Privacy Policy

When you use Our Services, you trust us with your information. We take your privacy very seriously and is committed to providing you with a positive experience on our website, with our products and in your other interactions with us.

This Privacy Policy is meant to help you understand what data we collect, why we collect it, and what we do with it. This is important – we hope you will take time to read it carefully.

The Privacy Policy explains our practices for handling personal information on- and off-line. If you provide us with personal information, we will treat it as outlined in the Policy. This Policy also explains responsibility for external links to third party websites, user content, the use of communication services, indemnity, intellectual property and other information available on Our websites.

For you to use Our products and Services, you have to agree to Our Privacy Policy. If you don’t agree with our Privacy Policy, we kindly ask you not to use Our Products and Services.

If We merge with or are acquired by another company, your information may be transferred to new owners.

Definitions

The data protection declaration of Company ToploBiro d.o.o. is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to begin by explaining the terminology used.

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular 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.

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Name and Address of the Controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection this is:

Company ToploBiro d.o.o.

Ulica bratov Učakar, 122, 1000 Ljubljana, SLOVENIA

Any data subject may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection.

What types of information do you collect?

We collect your information through our sites in several ways:

Traffic information is erased or made anonymous when it’s no longer needed for the purpose of transmission or, in the case of payable services, up to the end of the period during which the bill may lawfully be challenged or payment pursued.

Beside traffic information mentioned above, we may collect two types of information: “personal information” and “aggregate information”.

We process personal information only for the purposes for which it was collected and in accordance with this Policy. We take reasonable steps to ensure that the personal information we process is accurate, complete and current, but we depend on you to update or correct your personal information when necessary. We store your information for as long as needed to provide you with Products and Services. As soon it is not needed anymore, we delete the information.

Personal information is used to locate you, contact you or to determine your specific identity (your name, e-mail address, mailing address, phone number, etc.). Your personal information is used to help communicate with you (solicit feedback, respond to questions, provide technical support, deliver Products and Services, inform you)

We collect the personal information:

  • you provide to purchase or pre-order Our Products and Services
  • you provide when you sign up (sign in) to use Our Products and Services
  • you provide when you register for contests and prize acceptance
  • you provide when you subscribe to our newsletter and other services
  • you allow us to connect from other social media services
  • you allow us to collect from your use of certain features
  • we get from your use of Our Products and Services
  • we get from communicating directly with you
  • we get from cookies and other technology

In general, the Personal Information you provide to Us is used to help communicate with you. For example, We use your Personal Information to contact you in response to questions, solicit feedback from you, provide technical support, deliver Products and Services, and inform you about promotional offers.

Aggregate information is information about your activities using Products and Services that cannot be used to identify, locate or contact you (for instance frequency of using data entered when using Our Products and Services, most frequently accessed pages, browser type, etc.). Aggregate information is used in a collective manner and no single person can be identified by that compiled information. We use it to provide our services and remuneration and to monitor, audit and analyze information pertaining to our business metrics.

In general, We use aggregate information to help improve Products and Services and customize your experience. We also use aggregated Information in order to track trends and analyze use patterns on the Site. This Privacy Policy does not limit in any way Our use or disclosure of aggregate information and We reserve the right to use and disclose such aggregate to our partners, advertisers and other third parties at our discretion.

We may combine automatically collected and other aggregate information with personal information. In that case we will treat the combined information as personal information under this Privacy Policy and it will be used for marketing purposes.

Will you sell or give my personal information to third parties?

We are not in the business of selling your personal information. We do not share your personal information with third parties for their direct marketing purposes, unless you have expressly agreed that we can do so.

We do use Third party services such as shipping company to fulfill your orders, a credit card processing company to bill you for goods and services, an email service provider to communicate with you on our behalf, etc. When you order our Product, we will share your personal information as necessary for the third party to provide applicable services. However, they are prohibited from using your personal information for any purpose.

We also may disclose information to comply with a law, regulation or compulsory legal request, to protect the safety of any person from death or serious bodily injury, prevent fraud or misuse of Service or it’s users or to protect Our property rights.

We do use aggregate information collected online to help improve our Products and services and customize your experience. By this Privacy Policy we are not in any way limited to use or disclose aggregate information to our partners, advertisers or any other third parties at our discretion.

Data protection provisions about the application and use of Facebook

On this website, the controller has integrated components of the enterprise Facebook. Facebook is a social network.

A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

With each call-up to one of the individual pages of this Internet website, which is operated by the controller and into which a Facebook component (Facebook plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed under the address: https://developers.facebook.com/docs/plugins/. During the course of this technical procedure, Facebook is made aware of what specific sub-site of our website was visited by the data subject.

If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-site of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g. the “Like” button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.

Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our website is made.

The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook, e.g. the Facebook blocker of the provider Webgraph, which may be obtained under http://webgraph.com/resources/facebookblocker/. These applications may be used by the data subject to eliminate a data transmission to Facebook.

Data protection provisions about the application and use of Google Analytics

On this website, the controller has integrated the component of Google Analytics. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under

http://www.google.com/analytics/terms/us.html.

Google Analytics is further explained under the following Link https://www.google.com/analytics/.

Data protection provisions about the use and application of Google Remarketing

On this website, the controller has integrated Google Remarketing services. Google Remarketing is a feature of Google AdWords, which allows an enterprise to display advertising to Internet users who have previously resided on the enterprise’s Internet site. The integration of Google Remarketing therefore allows an enterprise to create user-based advertising and thus shows relevant advertisements to interested Internet users.

The operating company of the Google Remarketing services is the Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

The purpose of Google Remarketing is the insertion of interest-relevant advertising. Google Remarketing allows us to display ads on the Google network or on other websites, which are based on individual needs and matched to the interests of Internet users.

Google Remarketing sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google enables a recognition of the visitor of our website if he calls up consecutive web pages, which are also a member of the Google advertising network. With each call-up to an Internet site on which the service has been integrated by Google Remarketing, the web browser of the data subject identifies automatically with Google. During the course of this technical procedure, Google receives personal information, such as the IP address or the surfing behaviour of the user, which Google uses, inter alia, for the insertion of interest relevant advertising.

The cookie is used to store personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to the interest-based advertising by Google. For this purpose, the data subject must call up the link to www.google.de/settings/ads and make the desired settings on each Internet browser used by the data subject.

Further information and the actual data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.

Data protection provision about the application and use of Google AdWords

On this website, the controller has integrated Google AdWords. Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords with the help of which an ad on Google’s search results only then displayed, when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.

The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

The purpose of Google AdWords is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in the search engine results of the search engine Google and an insertion of third-party advertising on our website.

If a data subject reaches our website via a Google ad, a conversion cookie is filed on the information technology system of the data subject through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, e.g, the shopping cart from an online shop system, were called up on our website. Through the conversion cookie, both Google and the controller can understand whether a person who reached an AdWords ad on our website generated sales, that is, executed or canceled a sale of goods.

The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for our website. These visit statistics are used in order to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.

The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, at any time, prevent the setting of cookies by our website, as stated above, by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie set by Google AdWords may be deleted at any time via the Internet browser or other software programs.

The data subject has a possibility of objecting to the interest based advertisement of Google. Therefore, the data subject must access from each of the browsers in use the link www.google.de/settings/ads and set the desired settings.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.

Data protection provision about the application and use of LinkedIn

The controller has integrated components of the LinkedIn Corporation on this website. LinkedIn is a web-based social network that enables users with existing business contacts to connect and to make new business contacts. LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world.

The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, UNITED STATES. For privacy matters outside of the UNITED STATES LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a LinkedIn component (LinkedIn plug-in) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to the download of a display of the corresponding LinkedIn component of LinkedIn. Further information about the LinkedIn plug-in may be accessed under https://developer.linkedin.com/plugins. During the course of this technical procedure, LinkedIn gains knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in at the same time on LinkedIn, LinkedIn detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-page of our Internet page was visited by the data subject. This information is collected through the LinkedIn component and associated with the respective LinkedIn account of the data subject. If the data subject clicks on one of the LinkedIn buttons integrated on our website, then LinkedIn assigns this information to the personal LinkedIn user account of the data subject and stores the personal data.

LinkedIn receives information via the LinkedIn component that the data subject has visited our website, provided that the data subject is logged in at LinkedIn at the time of the call-up to our website. This occurs regardless of whether the person clicks on the LinkedIn button or not. If such a transmission of information to LinkedIn is not desirable for the data subject, then he or she may prevent this by logging off from their LinkedIn account before a call-up to our website is made.

LinkedIn provides under https://www.linkedin.com/psettings/guest-controls the possibility to unsubscribe from e-mail messages, SMS messages and targeted ads, as well as the ability to manage ad settings. LinkedIn also uses affiliates such as Eire, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame. The setting of such cookies may be denied under https://www.linkedin.com/legal/cookie-policy. The applicable privacy policy for LinkedIn is available under https://www.linkedin.com/legal/privacy-policy. The LinkedIn Cookie Policy is available under https://www.linkedin.com/legal/cookie-policy.

Data protection provisions about the application and use of Tweeter

On this website, the controller has integrated components of Twitter. Twitter messages (tweets)  are available for everyone, including those who are not logged on to Twitter. The tweets are also displayed to so-called followers of the respective user. Followers are other Twitter users who follow a user’s tweets. Furthermore, Twitter allows you to address a wide audience via hashtags, links or retweets.

The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, UNITED STATES.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a Twitter component (Twitter button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding Twitter component of Twitter. Further information about the Twitter buttons is available under https://about.twitter.com/de/resources/buttons. During the course of this technical procedure, Twitter gains knowledge of what specific sub-page of our website was visited by the data subject. The purpose of the integration of the Twitter component is a retransmission of the contents of this website to allow our users to introduce this web page to the digital world and increase our visitor numbers.

If the data subject is logged in at the same time on Twitter, Twitter detects with every call-up to our website by the data subject and for the entire duration of their stay on our Internet site which specific sub-page of our Internet page was visited by the data subject. This information is collected through the Twitter component and associated with the respective Twitter account of the data subject. If the data subject clicks on one of the Twitter buttons integrated on our website, then Twitter assigns this information to the personal Twitter user account of the data subject and stores the personal data.

Twitter receives information via the Twitter component that the data subject has visited our website, provided that the data subject is logged in on Twitter at the time of the call-up to our website. This occurs regardless of whether the person clicks on the Twitter component or not. If such a transmission of information to Twitter is not desirable for the data subject, then he or she may prevent this by logging off from their Twitter account before a call-up to our website is made.

The applicable data protection provisions of Twitter may be accessed under https://twitter.com/privacy?lang=en.

Data protection provision about Company ToploBiro d.o.o.

How do you protect my personal information?

We appreciate your trust in sharing your personal information with us and are committed to protecting it.

We take appropriate security measures to protect against unauthorized access or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures as well as physical security measures. We restrict access to personal data to our employees, service providers and agents who need to know that information in order to operate, develop or improve our services.

We use secure socket layer (SSL) technology to encrypt and protect your personal information (including your credit card number).

Please note that if you click away from our site to any other site you might be asked for your payment card or other personal data. These companies have their own privacy and data collection practices. We have no responsibility or liability for these policies.

How can I update or remove my personal information or opt-out?

You can update or remove your personal information or opt- out at any time.

  • Updates: If you still wish to use Our Products and Services and your relevant personal information (name, e-mail, postal address, telephone number, etc.) changes, please let us know at info(at)toplobiro.si
  • Information removal: If you wish to completely remove your data from our collections please send us a deletion request at info(at)toplobiro.si
  • Opt-out: If you don’t like to receive our newsletter or other marketing material e-mails, you can unsubscribe any time with the “unsubscribe” link within any marketing e-mail you receive from us. We’ll be sad to see you go, but we respect your privacy.

Any request that you send to info(at)toplobiro.si may take up to 10 days to process and become effective.

Rights of the data subject

Right of confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.

Rights of access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipients to whom the personal data have been or will be

disclosed, in particular recipients in third countries or international organisations;

  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
  • the existence of the right to lodge a complaint with a supervisory authority;
  • where the personal data are not collected from the data subject, any available information as to their source;
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

 

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may at any time contact our Data Protection Officer or another employee of the controller.

Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.

Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
  • The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
  • The personal data have been unlawfully processed.
  • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
  • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by [Company name], he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of Company ToploBiro d.o.o. or another employee shall promptly ensure that the erasure request is complied with immediately.

Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The Data Protection Officer of Company ToploBiro d.o.o.  or another employee will arrange the necessary measures in individual cases.

Right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
  • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by Company ToploBiro d.o.o., he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of Company ToploBiro d.o.o.  or another employee will arrange the restriction of the processing.

Right to data portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact the Data Protection Officer designated by Company ToploBiro d.o.o. or another employee.

Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

[Company name] shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

If Company ToploBiro d.o.o. processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to [Company name] to the processing for direct marketing purposes, Company ToploBiro d.o.o. will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by Company ToploBiro d.o.o. for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may directly contact the Data Protection Officer of Company ToploBiro d.o.o. or another employee. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

Automated individual decision-making, including profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, Company ToploBiro d.o.o. shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact our Data Protection Officer of Company ToploBiro d.o.o. or another employee of the controller.

Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact our Data Protection Officer of Company ToploBiro d.o.o. or another employee of the controller.

What happens if a breach of security occurs and my information is taken?

While we strive to protect your personal information, we cannot guarantee its absolute security. Despite our efforts, there remains the possibility that information may be accessed, altered, disclosed, or destroyed due to a security breach. In the unlikely event of a breach of security, and we have a way and (if required) your permission to do so, we will notify you by email if your personal information was involved in any way.

However, we cannot be responsible for the functionality, privacy or security measures of any other organization.

What are cookies and do you use them?

Cookies are small text files placed on your hard drive. We use cookies or similar technologies (pixels etc.) to personalize your online experience and improve our services to you. For example, cookies will remember and process the items in your shopping cart on our website. This saves you time, since you are not required to re-enter the same information each time you visit our site.

 

Here is a list of cookies that we use. We have listed them here so you can decide whether you would like to opt-out or not.

We use cookies for the following purposes:

  • to enable certain functions of the Service
  • to provide analytics we use Google Analytics cookies
  • to store your preferences we use session cookies.

The session cookies are essential for providing an appropriate booking and product shopping experience. This ensures that the site remembers when you have added something to your basket in order to complete your order or booking, check out and make your payment. The session cookie we use is:

  • wp_woocommerce_session
  • woocommerce_cart_hash
  • woocommerce_items_in_cart

Third-party cookies

We use Google Analytics, a web analysis service provided by Google Inc. (“Google”) for statistical purposes. This service uses cookies (both persistent and session) to analyse how visitors use our website. The information generated by the cookies concerning your use of our website (including your IP address, time of visit to the site, the type of browser that you use, the pages you consult and the files you download) is transferred to and archived by Google on servers in the United States. Google uses this information to create reports on the website activity for us. Google may not supply this information to third parties unless there is a legal obligation to do so. Google will not combine your IP address with other data at its disposal. By using our website, you consent to the processing of the information by Google in the manner and for the purposes as described above. The Google cookies are:

  • _ga
  • _gat
  • _gid

Google complies with the Safe Harbor principles and subscribes to the Safe Harbor programme operated by the U.S. Department of Commerce.

In the event that you do not wish data on your website visit to be forwarded to Google Analytics, you can download and install the Google Analytics Opt-out Browser Add-on.

You will find further information in Google Analytic’s privacy policy.

We use Stripe as our payment gateway. In order to make payments via Stripe you will need to accept the following Stripe cookies:

  • __stripe_mid
  • __stripe_sid

We use JivoSite as our chat solution. In order to chat with operators you will need to accept the following JivoSite cookies

  • enter_ts              first visit to the website
  • visits_count        number of visits to the website
  • pages_count      number of pages viewed
  • refer      source of entry to the website
  • utm        ID of the marketing campaign of the visit
  • invitation_time time of appearance of proactive invitation
  • country country of the visitor
  • city         city of the visitor
  • close_time          time the widget was closed
  • cw_timer             time the callback request was initiated
  • callback_ping_response cash of callback backend script response
  • use_lp  flag that enables long_pooling
  • mframe_protected         indication if iframe is forbidden
  • ab_test_group  a/b testing group flag

Can I reject all cookies?

You can modify your browser settings to control whether your computer accepts or declines cookies. If you choose to decline cookies, you may not be able to use certain interactive features of our Sites. Note that you can always go back and delete cookies from your browser; however, that means that any settings or preferences controlled by those cookies will also be deleted and you may need to recreate them.

What happens to the financial information that I give you when purchasing your Products and services?

We need certain information to complete the online transaction when you preorder or order our Products and services online:

  • your name,
  • your email address,
  • your billing and shipping address,
  • phone number,
  • credit/debit/bank information,
  • items purchased, and
  • any other information necessary to complete the transaction.

We do not collect or store your full credit card number.

What about intellectual property?

All content you can find on our websites is the property of Us or our suppliers and is protected by copyright or other intellectual property laws. Our content is not for resale.

You agree not to modify, publish, transmit, reverse engineer, participate in the transfer or sale, create derivative works, or in any way exploit any of the content, in whole or in part, found through our websites. Our content is not for resale.

Your use of our websites does not entitle you to make any unauthorized use of any protected content, and in particular you will not delete or alter any proprietary rights or attribution notices in any content. You will use protected content solely for your personal use, and will make no other use of the content without the express written permission of Us and the copyright owner. You agree that you do not acquire any ownership rights in any protected content. We do not grant you any licenses, express or implied, to Our or our’s licensors except as expressly authorized by this Policy and Terms of Use.

What happens when I share content from other sources through your Products and Services?

Some of our Products and Services may enable you to publish or share publicly content you have generated or obtained from other sources. For this content you retain any and all intellectual property rights.

However, by publishing and sharing your user content through our Products and Services, you grant Us some rights solely for the purpose to provide the products and services to you:

  • A non-exclusive, unrestricted, unconditional, unlimited, worldwide, irrevocable, perpetual, and cost-free right and license to use, copy, record, distribute, reproduce, disclose, sell, re-sell, sublicense (through multiple levels), modify, display, publicly perform, transmit, publish, broadcast, translate, make derivative works of, and otherwise exploit in any manner whatsoever, all or any portion of the User Content you publish or share through the Site.

Please be aware of certain conditions and warranties when publishing and sharing User content:

  • Each time you publish or share any User Content, you represent and warrant that you are at least the age of the majority in the state in which you reside and are the parent or legal guardian, or have all proper consent from the parent or legal guardian, of any minor who is depicted in or contributed to any User Content you publish or share, and that, in regard to that User Content,

(a) you are the sole author and owner of the Intellectual property and other rights to the User Content, or you have a lawful right to publish and share the User Content and grant the right to use it as described in this Section, all without any Our obligation to obtain consent of any third party and without creating any obligation or liability of Us;

(b) the User Content is accurate;

(c) the User Content does not and, as to Products and Services’ permitted uses and exploitation set forth in this Policy and Terms of use, will not infringe any Intellectual property or other right of any third party; and

(d) the User Content will not violate this Privacy Policy and Terms of Use or cause injury or harm to any person.

What are the rules of using your communication services?

We like to communicate with you that’s why we use multiple Communication services, such as chat areas, news groups, forums, communities, etc.

These Communication services are there to support you and make your experience with our Products and Services better. That’s why they are meant only for posting, sending and receiving messages and material that is proper and related to the particular service that you’re using.

We reserve the right to terminate your access to any or all of the Communication services at any time without notice for any reason whatsoever.

Please always use caution when giving out any personally identifying information about yourself or your children in any communication service.

By way of example, and not as a limitation, you agree that when using a Communication Service, you will not:

  • defame, abuse, harass, stalk, threaten or otherwise violate the legal rights (such as rights of privacy and publicity) of others;
  • publish, post, upload, distribute or disseminate any inappropriate, profane, defamatory, infringing, obscene, indecent or unlawful topic, name, material or information;
  • upload files that contain software or other material protected by intellectual property laws (or by rights of privacy of publicity) unless you own or control the rights thereto or have received all necessary consents;
  • upload files that contain viruses, corrupted files, or any other similar software or programs that may damage the operation of another’s computer;
  • advertise or offer to sell or buy any goods or services for any business purpose, unless such Communication Service specifically allows such messages;
  • conduct or forward surveys, contests, pyramid schemes or chain letters;
  • download any file posted by another user of a Communication Service that you know, or reasonably should know, cannot be legally distributed in such manner;
  • falsify or delete any author attributions, legal or other proper notices or proprietary designations or labels of the origin or source of software or other material contained in a file that is uploaded, restrict or inhibit any other user from using and enjoying the Communication Services;
  • violate any code of conduct or other guidelines which may be applicable for any particular Communication Service;
  • harvest or otherwise collect information about others, including email addresses, without their consent; violate any applicable laws or regulations.

Is the information available on your sites accurate?

The material on our sites is provided for general information only. We are not responsible if this information is not accurate, complete or current, though we will do our best that we provide information of that standard. However, any reliance on the material on our sites is at your own risk.

Our sites may also contain links to other sites. Those websites may have their own Privacy Policies or none at all. We do not take any responsibility for those websites.

Legal basis for processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

My country / industry has laws requiring data privacy and security. Can I use your products and services and still comply with these laws?

Our services are controlled, operated and administered by Us from our offices in EU. If you access our Products and services from outside of EU, you are responsible for compliance with all local laws.

Does the Privacy Policy relate to all countries?

Yes, Our Privacy Policy is applicable worldwide.

What happens if I violate this Privacy Policy?

If you violate this Privacy Policy in any way or if you in any way misuse our websites, misuse our Products and Services, make inappropriate user posts or violate any Third party rights, applicable laws, rules or regulations, you are to indemnify Us, our partners, officers, agents and others related to Us.

Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact our Data Protection Officer. Our Data Protection Officer clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.