Privacy policy

Last updated

When you use Our Services, you trust us with your information. We take your privacy very seriously and are committed to providing you with a positive experience on our website, with our products and in your other interactions with us.

This Privacy Policy is meant to help you understand what data we collect, why we collect it, and what we do with it. This is important; we hope you will take time to read it carefully.

The Privacy Policy explains our practices for handling personal information on- and off-line. If you provide us with personal information, we will treat it as outlined in the Policy. This Policy also explains responsibility for external links to third-party websites, intellectual property and other information available on our websites.

If We merge with or are acquired by another company, your information may be transferred to new owners.

Definitions

The data protection declaration of VIAR d.o.o. is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to begin by explaining the terminology used.

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person*.*

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Name and Address of the Controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection this is:

VIAR d.o.o.

Breg 16

3000 Celje, Slovenia

What types of information do you collect?

We collect your information through our sites in several ways.

Traffic information is erased or made anonymous when it’s no longer needed for the purpose of transmission or, in the case of payable services, up to the end of the period during which the bill may lawfully be challenged or payment pursued.

Beside traffic information mentioned above, we may collect two types of information: “personal information” and “aggregate information”.

We process personal information only for the purposes for which it was collected and in accordance with this Policy. We take reasonable steps to ensure that the personal information we process is accurate, complete and current, but we depend on you to update or correct your personal information when necessary. We store your information for as long as needed to provide you with Products and Services. As soon it is not needed anymore, we delete the information.

Personal information is used to locate you, contact you or to determine your specific identity (your name, e-mail address, mailing address, phone number, etc.). Your personal information is used to help communicate with you (solicit feedback, respond to questions, provide technical support, deliver Products and Services, inform you)

We collect the personal information:

  • you provide to purchase or pre-order Our Products and Services
  • you provide when you sign up (sign in) to use Our Products and Services
  • you provide when you register for contests and prize acceptance
  • you provide when you subscribe to our newsletter and other services
  • you allow us to connect from other social media services
  • you allow us to collect from your use of certain features
  • we get from your use of Our Products and Services
  • we get from communicating directly with you
  • we get from cookies and other technology

In general, the Personal Information you provide to Us is used to help communicate with you. For example, We use your Personal Information to contact you in response to questions, solicit feedback from you, provide technical support, deliver Products and Services, and inform you about promotional offers.

Aggregate information is information about your activities using Products and Services that cannot be used to identify, locate or contact you (for instance frequency of using data entered when using Our Products and Services, most frequently accessed pages, browser type, etc.). Aggregate information is used in a collective manner and no single person can be identified by that compiled information. We use it to provide our services and remuneration and to monitor, audit and analyze information pertaining to our business metrics.

In general, We use aggregate information to help improve Products and Services and customize your experience. We also use aggregated Information in order to track trends and analyze use patterns on the Site.

We may combine automatically collected and other aggregate information with personal information. In that case we will treat the combined information as personal information under this Privacy Policy.

Will you sell or give my personal information to third parties?

We are not in the business of selling your personal information. We do not share your personal information with third parties for their direct marketing purposes, unless you have expressly agreed that we can do so.

We use third-party service providers to operate our website and to communicate with you, for example our CRM and email providers. They process your personal information only on our behalf and may not use it for any other purpose.

We also may disclose information to comply with a law, regulation or compulsory legal request, to protect the safety of any person from death or serious bodily injury, prevent fraud or misuse of Service or it’s users or to protect Our property rights.

Services we use on this website

Demo request form. When you request a demo, the details you enter (your name, work email, company and, if you choose, your role, phone number and message) are stored in our website's database so our team can respond and arrange the demo (Art. 6(1) lit. b GDPR). We keep these requests for as long as needed to handle them and our resulting business relationship.

Analytics (HubSpot). If you accept analytics cookies, we use HubSpot, a service of HubSpot, Inc. (USA), to understand how visitors use our website and to connect website visits with enquiries in our CRM. HubSpot sets the cookies __hstc and hubspotutk (13 months) and __hssc and __hssrc (session), and messagesUtk (13 months) if you use HubSpot chat, and processes data such as the pages you view, the referring website, your IP address and browser information. The legal basis is your consent (Art. 6(1) lit. a GDPR), which you can withdraw at any time via "Cookie settings" at the bottom of every page. HubSpot complies with the EU-U.S. Data Privacy Framework. Without your consent, the HubSpot script is not loaded.

Visitor statistics (Lovable). Our website is hosted on Lovable, which provides built-in visitor statistics. They count visits, pages viewed, the traffic source (for example a search engine or another website), the device type (desktop, mobile or tablet) and an approximate country derived from the browser's time zone. The statistics measure overall traffic only: they do not identify individual visitors, build visitor profiles or link separate visits. The legal basis is our legitimate interest in understanding and improving our website (Art. 6(1) lit. f GDPR).

Videos (YouTube). Some articles include YouTube videos embedded in privacy-enhanced mode (youtube-nocookie.com). YouTube receives data such as your IP address only when you play a video.

Hosting. Our website is hosted by a service provider that processes technical data, such as IP addresses and server logs, to deliver the site securely (Art. 6(1) lit. f GDPR).

How do you protect my personal information?

We appreciate your trust in sharing your personal information with us and are committed to protecting it.

We take appropriate security measures to protect against unauthorized access or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures as well as physical security measures. We restrict access to personal data to our employees, service providers and agents who need to know that information in order to operate, develop or improve our services.

We use secure socket layer (SSL) technology to encrypt and protect your personal information.

How can I update or remove my personal information or opt-out?

You can update or remove your personal information or opt- out at any time.

  • Updates: If you still wish to use Our Products and Services and your relevant personal information (name, e-mail, postal address, telephone number, etc.) changes, please let us know at info@viar.si

  • Information removal: If you wish to completely remove your data from our collections please send us a deletion request at info@viar.si

  • Opt-out: If you don’t like to receive our newsletter or other marketing material e-mails, you can unsubscribe any time with the “unsubscribe” link within any marketing e-mail you receive from us. We’ll be sad to see you go, but we respect your privacy.

Any request that you send to info@viar.si may take up to 10 days to process and become effective.

Rights of the data subject

Right of confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact us at info@viar.si.

Rights of access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

  • the purposes of the processing
  • the categories of personal data concerned;
  • the recipients or categories of recipients to whom the personal data have been or will be

disclosed, in particular recipients in third countries or international organizations;

  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
  • the existence of the right to lodge a complaint with a supervisory authority;
  • where the personal data are not collected from the data subject, any available information as to their source;
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may at any time contact us at info@viar.si.

Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact us at info@viar.si.

Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
  • The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
  • The personal data have been unlawfully processed.
  • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
  • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by VIAR d.o.o., he or she may at any time contact us at info@viar.si. We shall promptly ensure that the erasure request is complied with immediately.

Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. We will arrange the necessary measures in individual cases.

Right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
  • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by VIAR d.o.o., he or she may at any time contact us at info@viar.si. We will arrange the restriction of the processing.

Right to data portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact us at info@viar.si.

Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

VIAR d.o.o. shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.

If VIAR d.o.o. processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to VIAR d.o.o. to the processing for direct marketing purposes, VIAR d.o.o. will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by VIAR d.o.o. for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may directly contact us at info@viar.si. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

Automated individual decision-making, including profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, VIAR d.o.o. shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact us at info@viar.si.

Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact us at info@viar.si.

Right to lodge a complaint

You have the right to lodge a complaint with a supervisory authority, in particular in the EU member state of your residence or place of work. In Slovenia this is the Information Commissioner of the Republic of Slovenia (Informacijski pooblaščenec, www.ip-rs.si).

What happens if a breach of security occurs and my information is taken?

While we strive to protect your personal information, we cannot guarantee its absolute security. Despite our efforts, there remains the possibility that information may be accessed, altered, disclosed, or destroyed due to a security breach. In the unlikely event of a breach of security, and we have a way and (if required) your permission to do so, we will notify you by email if your personal information was involved in any way.

However, we cannot be responsible for the functionality, privacy or security measures of any other organization.

What are cookies and do you use them?

Cookies are small text files stored by your browser. We use cookies only for analytics, and only if you agree: HubSpot analytics cookies (see "Analytics (HubSpot)" above) are set only after you click "Accept" in the cookie banner. We remember your choice in your browser's local storage (not a cookie, and it contains no personal data) so we don't ask on every page. You can change your choice at any time via "Cookie settings" at the bottom of every page.

Can I reject all cookies?

You can modify your browser settings to control whether your computer accepts or declines cookies. If you choose to decline cookies, you may not be able to use certain interactive features of our Sites. Note that you can always go back and delete cookies from your browser; however, that means that any settings or preferences controlled by those cookies will also be deleted and you may need to recreate them.

What about intellectual property?

All content you can find on our websites is the property of Us or our suppliers and is protected by copyright or other intellectual property laws. Our content is not for resale.

You agree not to modify, publish, transmit, reverse engineer, participate in the transfer or sale, create derivative works, or in any way exploit any of the content, in whole or in part, found through our websites. Our content is not for resale.

Your use of our websites does not entitle you to make any unauthorized use of any protected content, and in particular you will not delete or alter any proprietary rights or attribution notices in any content. You will use protected content solely for your personal use, and will make no other use of the content without the express written permission of Us and the copyright owner. You agree that you do not acquire any ownership rights in any protected content. We do not grant you any licenses, express or implied, to Our or our’s licensors except as expressly authorized by this Policy and Terms of Use.

Is the information available on your sites accurate?

The material on our sites is provided for general information only. We are not responsible if this information is not accurate, complete or current, though we will do our best that we provide information of that standard. However, any reliance on the material on our sites is at your own risk.

Our sites may also contain links to other sites. Those websites may have their own Privacy Policies or none at all. We do not take any responsibility for those websites.

Legal basis for processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

Where the processing of personal data is based on Article 6(1) lit. f GDPR, our legitimate interests are operating and securing our website, responding to enquiries, and informing businesses about our products.

My country / industry has laws requiring data privacy and security. Can I use your products and services and still comply with these laws?

Our services are controlled, operated and administered by Us from our offices in EU. If you access our Products and services from outside of EU, you are responsible for compliance with all local laws.

Does the Privacy Policy relate to all countries?

Yes, Our Privacy Policy is applicable worldwide.

Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. If you are unsure whether you are required to provide personal data, contact us at info@viar.si and we will explain whether it is required by law or contract and what happens if it is not provided.