At MARMOR HOTAVLJE d.o.o. we process personal data when conducting our business operations and handle it in accordance with the applicable Slovenian and European legislation in the field of personal data protection, which means legally, safely, with care and transparency. We are aware of our responsibility to keep your personal data confidential, for this purpose all key information regarding the processing of personal data is indicated below
I. PERSONAL DATA CONTROLLER
The controller of personal data is MARMOR HOTAVLJE, družba za obdelavo kamna, d.o.o. Hotavlje 40, 4224 Gorenja vas (henceforth: MARMOR HOTAVLJE, d.o.o. or administrator); Phone: +386 (0) 4 507 0000, E-mail: info@m-h.si.
For all questions, information regarding the exercise of rights and enforcement of claims relating to the processing of personal data contact us at vop@m-h.si.
II. PURPOSES AND LEGAL BASES FOR PERSONAL DATA PROCESSING
We process your personal data in accordance with legal bases governed by the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND COUNCIL dated 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free flow of data, and the repeal of Directive 95/46/EC (hereinafter referred to as: General Data Protection Regulation (GDPR)), namely the consent, conclusion and/or implementation of contracts, legal obligations, legitimate interests of the controller or third parties, in the necessary scope and duration, which is necessary for purposes for which personal data was collected.
III. LEGAL BASES FOR PERSONAL DATA PROCESSING
A.) CONCLUDING AND IMPLEMENTING CONTRACTS
Your personal data is processed with the purpose of concluding contracts and for fulfilling our obligations from the mutual contractual relationship. The following processing procedures are carried out for this purpose: enquiry processing, offer preparation, new contract conclusion or amendment of the contractual relationship, supplying and charging services or products under the contract, issuing or settling invoices, monitoring payments and their recovery, resolving claims, informing about amendments to the terms and conditions and the legislation and for other similar purposes necessary in order to conclude or implement the contractual relationship.
Data may be collected directly from you, from publicly accessible sources or from competent/authorised national authorities or institutions. Your personal data is also processed as part of implementing the contractual relationship in order to provide you at any time with quality and timely information, which are relevant to you, e.g. to inform you about debts due resulting from outstanding commitments, to exchange data with providers of payment services in order to ensure a successful purchase transaction, to forward data to services carrying out delivery or mailing services in order for them to deliver the ordered products, and other information necessary for quality implementation of the contractual relationship. The following personal data, collected before concluding the contract or during contract implementation, is mainly necessary for concluding and implementing contracts: first name and surname, address (street, city/town, post code, country), phone number, e-mail address, bank account number.
On this legal basis we process your personal data (identification and contact information) in the segment of product sales and services with companies that are either signatories, managers or operators of contracts concluded with us, in order to provide you the ordered services or products.
Personal data processed on the basis of concluding or implementing contracts may be kept for purposes of fulfilling contractual obligations up to the full settlement of contractual obligations and not longer than the expiry of the limitation periods relating to each individual claim.
B.) LAW
You personal data may be processed on the basis of applicable laws in the area of consumer protection, personal data protection, regulation of electronic communication, obligations, enforcements, taxes and other laws that we must observe as the personal data controller.
C.) LEGITIMATE INTEREST
You personal data may be processed on the basis of legitimate interest the existence and justification of which may be substantiated on the basis of a careful assessment that your interests and fundamental rights relating to the processing of personal data are not prevailing over the interests of the personal data controller and that during the period of collecting personal data you may reasonably expect that data will be processed for that purpose. On this basis we carry out the following processing or activities:
- Direct marketing may be implemented as a form of communication with which we send to our current and potential clients various information on novelties and offers relating to our products and services. For this purpose we process personal data collected as part of the legal performance of our activity selling products or services to our clients or collected from publicly accessible sources:, namely: first name and surname, address (street, city/town, post code, country), phone number, e-mail address. As an individual to whom such personal data refers to, you have the right to object at any time to this processing, including the creation of your profile, when this is related to direct marketing, and revoke your consent for further processing and request the deletion of personal data or the cancellation of direct marketing. At the bottom of each e-mail with marketing content you may find information on your rights, instructions and a link to cancel direct marketing via e-mail messages.
- In order to optimise web pages in terms of systemic efficiency, availability and to ensure useful information about our services, we use cookies on your device to automatically collect and store information containing your IP address, date and time of visits and other data, consistently with the description of the cookies. This data is used for a more efficient management of web pages in order to gain a better insight into the interest of users for individual contents, to optimise and improve user experience, our product range and services, etc. The collected data may be used for analyses carried out based on legitimate interest, however, this data is not processed so as to identify you in any way nor it is used in order to adjust the individual offer to you or to profile you for the needs of personalised marketing. Web pages may therefore use cookies to improve their performance. You can find out more about cookies HERE.
User safety, preventing or restricting misuses and frauds are also some of the reasons of legitimate interest due to which we process your personal data.
D.) CONSENT
Your data may be processed on the basis of a consent that you have provided us for specific purposes known in advance, by giving your express, clear and unambiguous decision. This consent may refer to the registration to eventual e-news, notifications regarding our product range and services, forwarding of offers, etc. You may revoke or change your consent at any time by changing it in the relevant box or field or by contacting us at vop@m-h.si or writing to the address of our company’s headquarters. In case you do not revoke your consent, we will cease to process your data after the expiry of the time period of which you have been specifically informed in advance for each consent.
IV. RETENTION PERIOD
When processing your personal data we first determine their purpose, legal basis and retention period, for each separate record. For this reason your personal data is processed and kept for no longer than necessary to fulfil the purpose for which the data was collected, until the expiry of the time periods specified by law and until the expiry of the deadline that was specified in advance for each individual case or until your revoke your consent. You may contact us at any time and enquiry about the concrete retention period for each individual data referring to you. Data forwarded via the on-line shop for purposes of purchasing individual products, specified on invoices, may be kept for a legally determined period of time of 10 years after the purchase, after the end of the year to which the individual invoice refers.
V. USERS OF YOUR PERSONAL DATA
Your personal data is mostly managed and processed in our company. For purposes of implementing our services, fulfilling legal obligations, performing activities within the framework of legitimate interests and carrying out services on the basis of your consent, your personal data may also be occasionally and to a smaller extent processed by certain other users or processors. In this case we will ensure that there is a relevant legal basis for this and that data is disclosed and processed to a minimal extent and, if necessary, obscured before its disclosure. Since not all data of all individuals is forwarded to the same external processors, you may contact us in each concrete case for more detailed information about who processes your personal data.
Users or processors of your personal data may therefore be IT companies providing information support, banks with which you opened your bank accounts, providers of mailing services through which we deliver your products, providers of internet services and web pages where the web page is hosted, national bodies in case of exercising legal rights and obligations, and other external providers of various services with which we concluded mutual contracts on protecting and processing personal data (contractual processors).
VI. TRANSFERRING DATA TO THIRD COUNTRIES OR INTERNATIONAL ORGANISATIONS
Personal data collections are processed in the territory of the Republic of Slovenia and are generally not transferred to third countries. Should your personal data be transferred to third countries, this will be done after a careful review of the legal bases and safeguard measures in place in each individual third country.
VII. AUTOMATED DECISION-MAKING
Our company processes most information digitally, however, all decisions relating to contractual relationships, to determining rights and obligations and adopting decisions with legal effects are made by our employees in person and based on collected information.
VIII. YOUR RIGHTS
The Constitution of the Republic of Slovenia, the General Data Protection Regulation (GDPR) and other European regulations and the Personal Data Protection Act (ZVOP-1) confer you several rights with regard to personal data protection. You will have the following rights relating to our mutual cooperation:
- the right to be informed about the processing of your personal data (this is information in the General terms and conditions of the on-line shop and in this Privacy policy and Notices on cookies);
- the right to correction (when your personal data does not match with the forwarded data or is subsequently amended or needs to be complemented);
- the right to access to personal data (this means that you can obtain confirmation from us where it is stated whether your personal data is being processed and, if this is the case, where to access to this data, the purpose of processing, the type of data being processed, the users of such data, the options to amend the data or cancel its processing, the right to object to the processing and the data sources are provided);
- the right to deletion or the right to be forgotten (means that we delete all your personal data being processed if the prescribed conditions for this are met, namely that processing is not necessary any more upon revoking your consent; when no other legal basis exists; if personal data is processed illegally or when deletion is requested by other applicable regulations);
- the right to restriction of processing (you may exercise this right when contesting the accuracy of the data in question, however, you do not wish for this data to be deleted, when data is not needed any more for its initial purpose, however, it cannot be deleted due to legal reasons; when a decision on your objection to processing is pending);
- the right to transfer data (we are liable to send you your personal data, which we are processing on the basis of your consent or contract, in a structured form via e-mail; you also have the right to forward this data to another controller without being prevented from doing so in any way);
- the right to objection (means that you can object to the processing of your personal data on the basis of public or legitimate interests of the controller; when your data is processed for purposed of direct marketing, you can at any time object to the processing of your personal data for purposes of such marketing).
IX. FORWARDING INFORMATION
We will forward you information on the basis of a request relating to the processing of your personal data and information regarding your rights referred to in the General Data Protection Regulation (GDPR) without undue delay or within one month from the receipt of a full request. As an exception, this period of time may be extended for no more than two months in case of a greater volume of information, having regard to the complexity and number of requests. In this case we will inform you about the reasons for the delay. Should you send your request by e-mail, we will provide you the information, whenever possible, in electronic form, unless you request a different form.
In case of a safety incident occurring or a personal data breach, or if it is likely that the breach would present great risk for your rights and freedoms, we will inform you without undue delay.
X. RIGHT TO COMPLAIN TO A SUPERVISORY BODY
If you think that your rights regarding the protection of personal data have been infringed, you may lodge a complaint to a supervisory body, even in a member state in which you reside or in which the alleged infringement occurred.
The supervisory body to which the complaint was lodged will inform you about the status of the case and about the decision on the complaint, including the use of a legal remedy on the basis of Article 78 of the General Data Protection Regulation. In Slovenia this is the Information Commissioner who will inform you about the status of the case and its decision on the complaint in accordance with regulations.
You may lodge your complaint to the address:
Information Commissioner of the Republic of Slovenia, Dunajska cesta 22, SI – 1000 Ljubljana,
Phone: 01 230 97 30,
E-mail: gp.ip@ip-rs.si
Hotavlje, 01/09/2019