Kovanec Unlimited d.o.o. Privacy Policy

General:
The purpose of the Privacy Policy of the KOVANEC UNLIMITED poslovno svetovanje d.o.o. (hereinafter: Kovanec Unlimited) is, in particular, to ensure an adequate level of transparency in our website operation as well as the information of the individual who is visiting our website, regardless of whether or not they choose to make an online purchase (hereinafter referred to as an individual).

With the goal to provide a transparent and legitimate privacy policy, Kovanec Unlimited enables you to familiarise yourself with all relevant data in order to keep you informed. We fully follow the provisions introduced by the Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation – GDPR ) as well as national laws governing the protection of personal data. 


Personal Data Controller Information:
The controller of personal data that is processed in accordance with this Privacy Policy is the company of Kovanec Unlimited.

Data Controller Details:
KOVANEC UNLIMITED poslovno svetovanje d.o.o.
Slovenska cesta 55a, 1000 Ljubljana
Registration number: 8302073000
Tax number: 78866553
Email: e-narocila@shieldmaske.si 

In order to maximise the security of your personal information, Kovanec Unlimited undertakes that such information will be treated confidentially and used solely for the purpose for which it was provided. We handle your personal information with the utmost care, respecting the effective legislation and adhering to the highest standards of personal information processing. 

In particular, we ensure an adequate level of personal data security through appropriate organizational measures, work procedures and advanced technological solutions, as well as by engaging external experts. We take the appropriate level of protection and effective physical, electronic and administrative measures to protect the collected personal information from unintentional or unlawful destruction, loss, alteration, unauthorised disclosure or against unauthorised access to personal data that has been transferred, stored or otherwise processed. In order to do this, we have severely restricted the access to your personal information, as such access is only allowed to authorised persons, and only to the extent that is strictly necessary for a seamless delivery of services provided by Kovanec Unlimited.


Purpose of personal data processing:
We process your personal information to provide services on the Website and, upon your prior consent, also for direct marketing purposes and for legitimate interests.

1. We may dispose of your personal information for the purpose of providing you with our services on our website. In accordance with the applicable regulations, a contract cannot be concluded without the submission of your information, as in such cases such information is mandatory. In addition to the necessary information, we may obtain other information from you for the purposes of providing the services. As part of exercising the contractual rights and the fulfilment of contractual obligations, Kovanec Unlimited processes your personal information for the identification of an individual, preparation of an offer, conclusion of a contract, provision of services ordered, notification of any changes, additional details and instructions for use of services, or to solve any technical problems, objections or complaints and bill for services, and for other purposes necessary to perform or enter into a contractual relationship between a business and an individual.

2. With the explicit and prior consent of the individual, Kovanec Unlimited may also acquire personal information directly from the individual, collecting and processing it for the purpose of informing or engaging in direct marketing based on profiling and segmentation. In such cases, the processing of personal data is limited by a consent granted by the individual, which defines the purpose and permissible extent of the processing as well as the agreed information channels. The processing of personal information is carried out until we receive your cancellation or by such moment when Kovanec Unlimited fulfils all existing and expected contractual and other obligations. 

3. Based on a legitimate interest, we use your personal information to detect and prevent any fraudulent use and misuse of services and ensure the stable and secure functioning of our system and services, as well as for the purposes of implementing the information security measures, meeting the quality service requirements, and detecting any technical system and service failures. Based on a legitimate interest, we also use your personal information for enforcement purposes, as well as judicial and extrajudicial recovery. In cases of suspected abuse, we process data on individuals to a reasonable and proportionate extent for the purpose of identifying and preventing a possible fraud or abuse and we may, where appropriate, forward such information to other providers of such services, business partners, police, public prosecutors or other competent authorities. In such a case, in order to prevent any future abuse or frauds, information about the history of identified abuse or frauds linked to an individual, such as the subscription data or an IP address, may be retained for up to five years after the termination of the business relationship.

Kovanec Unlimited handles all personal data with care and in accordance with the EU Regulation 2016/679 ("GDPR"), which protects the rights of individuals with regard to the protection of personal data. An individual has the right to lodge a complaint with the Information Commissioner of the Republic of Slovenia if they feel that their personal data is processed in contradiction of the applicable regulations governing the personal data protection.

Kovanec Unlimited processes the following personal data of an individual in the databases it establishes, manages and maintains in accordance with the regulations governing the protection of personal data:

  • information which the individual enters in the online forms at the Online Store for participating in a prize-winning contest,  
  • information about the offers that Kovanec Unlimited provided to individuals and information about accepted offers,
  • information about winners and about claims filed by the individual regarding the prize-winning contests organised by Kovanec Unlimited,
  • information which Kovanec Unlimited obtains in other communications with an individual (e.g. relating to events organised by Kovanec Unlimited, registration and use of mobile applications, use of web applications, etc.),
  • information about the consent granted by the individual.


Your rights:
Kovanec Unlimited guarantees an unobstructed exercise of your rights regarding the processing of your personal information. These rights which are further defined in Articles 16 to 24 of the General Regulation include: the right to be informed, the right to amend, the right to delete data or limit processing, the right to object to the processing and the right to transfer personal data. All of these rights can be easily exercised by contacting us at e-mail: e-narocila@shieldmaske.si
, or in writing at the headquarters of Kovanec Unlimited. In this case, please let us know which of the rights you will exercise and regarding which personal information.

Also, the consent to the processing given on the website is not final, as it can be permanently or temporarily cancelled either fully or in part by email to e-narocila@shieldmaske.si. We would like to emphasise that the withdrawal of consent to the processing of personal data will not result in any negative consequences or sanctions for you. The withdrawal of consent results only in the fact that we will no longer collect and process your personal data unless it is absolutely necessary despite of your withdrawal (e.g. for the purposes of proceedings before state authorities, fulfilment of contractual obligations, etc.). 

The data subject may contact Kovanec Unlimited via the email address provided above for a clarification of any issues related to the processing of their personal data and for exercising their rights under the applicable regulations governing the protection of personal data.

An individual is also entitled to lodge a complaint with the Information Commissioner of the Republic of Slovenia, Zaloška cesta 59, 1000 Ljubljana, if they believe that the regulations governing the protection of personal data have been violated. 

If the requests of the data subject are manifestly unfounded or excessive, Kovanec Unlimited may charge the individual a reasonable fee or refuse to act on the request.


Retention period for personal information:
We process personal data until such time as the purpose of their processing is fulfilled, or until you provide your cancellation within the statute of limitation effective for obligations that may result from the processing of such personal data, especially when the processing of personal data is required in the framework of the conclusion or execution of contractual arrangements (for example, the fulfilment of an online order), except where the specific retention period for personal data is prescribed by a regulation. Once the retention period has expired, the data shall be erased, destroyed, blocked or anonymised, unless otherwise provided by law for each type of data.

Who has access to personal information?
We keep your information to ourselves. To the extent that the nature of individual activities so requires, we provide your information to our contractors (e.g. accounting service providers, post offices, etc.) or to public authorities (administrative authorities, supervisory authorities, police, etc.). 


Security:
All employees, contractors and other persons who have your personal consent or other appropriate legal basis for the processing of your data are obliged to protect the confidentiality of your data and must not disclose it to unauthorised persons or persons who do not have a proper basis for processing your personal data. Through regular inspections, maintenance and restoration, we make sure that the premises where we store personal data, as well as hardware and software necessary for the management and processing of personal data, provide safe conditions and do not allow an unauthorised access to the personal data of an individual.

This Privacy Policy, which is published on the data controller's website, takes effect as of 26 March 2020.

We will modify the content of our Privacy Policy as necessary, so we would like to invite you to regularly monitor our website, where we will notify you of any changes in a timely and appropriate manner.
 

KOVANEC UNLIMITED poslovno svetovanje d.o.o.
Ljubljana, 26 March 2020

 

SUMMARY OF THE MUTUAL PERSONAL DATA MANAGEMENT AGREEMENT 

On 15 November 2019, the Kovanček Group, consisting of the companies Kovanček Group d.d., Kovanček d.o.o., Kovanček posredovanje d.o.o., Kovanček prihranki d.o.o., Kovanček zavarovanja d.o.o. and Pro Services d.o.o., in accordance with the Article 26 of the EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (hereinafter referred to as the General Regulation) adopted the Agreement on the Common Management of Personal Data (hereinafter referred to as the Agreement). 

In order to fulfil the requirement of transparency in the processing of personal data, we provide below a summary of the Agreement.

Purpose of the Agreement:

The main purpose of the Agreement is to regulate the mutual relations and the method of treatment as well as the rights and obligations of each company and a way to effectively exercise the rights of the individuals whose data is processed. 

Personal information subject to the Agreement:

The subject of this Agreement is all personal data obtained from individuals by any of the companies in the Kovanček Group based on the individual's prior consent or for the purpose of fulfilling the obligations assumed by the contract.

The purpose of processing personal data in accordance with the Agreement:

Joint controllers will process personal data for:

  • organization and execution of prize-winning contests and benefit programs, notification on the receipt of prizes or benefits, communication with participants regarding the implementation of a prize-winning contest or benefits program, public announcements of the prize winners and tax processing of data or fulfilment of the company's tax obligations regarding the awarded prizes;
  • direct marketing by telephone, SMS/MMS or e-mail or in writing by mail;
  • transfer of the collected personal data to companies in the Kovanček Group that can process personal data of an individual for the purposes of direct marketing by telephone, SMS/MMS or e-mail messages or by mail; 
  • designing and forwarding personalised offers regarding the novelties or benefits, which are prepared according to the identified interests, habits, requirements and needs of the participant (based on the individual's profile), by telephone, SMS/MMS or e-mail or in writing by mail;
  • processing of collected personal data and its exchange among companies within the Kovanček Group for the purpose of optimizing the business operations, for securing the efficient and undisturbed operation of companies in the Kovanček Group, providing rights to the processing of personal data, and protecting the information system against unauthorised intrusions;
  • making and implementing donor arrangements;
  • profile creation or automated processing of personal data, including the use of personal data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict work performance, economic status, health, personal taste, interests, reliability, behaviour, location or movement of an individual;
  • entering into and conducting legal transactions (e.g., insurance contracts);
  • ensuring the traceability in the processing of personal data;
  • fulfilment of legal obligations; 
  • taking photographs and video recordings for promotional purposes.

Retention time for personal information:

The retention period of personal data depends on the purpose of personal data collection and lasts until the purpose is fulfilled or until the individual has recalled consent at the latest, except in cases where personal data necessary for judicial, disciplinary or administrative proceedings is kept until the final judicial, disciplinary or administrative procedure is completed.

Obligations of companies in the Kovanček Group in the processing of personal data:

Each of the companies in the Kovanček Group must make sure that it:

- informs the individual of the processing of personal data and of their rights under the Regulation;

- ensures that the processing of personal data is in accordance with the regulations in force at all times;

- after the expiry of the retention period, ensures that personal data is deleted, destroyed, blocked or anonymised;

- ensures an adequate level of security of personal data in order to prevent unauthorised access to personal data.

The rights of individuals whose personal data is processed:

The agreement does not affect the rights conferred on individuals by the General Regulation, namely:

  • the right to access the data that is subject to this Agreement; 
  • the right to request the companies in the Kovanček Group to provide them with:
    • a copy of the data being processed, 
    • information on the type of personal data being processed, the purpose of the processing, the category of users to whom the personal data has been disclosed and the estimated retention period of the personal data;
  • the right to correct any inaccurate data without undue delay or to supplement incomplete information;
  • the right to erasure (right to be forgotten): the controller shall delete personal data without undue delay if the following conditions are fulfilled:
    • personal data is no longer needed for the purposes for which it was collected or otherwise processed;
    • the data subject revokes the consent on the basis of which the processing takes place, or no other legal basis exists for the processing;
    • personal data was processed illegally;
    • personal data must be deleted in order to fulfil a legal obligation under EU law or the law of the EU Member State applicable to the controller;
  • the right to restrict processing: an individual has the right to request that the data controller restricts processing in the following cases:
    • if the individual requests a correction of inaccurate data during the period when the data controller checks the accuracy;
    • the processing is illegal and the individual opposes the erasure of the data and requests a restriction;
    • the personal data controller no longer needs the data for the purposes of processing, yet it is required the data subject to enforce, execute or defend legal claims;
  • the right to transferability: an individual has the right to receive personal data which is held by the controller and is relating to the individual, and has the right to receive it in a structured, commonly used and machine-readable form, as well as the right to transmit that information to another controller without the controller to whom the personal data was provided obstructing the individual;
  • the right to contest.

All of the above rights may be claimed by the individual in respect of all personal data which they have provided to the Kovanček Group and can be claimed against every company. To this end, a common (single) point of contact has been established:

- Address: Slovenska cesta 55a, 1000 Ljubljana

- email info@kovancek.com

The companies in the Kovanček Group have appointed a common contact who is authorised to protect personal data and is available to individuals for all matters relating to the processing of their personal data and exercising their rights under the General Regulation. The authorised person is available to individuals every working day. 

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