Information on personal data protection
Comland is aware of the responsibility related to the processing of personal data of its customers, potential customers, site visitors of Comland and all individuals who disclose their personal information when contacting us. We have therefore brought our operations into line with the Personal Data Protection Act (PDPA-1, Official Gazette of the RS, no. 94/2007) and Regulation (EU) 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 and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as “General Data Protection Regulation”).
Expressions such as “controller”, “processing”, “restriction of processing”, “processor”, “profiling”, “pseudonymisation”, “third person” and “company” shall have the meaning as defined by the General Data Protection Regulation.
Comland protects with special care the security and privacy of information obtained from its web page users and their personal data in compliance with the applicable legal provisions of the Republic of Slovenia. Please read more below about collecting, saving, using and disseminating information.
You may use our website without entering your personal data. You are only asked to submit your personal data if you order any of our products or services.
Information on the controller and contact addresses
The data controller is company Comland d.o.o., Litostrojska cesta 58c, 1000 Ljubljana.
Personal data is information that identifies you as an identified or identifiable individual. A user is identifiable when it can be directly or indirectly determined, in particular by specifying identifiers such as name, identification number, location data, online identifier or an indication of one or more factors that are specific to the user’s physical, physiological, genetic, mental, economic, cultural or social identity.
What type of personal data do we collect on our website?
You may use our website without entering your personal data. You are only asked to submit your personal data if you order any of our products or services or send us e-mail.
We collect personal data only when you send them to us by registration, completion of forms or e-mails, as part of an order of products or services, inquiries or requests about materials being ordered and similar situations when you decide to send your personal data to us.
For which purposes do we process data you submit through our website?
The data you send to us may be processed for the following purposes: providing you with products or services you have ordered through our website; or for other purposes you have requested or agreed to, unless otherwise required by law.
Where do we store personal data you submit through our website?
Your personal data is stored on our servers that we manage ourselves. Our business partners, who in some cases store personal data for us, ensure a level of protection that is at least equivalent to the one we have at Comland. Your personal data shall not, in any form, be conveyed to third parties, unless we obtain your consent to do so, or if so required by legal authorities.
The retention period of personal data
Comland does not process the data for longer than is necessary to achieve the purposes for which personal data have been collected and further processed. Personal data processed by Comand. for the performance of contract are kept by Comland. for the period which is necessary for the execution of the contract and 5 years after its termination, except in cases where there is a dispute between you and the controller concerning the contract. In this case, Comland keeps data for 5 years after the final judicial or arbitral decision or settlement, or if there is no litigation, 5 years from the date of an amicable settlement.
Personal data processed by Comland on the basis of the law are kept by Comalnd. for the period prescribed by law. Personal data processed by the controller based on your personal consent or legitimate interest are kept by Comland. permanently, until your consent is revoked or until a request is made to discontinue processing. Comland shall delete such data before cancellation only in the event that the purpose of the processing of personal data has already been made or if the law so provides.
After the expiration of the retention period, Comland will effectively and permanently delete or anonymise your personal information so that it will no longer be associated with you.
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Users’ rights relating to the protection of personal data
In accordance with the General Data Protection Regulation, Comland provides the following rights regarding the protection of personal data, which are discussed in more detail below:
- The right of access to information,
- The right of rectification,
- The right to delete (“right to oblivion”),
- The right to limit processing,
- The right to data portability,
The right to object.
The right of access to information
You have the right to obtain confirmation from Comland as to whether your personal data are processed, and if so, you have the right to obtain access to your personal data and the following information concerning the processing of personal data:
- The purpose of processing,
- Type of personal data,
- Users or user categories which have been or will be disclosed your personal information, especially users in third countries or international organizations,
- Where possible, the expected period of retention of personal data or, if this is not possible, the criteria used to determine this period,
- Existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data relating to data subjects, or existence of the right to object to such processing,
- The right to lodge a complaint with the supervisory authority,
- Where personal data are not collected from the user, all available information as to their source,
- Existence of an automated decision-making, including the creation of profiles and meaningful information about the reasons for it, as well as the importance and the anticipated consequences of such processing for the user.
Based on your request, Comland will provide you with one free copy of your personal data being processed. Any additional copies of data that you should require will be charged a reasonable fee by the company to take into account administrative costs.
Right of rectification
You have the right to request from Comland to correct, without undue delay, any inaccurate personal data relating to you. Considering the purposes of the processing, you are entitled to the completion of incomplete personal data, including the presentation of a supplementary declaration.
The right to delete (“right to oblivion”)
You have the right to request from Comland to delete your personal information without undue delay; the company shall delete your personal information, without undue delay, in the following cases:
- The data are no longer needed for the purposes for which they were collected or otherwise processed,
- You cancel your consent, which is the basis for the processing of your personal data, and there is no other legal basis for the processing,
- You object to the processing on the basis of a legitimate interest of the controller, and there are no overriding legitimate reasons for the processing,
- You object to processing for the purposes of direct marketing,
- Personal data must be deleted to comply with legal obligations under European Union law or the Slovenian legal order.
Where Comland transmits your personal information, it shall take reasonable steps, including technical, to inform the processors who process your personal information that the data subject requires from the controller to erase any links to these personal data or copies thereof.
The right to limit processing
You have the right to require that Comland restrict the processing of your personal data subject to one of the following cases:
- You dispute the accuracy of the data for the period which enables the controller to verify the accuracy of your personal data,
- The processing is unlawful, and you oppose the deletion of personal data, and instead ask for restrictions on their use,
- Comland no longer needs personal data for the purposes of the processing, but you need them for the establishment, exercise or defence of legal claims,
- You filed an objection with regard to the processing, until it is checked whether legitimate reasons of the controller outweigh your reasons.
The right to data portability
You have the right to receive personal data relating to you in possession of Comland in a structured, widely used and machine-readable form, and the right to forward such information to another controller, without Comland for whom the data was provided, hampering you, where:
- Processing is based on your consent or agreement and
- Processing is carried out by automated means.
The right to object
On grounds related to your particular situation, you have the right, at any time, to object to the processing of personal data if this is based on the legitimate interests pursued by Comland d.o.o. or a third party Comland will cease to process personal data, unless it proves compelling reasons for processing that outweigh your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. Where personal data are processed for direct marketing purposes, you have the right, at any time, to object to the processing of your personal data for such marketing purposes, including profiling, if it is associated with such direct marketing. Where direct marketing is based on consent, the right of reply can be made by cancelling the given personal consent.
Procedure for asserting your rights
All the above-mentioned requirements which relate to the exercise of rights in connection with your personal data may be addressed in writing to the controller by using the contact addresses for personal data protection. If you submit your request in accordance with the above paragraph by electronic means, the information, to the extent possible, will be provided to you by electronic means, unless you request otherwise.
For the purposes of reliable identification in the event of exercising your rights with respect to personal information, the controller may request additional information from you needed to confirm your identity; it may refuse to act in accordance with this chapter only in the event that it proves that you cannot be reliably identified.
The request by which you exercise your rights in relation to your personal data will be responded without undue delay and no later than one month from receipt of the request. Comland may extend the limit for exercising the rights for up to two additional months, considering the complexity and the number of requests. Where Comland extends the deadline, you will be notified of any such extension within one month of receipt of the request together with the reasons for the delay.
Where, in accordance with this chapter, your requests are manifestly unfounded or exaggerated, especially since they are repeated, Comland may:
- Charge a reasonable fee, taking into account administrative costs of the provision of information or messages or performing the required action,
- Dismiss action concerning the request.
The right to lodge complaints with regard to the processing of personal data
Any complaint with regard to the processing of your personal data may be directed to the contact addresses for personal data protection.
You have the right to lodge a complaint directly with the Information Commissioner if you think that the processing of personal data relating to you violates Slovenian rules or regulations of the European Union in the field of personal data protection.
Comland designated a Data Protection Officer (DPO) who is in charge of personal data protection
Data protection officer
Litostrojska cesta 58c
Rights of data subjects
You can submit request (for Access, Rectification, Erasure and Withdrawal of Personal Consent, Restriction of Processing and Objection to Processing) in person or as a certified document by a notary or an administrative unit serving as proof that the right person is exercising their right. Protection of personal data against unauthorised consultation and ensuring personal data accuracy are among key objectives of the GDPR, therefore data subjects must accept Comland’s requirement for identification. Otherwise anyone could request a copy or a rectification of anyone’s personal data, and this could lead to unauthorised disclosure or use of incorrect personal data.
In cases where data subjects give consent following a request by electronic means, the withdrawal of such a consent shall be possible, and the identity of such data subjects shall be verified using e-mail confirmation.
We shall address each request submitted by data subjects and carry out appropriate procedures or notify data subjects that this is not possible and state the reason why.
Comland uses technical and organizational security precautions to protect data from manipulation, loss, destruction or access by unauthorized persons. To ensure the security and confidentiality of personal data that we collect on-line, we use data networks that are among other things protected also by industry standard firewall and password. In the course of handling personal data, we take measures reasonably designed to protect that information from loss, misuse, unauthorized access, disclosure, alteration or destruction. While we cannot guarantee against any loss, misuse, unauthorized access, disclosure, alteration or destruction of data, we endeavour to prevent such unfortunate occurrences.
Changes to this document
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Last updated in June 2019