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Privacy terms

 

Company Privacy Terms ACTIVION d.o.o.

 

MEANING OF TERMS

Privacy terms

The privacy conditions are an internal act of the company ACTIVION d.o.o. ( hereinafter: the processor) and apply to all legal relationships between it and service subscribers (hereinafter: the operator). The act determines the rights and obligations of the processor and controller in the management and processing of personal data of individuals.

Personal information

Personal data means any information relating to a specific or identifiable individual who is a natural person. A designated individual is one whose personal data is determined and processed in accordance with the purposes determined by the controller. An identifiable individual is one who can be directly or indirectly identified and whose personal data can be processed in accordance with the purposes determined by the controller.

Individual

An individual is any natural person whose personal data is processed on a legal or contractual basis between the controller and that individual or on the basis of the express consent given by the individual to the controller.

Manager

The controller determines the purposes and means of processing within the framework of its registered activity and/or legal authorizations. The individual is informed in advance who is the manager of personal data and who is the processor of his personal data.

Processor

The processor processes the personal data of individuals on behalf of the controller, according to his instructions, within the framework of legal purposes and methods of processing.

Subprocessor

The sub-processor processes the personal data of individuals on behalf and according to the instructions of the processor, within the framework of the legal purposes and methods of processing.

Processing

Processing of personal data means any act or set of acts carried out in relation to personal data or sets of personal data with or without automated means, such as collection, recording, editing, structuring, storage, adaptation or modification, retrieval, access, use , disclosure by transmission, dissemination or otherwise making accessible, adaptation or combination, restriction, erasure or destruction.

Restriction of processing

Limitation of processing means marking stored personal data in order to limit their processing in the future.

Designing profiles

Profiling means any form of automated personal data processing that involves the use of personal data to evaluate certain personal aspects relating to an individual, in particular to analyze or predict performance at work, economic situation, health, personal taste, interests, reliability, behaviour, location or movements of that individual.

Pseudonymization

Pseudonymization means the processing of personal data in such a way that the personal data can no longer be attributed to a specific individual to whom the personal data relates, provided that such information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to a specific or identifiable individual.

Consent of the individual

The consent of the data subject means any voluntary, explicit, informed and unequivocal declaration of will by the data subject, by which he expresses consent to the processing of personal data relating to him by a statement or a clear affirmative action.

Breach of personal data protection

A personal data breach means a breach of security that results in the intentional or illegal destruction, loss, alteration, unauthorized disclosure or access to personal data that is transmitted, stored or otherwise processed.

PERSONAL DATA PROCESSING

Processor data

COMPANY NAME: ACTIVION d.o.o.
COMPANY ADDRESS: Mivka 10a, 1000 Ljubljana
Registration number: 1629077000
Tax number: 41460804


The person responsible for providing information regarding this act and the protection of personal data is:

Matej Pestotnik 

Subprocessors

The processor has concluded contracts on the further processing of personal data of individuals of a specific controller in cases where it has external processors for the performance of its services, who are its sub-processors in relation to the controller. The processor is responsible for the selection of sub-processors and ensures that they are bound to the same or higher level of personal data protection as stipulated by Slovenian and European Union regulations. The processor informs the administrator about its existing processors and about any replacement of processors or the hiring of new processors. It does this by announcing the publication of new privacy conditions, in which it specifies the new processors and gives the manager thirty days to comment on the changes, confirm or oppose them.

Legal basis for processing personal data

The processor has a legal basis for processing the personal data of individuals of a specific controller in a previously concluded contract between the controller and the processor or on the basis of another agreement on the order of the service.

The processor is responsible for ensuring that managers are familiar with this act and other acts of the processor, insofar as they regulate the processing of personal data of individuals and/or the terms of business for the provision of ordered services.

The controller is responsible for ensuring the appropriate legal basis for the processing of personal data (legal interest, contractual interest and/or express consent of the individual).

Types of personal data

The processor processes the personal data provided by the controller. The processor never processes other personal data of the individuals of the specific controller.

Purposes of personal data processing

The processor processes the personal data of the individuals of a specific operator only for the purposes for which the operator has given him an instruction. The processor never processes the personal data of the individuals of a specific controller for other purposes.

The role of the manager

The controller is obliged to give instructions to the processor for the processing of the personal data of the individuals it manages. The controller must provide the processor with clear and unambiguous information about what types of personal data and for what purposes it can process.

Documented operator instructions

According to this act, the controller is obliged to specify to the processor the content and duration of the processing of personal data, the nature and purpose of the processing, the types of personal data and the categories of individuals to whom the personal data relate.

The operator’s instructions must be documented, whereby they can be given in writing by regular or electronic mail, and in the case of oral instructions, the processor also requires written confirmation by regular or electronic mail.

The processor is not responsible for the legality of the instructions received from the controller for the processing of personal data of individuals of a particular controller.

Data confidentiality

The processor ensures that the persons authorized to process personal data are bound by confidentiality or are bound by the relevant law to confidentiality. The processor has adopted internal regulations on the protection of personal data and obtains from all employees and external collaborators a written commitment to data confidentiality, familiarization with the regulations and the appropriate security measures implemented by the processor to ensure an adequate level of data security.

The rights of individuals

The processor technically ensures that, according to the controller’s instructions and within the legal scope, it provides support and technical solutions as well as the final data that the controller needs when individuals exercise one or more rights with the controller that are provided for them by legislation: the right to correction, the right to deletion , the right to limit processing, the right to data portability and the right to object.

Deletion or transfer of data

Based on the prior documented instructions of the controller, the processor deletes or returns all personal data to the controller after the completion of the service it performs for the controller and destroys existing copies, except in cases where data storage is prescribed by law.

Access to information

The processor provides the controller with all the information necessary to prove compliance with the obligations from this act and the legislation, and allows the controller or another auditor authorized by the controller to carry out audits, including inspections, and participates in them.

SECURITY OF PERSONAL DATA PROCESSING

Security of processing

The processor and operator, taking into account the latest technological development and costs of implementation and the nature, scope, circumstances and purposes of processing, as well as risks to the rights and freedoms of individuals, which differ in probability and severity, the operator and processor ensure by implementing appropriate technical and organizational measures the level of security in relation to the risk, including but not limited to measures covering:

  • pseudonymization and encryption of personal data,

  • the ability to ensure ongoing confidentiality and integrity, availability and resilience of processing systems and services,

  • the ability to timely restore availability and access to personal data in the event of a physical or technical incident,

  • procedures for regular testing, assessment and evaluation of the effectiveness of technical and organizational measures to ensure processing security.

In determining the appropriate level of security, particular consideration shall be given to the risks posed by processing, in particular due to accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access to personal data that is transmitted, stored or otherwise processed.

Authorized person for data protection

The processor is not obliged to appoint a person authorized to protect personal data, because it does not carry out the processing as a public authority or body, nor does it carry out processing in its core activity, which, due to their nature, scope and/or purposes, would require individuals to whom to which personal data relates, should be monitored regularly and systematically, and the basic activity of the processor does not include the extensive processing of special types of personal data.

Security measures

The processor ensures adequate security measures in the processing of personal data to ensure the protection of personal data. Security measures are regularly monitored and updated in accordance with the development of technology and the requirements of legislation.

The processor informs the controller about security measures and appropriate technical solutions in a separate document, which is an integral part of these privacy conditions, which govern the legal relationship between the controller and the processor, and the Rules on the Protection of Personal Data, which govern the legal relationship between the processor and employees who process personal data of individuals of a specific manager.

FINAL PROVISIONS

Binding nature of legal terms

  • The privacy conditions  apply to all managers with whom the processor has a regulated legal-business relationship by contract or in writing via e-mail and confirmed by the managers via e-mail, and it is considered that an annex to the existing legal relationship or a written annex to the existing written agreement has been accepted contract, if the controller so requests.

  • Privacy conditions are  binding for all legal transactions concluded on their basis.

  • The privacy terms are  an integral part of the order of the service  by the operator.

  • The administrator confirms  familiarity with and agreement  with these privacy conditions before ordering the service (in the contract or in writing via electronic communication).

 

Changes to the privacy terms

  • The processor regularly updates the privacy conditions with legal changes.

  • The processor informs the operator about the changes in a timely manner in writing by e-mail.

  • The processor provides an archive of changes to the privacy conditions, which can be accessed by any operator with a prior written request to the processor’s contact email address.

 

Conflict solving

The processor and operator undertake to resolve any disagreements and disputes  peacefully and amicably.  To the extent that an amicable solution is not possible, the court  in the Republic of Slovenia based on the registered office of the processor is competent to resolve the dispute .

 
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