Privacy Notice

Privacy policy regulates the collection, storage, processing and protection of the personal data and the use of cookies processed by the PROMIN Trgovina site. The website is managed by PROMIN d.o.o., Karantanska 20, SI-1230 Domžale.

The Privacy Notice is collected to inform buyers about the purposes and the basis of processing the personal data on the PROMIN pages and to inform buyers about their rights in this field. Moreover, it gives information about cookies and their processing in connection of using the web site.

The security of our buyer's personal data is our priority. We pay great attention to their protection. PROMIN, in the role of the manager of processing and handling of the buyer's personal data, will handle them accordant with the requirements of the applicable legislation in the field of personal data protection. In order to protect personal data, the operator will take all organizational, technical and other appropriate procedures and measures to prevent an unauthorized destruction, change, loss or unauthorized processing of the data. All information provided is protected against the unauthorized access of the third parties. Buyer's personal data are protected from loss, destruction, forgery, manipulation and unauthorized access or disclosure at all times in accordance with the policy of the website hosting company.

We collect different information about you, which depends on the level of the business relationship with you.

In the case you bought a book or merchandise, we collect the following data: name, surname, address (including date of changes), date of birth, buyer's code, notification method, date of input, contact date, delivery address, tax number (companies), payment method, credit card information (in case of credit card use), landline phone, mobile phone, sex, email address, number of purchases, amount of purchases, amount of debt, past orders, past shopping habits (delivery method, special services, e.g. delivery in the morning, etc.), data about orders and purchases (purchase history: particular item, trademark), responses to telephone calls in the past, date of order, date of invoice, and response to sent offers.

Processing of the personal data regards any processing or a series of processes that are carried out to execute required services or to perform measures to accomplish buyer order. Operations that regard the personal data collections are automated or manually processed. They may be put into the personal data collection, particularly: collection, acquisition, input, editing, storage, alteration or modification, recall, inspection, use, disclosure by transmission, informing, dissemination or availability, classification or linking, blocking, anonymizing , deletion or purging. Processing can be manual or automated.

PROMIN is processing the personal data of buyers to fulfill the obligations that originates from contract relationship made with buyers (book orders, merchandise). Performing the contractual obligations and exercising rights under the contract, PROMIN is processing the contact personal data of buyers (name, surname, address, telephone number, postal address, e-mail) to meet the following needs: identification of the buyer or member, contract conclusion, supply of ordered goods, delivery of ordered goods to desired address, investigation and analysis of buyer's purchasing habits, and consequently directed marketing. On that basis, the buyer or member receive notifications about interesting offers from PROMIN. Buyer can also receive offers and other information that are adjusted to each buyer separately. Moreover, buyer also receives notifications about resolving any objections and complaints, and information that regards the implementation of the contractual relationship. Additionally, buyer can receive information about execution of debts and for other purposes that are necessary for the implementation or conclusion of a contractual relationship between PROMIN and buyer or member.

Based on a local legislation (e.g. tax legislation), certain data must be kept for a specified period of time. PROMIN is obliged to keep that kind of data also in case of cancellation the consent for processing of the personal data. The same can be expected, if buyer requests limitation of processing the personal data or terminates the contract with PROMIN. PROMIN will destroy those data after the statutory period passes.

PROMIN can process the personal data on the basis of legitimate interest, but only on careful judgment that the interests of PROMIN do not override the interests or fundamental rights and freedoms of the buyer. Doing so, the reasonable expectations of buyers are taken into account, depending on their relationship with the operator, which is PROMIN. In accordance with the GDPR (General Data Protection Regulation), the lawful interests of the data manager are those data, which are necessary to prevent fraud, misuse and to recover unpaid contractual obligations from buyers. The personal data of buyers are processing in a limited extent also for direct marketing, on the basis of legitimate interest. In that case the processing of the personal data is limited in time; general offers for a maximum of five years from the last purchase, and in the case of luxury issues the time can be longer exceptionally. The processing of data is subject to strict conditions of applicable law and is carried out in a very limited extent, especially for segmentation and profiling purposes. The collecting of personal data does not reach a great extent in any case. Collection is not intrusive and does not include specific types of the personal data. Data collection is organized in a way that the position of buyer is not subordinated to the data manager. The personal data are not a base for automated or other kind of decision of his rights in any way. Buyer may object for his data to be processed at any time.

Data processing can base on the consent that buyer is given to PROMIN. PROMIN is processing the personal data of buyers for the following purposes: identification of buyer, notifications about offers and other information, estimations and analysis of buyer responses to addressed offers. To inform buyer the following methods can be used: mail, e-mail, telephone, SMS messages. It depends on the buyer, which method he chose when giving consent to PROMIN for direct marketing purposes.

The buyer, to whom the personal data relates, may withdraw or change his consent at any time, in the same way as the consent was given. The withdrawal of his consent can be alternatively given in other way that is declared by PROMIN. PROMIN is reserving the right to identify the buyer who gives such a request, when a reasonable doubt about his identity exists, in order to properly fulfill his obligation, accordant with the buyer's request. The right to cancel consent of the personal data does not affect to existing relationship with PROMIN that obligated the buyer, unless he settle a debt. Since under aged child can not give consent on his own, the consent may be given one of his parents or legal representative. Such consent is valid as long as one of the parents or legal representative recalls or changes it. The same can perform the child himself, but not until he reaches full age, according to the valid legislation.

In the cases when consent involves direct marketing on the basis of the buyer's profile, PROMIN may carry out buyer profiling on the basis of his past purchases. This allows the buyer to receive a customized offer or information from PROMIN, which suits his taste and habits. The profiling has no legal consequences for buyer in relation to PROMIN, not in terms of obligations or in terms of legal consequences. Profiling, for the purpose of direct marketing, may include the use of birth date.

The personal data of the buyer will be transferred to third parties or in other way only, if this is necessary to perform rights and obligations arising from a sales contract. The basis for data transfer is the legitimate interest of the data manager or explicit agreement of the buyer.

Data will be transferred to:

• companies that issue credit cards, to payment service providers to process payments and to banks for implementing the buyer's order in purpose to complete the sales contract
• transport companies, postal services for the purpose of delivery of the ordered products, and to resolve buyer complaints and withdrawing from the contract
• press companies for the purpose of printing

PROMIN keeps and processes the personal data of buyers as long as it is strictly necessary to achieve the purpose for which they were processed.

In case that the personal data is processed on the basis of consent, PROMIN keeps and processes them until the consent is revoked by the buyer.

Based on legislation, PROMIN usually keeps data for 5 years from the last purchase.

PROMIN, as the data manager, is obliged to keep specific data for 10 years from their publishing, in accordance with the current legislation (e.g. invoices). The data of participants of prize games are stored only for the time, until the prizes are awarded. After then they are deleted. The personal data of the winners are accepted. They are obliged to be kept according to the valid legislation for 10 years from award.

PROMIN ensures that personal data will be deleted or that access to the collected data will be blocked, after the purpose of data processing is completed or after buyer revokes his consent. Instead of erasing, due to the need for further market analyzes and the investigation of purchasing habits, PROMIN may decide to anonymize some of data. That has to be performed in a way that buyer's data are no longer recognizable.

Implementation of the buyer's rights without undue delay is provided by PROMIN. Buyer complains and other claims will be solved within a time limit declared by authoritative legislation. In the case when deadline is longer than 1 month, buyer rights will be accomplished likewise in 1 month from the day when buyer's request will be received. Taking into account the complexity and number of requests, PROMIN may extend the deadline for maximum of 2 additional months, to accomplished rights of the buyer. In such a case, PROMIN shall inform the buyer of any extension, together with reasons for the extension. The notification shall be sent within 1 month from requested claim.

All claims and requirements about processing the buyer personal data have to be addressed to PROMIN e-mail address: info@promin.si or posted to PROMIN doo, Karantanska 20, 1230 Domžale.

If buyer sends the upper mentioned data in , the PROMIN's shall also reply in electronic form, unless buyer demands some other communication way. When a reasonable doubt about the buyer's identity appears, PROMIN may request additional information that is necessary to establish or confirm his identity. If the buyer's claims are clearly unfounded or excessive, especially, if they are repeated, PROMIN may charge a reasonable price for processing buyer's requests. The administrative costs for managing, processing and transmitting the buyer's request are taking into account. The other possibility is to reject buyer's request.

PROMIN provides buyers with the following rights that regard processing of the personal data:

• right to access data
• right to change
• right to delete (right to forget)
• right to restrict processing
• right to data portability
• right to object

The buyer to whom the personal data relates has the right to obtain confirmation from PROMIN whether any personal data is processed about him. Where this is the case, PROMIN shall give to user access to his personal data and additional information concerning the processing of the personal data, on the buyer's request. Those data are:

• purpose of processing
• types of the personal data
• users or categories of users to whom the personal data have been or will be disclosed, in particular users in third countries (ie non-EU countries)
• the planned period of keeping the personal data or, if that is not possible, the criteria used to determine this period
• the existence of the right to demand on request that data manager to correct or to delete the personal data or to restrict processing of the personal data that relates the buyer, or existence of the right to object such processing
• the right to lodge a complaint to supervisor authority, i.e. Information Commissioner
• when personal data about buyer are not provided by him, a list of available sources from which data originates
• the existence of automated decision-making, including profiling, and meaningful information about reasons, as well as the significance and predicted consequences of such processing for the buyer

PROMIN provides a copy of the buyer's personal data that are being processed, on his request. PROMIN can charge a reasonable price for any additional copies of the personal data required by buyer, taking into consideration administrative and material costs.

Buyer, to whom the personal data relates, has the right to correct the inaccurate data by PROMIN, without undue delay. In the light of the purposes of the processing, buyer has the right to supplement incomplete information, including submission of a supplementary declaration.

Buyer has the right his personal data to be deleted, which is processing by PROMIN without undue delay:

• where data are no longer needed for purposes for which they were collected or otherwise processed
• when buyer withdraws his consent for his data processing and no other legal basis exists for the further processing
• when buyer objects to process his personal data based on PROMIN's legitimate interest, while there are no prevailing legal reasons for further processing
• where buyer objects to processing for direct marketing purposes
• when the personal data have to be deleted in order to fulfill a legal obligation in accordance with EU or Slovenian law
• when data are collected incorrectly from a child who, according to the applicable legislation, can not provide such information

Buyer, to whom the data relates, has the right to limit PROMIN to restrict processing, if:

• buyer disputes the accuracy of data that regard him, for a period of time which enable data manager to verify the accuracy of the personal data
• processing is illegal and buyer disputes to erase his personal data, while he requires a restriction on their use instead
• data are no longer needed for processing purposes to PROMIN, but buyer needs them to enforce, to proceed or to defend his legal claims
• until it is verified that the legitimate interests of the data manager prevail over buyer interests, to whom the data relates, since buyer filed an objection that concern data processing

Buyer has right to receive his personal data he has provided to PROMIN in a structured, generally known electronic form. Moreover, buyer has the right to forward those data to some other data manager, without any way hinders by PROMIN, if processing is based on buyer's consent or contract, and processing is made electronically.

Buyer has a right at any time to object to processing of his personal data, on grounds relating to his particular situation, if it is based on the legitimate interests pursued by PROMIN. PROMIN stops with processing his personal data unless it proves the necessary processing grounds that prevail over the interests, rights and freedoms of buyer, or when data are vital for enforcement, execution or defense of legal claims.

Where the personal data are processing for the purposes of direct marketing, buyer has the right at any time to object of processing his data for the purposes of such marketing, which include profiling, insofar as it relates to direct marketing. If direct marketing is based on consent, the right to object comes in effect by canceling the given personal consent.

Buyer shall send a complaint that regard processing of his personal data to data manager by e-mail: info@promin.si or by post to address: PROMIN doo, Karantanska 20, 1230 Domžale, Slovenia.

Additionally, buyer has a right, about his personal data, to lodge a complaint directly to Information Commissioner, if he considers that processing of his personal data violates Slovenian or EU regulations in the field of personal data protection.

If buyer claimed to PROMIN the right of receive his data, but PROMIN estimated that the buyer's data are not of the personal character or, if buyer believes that he has not received all personal data expected. He can file complaint to Information Commissioner, but before he is invited to send a reasoned complaint to PROMIN, within 15 days of receipt of the PROMIN's decision about the personal data. In that case PROMIN is obligated decide on complaint within 5 working days.

Files known by the name cookies are frequently used on websites during a buyer visit. Cookies are essential for providing friendly online services to buyer. The most common e-commerce functions would not be possible without cookies. Interaction between user and website is quicker and easier with the help of them. Due to the use of cookies, PROMIN can serve users more relevant and interesting offer and provide them with a pleasant user experience. Cookies store on the buyer's computer, smartphone or other similar device. Saving cookies is regulated by the buyer's browser. Buyer can limit or disable cookie storage, if he wishes. Cookies are not harmful and are always time-limited. With their help, the site remembers user's requirements, benefits and experience, therefore they save buyer's time and make web browsing more efficient, easy going and user-friendly.

Specific examples of using cookies:

• for better user experience, websites adjust display of the content according to past visits to user
• keeps user logged on where the login is required
• to identify user's device type for adjusting view of the content
• to monitor visits, which allows manager to adjust effectiveness of the content display, relevance of advertising and continuously improvement of web pages
• they are necessary for operation of certain web services, for example online stores

Webpage cookies origins from PROMIN domain or eventually its web address. Cookies from other web sites origin from their domains, which may have various elements embedded on site, e.g. ads or images. Cookies can be determined by the website where user (own cookies) is located, or it can be determined by the third website that manages a part of website content that is browsing by user (outer cookies). Cookies can be stored on buyer's device for different period of time, i.e. only for duration of the browsing session, or they can be stored for a longer period of time. A temporary or session cookie allows PROMIN to link user activities during his browsing on the web store. The browsing session starts when buyer opens the web-store page and it ends when page is closed. Temporary session cookies are created and are deleted when the user closes browser window. Permanent or stored cookies are cookies that remain stored on the user's device for a longer time. Permanent cookies are activated each time when user visits the site, which created that particular cookie. Three main types of cookies exist:

• Urgent cookies: these cookies are critical for navigation on websites and for using specific features of websites, or for providing the required services (for example, to store products that buyer has added to shopping cart). PROMIN does not require user permission to use these cookies.
• Web analytics cookies: these cookies help PROMIN to understand how users use websites. With their help, PROMIN improves user experience and recognizes buyer requirements and trends. PROMIN is using these cookies only, if the user agrees with.
• Target cookies or third-party advertising cookies: these cookies are used to deliver advertisements that are more relevant for user and his interests. They are also used to limit the number of representations of each advertisement. It is also used as a helping tool when measuring the effectiveness of an advertising campaign. They are usually installed by advertising companies with the permission of the site manager. Cookies remember that you have visited a website and this information is provided to other organizations, such as advertisers. Targeted or advertising cookies are frequently linked with functionality of a website that is provided by another organization. These include social network cookies (Twitter, Facebook or Google)

Cookie name	Purpose	Time to pass	Manager
_gat	Statistics of user's website views	30 minutes	PROMIN

There are several ways to manage and control user settings for cookies. By deleting or blocking cookies of a particular web page, it will not work properly or effectively in the same way as with the help of cookies. If user deletes all cookies, his choices will be lost and consequently, he will receive a cookie notification every time again he visits this site. Most modern web browsers provide general information about cookies. They allow to user to view all uploaded cookies and additionally allow him to delete all or specific cookies. User can block or allow cookies for all websites or for individual websites. In the same way, user may also exclude individual third-party advertising cookies. If a user changes personal cookie settings in his web browser, changes will apply to all websites he visits, not just for websites that are managed by PROMIN, unless he deletes or blocks each cookie separately. Information about cookies is usually located in the "help" menu of web browsers.

Privacy Notice written in English language can be used for informational purposes, while in the case of charge only the Slovene text has the legal authority.

Last modified: 19/7/2019

PROMIN d.o.o.