As privacy and the processing of your personal data are important to us, we carefully protect them in the La Popsi refrigerator. If you want to know how we process them, open the refrigerator and read.
Personal Data Protection Policy
About the Personal Data Protection Policy
The purpose of the Personal Data Protection Policy (hereinafter: the Policy) is to inform users and other individuals (hereinafter: Users) about the purposes and basis of processing personal data by La Popsi d.o.o., as well as the rights of Users in this area. At the same time, this Policy further explains consent for data processing. In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter the General Data Protection Regulation), the Policy includes the following information: La Popsi d.o.o. contact information and the contact information of the data protection officer, the purposes, bases, and types of processing of various types of personal data of Users, including profiling of Users’ personal data, the transmission of data to third parties and to third countries, the retention period of individual types of personal data, Users’ rights in relation to the processing of personal data, and the right to lodge a complaint in relation to the processing of personal data. Where appropriate, provisions relating to Users also apply to the confidentiality and secrecy of Users’ communications that are legal persons.
Manager and authorized person for data protection
The controller of personal data of users processed in accordance with the Policy of personal data protection is La Popsi d.o.o. Within La Popsi d.o.o, an authorized person for data protection has been appointed, who can be contacted at the email address firstname.lastname@example.org.
Purposes of processing and legal basis for processing data
La Popsi d.o.o processes personal data of users for the sale of goods and/or services on the basis of a contract. In the course of asserting rights and fulfilling contractual obligations, La Popsi d.o.o processes personal data of users for the following purposes: identification of the user, preparation of offers, conclusion of contracts, delivery of services or products, delivery of products and/or documentation to the home, notification of changes in legislation in a particular area, implementation of changes in the contractual relationship, invoicing of services, resolution of any technical issues, objections or complaints of users, sending notifications to users regarding the implementation of the contractual relationship, implementation of any recovery procedures, sale of claims and for other purposes necessary for the implementation or conclusion of the contractual relationship between La Popsi d.o.o and the user.
La Popsi d.o.o processes personal data of users in accordance with the La Popsi law for the purposes of creating, implementing, monitoring and terminating contracts.
La Popsi d.o.o can also process data based on a legitimate interest pursued by La Popsi d.o.o or a third party, except when such interests are overridden by the interests or fundamental rights and freedoms of the individual whose personal data is being processed, especially when the data relates to a child. When it comes to the further use of data collected about the user, La Popsi d.o.o conducts an assessment in accordance with the General Data Protection Regulation. Such further use of data in pseudonymized or aggregated form, for example, represents a lawful use of data for marketing and other business or technical analyses by La Popsi d.o.o. As an additional measure for certain forms of further traffic data, the deletion of certain data may also be used. Direct marketing is also considered a legitimate interest in accordance with the General Data Protection Regulation. For the purposes of direct marketing, La Popsi d.o.o may also create user profiles without consent based on basic information such as subscribed services or products, or past marketing contacts with the user, particularly regarding expressed interest or lack of interest in certain services or products. The user may object to such processing in accordance with section 6/iv of the policy.
La Popsi d.o.o may contact users for the purpose of improving services in accordance with a legitimate interest, for the purpose of determining their satisfaction with the services or user experience, even in cases where it is not necessary to execute a contract. La Popsi d.o.o does not contact users who have objected to this again due to the weighing of this interest against the user’s interests. La Popsi d.o.o has a legitimate interest in anonymizing or aggregating data until the expiration of the legal retention period and further using it for marketing, network planning, and similar purposes. Other legitimate interests may include asserting claims or defending against claims in administrative and judicial proceedings. In the event of suspected abuse, La Popsi d.o.o may process user data to the extent necessary and proportionate for the purpose of identifying and preventing potential fraud or abuse, and may also transmit this data to other operators, business partners, the police, the state prosecutor’s office or other competent authorities, if appropriate.
Processing based on consent for the processing of personal data
Data processing may be based on consent given by an individual to La Popsi d.o.o. Consent may relate, for example, to information about offers and services, preparation of offers tailored to individual user habits, or the provision of value-added services. Notification is carried out through channels selected by the user in the consent. Using an email address for notifications may include providing the email address to an external processor to display La Popsi d.o.o’s advertising messages while browsing the web. The user whose personal data is processed may withdraw or change their consent at any time in the same way that consent was given, or in another way defined by La Popsi d.o.o, with La Popsi d.o.o reserving the right to identify the customer. Consent change can be arranged, among other things, through a contact center. Revocation or change of consent applies only to data processed based on consent. The last consent provided by the user received by La Popsi d.o.o is valid. The possibility of withdrawing consent does not represent a contractual right of the user with La Popsi d.o.o. One of the parents, foster parents, or legal guardians may give consent for a minor child who, according to applicable law, cannot give consent on their own. Such consent will be valid until revoked or changed by one of the parents, foster parents, or legal guardians, or the child himself when he acquires this right in accordance with applicable law.
Disclosure of data to third parties and transfer of data to third countries (countries that are not members of the European Union or the European Economic Area)
La Popsi d.o.o may, if it is in accordance with the purpose for which personal data are processed under EU and Slovenian laws, disclose personal data of users to: (i) persons who perform individual processing tasks for La Popsi d.o.o, such as preparing and sending invoices or data analytics; (ii) persons who provide sales and marketing services for La Popsi d.o.o, including field sales and marketing, or collaborate with La Popsi d.o.o in the field of marketing and selling their own services or the services of third parties, to the extent necessary for such tasks within the purposes and bases defined in this Policy. Traffic data may be processed only by authorized persons within La Popsi d.o.o who, under the supervision of La Popsi d.o.o, manage traffic billing, respond to user inquiries, detect fraud, market, provide value-added services or perform other tasks requiring the processing of personal data, with such processing being limited to the extent necessary for such activities. The transfer of data to third countries is provided in accordance with the legal bases for the transfer of data to third countries prescribed by EU law and applicable Slovenian regulations.
Accounts are stored for 10 years after the end of the year to which the account refers in accordance with the law governing value-added tax. If data on transactions are processed based on the User’s consent for marketing services, sale of goods, or the provision of value-added services, such data can be processed to the necessary extent for such marketing or services.
User Rights Regarding Personal Data Processing
La Popsi d.o.o ensures that Users can exercise their rights without undue delay and in any case within one month of receipt of the request. La Popsi d.o.o may extend the deadline for exercising User rights by up to two additional months, taking into account the complexity and number of requests. If La Popsi d.o.o extends the deadline, it informs the User of each such extension within one month of receipt of the request, along with the reasons for the delay. La Popsi d.o.o accepts requests regarding User rights via email or mail to La Popsi d.o.o. When there is reasonable doubt about the identity of the User submitting a request regarding one of their rights, La Popsi d.o.o may request additional information necessary to confirm the identity of the individual to whom the personal data relates. If a User’s requests relating to personal data are manifestly unfounded or excessive, particularly because they are repetitive, La Popsi d.o.o may charge a reasonable fee, taking into account the administrative costs of providing information or communication or taking the requested action, or refuse to take action regarding the request. La Popsi d.o.o allows Users the following rights regarding the processing of personal data: the right to withdraw consent, the right to object, the right to rectification, the right to restriction of processing, the right to data portability, the right to lodge a complaint, and the right to access to erasure (“right to be forgotten”). The User to whom the personal data relates has the right to receive confirmation from La Popsi d.o.o as to whether personal data concerning them is being processed, and where that is the case, access to personal data and additional information relating to the processing of personal data, including: the purposes of the processing; the types of personal data; 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 organizations; 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 right to lodge a complaint with a supervisory authority; where the personal data are not collected from the User, any available information regarding their source.
Right to withdraw consent: Where the processing of your personal data is based on your consent, you may withdraw that consent at any time. You can withdraw your consent in writing to La Popsi d.o.o, Šubičeva ulica 7, 1234 Mengeš, marked “for PVOP”.
Right of access: You may request information from La Popsi d.o.o about the personal data it holds about you at any time, including information about the types of personal data it holds, what it uses them for, where it collects them from if not directly from you, to whom they have been disclosed if appropriate, the period of retention of your personal data, your rights relating to your personal data, and information about the existence of automated decision-making (including profiling) and the reasons for it, as well as the significance and envisaged consequences of such processing for you.
Right to rectification: You may request that La Popsi d.o.o correct any inaccurate personal data it holds about you at any time.
Right to restriction: You may request that La Popsi d.o.o restrict the processing of your personal data if: you contest the accuracy of your personal data, for a period during which La Popsi d.o.o verifies the accuracy of the data; the processing is unlawful and you request restriction of processing instead of erasure of your personal data; La Popsi d.o.o no longer needs your data but must keep it for the establishment, exercise, or defense of legal claims; or you object to processing while La Popsi d.o.o verifies whether its legal basis overrides your interests.
Right to data portability: Upon request and where technically feasible, La Popsi d.o.o will transfer your personal data to another controller, if the processing is based on your consent or necessary for the performance of a contract and if the processing is carried out by automated means.
Right to object: If processing is based on your consent or necessary for the performance of a contract and if the processing is carried out by automated means, you may object to the processing of personal data relating to you at any time for reasons related to your particular situation. If your personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing, including profiling. In addition, you have the right to object to the processing of your personal data for reasons related to your particular situation when the personal data are processed for scientific or historical research or statistical purposes, unless the processing is necessary for the performance of a task carried out in the public interest.
Automated decision-making, including profiling, You have the right to request that La Popsi d.o.o does not apply a decision based solely on automated processing of your personal data, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Right to lodge a complaint In case of a suspected violation of privacy laws, you have the right to lodge a complaint with the supervisory authority for data protection in the country where you reside or where the alleged violation occurred.
Right to erasure You have the right to request that La Popsi d.o.o erase your personal data at any time, if: the personal data are no longer necessary for the purposes for which they were collected or otherwise processed; processing is based on your consent, and you withdraw your consent and there is no other legal basis for the processing; processing is based on your consent, and you object to the processing, and there is no other legal basis for the processing; the personal data have been processed unlawfully; it is necessary to comply with legal obligations; the personal data were collected in relation to the offer of information society services directly to a child. Processing of personal data of a child is lawful if the child is at least 16 years old. If the child is under the age of 16, such processing is lawful only if such consent is given or authorized by the child’s parent or legal guardian.
Validity of the Policy
This Policy was published on 19.12.2019 and takes effect on 19.12.2019.