PRIVACY NOTICE
1. purpose of this privacy notice
1.1 This privacy notice aims to give you information on how PIONIRSKI DOM collects and processes your personal data through your use of this website or via visit, phone call, email or other communication.
1.2 Minors, younger than 16 years of age should not provide any kind of personal data on website or without permission (approval or consent) of the person with parental responsibility (one of the parents or legal guardian). PIONIRSKI DOM will not consciously collect personal data from persons, for which he knows or are there reasonable circumstances for conclusion, that are minors (younger than 16 years of age), or use in any kind of way or reveal without authorization of the person with parental responsibility.
1.3 Stated does not affect rules of general contractual law member states, like rules on validity, design or effect of the contract regarding minor.
1.4 PIONIRSKI DOM will conduct appropriate verification using available technology if the person with parental responsibility gave his approval or consent.
2. controller
2.1 PIONIRSKI DOM, d.o.o. is the controller and responsible for your personal data (collectively referred to as ”PIONIRSKI DOM”, “we”, “us” or “our” in this privacy notice).
2.2 We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, contact the data privacy manager using the details set out below.
3. contact details
3.1 Our full details are:
Full name of legal entity: PIONIRSKI DOM - Center za kulturo mladih
Name of data privacy manager: Viktorija Potočnik
Email address: info@pionirski-dom.si
Postal address: Vilharjeva 11, SI-1000 Ljubljana, Slovenia
3.2 You have the right to make a complaint at any time to the Information Commissioner’s Office (IP), the SLO supervisory authority for data protection issues (www.ip-rs.si). We would, however, appreciate the chance to deal with your concerns before you approach the IP so contact us in the first instance.
4. changes to the privacy notice and your duty to inform us of changes
4.1 This version was last updated on 25th May 2018.
4.2 It is important that the personal data we hold about you is accurate and current. Keep us informed if your personal data changes during your relationship with us.
5. third-party links
5.1 This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit
6. the data we collect about you
6.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
6.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
(a) Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].
(b) Contact Data includes [billing address, delivery address, email address and telephone numbers].
(c) Financial Data includes [bank account and payment card details].
(d) Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us].
(e) Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website].
(f) Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses].
(g) Usage Data includes [information about how you use our website, products and services].
(h) Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
6.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
6.4 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
7. if you fail to provide personal data
7.1 Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
8. how is your personal data collected?
8.1 We use different methods to collect data from and about you including through:
(a) Direct interactions. You may give us your [Identity, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
(i) apply for our products or services;
(ii) create an account on our website;
(iii) subscribe to our service or publications;
(iv) request marketing to be sent to you;
(v) enter a competition, promotion or survey; or
(vi) give us some feedback.
(b) Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. [We may also receive Technical Data about you if you visit other websites employing our cookies.] See our Cookie Policy for further details.
(c) Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.
(d) Technical Data from the following parties:
(i) analytics providers;
(ii) advertising networks; and
(iii) search information providers.
8.2 Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
8.3 Identity and Contact Data from data brokers or aggregators.
8.4 Identity and Contact Data from publicly availably sources.
9. how we use your personal data?
9.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
(a) Where we need to perform the contract we are about to enter into or have entered into with you.
(b) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
(c) Where we need to comply with a legal or regulatory obligation.
9.2 Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.
10. purposes for which we will use your personal data
10.1 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
10.2 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To register you as a new customer |
(a) Identity (b) Contact |
Performance of a contract with you |
|
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
|
To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
11. marketing
11.1 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
12. promotional offers from us
12.1 We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
12.2 You will receive marketing communications from us if you have requested information from us or purchased [goods or services] from us [or if you provided us with your details when you entered a competition or registered for a promotion] and, in each case, you have not opted out of receiving that marketing.
13. third-party marketing
13.1 We will get your express opt-in consent before we share your personal data with any company outside the PIONIRSKI DOM group of companies for marketing purposes.
14. opting out
14.1 You can ask us to stop sending you marketing messages at any time by Contacting us.
15. cookies
15.1 You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, see Cookie Policy.
16. change of purpose
16.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, Contact us.
16.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
16.3 Note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
17. disclosures of your personal data
17.1 We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
17.2 Our Internal Third Parties are: [•]
17.3 Our External Third Parties are:
(a) Mailing provider for sending enews
(b) Hosting provider
(c) Web development company
17.4 Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
17.5 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
18. international transfers
18.1 We do not transfer your personal data outside the European Economic Area (EEA).
19. data security
19.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
19.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
20. how long will you use my personal data for?
20.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or tax requirements.
20.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
21. your legal rights
21.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data:
(a) Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(b) Request correction of the your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(d) Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
(e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(f) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
(g) Withdraw consent at any time where we are relying on consent to process your personal data.
21.2 If you wish to exercise any of the rights set out above, Contact us.
22. no fee usually required
22.1 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
23. what we may need from you
23.1 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
24. time limit to respond
24.1 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you
