INFORMATION ON LOYALTY PROGRAM:

The following rules have been in force since 1 June 2018, except the rules that are explicitly stated to be applicable from 1 January 2023

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The principal instrument of our Loyalty Program is the Golden Tower Card. In order to become a user of GOLDEN TOWER CARD, you need to fill out the application form at our Info Point (4th floor of Tower Center Rijeka) . After submitting a properly filled out form, users get issued their GOLDEN TOWER card at Info Point, which they can start using in shopping right away. It is required for the card user to be an adult.

The GOLDEN TOWER PROGRAM functions in such a way that with each purchase made above EUR 10,00 the points get transferred to the GOLDEN TOWER CARD by means of a corresponding mobile device, in stores that are part of the Loyalty Program, which are all marked with labels placed at the store entrance and at their cash registers. For every 1,00 EUR spent, 1 point is awarded to the user account.

Starting from 1 January 2023, the new points system will be applied in such a way that each purchase of EUR 10.00 or higher will earn points on the GOLDEN TOWER CARD via an applicable mobile device in stores participating in the Loyalty Programme, which are marked with stickers on entrances to stores and casinos. For every EUR 1.00 spent, the user will receive 1 point, with a minimum of 10 points.

PERSONAL DATA PROCESSING WITHIN THE GOLDEN TOWER PROGRAM

The personal data processing in Golden Tower Program is based on your signed Agreement on processing the personal data, which you provide along with the application form.

Personal Data Controller: The Personal Data Controller is Tower Center Rijeka Ltd., Rijeka, Strossmayerova 16, OIB 84184387126 - the manager of the shopping mall Tower Center Rijeka. Contact phone: 00385(51) 403 815; Email: info@tower-center-rijeka.hr (TCR).

Personal information collected by TCR: For the participation in the Golden Tower Card, the following minimum information is collected: name, surname and date of birth (mandatory data) and purchase information in the Tower Center Rijeka stores for which points are awarded on the Golden Tower card shop, purchase time, purchase amount and number of collected points). To participate in marketing campaigns created for users of the Golden Tower Card program, TCR collects the home address (street and house number, city), email address and phone / mobile phone number. All of the above data is stored under the number of the card in the user account. To send a newsletter, the TCR collects the email address to allow you to receive the newsletter.

Providing personal data from your privates is essential for accessing and participating in the Golden Tower Card and for receiving promotional promotional news and newsletters.

Personal Data Protection Officer: The contact info of our Data Protection Officer is published on the TCR’s website: Information.
Contact e-mail: tower.center.sluzbenik.zop@kvadratiupravljanje.hr

The purpose of data processing within the Golden Tower Card program: The data is collected: a) for the purpose of user identification and enabling keeping the record of points added to a Golden Tower Card, obtained by purchasing; for obtaining the benefits provided through the Golden Tower Card program and profiling consumer habits within Tower Center Rijeka regarding the store, amount and time of purchase; for adjusting the content and the type of promotional messages and notifications on the benefits, b) in a case of promotional purposes - for sending the promotional material, marketing notifications on the benefits and notifications on carrying out prize giveaways and drawings; for sending other promotional notifications related to Tower Center Rijeka; for carrying out the surveys and research via e-mail, SMS, promotional calls or other electronic means of communication and by physical mail - if the consent was given for receiving the promotional material.

The purpose of processing for sending newsletters: The email address is collected for the purpose of sending newsletter material.

The procedure of data processing: Personal data gets processed by the outsourced partners of TCR who are responsible for managing the Program. Data is protected by at least the following measures: the access is enabled strictly to authorized persons, with a passcode and a record of the access, with the application of IT safety measures against any unwanted access and for protection against the loss of data: backup, firewall, SSL certificate. The processing can include profiling, but not the automated decision making. This kind of processing is made automatically by rule in order to send the targeted promotional material and other marketing campaigns, and only for the purchases for which the members of our Loyalty Program willingly register their points to their user account. Personal data will not be disclosed to third-party recipients, unless such transfer is justified by the regulation. The collected data is not provided outside the European Union.

The legal basis of data processing: Personal data gets processed based on the agreement of the Golden Tower Card user. The consent is valid until revoked or 3 years from the last usage date of the Golden Tower Card, after which all the private information gets erased.

The period of storage of personal data for the purpose of Golden Tower Card program membership: Personal data gets collected and remains stored throughout the whole period during which the user participates in the Golden Tower Card program. The data gets erased immediately after:

a) a user’s request for exclusion from the Golden Tower Card program;
b) the Golden Tower Card program gets canceled by TCR;
c) the consent on data processing gets revoked;
d) the consent ceases to be valid.

The consent can be revoked either in full or partly. Partially regarding the data needed for participating in Golden Tower Card program, for participating in marketing programs created for the Golden Tower Card users and for sending newsletters. The consent can be revoked by sending the written annulment by mail to TCR’s address or by email to info@tower-center-rijeka.hr or tower.center.sluzbenik.zop@kvadratiupravljanje.hr. Once the consent has been revoked, TCR will no longer process the private data for which the agreement has not been given and will erase it. The recall of the consent is not affecting the legality of data processing prior to the annulment.

USER RIGHTS

The right to access personal data: The user has a right to access their personal data and to get a confirmation from TCR weather the data that refers to them is being processed, as well as the information on the purpose of data processing, categories of data that are being processed, recipients, storage period, their rights as examinee in terms of correction, erasing or limiting the processing itself, their right to lodge a complaint with a supervisory authority, and all the other relevant information relating the data processing. Unless the user requests otherwise, this information is given in a digital form via e-mail.

The right of data correction: The user has a right to request the correction of inaccurate data if the data refers to them.

The right to be forgotten: The user has a right to obtain from TCR the deletion of personal data that refers to them and, depending on the data that was requested to delete, some or all of the membership benefits might get terminated (e.g. receiving the loyalty points as our Loyalty Program member, participating in the marketing campaigns created for Golden Tower Card users, or receiving our newsletters).

The right to restrict processing: The user has a right to obtain from TCR the restriction of data processing if the data refers to them.

The right to lodge a complaint: At all times, the user has a right to object to processing their personal data, especially in a case of promotional purposes (e.g. for sending promotional material, marketing announcements on the related benefits and notices on prize giveaways and drawings, for sending other marketing information related to Tower Center Rijeka, for carrying out the surveys and research via e-mail, SMS, promotional phone calls or other electronic means of communication and by sending the content via mail). If user objects to it, their personal information will no longer be processed for these purposes.

The right to data portability: The user has a right to receive all the personal data that refers to them and transfer it over to some other processing manager. If it is technically doable, the transfer will be done by automated means.

These rights are exercised by request in writing to either TCR’s or Personal Data Protection Officer’s e-mail address.

The user has a right to lodge a complaint on personal data processing to the supervisory authority: Personal Data Protection Agency, Martićeva ulica 14, HR - 10 000 Zagreb, Tel. 00385 (0)1 4609-000, Fax. 00385 (0)1 4609-099, E-mail: azop@azop.hr, Web: www.azop.hr.

USING EARNED POINTS WHILE SHOPPING

Earned points may be used to reduce the receipt total while shopping in stores participating in the programme. To do this, you need to earn 500 points and find the information counter where employees will issue you a coupon for 500 points, which will expire in 30 days. The 500 point coupon is equivalent to EUR 5 while shopping in stores participating in the programme.

Starting on 1 January 2023, the value of 100 newly earned points (earned on and after 1 January 2023) will be equivalent to EUR 1.00.

The available coupons for the reduction of the receipt total (from 1 January 2023) will be issued in the following amounts:

• 500 points - EUR 5.00 coupon
• 1000 points - EUR 10.00 coupon
• 1500 points - EUR 15.00 coupon
• 2000 points - EUR 20.00 coupon.

You can convert your points to coupons also by using the totem located on the 2nd floor. You can get your coupon by following a few easy steps:

1. Use the totem's QR code reader to scan either your Card’s QR code or the code on your Tower App screen
2. Check the balance of the collected points
3. Tap on the amount of coupon you want to print and use
4. Take the coupon with you and start shopping :)

The points balance on a GOLDEN TOWER CARD can be checked at any moment, on the Center’s website www.tower-center-rijeka.hr, (on the Home page), by entering the card ID number in the provided field. Any deviation from the real balance is possible within 48 hours from the last transaction made.

STORES THAT ARE PART OF THE GOLDEN TOWER LOYALTY PROGRAM ARE:

Store	Floor
Müller	5
VetPet boutique	4
Triumph	4
SOPHOSlab	4
Posteljina.hr	4
Mobia	4
Magic Baby	4
Info pult Tower	4
Hoću knjigu	4
Ghetaldus optika	4
DOTA	4
dm	4
CCC	4
U.S.POLO ASSN	3
Tvornica Zdrave Hrane	3
Tommy Hilfiger	3
Tom Tailor	3
The Core	3
Sport Vision	3
Skechers	3
S.Oliver	3
Prahir Fine Jewellery/De’llure	3
Polleo Sport	3
Pelgolo	3
Os Superbrands	3
Napapijri	3
Lisca	3
L'Occitane en Provence	3
Kiko Milano	3
Kerver	3
Kerver	3
Intimissimi	3
Heta 1892	3
Hespo	3
Galileo	3
Froddo shop	3
Five Star Fashion	3
Europa 92	3
Douglas	3
Cubus	3
Calzedonia	3
Baby Center	3
A1 Mobilcentar	3
Yamamay	2
Ulla Popken	2
Tezenis	2
Terranova	2
Sally Atelier	2
Replay	2
Pandora	2
Mass	2
IZIPIZI	2
Interoptika	2
Guess Accessories	2
Galeb	2
Furla Corner	2
Fashion&Friends	2
Elipso	2
Ciciban	2
BOSS STORE	2
Argentum	2
Alpina	2
Aldo	2
Kopitarna	1
Intersport	1
Farmacia	1
Buzz	1

The rules of Golden Tower Card Program

1. Issuance and the ownership of the card

1. Golden Tower Card gets issued within the Golden Tower Card Loyalty Program (in the following text - Program). The Program is carried out and regulated by this Program Policy (in the following text - Policy).
2. The issuer of the Golden Tower Card (in the following text - Card) is Tower Center Rijeka Ltd., Rijeka, Strossmayerova 16, OIB 84184387126 (in the following text - TCR). The Card is in ownership of TCR. The manager of the Program is M2 upravljanje plus Ltd., from Zagreb, Heinzelova 33, OIB 18363637837.
3. Any adult who submits a valid request for issuing a Card can become a Card owner, in accordance with these Policy directives. The Card gets issued free of charge.
4. By taking the Card, user agrees with this Policy. The Card is issued at the request of the user, given by submitting a filled out and signed application form. The form is available at Info point of Tower Center Rijeka. The filled out and signed application form can be submitted either to the same Info point or via e-mail address listed on the Center’s website. . The filled out and signed application form can be submitted either to the same Info point or via e-mail address listed on the Center’s website.
5. Right after submitting the application form, once all the required data is entered into the electronic database, a Card is handed over to a user. Each Card is individualized with a unique ID number that is linked within the database to the user of the Card and to their account on which their loyalty points get registered.
6. TCR reserves the right to withdraw the Card at any time, to modify or to entirely revoke the elements of the Program. The user will be adequately notified about these changes.

2. Usage

1. The Card is not transferable and it does not represent a means of payment. The Card does not oblige the user to purchase. The Card can be used only by the person to whom it was issued, or by up to two other persons formerly specified by the user. Whenever the Card is being used, the seller is authorized to condition the use of the Card by first showing a personal identity card of the bearer.
2. The user has a right to collect points by handing over the Card before the cashier concludes the transaction and gives a receipt to the customer, at the stores within Tower Center Rijeka that participate in our Loyalty Program and have the Program sign highlighted at the entrance. The points get registered to the user account upon making a payment.
3. TCR and M2 upravljanje plus Ltd. are not subject to any liability for non-participation or withdrawal of any individual seller or store that is participating in the Program.
4. For the first 100,00 kunas spent per account, the user is entitled to 1 point registered within the Loyalty Program. For each additional HRK 100,00 spent per account, the user again gets awarded 1 point. All the collected points add up.
5. An individual seller may award more points than envisioned in the last paragraph, on which the visitors will be informed by the seller, in the manner which they see as most appropriate. TCR and M2 upravljanje plus Ltd. are not subject to any liability for the lack of information nor for the alterations made in the terms of point awarding system defined by each individual seller.
6. The collected points are valid until 28th of February each year. Any unused points collected prior to that date will automatically be erased from the user account on 28th of February each year. The first deletion will be put into effect on 28th of February 2013.
7. The first step to use the collected points is to ask for the issuance of a 25-points coupon at the Info point, which can immediately be used and validated at every store that is part of the Loyalty Program. The value of a 25-points coupon equals a value of HRK 25,00 and so the receipt issued by the cashier gets reduced for that amount. The issued coupon is valid for 30 days from the date of issuance.
8. When using the points, the user hands over the Card and the 25-points coupon to the cashier who validates the coupon via the app on the mobile device, after which the final amount on the receipt gets reduced by 25 kunas and the usage of points is recorded on the related user account. The seller is authorized to request the personal identification card upon using the Loyalty Card.
9. The account balance can be checked by the user at any moment either on the Center’s website www.tower-center-rijeka.hr (on the Home page), at our Info point within Tower Center Rijeka (at the 4th floor) or by calling 00385(51) 403 815 during the Center’s working hours.
10. The points can not be exchanged for money.
11. The points are not transferable between cards nor users. The points can be given to another person as a gift.

3. Lost or stolen cards

1. In case of loss or theft of the Card, the user can request to block the Card and to issue a new one. By receiving a new Card, a new user account will be created as well. All of the previously recorded points related to the Card that is being replaced will then be registered to a newly opened account. When applying for a new Card, user may be required to show a personal identification card.
2. The user can request to block the Card at the Info point within Tower Center Rijeka and via phone number 00385(51) 403 815. Upon requesting the re-issuing, in order to identify the user, some questions can be asked about the data provided in the application form.
3. The user can request the issuance of a new Card after the loss or theft of their Card, at the Info point of Tower Center Rijeka.
4. TCR, M2 upravljanje plus Ltd. and the sellers operating within the Center are not subject to any liability for the unauthorized usage of points made by persons who were not stated in the application form prior to the request made by the user for blocking the lost or stolen Card, nor within one hour after that request was made.

4. Cancellation

1. The user has a right to terminate the use of the Card at any time via written request. The cancellation is valid from the moment when TCR receives notice of termination. Cancellations can be made by written request at the Info point (at Tower Center Rijeka) and by writing an email to info@tower-center-rijeka.hr. Upon receiving the cancellation the user account gets terminated, all the collected points get erased and the Card can no longer be used. Once terminated, the Card and the points related to the canceled account can no longer be renewed.
2. TCR has a right to terminate the use of the Card for a user at any moment and with no explanation, along with the revocation of the Card validity. TCR has a right to terminate the Program at any time. The Program can be terminated with a 14-day cancellation period starting from a date of publication of the notice on termination. The notice of termination would be published on the website www.tower-center-rijeka.hr.
3. In case of the Card cancellation for an individual user or the cancellation of the Program in full, the points can be used within the cancellation period. Once the cancellation period expires, the points become void and there is no further obligation towards the user of the Card, neither on the part of TCR nor on the part of the sellers who participated in the Program.

5. Use and protection of personal data

1. The user of the Card agrees that TCR as the owner and issuer of the Card, M2 upravljanje plus Ltd., from Zagreb, Heinzelova 33, as the manager of the Tower Center Rijeka shopping mall, and Exevio Ltd., from Rijeka, Vukovarska 6, as the data processing company, can all collect, process and transfer to each other the user’s personal data provided in the application form and the data on the amount purchased and the stores in which the purchase was made, within Tower Center Rijeka, while using the Card. According to the explicit authorization given by TCR as the Card issuer, the head of the personal data collection is M2 upravljanje plus Ltd.
2. The user of the Card agrees that their personal data can be transferred to Italy, as the country of the founder’s (M2 upravljanje plus Ltd.) headquarter.
3. The purpose of collecting, processing and transferring the personal data of the user is to enable keeping a record of the points in order to realize the benefits envisioned by this Policy.
4. The personal data of the user are collected, processed and used in accordance with the Personal Data Protection Act. The user is aware that they have a right to revoke this statement of consent at any time, in which case they cease to be the Card user and can no longer use the intended benefits. Such a revocation has the effect of the Card cancellation made by the user.
5. The user data can also be used for promotional purposes - to send the promotional material, promotional notices and notifications on conducting the prize giveaways and drawings, all under condition that the user has not explicitly stated in their application form that they do not agree to have their personal data used for such purposes.
6. The user is aware that, when filling in the application form and at any later moment, they have a right to refuse the processing of their personal data for promotional purposes, in which case their personal data will no longer be used for that purpose.
7. The personal data will no longer be processed after: a) the Card cancellation made by the user; b) the Card termination made by TCR; c) termination of the Card validity and closing the account by any basis; d) termination of the Program.

6. Notices

1. All general announcements related to the Program will be published on the website www.tower-center-rijeka.hr. Delivering these notices to all the users of the Card will be regarded as orderly conducted on the day of publishing.
2. In addition to delivering the notices in a manner specified in the previous paragraph and for the reports that refer to an individual user, the notices will be communicated via email and/or regular mail, to the last registered address of the user, and/or via SMS.
3. The current points balance of a GOLDEN TOWER CARD can be checked by the user in person at the Info point of Tower Center Rijeka or at the website www.tower-center-rijeka.hr (on the Home page).

7. Changes to the Program Policy

1. TCR is authorized to modify the content of this Policy at any time and without the explicit consent of users, except for the rules that relate to the protection and use of personal data.
2. The changes to the Policy go into effect upon the expiration of 14-days period, starting from the date of publication.

8. Governing law and jurisdiction

1. Any dispute that may arise from the application of this Policy and from the participation in the Program in general, is subject to the provisions of Croatian law and local jurisdiction of the relevant Court in Rijeka.