owner of the e-mail address provided, can register for the newsletter. Your confirmation must be sent promptly after receipt of the confirmation e-mail, otherwise your newsletter registration will be automatically deleted from our database.
b) Legal basis
The data processing described above for the purpose of contacting you is carried out in accordance with Art. 6 Para. 1 lit. a DSGVO on the basis of the declaration of consent voluntarily submitted by you.
c) Storage period
Your e-mail address and, optionally, title and name will be stored for as long as you are subscribed to the newsletter. After unsubscribing from the newsletter, your e-mail address and other data will be deleted. You can unsubscribe from the newsletter by using the unsubscribe link which is included in every newsletter. Further storage may take place in individual cases if this is required by law. 6.
6. Will your data be passed on to third parties?
We only pass on your personal data to third parties if:
– you have given your express consent to this in accordance with Art. 6 Para. 1 lit. a DSGVO
– this is legally permissible and necessary for the fulfilment of a contractual relationship with you according to Art. 6 para. 1 lit. b DSGVO
– there is a legal obligation for the transfer according to Art. 6 Para. 1 lit. c DSGVO
– the disclosure is necessary in accordance with Art. 6 Para. 1 lit. f DSGVO for the protection of legitimate business interests, as well as for the assertion, exercise or defence of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data.
Due to legal requirements, we are obliged in certain cases to disclose your personal data to third parties. This is the case, for example, if there is suspicion of a criminal offence or misuse of our website. We are then obliged to pass on your data to the relevant law enforcement authorities. Furthermore, your data will only be stored in our database and on our servers or those of our order processors.
7. Use of cookies
a) Type and scope of data processing
We use cookies on our website. Cookies are small files that are sent by us to the browser of your terminal device when you visit our website and are stored there. Some functions of our website cannot be offered without the use of technically necessary cookies. Other cookies, however, enable us to carry out various analyses. Cookies are, for example, able to recognise the browser you are using when you visit our website again and to transmit various information to us. With the help of cookies, we can, among other things, make our website more user-friendly and effective for you, for example by tracking your use of our website and determining your preferred settings (e.g. country and language settings). If third parties process information via cookies, they collect the information directly via your browser. Cookies do not cause any damage to your end device. They cannot execute any programs and cannot contain viruses.
Different types of cookies are used on our website, the type and function of which are explained in more detail below.
Function 1: Essential cookies
These cookies are required for technical reasons so that you can visit our website and use functions offered by us. This refers, for example, to the following applications: CookieConsent from the provider Beeclever, which stores the user’s consent status.
Furthermore, these cookies contribute to a safe and compliant use of the website.
Function 2: Statistics Cookies
Statistics cookies help website owners understand how visitors interact with websites by collecting and reporting information anonymously.
Function 3: Marketing Cookies
Advertising cookies (third party) allow us to show you different offers that match your interests. Through these cookies, users’ web activity can be tracked over time. You may recognise the cookies on different end devices that you use.
Furthermore, certain cookies allow us to connect to your social networks and share content from our website within your networks.
b) Legal basis
The legal basis for the processing of so-called technically necessary cookies is our legitimate interest in processing personal data according to Art. 6 (1) lit. f DSGVO. For technically unnecessary cookies or so-called third-party cookies, we require your consent. If you have given us your consent to the use of cookies on the basis of a notice issued by us on the website (“cookie banner”), the lawfulness of the use is additionally based on Art. 6 para. 1 lit. a DSGVO. You can revoke this consent at any time by deactivating cookies in your browser settings for the future.
c) Storage period
As soon as the data transmitted to us via the cookies is no longer required to achieve the purposes described above, this information is deleted, in particular when the cookies are deactivated. Further storage may take place in individual cases if this is required by law.
d) Configuration of browser settings
You can manage your cookie settings by using the setting options listed below or by configuring your browser settings.
Most browsers are preset to accept cookies by default. However, you can configure your respective browser so that it only accepts certain cookies or not at all. However, we would like to point out that you may no longer be able to use all the functions of our website if cookies are deactivated by your browser settings on our website. You can also use your browser settings to delete cookies already stored in your browser or to have the storage period displayed. Furthermore, it is possible to set your browser to notify you before cookies are stored. Since the various browsers can differ in their respective functions, we ask you to use the respective help menu of your browser for the configuration options.
If you wish to have a comprehensive overview of all third-party accesses to your internet browser, we recommend that you install specially developed plug-ins for this purpose.
Further information on the cookies used in detail can be found in our cookie content manager. You can also manage your consent there.
8 .Tracking and analysis tools
We use tracking and analysis tools to ensure the continuous optimisation and needs-based design of our website. With the help of tracking measures, it is also possible for us to statistically record the use of our website by visitors and to further develop our online offer for you with the help of the knowledge gained. Based on these interests, the use of the tracking and analysis tools described below is justified pursuant to Art. 6 (1) lit. f DSGVO. If you have given us your consent to the use of cookies on the basis of a notice (“cookie banner”) issued by us on the website, the lawfulness of the use is additionally based on Art. 6 (1) lit. a DSGVO. The following description of the tracking and analysis tools also shows the respective processing purposes and the data processed.
8.1 Google Analytics
a) Type and scope of data processing
This website uses Google Analytics, a web analytics service provided by Google Inc, 1600 Amphitheatre Parkway, Mountainview, CA 94043 USA (“Google”). Google Analytics uses so-called “cookies”, which are text files placed on your computer, to help the website analyse how users use the site.
The information generated by these cookies, for example about the time, place and frequency of your use of this website, is usually transferred to a Google server in the USA and stored there. When using Google Analytics, it cannot be ruled out that the cookies set by Google Analytics may also collect other personal data in addition to the IP address. Please note that Google may transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.
Google will use the information generated by cookies on behalf of the operator of this website for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. According to Google, the IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.
You can generally prevent cookies from being stored by setting your browser software accordingly. However, we would like to point out that in this case you may not be able to use all the functions of this website to their full extent.
It cannot be ruled out that the cookies set by Google Analytics may collect further personal data in addition to the IP address. To prevent information about your use of the website from being collected by Google Analytics and transmitted to Google Analytics, you can download and install a plugin for your browser at the following link: https://tools.google.com/dlpage/gaoptout?hl=de. This plugin prevents information about your visit to the website from being transmitted to Google Analytics. This plugin does not prevent any other analysis.
We would like to point out that you cannot use the browser plugin described above when visiting our website via the browser of a mobile device (smartphone or tablet). By clicking on this link, a so-called opt-out cookie is set in your browser. This prevents information about your visit to the website from being transmitted to Google Analytics. Please note that the opt-out cookie is only valid for this browser and only for this domain. If you delete the cookies in this browser, the opt-out cookie will also be deleted. To continue to prevent collection by Google Analytics, you must click the link again. The use of the opt-out cookie is also possible as an alternative to the plugin above when using the browser on your computer.
In order to ensure the best possible protection of your personal data, the code “anonymizeIp” has been added to Google Analytics on this website. This code has the effect that the last 8 bits of the IP addresses are deleted and your IP address is thus recorded anonymously (so-called IP masking). Your IP address will be shortened and thus made anonymous by Google before it is transmitted within member states of the European Union or in other states that are party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
In the context of the use of Google Analytics, personal data may be transferred to countries outside the EU/EEA, in particular to the USA. In order to be able to guarantee adequate protection of your personal data in the event of personal data being transferred to such so-called third countries, we have concluded so-called EU-US standard contractual clauses with Google. The USA is assessed by the European Court of Justice as a country with an inadequate level of data protection according to EU standards. Due to the lack of an adequacy decision and without appropriate safeguards, there is a particular risk that your data may be processed by US authorities for control and monitoring purposes, possibly also without any legal remedy. Furthermore, we are in constant exchange with Google to ensure the protection of your personal data with any additional measures that may be necessary.
You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.
You can find more information on this at https://tools.google.com/dlpage/gaoptout or at https://policies.google.com/ (general information on Google Analytics and data protection).
b) Legal basis
The legal basis for the use of Google Analytics is your express consent, Art. 6 para. 1 lit. a DSGVO. You can revoke this consent at any time by deactivating the cookies in your browser settings for the future.
c) Storage period
The storage period of the data in Google Analytics is set at 14 months. The cookies set by Google Analytics are valid for up to 2 years.
8.2 Google AdWords
a) Type and scope of data processing
We use the technology “Google AdWords” and specifically the conversion tracking. Google Conversion Tracking is an analysis service provided by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. If you click on an ad placed by Google, a cookie for conversion tracking will be stored on your PC. The cookies are valid for 30 days and are not used for personal identification. If you visit certain pages of our website when the cookie has not yet expired, Google and we will be able to recognise that you have clicked on a particular ad and have been redirected to that page. Google AdWords customers each receive a different cookie. Thus, it is not possible to track cookies across the websites of AdWords customers.
The data collected with the help of the conversion cookie is used to create conversion statistics for AdWords customers who use conversion tracking. The customers thereby learn the number of users who clicked on their ad and were then redirected to a page marked with a conversion tracking tag. However, they do not receive any information that can be used to identify users personally.
If you do not wish to participate in conversion tracking, you can prevent this by making the appropriate setting in your browser, e.g. by generally preventing the installation of cookies. You can also deactivate cookies for conversion tracking by setting your browser so that only cookies from the web address “googleadservices.com” are blocked.
In the context of using Google AdWords, personal data may be transferred to countries outside the EU/EEA, in particular to the USA. In order to be able to guarantee adequate protection of your personal data in the event of personal data being transferred to such so-called third countries, we have concluded so-called EU-US standard contractual clauses with Google. The USA is assessed by the European Court of Justice as a country with an inadequate level of data protection according to EU standards. Due to the lack of an adequacy decision and without appropriate safeguards, there is a particular risk that your data may be processed by US authorities for control and monitoring purposes, possibly also without any legal remedy. Furthermore, we are in constant exchange with Google to ensure the protection of your personal data with any additional measures that may be necessary.
b) Legal basis
The legal basis for the use is your expressly given consent, Art. 6 para. 1 lit. a DSGVO. You can revoke this consent at any time by deactivating cookies in your browser settings for the future.
c) Storage period
The cookies set have a validity of 30 days. The personal data collected with the help of the conversion cookie will be deleted when it is no longer required for the active campaign and there is no other legal obligation to retain it.
8.3 Google Remarketing
a) Type and scope of data processing
We use the “Google Remarketing” technology of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA . Google Remarketing is used to display ads for users who have already visited our websites and online services and are interested in a particular offer. Within the Google advertising network, this enables targeted and interest-based advertisements to be displayed on our site. Google remarketing uses cookies for this analysis. This enables our visitors to be recognised as soon as they call up websites within the Google advertising network. Within the Google advertising network, targeted and interest-based advertisements can thus be displayed that are based on the web pages previously visited by the visitor within the Google advertising network (which also use Google’s remarketing function).
If you do not wish to receive targeted, interest-based advertising, you can deactivate the use of cookies by Google for these purposes via the link: https://www.google.de/settings/ads
In the context of the use of Google Remarketing, personal data may be transferred to countries outside the EU/EEA, in particular to the USA. In order to be able to guarantee adequate protection of your personal data in the event that personal data is transferred to such so-called third countries, we have concluded so-called EU-US standard contractual clauses with Google. The USA is assessed by the European Court of Justice as a country with an inadequate level of data protection according to EU standards. Due to the lack of an adequacy decision and without appropriate safeguards, there is a particular risk that your data may be processed by US authorities for control and monitoring purposes, possibly also without any legal remedy. Furthermore, we are in constant exchange with Google to ensure the protection of your personal data with any additional measures that may be necessary.
b) Legal basis
The legal basis for the use is your expressly given consent, Art. 6 para. 1 lit. a DSGVO. You can revoke this consent at any time by deactivating the cookies in your browser settings for the future.
c) Storage period
The cookies set have a validity of 30 days. The personal data collected with the help of the analysis cookie is deleted when it is no longer required for the active campaign and there is no other legal obligation to retain it.
8.4 Facebook for Business applications
a) Type and scope of data processing
On our website, we use so-called conversion and retargeting tags (formerly “Facebook Analytics”) of the social network Facebook, a service of Facebook Inc, 1601 Willow Road, Menlo Park, California 94025, USA (“Facebook”), for marketing purposes. We use Facebook Pixel to analyse the general use of our website and to track the effectiveness of Facebook advertising (“Conversion”). In addition, we use the Facebook pixel to play you individualised advertising messages based on your interest in our products (“retargeting”). For this purpose, Facebook processes data that the service collects on our website.
If you are a Facebook member and have allowed Facebook to do so via your account’s privacy settings, Facebook may also link the information collected about your visit to us to your member account and use it to target Facebook ads. You can view and change the privacy settings of your Facebook profile at any time.
You can find more information on this in Facebook’s privacy policy: https://www.facebook.com/about/privacy.
b) Legal basis
The legal basis for the use is your expressly given consent, Art. 6 para. 1 lit. a DSGVO. You can revoke this consent at any time by deactivating the cookies in your browser settings for the future.
c) Storage period
The cookies set have a validity of 30 days. The personal data collected with the help of the conversion cookie is deleted when it is no longer required for the active campaign and there is no other legal obligation to retain it.
9 Facebook, Instagram and YouTube
Our websites contain social plugins of the social networks “Facebook” (Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA), “Instagram” (Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA), and “YouTube” (YouTube, 1600 Amphitheater Parkway, Mountain View, California 94043, USA). It is possible that personal data about visitors to the website is also collected via these plugins, transmitted to the respective service and linked to the visitor’s respective service. Marton Koncept d.o.o. itself does not collect any personal data via the social plugins and their use.
To prevent data from being transmitted to the service providers in the USA without the user’s knowledge, we have used passive social media buttons or the so-called Shariff solution on our website. This has the effect that the respective social plugins are initially only integrated as graphics on the website. These graphics contain a link to the website of the corresponding provider of the plugin. Only when you click on one of the graphics will you be redirected to the service of the respective provider. This solution ensures that no personal data is automatically forwarded to the providers of the respective social plugins when you visit our website. If you click on one of the graphics of the social plugins, data may be transmitted to the respective service provider and stored there. If you do not click on any of the graphics, no data transmission takes place between you and the respective provider of the social plugin.
You can find more information about the Shariff solution on the following website: https://www.heise.de/ct/artikel/Shariff-SocialMedia-Buttons-mit-Datenschutz-2467514.html.
After clicking on a social plugin, the respective service provider receives the information that you have visited the corresponding page of our online offer. Please note that you do not need to have a user account with the service in question, nor do you need to already be logged in there. However, if you already have a user account with the relevant service provider and are already logged in to this account while visiting our website, the data collected by the social plugin will be directly assigned to your account. If you do not want the assignment to your profile with the service provider, you must log out of your user account before clicking on one of the social plugins.
Please note that Marton Koncept d.o.o. has no influence on whether and to what extent the respective service providers collect personal data. We are not aware of the scope, purpose and storage periods of the respective data collection. However, we would like to point out that it must be assumed that at least the IP address and device-related information are used and collected via social plugins. It is also possible that the respective service providers use cookies.
In the context of using the plugins, personal data may be transmitted to countries outside the EU/EEA, in particular to the USA. In order to be able to guarantee adequate protection of your personal data in the event of the transfer of personal data to such so-called third countries, we have concluded so-called EU-US standard contractual clauses with the providers. The USA is assessed by the European Court of Justice as a country with an inadequate level of data protection according to EU standards. Due to the lack of an adequacy decision and without appropriate safeguards, there is a particular risk that your data may be processed by US authorities for control and monitoring purposes, possibly also without any legal remedy. Furthermore, we are in constant exchange with the providers to ensure the protection of your personal data with any additional measures that may be necessary.
The scope and purpose of the data collection by the respective service and the further processing and use of your data there can be found in the data protection information directly from the website of the respective service. There you will also receive further information about your corresponding data protection rights and setting options to protect your privacy.
a) Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA
https://www.facebook.com/policy.php
https://www.facebook.com/help/186325668085084
b) Instagram, Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA
https://help.instagram.com/519522125107875/?helpref=hc_fnav&bc[0]=Instagram-Hilfebereich&bc[1]=Privatsph%C3%A4re%20und%20Sicherheit
c) YouTube, 1600 Amphitheater Parkway, Mountain View, California 94043, USA
https://www.youtube.com/t/privacy
10. Hyperlinks to external websites
Our website contains so-called hyperlinks to websites of other providers. When activating these hyperlinks, you will be forwarded from our website directly to the website of the other provider. You will recognise this by the change of URL, among other things. We cannot accept any responsibility for the confidential handling of your data on these third-party websites, as we have no influence on whether these companies comply with data protection regulations. This applies in particular to the social plugins mentioned above, such as “facebook.com”. Please inform yourself about the handling of your personal data by these companies directly on these websites.
11. Data subject rights
The following rights arise from the GDPR for you as a data subject of a processing of personal data:
– According to Art. 15 DSGVO, you can request information about your personal data processed by us. In particular, you can request information about the processing purposes, the categories of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of complaint, the origin of your data if it has not been collected by us, about a transfer to third countries or to international organisations, as well as about the existence of automated decision-making, including profiling, and, if applicable, meaningful information about its details. Automated decision-making including profiling does not take place.
– Pursuant to Art. 16 DSGVO, you may immediately request the correction of inaccurate or the completion of your personal data stored by us.
– Pursuant to Art. 17 DSGVO, you may request the erasure of your personal data stored by us, unless the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the assertion, exercise or defence of legal claims.
– Pursuant to Article 18 of the GDPR, you may request the restriction of the processing of your personal data if you dispute the accuracy of the data, the processing is unlawful, we no longer need the data and you object to their deletion because you need them to assert, exercise or defend legal claims. You also have the right under Article 18 of the GDPR if you have objected to the processing in accordance with Article 21 of the GDPR.
– Pursuant to Art. 20 DSGVO, you may request to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or you may request that it be transferred to another controller.
– Pursuant to Art. 7 (3) DSGVO, you may revoke your consent once given to us at any time. This has the consequence that we may no longer continue the data processing based on this consent for the future.
– According to Art. 77 DSGVO, you have the right to complain to a supervisory authority. As a rule, you can contact the supervisory authority of your usual place of residence, your place of work or our company headquarters for this purpose.
12. Right of objection
When your personal data is processed on the basis of legitimate interests pursuant to Art. 6 (1) lit. f DSGVO, you have the right to object to the processing of your personal data pursuant to Art. 21 DSGVO, insofar as there are grounds for doing so that arise from your particular situation or the objection is directed against direct advertising. In the case of direct advertising, you have a general right of objection, which is implemented by us without specifying a particular situation.
13. Data security and security measures
We undertake to protect your privacy and to treat your personal data confidentially. In order to prevent manipulation, loss or misuse of your data stored with us, we take extensive technical and organisational security precautions, which are regularly reviewed and adapted to technological progress. These include, among other things, the use of recognised encryption procedures (SSL or TLS). However, we would like to point out that, due to the structure of the Internet, it is possible that the rules of data protection and the above-mentioned security measures are not observed by other persons or institutions not within our sphere of responsibility. In particular, data disclosed unencrypted – e.g. if this is done by e-mail – can be read by third parties. We have no technical influence on this. It is the user’s responsibility to protect the data he or she provides against misuse by encrypting it or in any other way.