1) About this Privacy Policy
The purpose of the Privacy Policy of LESTRANS d.o.o. (hereinafter: “Privacy Policy”) is to familiarize users of LESTRANS d.o.o. services and other persons (hereinafter also referred to as: “individuals”) with the purpose and basis of the processing of personal data by LESTRANS d.o.o., Dunajska cesta 5, 1000 Ljubljana (hereinafter: “Company”) and the rights of individuals in this area.
The Company offers special attention to the safety of your personal information. All personal data transmitted are treated confidentially and are used only for the purpose for which they were transmitted. We handle your personal data with utmost care, taking into account the applicable legislation and the highest standards of their treatment. For the security of your personal data, we also provide for appropriate organizational measures, work procedures and advanced technology solutions, as well as external experts, in order to protect your personal data as effectively as possible. We use an appropriate level of protection and reasonable physical, electronic and administrative measures to protect the collected data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of personal data or unauthorized access to personal data that has been transferred, stored or otherwise treated.
At the same time, this Privacy Policy further explains the consent you have given for the processing of your personal data.
In accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regards to the processing of personal data and the free movement of such data and repealing Directive 95/46/EC (hereinafter: “General Data Protection Regulation”), this Privacy Policy includes the following information:
Contact information of the Company;
Purposes, bases and types of processing of various types of personal data of individuals;
The time of retention of individual types of personal data;
The rights of individuals with regards to the processing of personal data;
The right to file a complaint concerning the processing of personal data;
The validity of the Privacy Policy.
2) Personal data collected by the Company
If you are only a visitor to the website, we only collect data using cookies. If you are a service user or a subscriber of a service provided by the Company, we also collect other personal information that we need to provide the services you have ordered or that you use. This personal information is:
Name and surname
Contact email address
Telephone number
IP address
Information for issuing an offer according to your demand (your address, tax number)
3) The controller of personal data
In accordance with this Privacy Policy the controller of the processed personal data is LESTRANS d.o.o., Cesta Notranjskega odreda 45 A, 1386 Stari trg pri Loži.
4) Categories of individuals whose personal data are processed
This Privacy Policy is for anyone who has ordered and/or uses our services, or has submitted a request, as well as for visitors to our website.
5) Purposes and basis for data processing
5.1. PROCESSING ON THE BASIS OF A CONTRACT:
In the context of the execution of contractual rights and the fulfilment of contractual obligations, the Company processes your personal information for the following purposes: identification of an individual, preparation of an offer, conclusion of a contract, to provide requested services, information on possible changes, additional details and instructions for using the services, to address any technical problems, objections or complaints, accounting for services and other purposes necessary for the implementation or conclusion of a contractual relationship between the Company and an individual.
When billing the services, based on tax regulations, we obtain and process your address for the correct issue of the invoice.
5.2. PROCESSING ON THE BASIS OF A LAW:
On the basis of legitimate interest, we use your personal information to detect and prevent fraudulent use and misuse of services, further in the context of ensuring stable and safe operation of our system and services, as well as for the purposes of implementing information security measures, meeting the requirements regarding quality of services and detecting technical system and service failure.
On the basis of legitimate interest, we use your personal information also for the purposes of possible enforcement, judicial and extrajudicial claims.
In accordance with the General Regulation, in the event of suspected abuses, an entity may process personal data in an appropriate and proportionate manner for the purpose of identifying and preventing potential fraud or misuse, and may, where appropriate, also forward this information to other providers of such services, business partners, the police, the Public Prosecutor's Office or other competent authorities. For the purpose of preventing future abuse or fraud, data on the history of identified abuses or fraud in connection with an individual, including subscriber relationship data and, for example, an IP address, can be kept for another five years after the termination of the business relationship.
5.3. PROCESSING ON THE BASIS OF CONSENT TO THE PROCESSING OF PERSONAL DATA:
Data processing can also be based on the consent you have provided to the Company.
Consent may, for example, relate to the notification of offers, benefits and improvements to the services provided by the Company. The purpose of this information is to make the services as close as possible to your needs and desires and to thereby increase their utility value. Communication is carried out via channels that you have selected in consent. You can revoke the notification at any time in the manner defined by the Privacy Policy.
You can either withdraw or alter your consent at any time in the same way as you gave it or otherwise, as defined by the Privacy Policy, whereby the Company reserves the right to identify the customer. The change of consent can also be regulated by e-mail to lestrans@siol.net or by written request sent to the address of the Company's headquarters.
The withdrawal or change of consent refers only to data processed on the basis of your consent. Your most recently sent consent applies. The possibility of revoking consent does not constitute a resignation in the business relationship of an individual with the Company.
Data for which your consent is given will be processed up to two years after the termination of the business relationship with the Company or until cancellation.
6) Restrictions on the transmission of personal data
If necessary, we will authorize other companies and individuals to perform certain works that contribute to our services. In such a case, the Company may also transfer personal data to such carefully selected external processors that will enter into a personal data processing agreement with the Company, or in substance the same agreement or other binding document (hereinafter: "Processing Agreement"). For external processors, such data will be transmitted or made accessible only to the extent required by a specific purpose. Such data may not be used by external processors for any other purpose, meeting at least all the processing standards of personal data provided for in the applicable law. External processors are contractually committed to the Company to respect the confidentiality of your personal information.
On the basis of a reasoned request, the Company also provides personal data to the competent state authorities, which have legal basis for this. LESTRANS d.o.o. will, for example, responded to the requests of courts, law enforcement and other state authorities, which could also involve the state authorities of another EU Member State.
7) The retention period of personal data
The retention period is determined according to the category of individual data. The data shall be kept for as long as necessary to achieve the purpose for which they were collected or further processed or until the expiration of the limitation periods for fulfilment of the obligation or the statutory retention period.
For the purpose of fulfilling contractual obligations, the accounting data and the associated contact information on individuals may be kept until the full payment of the service or at the latest until the expiration of the limitation period in relation to an individual claim, which can be statutory from one to five years. Invoices are kept for 10 years after the expiration of the year to which the invoice relates in accordance with the law governing value added tax.
Other information that we have obtained on the basis of your consent is kept for the duration of the business relationship and for 2 years after the termination, unless the law provides for a longer retention period. If the individual who gave his / her consent to the processing of personal data has not entered into a business relationship with us, his / her consent is valid for 2 years from the date of his / her cancellation.
After the expiry of the retention period, the data is deleted, destroyed, blocked or anonymised, unless the law specifies otherwise for the particular type of data.
8) Rights of individuals in relation to the processing of personal data
The exercise of your rights regarding the processing of your personal data is guaranteed without undue delay. We will decide on your request within one month of receiving your request. In the event of complexity and a greater number of requirements, the deadline may be extended by up to two additional months. If we extend the deadline, we will notify you of any such extension within one month of receiving the request together with the reasons for the delay.
The requirements regarding the exercise of your rights can be obtained by e-mail lestrans@siol.net or by post to LESTRANS d.o.o., Cesta Notranjskega odreda 45 A 1386 Stari trg pri Loži.
Whenever you submit a request by electronic means, we will, whenever possible, provide you with information electronically, unless you request otherwise.
Where there is reasonable doubt as to the identity of an individual who submits a request relating to one of his / her rights, we may request that additional information be provided to confirm the identity of the data subject.
If requests of data subject are unfounded or excessive, in particular, because they are repetitive, the Company may:
Charge a reasonable fee, taking into account administrative costs of providing information or communication or implementing the required action or
Refuses to take action on the request.
We provide the following rights regarding the processing of your personal information:
(i) The right of access to information
(ii) The right to rectification
(iii) The right to erasure (“right to be forgotten”)
(iv) The right to limit processing
(v) The right to data portability
(vi) The right to object
(i) The right of access to information
You are always entitled to know whether personal data is being processed in respect of you and, if so, access to your personal data and the following information:
Processing purpose;
Types of personal data being processed;
Users or categories of users to whom personal data has been or will be disclosed;
The planned retention period of personal data or, if this is not possible, the criteria used to determine this period;
The existence of the right to require the administrator to correct or delete personal data or limit the processing of your personal data, or the existence of the right to object to such processing;
The right to file a complaint with the supervisory authority;
When personal data is not collected from you, all available information related to its source.
(ii) The right of rectification
You have the right to correct, without undue delay, inaccurate personal data relating to you 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 (“right to be forgotten”)
You have the right to delete, without undue delay, your personal information if one of the following reasons applies:
The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
You revoke the consent on which the processing is based and there is no other legal basis for the processing;
You object to the processing of data and there are no overriding legitimate grounds for the processing;
The personal data have been unlawfully processed;
The personal data have to be erased for compliance with a legal obligation in accordance with EU or Slovenian law.
(iv) The right to limit processing
You have the right to limit processing of your personal data when one of the following is true:
You dispute the accuracy of the data for the period which enables the controller to verify the accuracy of your personal data;
The processing is unlawful, and you object to the deletion of personal data, and instead ask for restrictions on their use;
We no longer need your personal data for the purposes of the processing, but you need them for the establishment, exercise or defence of legal claims;
If you filed an objection with regard to the processing which is based on legitimate reasons of the Company, until it is checked whether our legitimate reasons outweigh your reasons.
When 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, or for the enforcement, execution or defence of legal claims or for the protection of the rights of another natural or legal person.
Before cancelling the processing limit of your personal data, we are obliged to inform you.
(v) The right to data portability
You have the right to receive your personal data that you have provided us in a structured, widely used and machine-readable form, and the right to forward this data to another controller without hindering you in the case where the processing is based on your consent and the processing is carried out by automated means. At your request, where technically feasible, personal data may be transferred directly to another controller.
(vi) The right to object
Whenever your data is processed on the basis of a legitimate interest for marketing purposes, you may object to such processing at any time.
We will stop processing your personal data unless proven necessary processing grounds that prevail over your interests, rights and freedoms, or to enforce, execute or defend legal claims.
9) The right to file a complaint concerning the processing of personal data
Any complaint regarding the processing of your personal data can be sent to lestrans@siol.net or by post to LESTRANS d.o.o., Cesta Notranjskega odreda 45 A, 1386 Stari trg pri Loži.
In the event that we do not decide on your request within the legal deadline or if we reject your request, you have the possibility to file a complaint with the Information Commissioner.
You also have the right to file 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 the right of access to the information and after receiving the decision, you believe that the personal data that you have received is not the personal data you requested or that you did not receive all the required personal information, you may file a reasoned complaint before submitting a complaint to the Information Commissioner with the Company within 15 days. We need to decide on your complaint as a new request within five business days.
10) Final provisions
For all that is not covered by this Privacy Policy, the applicable law shall apply.
The Company reserves the right to change this Privacy Policy. We will notify you of the change on the official website of LESTRANS d.o.o. 30 days before its entry into force.
In the case of questions about the Privacy Policy or the data that we keep about you, please contact us at lestrans@siol.net.
11) Validity of the Privacy Policy
This Privacy Policy is published on the website of LESTRANS d.o.o. and is valid from 25 May 2018.
LESTRANS d.o.o.