The protection of personal data is the responsibility of SPIRO d.o.o., Velika pot 24, 5250 Solkan, identification number: 3851028000, VAT nr. ID SI84378000 (hereinafter: SPIRO).
The present text is intended to inform you about the SPIRO policy regarding the protection of the personal data of our clients and to inform them of their rights regarding the protection of personal data which they have entrusted to us and the purposes of their use.
SPIRO stores and protects personal information so that any unauthorized disclosure of information to unauthorized persons does not occur. At SPIRO, we undertake not to provide, update or sell personal information to a third party without prior notice and obtaining your consent (except as otherwise provided by applicable law), without appropriate appropriate safeguards, and to process personal data only within the framework of legal legal bases and chosen purposes.
SPIRO is not responsible for any misuse or disclosure of an individual’s personal information as a result of an individual’s misconduct.
SPIRO processes personal information in the course of its business through https://spiroteh.com/
Personal data controller:
SPIRO Proizvodnja, trgovina in storitve d.o.o.,
Velika pot 24,
Registration number: 3851028000,
VAT nr ID: SI84378000
(hereinafter referred to as SPIRO)
Data processors (contract controllers): When providing SPIRO services, your personal data may also be processed by communication channel providers (eg postal service providers) and accounting services. All potential processors have appropriate processing agreements, requesting them to process the personal data in the degree of security of as required by applicable law.
WHY AND WHAT PERSONAL DATA WE USE AND ON WHICH BASIS
- a) Performance of contractual obligations or measures prior to the conclusion of the contract
SPIRO processes the personal data of the parties within the framework and for the purpose of performing the contracts or services provided on their basis. In this context, it processes the collected personal information of individuals for the purpose of providing services and for monitoring customer satisfaction (including complaints) and managing contacts with individuals through various channels.
The use of personal data of individuals necessary for the purpose of performing the contract includes the use of personal information that is strictly necessary for the provision of the services of the online B2B website https://spiroteh.com/ and the provision of all other services we provide for our clients.
At https://spiroteh.com/, our customers can also register and create their online user account in order to facilitate their receipt of SPIRO services. In this case, SPIRO also processes their username and password in relation to the personal information below.
For the purpose of providing services, SPIRO may also become aware of personal information through customer inquiries by telephone, e-mail, third-party orders, etc., with SPIRO always collecting only the personal information that is strictly necessary to enter into a contract or to provide services ordered.
For the purpose of providing the online store service, https://spiroteh.com/ SPIRO processes the following personal information: company name, name and surname, invoice and delivery address, telephone and e-mail of the customer. For the purpose of entering into the contract, SPIRO may also process other personal data that are strictly necessary for the conclusion of the contract (eg IBAN account number).
b) Fulfillment of legal obligations
Use of your personal information to fulfill legal obligations includes, in particular, the recording of invoices.
c) Use of your personal information on the basis of a legitimate interest
We also use the personal information of individuals obtained through their registration at https://spiroteh.com/ to keep up-to-date and special, customized offer, news of offers or services and other SPIRO news. In addition, we use personal information that is publicly available for direct marketing purposes.
For direct marketing purposes, we use only email addresses and telephone numbers. When conducting direct marketing, we always provide all information that the individual must be aware of in accordance with applicable law.
CANCELLATION OF DIRECT MARKETING
Individuals can always “unsubscribe” from receiving individual SPIRO messages through the communication medium to which they received a particular message.
If an individual wants to cancel direct marketing, he or she may object to its execution at any time. Link to unsubscribe information on how to realize the checkout is in the message. The individual’s request for cancellation will be recorded in the system and will be effective immediately or 15 days after the termination exercise immediately after the cancellation request is made.
An individual may also object to the execution of direct marketing at any time by submitting the objection electronically to firstname.lastname@example.org or in writing to SPIRO d.o.o., Velika pot 24, 5250 Solkan. Revocation of consent does not affect the lawfulness of the processing of personal data on the basis of consent prior to revocation.
SPIRO will immediately cease processing of an individual’s personal information for direct marketing purposes if a complaint is raised.
USERS OF PERSONAL DATA
a) Who can access your personal information
The personal data of individuals is used only by SPIRO employees (or employees of potential SPIRO processors) who are obliged to comply with the provisions of personal data protection regulations and contracts concluded under which they are obliged to protect confidential information and to respect and protect the personal data of clients.
Customer personal information is a business secret. Users access the data in accordance with the granted data access rights.
b) Disclosure of your personal information
SPIRO protects the personal data of individuals and any other data processed in pursuit of their legitimate interests that outweighs the interests of the individual, against unauthorized disclosure and disclosure to unauthorized third parties, in accordance with applicable regulations governing the protection of personal data.
Exceptionally, SPIRO also transmits personal data to third parties if such an obligation to disclose or disclose is imposed by applicable legislation (for example, the Financial Administration of Republic of Slovenia, courts, police, etc.).
STORAGE OF YOUR PERSONAL DATA
The retention period of personal data depends on the basis of the processing and the purpose of the processing of each category of personal data.
Personal data after completing the purpose of the processing or processing. after expiry of the retention period, permanently delete.
For the purpose of direct marketing, SPIRO processes personal data of individuals only as long as there is a legitimate interest in such processing or until the individual is revoked.
YOUR RIGHTS RELATING TO PROCESSED PERSONAL DATA
In the following, we outline all the rights of individuals with regard to our processing of personal data relating to them and to ensuring their lawful and transparent processing.
All claims regarding the rights of individuals described below may be made in writing by email to email@example.com. More information on exercising the rights described below is given in the next section.
In the case of rights ambiguities, you can always ask us for further clarification on the contact information above.
a) Right to withdraw consent
We do not process personal information on the basis of consent. To the extent that personal data are processed on the basis of consent, the individual could revoke their consent at any time.
b) Right of access
The personal data we process can be accessed at any time, free of charge, easily and at reasonable intervals, upon request.
In this regard, upon request, we confirm to the individual whether or not we process personal data in connection with it, and when we process personal data in connection with it, we provide their access and the following information:
– the purposes of processing;
– the types of personal data concerned;
– users or categories of user to whom personal data have been or will be disclosed, in particular to users in third countries or international organizations;
– where possible, the envisaged period of retention of personal data or, where this is not possible, the criteria to be used to determine that period;
– the existence of the right to request from the controller the correction or deletion of personal data or restrictions on the processing of personal data concerning the data subject or the existence of the right to object to such processing;
– the right to lodge a complaint with the supervisory authority;
– where personal data are not collected from the data subject, all available information regarding their source; and
– the existence of automated decision-making, including the creation of the profiles referred to in the Article, and at least in such cases meaningful information as to the reasons for it, as well as the meaning and anticipated consequences of such processing for the data subject.
Additional copies or, in the case of manifestly unfounded or repeated requests, we may charge a reasonable fee, taking into account administrative costs.
c) Right of correction
At the request of the individual, we correct or supplement inaccurate and / or inaccurate or irregularities without undue delay. up-to-date personal information that we process in connection with it.
d) the right of erasure
(i) no longer required for the purposes for which they were collected or otherwise processed,
(ii) which are processed on the basis of withdrawn consent and there is no other legal basis for processing,
(iii) in respect of the processing of which you have objected and there are no prevailing laws to process themthose reasons, or those
(iv) which have been processed unlawfully, or
(v) if required by law,
at the individual’s request, we delete it without undue delay.
e) Right to limit processing
We restrict the processing of personal data at the request of an individual when
(i) the individual disputes their accuracy (in which case we will limit the processing of personal data for the time of verifying the accuracy of that data),
(ii) their processing is illegal but the individual wants to restrict their processing instead of deleting them,
(iii) they are no longer needed for processing purposes but are needed by the individual to assert, enforce or defend legal claims; or
(iv) the individual has lodged an objection regarding the processing of the data until it is verified that the controller’s legitimate reasons outweigh the reasons for the data subject.
In the event of a restriction, such personal data, with the exception of their storage, shall be processed only with the consent of the data subject or for the enforcement, enforcement or defense of legal claims in order to protect the rights of another natural or legal person.
We always inform the individual before canceling the processing restriction.
f) Right to portability of data
At the request of the individual, personal data provided to us by an individual are provided to another controller when processing is based on consent or contract and when technically feasible.
g) Right to contract
If we process personal data on the basis of our legitimate interest or for direct marketing purposes, such processing may be subject to objection by the individual at any time.
In the event that an objection is raised, we shall immediately cease processing personal data unless we have proven compelling legitimate reasons for (i) processing that outweighs the interests, rights and freedoms of the individual, or (ii) for the enforcement, enforcement or defense of legal claims. This does not apply in the case of an objection to the processing of personal data for direct marketing purposes, where in the case of an individual objection for the purpose of direct marketing, we immediately cease processing personal data related to him.
h) Right to lodge a complaint with the Information Commissioner
If we do not respond to an individual’s request within 1 month or if we reject his / her request, the individual may file an appeal, which is the responsibility of the Information Commissioner.
A complaint for refusal must be lodged with the operator within 15 days of the expiry of the one-month period or the receipt of the refusal. The request and complaint can be submitted by an individual using the special form published on the web site of the Information Commissioner.
EXERCISE OF RIGHTS RELATING TO THE PROTECTION OF PERSONAL DATA
SPIRO guarantees individuals the exercise of their rights without undue delay and within one month of receiving the request at the latest, with the deadline for exercising individual rights for up to two additional months, taking into account the complexity and number of requests. If SPIRO extends the deadline, it shall notify any such extension within one month of receipt of the request, together with the reasons for the delay.
All rights claims described in the previous section may be submitted by individuals in writing to: SPIRO d.o.o., Velika pot 24, 5250 Solkan or email firstname.lastname@example.org
SPIRO may, when it has reasonable doubt as to the identity of the individual submitting the request for its rights referred to above, may request the provision of additional information necessary to confirm the identity of the data subject.
If the requests of the data subject are manifestly unfounded or excessive, especially as they are repeated, SPIRO may:
– charge a reasonable fee, taking into account the administrative costs of providing the information or message or the implementation of the action requested, or
– refuse to act on the request.
We also recommend that you take care of your privacy and personal information.
Each individual is agreed to provide:
– security of usernames and passwords, which should be properly stored and disclosed only to those persons whom they fully trust,
– the security of your email address
– and appropriate software (antivirus) protection for your computer or other devices to access various content.
In case of significant changes or changes in the way SPIRO uses personal information, we will notify users before introducing the changes on the website or where we have a legitimate interest in communicating via email, also in the manner indicated.
We recommend that users regularly review this policy to obtain information on how SPIRO protects their privacy.
For additional information regarding the processing of personal data and suggestions for improvements, you can contact us at email@example.com or email us at: SPIRO d.o.o., Velika pot 24, 5250 Solkan