- company contact information,
- purposes, basis, and types of processing of different types of personal data provided by individuals,
- retention time of single types of personal data,
- rights of individuals with regard to the processing of personal data,
- the right to issue a complaint concerning the processing of personal data,
Personal data collected by the company
If the individual is just a visitor to our website, we only collect information about you using cookies. If you are a user or a subscriber of services offered by the company, we also collect other personal data that are necessary to perform the services you have ordered or that you use. Personal information we collect is:
- name and surname
- e-mail address
- telephone number
- IP address
- informations that are necessary to adapt our offer to your demands (your address, VAT number).
Personal data manager
Categories of individuals whose personal data are processed
Puposes of processing and bases for data processing
5.1. Contract processing:
As part of the exercise of contractual rights and fulfillment of contractual obligations, the company processes your personal data for the following purposes: identification of the individual, preparation of an offer, conclusion of a contract, provision of ordered services, notification of possible changes, additional details and instructions for using services, objections or complaints, billing for services, and for other purposes necessary for the implementation or conclusion of a contractual relationship between the company and the individual.
For service billing, on the basis of tax regulations, we collect and process your address to correctly issue the invoice.
5.2. Legal grounds for processing personal data:
Based on a legitimate interest, we use your personal data to detect and prevent fraudulent use and misuse of services, to ensure the stable and secure operation of our system and services, as well as to implement information security measures, meet service quality requirements and detect technical system and service failures.
Based on a legitimate interest, we also use your personal data for legal enforcement, judicial, and extrajudicial recovery of debt.
In accordance with the General Regulation, in the event of suspected abuse, the company may process data of individuals to an appropriate and proportionate extent in order to identify or prevent possible fraud or abuse and may, if appropriate, pass this information on to other service providers, business partners and the police, the public prosecutor’s office or other competent authorities. In order to prevent future abuses or frauds, data on the history of identified abuses or frauds in connection with an individual – which includes data on the subscription relationship and, for example, IP address – may be kept for five years after the termination of the business relationship.
5.3. Consent for processing of personal data:
The processing of personal data may also be based on the individual’s consent given to the company.
Withdrawal or change of consent only applies to data processed on the basis of your consent. Your last consent given to us is valid. The possibility of revoking the consent does not constitute a right of withdrawal in the business relationship of the individual with the company.
The data for which customers have given their consent are processed in the absence of revocation up to two years after the termination of the business relationship with the company.
Restrictions on the transmission of personal data
If necessary, we will authorize other companies and individuals to perform certain activities that contribute to our services. In such a case, the company may also provide personal data to such carefully selected external processors who will either conclude a contract with the company for the processing of personal data, or the same agreement, or another binding document (hereafter: ‘Processing Agreement’). We will provide or make such external data available to external processors only to the extent required for a specific purpose. This data cannot be used by an external processor for any other purpose, provided that it meets all the standards for the processing of personal data provided by the applicable legislation. External processors are contractually obliged by the company to respect the confidentiality of your personal data.
On the basis of a reasoned request, the company may also provide personal data to the competent state authorities, who have legal grounds for these matters. Tina d.o.o. will e.g. respond to requests from courts, legal enforcement, and other public authorities, which may include EU authorities or another EU member state authorities.
Retention period for keeping of personal data
The retention period of personal data is determined by the category of the individual data. The data shall be kept for a maximum period of time which is necessary to achieve the purpose for which they were collected or further processed, or until the expiry of the statute of limitations for the fulfillment of obligations or for the legally prescribed retention period.
Accounting data and related contact data regarding individuals may be kept for the purpose of fulfilling contractual obligations until the full payment of the service or until the expiration of the statute of limitations in relation to an individual claim (from one to five years). The invoices shall be kept for 10 years after the end of the year to which the invoice refers, in accordance with legal provisions regulating VAT.
Other data collected on the basis of your consent are kept for the duration of the business relationship and for 2 years after the termination of this – unless the law establishes a longer retention period. If the individual who gave consent for the processing of personal data has not entered into a business relationship with us, his consent is valid for 2 years from its submission or until its revocation.
At the end of the retention period, the data shall be deleted, destroyed, blocked or anonymised, unless otherwise provided by law for each type of data.
Rights of individuals in relation to the processing of personal data
We ensure the exercise of your rights in relation to the processing of your personal data without unnecessary delay. We will decide on your request within one month after receiving your request. In case of dififculties and a large number of requests, the deadline can be extended by a maximum of two additional months. If we extend the deadline, we will notify you of any such extension within one month after receiving the request, together with the reasons for the delay.
Requests regarding the exercise of your rights are to be sent via e-mail at email@example.com or via mail to the address Tina d.o.o., Nasovče 18 a, 1218 Komenda, Slovenia.
If you submit a request by electronic means, we will provide you with the requested information by electronic means whenever possible, unless you request otherwise.
If there is any reasonable doubt regarding the identity of the data subject, we may request the provision of additional information necessary to confirm the identity of the data subject.
If the data subject’s requests are manifestly unfounded or excessive, in particular if they are repetitive, the company may:
– charge a reasonable fee, this taking into account the administrative costs of providing the information or communication or implementing the required action, or
– refuse to respond to the request.
We grant you the following rights in relation to the processing of your personal data:
(i) the right to access to data
(ii) the right to rectification
(iii) the right to erasure (the »right to forget«)
(iv) the right to restrict processing
(v) the right to data portability
(vi) the right to object
(i) the right to access to data
You always have the right to know whether your personal data is being processed and, if so, to access to personal data and the following information:
– processing purposes,
– type of personal data being processed,
– users or categories of users to whom personal data have been or will be disclosed,
– the envisaged retention period of the personal data or, if that is not possible, the criteria used to determine that period,
– the existence of a right to require the controller to either correct or delete personal data or to restrict the processing of your personal data, or the existence of a right to object to such processing,
– the right to issue a complaint to the supervisory authority,
– if personal information is not collected from you, all available information regarding the source.
(ii) right to rectification
You have the right to rectify inaccurate personal data concerning you without undue delay and, taking into account the purposes of the processing, the right to supplement incomplete personal data, including the submission of a supplementary statement.
(iii) the right to erasure (the »right to forget«)
You have the right to rectify inaccurate personal data concerning you without unnecessary delay and, taking into account the purposes of the data processing, the right to supplement incomplete personal data, including the submission of a supplementary statement:
– if personal data are no longer necessary for the purposes for which they were collected or processed,
– if you revoke the consent on the basis of which the processing takes place, as there is no other legal basis for the processing,
– if you object to the processing of data and there are no overriding legitimate reasons for processing it,
– if personal data have been processed unlawfully,
– if personal data must be deleted in order to fulfil a legal obligation in accordance with EU law or Slovenian law.
(iv) the right to restrict the processing of personal data
You have the right to limit the processing of your personal data in one of the following cases:
– if you dispute the accuracy of the data, namely for a period that allows us to verify the accuracy of the personal data,
– if data processing is illegal and you oppose the deletion of personal data and instead request a restriction on their use,
– if we do not need your personal data anymore for processing purposes, but you need your personal data to assert, enforce or defend legal claims,
– if you have objected to processing based on the legitimate interests of the company – as long as it has been verified that our legitimate reasons outweigh your reasons.
If the processing of your personal data has been restricted in accordance with the preceding paragraph, such personal data, with the exception of their storage, shall be processed only with your consent, either to assert, enforce or defend legal claims or to protect the rights of another natural or legal person.
We are obliged to inform our customers before lifting any restriction on the processing of their personal data.
(v) the right to data portability
You have the right to receive your personal data in a structured, commonly used and machine-readable form, and to pass this data on to another data manager without being hindered by the company when processing is based on your consent and is performed by automated means. At your request, if it is technically feasible, personal data may be transferred directly to another data manager.
(vi) right to object
If we process your data on the basis of a legitimate interest for marketing purposes, you may object to such processing at any time.
We stop processing your personal data unless we can prove compelling reasons for the processing that outweigh your interests, rights and freedoms, or to assert, enforce or defend legal claims.
The right to issue a complaint regarding the processing of personal data
Any complaint regarding the processing of personal data can be sent to our e-mail address firstname.lastname@example.org or via mail to the address Nasovče 18a, 1218 Komenda, Slovenia.
If we either do not decide on your request within the legal deadline or reject your request, you can file a complaint with the Information Commissioner.
You also have the right to lodge a complaint directly with the Information Commissioner if you believe that the processing of your personal data violates Slovenian or EU regulations in the field of personal data protection.
If you have exercised your right of access to your data and after receiving the decision you believe that the personal data you have received is not the personal data you have requested or that you have not received all the requested personal data, we kindly ask you to file a reasoned complaint with the company within 15 days before filing a complaint with the Information Commissioner. We need to decide on your appeal – as on a request – within five business days.