PRIVACY POLICY

1 SCOPE AND GENERAL INFORMATION

This Privacy Policy governs the collection, storage, and processing of personal information that NBplus collects from you when you use the website https://gabriellleithani.com (hereinafter referred to as “website”). User is any legal or natural person who uses or visits the website (hereinafter referred to as “user”). The data controller of personal data within the meaning of the European General Data Protection Regulation and applicable Slovenian legislation on the protection of personal data is NBplus, digitalne transformacije, Nejc Babič s.p., Korpe 2, 1223 Blagovica, Slovenia, (hereinafter referred to as “provider” or “data controller” or “we”).

In addition to this Privacy Policy, please familiarize yourself also with the Terms of Website governing the use of the website, as well as with the Cookie Policy, which discloses which cookies we collect and for what kind of purposes.

2 PERSONAL DATA

Personal data is any information relating to a natural person who can be identified, directly or indirectly, 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.

The data controller, according to the purposes defined in this Privacy Policy, collects the following personal data:

We also obtain certain data through cookies. Cookies are small pieces of data that are temporarily stored on your hard drive that allow our website to recognize your computer the next time you visit the website. Cookies help us improve the website and your experience with the website. For details on cookies, please read our Cookie Policy.

3 PURPOSES AND LEGAL GROUNDS FOR DATA PROCESSING

The data controller collects and processes your personal data on the basis of individual’s consent (order of products) or when there is legal basis for the collection of personal data, or the data controller has legitimate interest for such processing of personal data. All personal data you provide to us will be treated confidentially and will only be used for the purpose for which it was provided and collected.

By submitting a request or question on our website, you are deemed to consent to our response to your email address and to providing you with information regarding our products. You can always unsubscribe from our mailing list by sending an email to contact@gabriellleithani.com.

In case we need to further process your personal data for any other purpose, we will contact you in advance and ask for your prior written consent. 

3.1 Data processing based on law and contractual relations

When ensuring personal data is a contractual obligation or an obligation required to conclude and perform a contract with the provider, or a legal obligation, you must provide personal data. If you do not provide personal data, you cannot enter into a contract with the provider, nor can the provider perform services or deliver products under the contract, since the provider does not have the necessary data to execute the contract.

3.2 Data processing based on legitimate interest

The provider can access data based on legitimate interest for which the provider is striving, provided that the interests or the fundamental rights and freedoms of the user are not overriding. Where using legitimate interest, the provider always makes a judgement in accordance with the European General Data Protection Regulation on data processing.

3.3 Data processing based on your consent

The provider collects and processes your personal data for the following purposes, when you consent to it:

4 CONTRACTUAL PROCESSING OF PERSONAL DATA

Provider will not forward your personal data to third unauthorized parties.

As an individual you are notified and agree that the provider may entrust some tasks related to your data to contractual processors. They may process entrusted personal data exclusively in the name of the provider, within the limits of the provider’s mandate, as specified in written contract or other legal act, and according to the purposes as defined in this Privacy Policy. Contractual processors can only process personal data within the framework of the controller’s instructions and must not use it to pursue any interests of their own. Contractual processors can only process personal data within the framework of the provider’s (data controller’s) instructions and must not use it to pursue any interests of their own.

Data controller may only share your personal data with third parties if it is strictly necessary to ensure compliance of the data controller’s business with laws and other legally binding acts, or if required by a competent state authority.

5 STORING PERSONAL DATA

The provider will store your personal data only for the time necessary to realise the purpose for which the personal data was collected and further processed.

The personal data that are being processed on a legal basis the provider stores for the time-period defined by law.

The personal data that are being processed based on a contract with the individual, the provider stores for the duration of the contract and 5 years after its expiration, unless there has been a dispute about the contract between the user and the provider. In this case, the provider stores such data for 5 years after the finality of the court or arbitrary ruling or settlement or, if there was no judicial dispute, 5 years from the day of amicable settlement.

The provider stores the data that are processed based on personal consent or legitimate interest permanently, until the revocation of such consent or objection to data processing from the user. The provider deletes these data before objection only when the purpose of storing data has already been fulfilled or when defined by law.

After the end of the period of personal data being stored, the data controller effectively and permanently erases or anonymizes the personal data so that they cannot be linked to an individual.

6 THIRD PARTY WEBSITES

Our website may contain links to third party websites. These websites have their own privacy policy for which the operator does not assume any liability.

7 RIGHTS OF THE INDIVIDUAL REGARDING DATA PROCESSING

If you have any questions about our Privacy Policy or processing in regard to your personal data, you can contact us at contact@gabriellleithani.com. Based on your request we will notify you in writing and in accordance with applicable legislation.

As an individual you have the following rights regarding data processing based on the European General Data Protection Regulation (hereinafter referred to as “GDPR”): 

The right to withdraw consent: if you have, as an individual, consented to processing of personal data (for one or more purposes), you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Consent can be withdrawn through a written statement that is sent to the provider to one of the contacts at the provider’s website https://gabriellleithani.com. Withdrawal of consent for personal data processing has no negative consequences or sanctions for the individual. However, it is possible that the data controller may not be able to offer one or more of its services after the withdrawal of consent if those services cannot be performed without personal data.

The right to access personal data: as an individual, you have the right to obtain confirmation from the provider (processor of personal data) as to whether or not your personal data are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing, the categories of personal data concerned, its users, the period for which the personal data will be stored, or the criteria used to determine that period, the right to request rectification or erasure of personal data or restriction of or objection to processing of personal data, the right to lodge a complaint with a supervisory authority, the source of the data if the data were not collected from you, the existence of automated decision-making, including profiling and  meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you, in accordance with Article 15 of the GDPR.

The right to rectify personal data: as an individual, you have the right to obtain from the provider without undue delay the rectification of inaccurate personal data concerning you. Considering the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

The right to deletion of personal data (“the right to be forgotten”): you have the right to obtain from the provider without undue delay the deletion of your personal data when one of the below reasons exists:

(i) the personal data are no longer necessary in relation to the purposes for which they are collected or otherwise processed,

(ii) you have withdrawn your consent, and there is no legal basis for further processing,

(ii) you have objected to the processing of your personal data, and there are no overriding legitimate grounds for the processing,

(iv) your personal data have been unlawfully processed,

(v) the personal data must be erased for compliance with legal obligation in European Union or Member State law to which the provider is subject,

(vi) the personal data have been collected in relation to the offer of information society.

As an individual under certain circumstances, as defined in Article 17, paragraph 3 of the GDPR, you do not have the right to data deletion.

The right to restriction of processing: as an individual, you have the right to obtain from the provider restriction of processing where one of the following applies:

(i) you contest the accuracy of the personal data for a period enabling the provider to verify the accuracy of the personal data,

(ii) the processing is unlawful, and you oppose the erasure of the personal data and request the restriction of their use instead,

(iii) the provider no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise, or defense of legal claims,

(iv) you have objected to processing pending the verification whether the legitimate grounds of the provider override yours.

The right to data portability: you have the right to receive the personal data concerning you, which you have provided to the provider, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another data controller without hindrance from the provider to which the personal data have been provided, where:

(i) the processing is based on consent or on a contract; and

(ii) the processing is carried out by automated means.

In exercising your right to data portability, you have the right to have your personal data transmitted directly from one data controller (provider) to another, where technically feasible.

The right to object to data processing: as an individual, you have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data that is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the provider (Article 6 (1), point (e) of the GDPR), processing is necessary for the purposes of the legitimate interests pursued by the provider or by a third party (Article 6 (1) point (f) of  the GDPR), including profiling based on the data; the provider shall no longer process your personal data unless the provider demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing; where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes. Where data are processed for scientific or historical research purposes or statistical purposes, you have the right, on grounds relating to your particular situation, to object to processing of your data, unless it is necessary for the performance of a task carried out in the public interest.

The right to lodge a complaint with a supervisory authority: without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes data protection regulations.

Without prejudice to any other administrative or non-judicial remedy, you have the right to an effective judicial remedy, against a legally binding decision of a supervisory authority concerning it, as well as where the supervisory authority which is competent does not handle a complaint or does not inform you within three months on the progress or outcome of the complaint lodged. Proceedings against a supervisory authority shall be brought before the courts of the Member State where the supervisory authority is established.

The individual may address all her or his requests regarding personal data in written form to the provider, through one of the contacts at the website https://gabriellleithani.com.

To ensure reliable identification in case of a user exercising his or her rights regarding personal data, the provider may request additional data from the user and shall not refuse to act on the request of the individual, unless the provider demonstrates that it is not able to identify the user.

The provider must, by user’s request to exercise his or her rights regarding data processing, provide information without undue delay and in any event within one month of receipt of the request.

8 CROSS BORDER DATA TRANSFERS

WARNING: By using the website, your personal information may be transferred to and processed in the United States or a third country. In this case, there may be less legal protection of your personal data than provided for by the General Data Protection Regulation.

We expressly emphasize and warn that from July 16, 2020, the so-called  Privacy Shield, which in certain circumstances represented an adequate level of protection for personal data in the United States, is no longer valid. This means that the Privacy Shield is no longer a valid legal basis for the transfer of personal data to the United States.

If data is transferred to the United States or if we use a service provider based in the United States, this is expressly stated in this Privacy Policy.

The controller strives to conclude standard contractual clauses with service providers based in the United States, which were adopted by the European Commission on July 4, 2021, and to request additional guarantees for the protection of personal data. Furthermore, when US-based service providers offer this option, the controller chooses to process personal data on servers located in the European Union, which is supposed to technically ensure that the data is located in the European Union and that American authorities cannot access this data.

9 CONTACT INFORMATION

Please submit any questions, concerns, or comments you have about this Privacy Policy or any requests concerning your personal data by contacting us at contact@gabriellleithani.com.

The information you provide when contacting us will be processed to handle your request and will be erased when your request is completed. Alternatively, we will restrict the processing of the respective information in accordance with statutory retention requirements.

10 AMENDMENTS TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy from time to time as necessary to the actual situation and legislation in the field of personal data protection. Please visit our website regularly and check our respective current privacy policy before any personal data is provided so that you are aware of any changes and additions. We will also notify you in advance of any changes that significantly affect the processing of your personal data (e.g., by notification on our website).

NBplus, digitalne transformacije, Nejc Babič s.p.

Last update: May 2023