Privacy policy
1. Important Information and who We are
Purpose of this Privacy Policy
1.1 The “Company”
as set forth in this Privacy Policy shall refer to:
TRIMO, arhitekturne rešitve, d.o.o.
Prijateljeva
cesta 12
SI-8210 Trebnje
Business Number: 5033411000
Tax and VAT ID Number: SI 85524310
1.2
This Privacy Policy aims to give you information on how the Company collects and processes your
personal data through your use of this website and through the use of our CRM.
1.3 This
website is not intended for children and we do not knowingly collect data relating to children.
1.4
It is important that you read this Privacy Policy together with any other privacy notice or fair
processing notice we may provide on specific occasions when we are collecting or processing personal
data about you so that you are fully aware of how and why we are using your data. This Privacy
Policy supplements the other notices and is not intended to override them.
Controller
1.5
The Company is the controller and responsible for your personal data (collectively referred also
to as “we”, “us” or “our” in this Privacy Policy.
Contact Details
1.6 Our
full details are:
(a) Full name of legal entity: TRIMO, arhitekturne rešitve, d.o.o.
(b)
Email address: privacy@trimo-group.com
(c) Postal address: Prijateljeva cesta 12, SI-8210
Trebnje, Slovenia
(d) Telephone number: +386 (0)7 34 60 200
1.7 You have the right
to make a complaint at any time to the Information Commissioner (“Informacijski Pooblaščenec”;
IP), the Republic od Slovenia’s supervisory authority for data protection issues (https://www.ip-rs.si).
We would, however, appreciate the chance to deal with your concerns before you approach the IP
so please contact us in the first instance.
Changes to the Privacy Notice and Your Duty to Inform Us of Changes
1.8
This version was last updated on 24th May 2018.
Third Party Links
1.9 This
website may include links to third-party websites, plug-ins and applications. Clicking on those
links or enabling those connections may allow third parties to collect or share data about you.
We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our website, we encourage you to read the privacy notice of every website you
visit.
2. The Data we collect about You
2.1 Personal data, or personal information, means
any information about an individual from which that person can be identified. It does not include
data where the identity has been removed (anonymous data).
2.2 We may collect, use, store
and transfer different kinds of personal data about you which we have grouped together follows:
(a)
Identity Data includes [first name, last name and gender].
(b) Contact Data includes [company, email address and telephone number and country].
(c) Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone
setting and location, browser plug-in types and versions, operating system and platform and other
technology on the devices you use to access this website].
(d) Usage Data includes
[information about how you use our website, products and services].
(e) Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication
preferences].
2.3 We also collect, use and share Aggregated Data such as statistical or demographic
data for any purpose. Aggregated Data may be derived from your personal data but is not considered
personal data in law as this data does not directly or indirectly reveal your identity. For example,
we may aggregate your Usage Data to calculate the percentage of users accessing a specific website
feature. However, if we combine or connect Aggregated Data with your personal data so that it
can directly or indirectly identify you, we treat the combined data as personal data which will
be used in accordance with this Privacy Policy.
2.4 We do not collect any Special Categories of Personal Data about you.
3. How is Your Personal Data collected?
3.1 We use different methods to collect data from and about you including through:
(a) Direct interactions. You may give us your Identity, Contact and other Personal Data by
filling in forms or by corresponding with us by post, phone, email or otherwise. This includes
personal data you provide when you:
(i) contact us through
different types of business cooperation;
(ii) use contact
form or newsletter subscription on our website;
(iii)
request marketing to be sent to you;
(iv) enter a competition.
(b)
Automated technologies or interactions. As you interact with our website, we may automatically
collect Technical Data about your equipment, browsing actions and patterns. We collect this personal
data by using cookies, google analytics and other similar technologies. Please see our Cookie
Policy for further details.
(c) Third parties or publicly available sources. We may
receive personal data about you from various third parties and public sources as set out:
(i) Technical Data from the following parties:
(A) search
information providers such as company registers, different public business databases, databases
of projects and companies.
(d) Identity and Contact Data from publicly availably sources.
4. How we use Your Personal Data
4.1
We will only use your personal data when the law allows us to. Most commonly, we will use your
personal data in the following circumstances:
(a) Where
we need to perform the contract we are about to enter into or have entered into with you.
(b) Where it is necessary for our legitimate interests
(or those of a third party) and your interests and fundamental rights do not override those interests.
(c) Where we need to comply with a legal or regulatory obligation.
4.2 Generally
we do not rely on consent as a legal basis for processing your personal data other than in
relation to sending direct marketing communications to you via email. You have the right
to withdraw consent to marketing at any time by using Unsubscribe link.
Purposes for which We will use Your Personal Data
4.3
For the most cases we will process your data because it is necessary for the performance
of a contract to which the you are a party or in order to take steps at the request of you
prior to entering into a contract.
4.4 From time to time we will also use your data
for purposes of informing you on our new products, or our special sale offers – for this
we will obtain your consent as described below.
Marketing
Promotional offers from Us
4.5
We may use your Contact, Technical and Usage Data to form a view on what we think you may
want or need, or what may be of interest to you. This is how we decide which products, services
and offers may be relevant for you (we call this marketing).
4.6 You will receive
marketing communications from us if you have requested information from us or purchased products
or services from us and, in each case, you have not opted out of receiving that marketing.
Opting-Out
4.7
You can ask us to stop sending you marketing messages at any time by Contacting us at any
time.
4.8 Where you opt out of receiving these marketing messages, this will not apply
to personal data provided to us as a result of a product/service purchase or warranty registration
or other transactions.
Cookies
4.9 You can set your browser to refuse
all or some browser cookies, or to alert you when websites set or access cookies. If you
disable or refuse cookies, please note that some parts of this website may become inaccessible
or not function properly. For more information about the cookies we use, please see our Cookie
Policy.
Change of Purpose
4.10 We will only use your personal data for
the purposes for which we collected it, unless we reasonably consider that we need to use
it for another reason and that reason is compatible with the original purpose. If you wish
to get an explanation as to how the processing for the new purpose is compatible with the
original purpose, please Contact us.
4.11 If we need to use your personal data for
an unrelated purpose, we will notify you and we will explain the legal basis which allows
us to do so.
4.12 Please note that we may process your personal data without your
knowledge or consent, in compliance with the above rules, where this is required or permitted
by law.
5. International Transfers
5.1 We do not share or transfer your
data outside the European Economic Area (EEA).
6. Data Security
6.1
We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition,
we limit access to your personal data to those employees, agents, contractors and other third
parties who have a business need to know. They will only process your personal data on our
instructions and they are subject to a duty of confidentiality.
6.2 We have put in
place procedures to deal with any suspected personal data breach and will notify you and
any applicable regulator of a breach where we are legally required to do so.
7. Data Retention
How long will you use My Personal Data for?
7.1 We will only retain your personal data
for as long as necessary to fulfil the purposes we collected it for, including for the purposes
of satisfying any legal, accounting, or reporting requirements.
7.2 In some circumstances
you can ask us to delete your data: see Request erasure below for further information.
7.3
In some circumstances we may anonymise your personal data (so that it can no longer be associated
with you) for research or statistical purposes in which case we may use this information indefinitely
without further notice to you.
8. Your Legal Rights
8.1 Under certain circumstances, you have rights under data protection
laws in relation to your personal data. Please click on the links below to find out more about
these rights:
(a) Request access to your personal data.
(b) Request correction of your personal data.
(c) Request erasure of your personal data.
(d)
Object to processing of your personal data.
(e)
Request restriction of processing your personal data.
(f)
Request transfer of your personal data.
(g) Right
to withdraw consent.
8.2 If you wish to exercise any of the rights set out above,
please Contact us at privacy@trimo-group.com.
8.3
You will not have to pay a fee to access your personal data (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive
or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What We need from You
8.4
We may need to request specific information from you to help us confirm your identity and
ensure your right to access your personal data (or to exercise any of your other rights).
This is a security measure to ensure that personal data is not disclosed to any person who
has no right to receive it. We may also contact you to ask you for further information in
relation to your request to speed up our response.
Time limit to respond
8.5
We try to respond to all legitimate requests within one month. Occasionally it may take us
longer than a month if your request is particularly complex or you have made a number of
requests. In this case, we will notify you and keep you updated.
9. Glossary
Lawful basis
9.1
Legitimate Interest means the interest of our business in conducting and managing
our business to enable us to give you the best service/product and the best and most secure
experience. We make sure we consider and balance any potential impact on you (both positive
and negative) and your rights before we process your personal data for our legitimate interests.
We do not use your personal data for activities where our interests are overridden by the
impact on you (unless we have your consent or are otherwise required or permitted to by law).
You can obtain further information about how we assess our legitimate interests against any
potential impact on you in respect of specific activities by Contacting us
9.2 Performance of Contract means processing your data where it is necessary for the performance of a contract to which
you are a party or to take steps at your request before entering into such a contract.
9.3
Comply with a legal or regulatory obligation means processing your personal data where
it is necessary for compliance with a legal or regulatory obligation that we are subject
to.
Your legal rights
9.4 You have the right to:
(a)
Request access to your personal data (commonly known as a “data subject access request”).
This enables you to receive a copy of the personal data we hold about you and to check that
we are lawfully processing it.
(b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate
data we hold about you corrected, though we may need to verify the accuracy of the new data
you provide to us.
(c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason
for us continuing to process it. You also have the right to ask us to delete or remove your
personal data where you have successfully exercised your right to object to processing (see
below), where we may have processed your information unlawfully or where we are required
to erase your personal data to comply with local law. Note, however, that we may not always
be able to comply with your request of erasure for specific legal reasons which will be notified
to you, if applicable, at the time of your request.
(d)
Object to processing of your personal data where we are relying on a legitimate interest
(or those of a third party) and there is something about your particular situation which
makes you want to object to processing on this ground as you feel it impacts on your fundamental
rights and freedoms. You also have the right to object where we are processing your personal
data for direct marketing purposes. In some cases, we may demonstrate that we have compelling
legitimate grounds to process your information which override your rights and freedoms.
(e) Request restriction of processing of your
personal data. This enables you to ask us to suspend the processing of your personal data
in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where
our use of the data is unlawful but you do not want us to erase it; (c) where you need us
to hold the data even if we no longer require it as you need it to establish, exercise or
defend legal claims; or (d) you have objected to our use of your data but we need to verify
whether we have overriding legitimate grounds to use it.
(f)
Request the transfer of your personal data to you or to a third party. We will provide
to you, or a third party you have chosen, your personal data in a structured, commonly used,
machine-readable format. Note that this right only applies to automated information which
you initially provided consent for us to use or where we used the information to perform
a contract with you.
(g) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect
the lawfulness of any processing carried out before you withdraw your consent. If you withdraw
your consent, we may not be able to provide certain products or services to you. We will
advise you if this is the case at the time you withdraw your consent.