Privacy Policy

1. General Provisions

This personal data processing policy has been compiled in accordance with legal requirements and defines the personal data processing procedures and personal data security measures taken by VIP Slovenia (hereinafter referred to as the Operator).
1.1. The Operator’s primary goal and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of their privacy, personal and family confidentiality.
1.2. This Operator’s personal data processing policy (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://vipslovenia.net.

2. Key Concepts Used in the Policy

2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary cessation of processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. The Website is a collection of graphic and informational materials, as well as computer programs and databases, making them available on the internet at the address https://vipslovenia.net.
2.4. Personal data information system is the collection of personal data contained in databases and the information technologies and technical means that enable their processing.
2.5. Anonymization of personal data is actions that make it impossible to determine, without the use of additional information, the attribution of personal data to a specific User or another personal data subject.
2.6. Personal data processing is any action (operation) or set of actions (operations) performed with personal data using automated tools or without the use of such tools, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator – a government agency, municipal authority, legal entity, or individual that, independently or jointly with other persons, organizes and/or processes personal data, and determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information directly or indirectly related to an identified or identifiable User of the website https://vipslovenia.net.
2.9. Personal data permitted for distribution by the subject of personal data – personal data, access to which by the general public is granted by the subject of personal data by consenting to the processing of personal data, permitted by the subject of personal data for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User – any visitor to the website https://vipslovenia.net.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including disclosing personal data in the media, posting it on information and telecommunications networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state to a foreign government agency, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data, making it impossible to further restore the contents of the personal data in the personal data information system, and/or the destruction of tangible media containing the personal data.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:
– receive reliable information and/or documents containing personal data from the personal data subject;
– if the personal data subject revokes consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject, provided there are grounds specified in the Personal Data Law;
– independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by The Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obligated to:
– provide the personal data subject, upon request, with information regarding the processing of their personal data;
– organize the processing of personal data in accordance with the procedure established by applicable law;
– respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
– notify the authorized body for the protection of the rights of personal data subjects, upon request of such body, of the necessary information within 30 days of the date of receipt of such request;
– publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
– take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
– cease transferring (distributing, providing, accessing) personal data, cease processing, and destroy personal data in the manner and in the cases stipulated by the Personal Data Law;
– fulfill other obligations stipulated by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:
– receive information regarding the processing of their personal data, except in cases stipulated by federal laws. Information shall be provided to the personal data subject by the Operator in an accessible form and shall not contain personal data related to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
– demand that the Operator clarify their personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, and also take measures stipulated by law to protect their rights;
– require prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
– revoke consent to the processing of personal data;
– appeal to the authorized body for the protection of the rights of personal data subjects or in court against the Operator’s unlawful actions or inaction when processing their personal data;
– exercise other rights provided by law.
4.2. Personal data subjects are obliged to:
– provide the Operator with accurate information about themselves;
– notify the Operator of any clarifications (updates, changes) to their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another personal data subject, without the latter’s consent will be liable in accordance with the law.

5. The Operator may process the following personal data of the User:

5.1. Last name, first name.
5.2. Email address.
5.3. Telephone numbers.
5.4. The website also collects and processes anonymized visitor data (including cookies) using internet statistics services (Yandex Metrica, Google Analytics, and others).
5.5. The above data is hereinafter collectively referred to as “Personal Data.”
5.6. The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, or intimate life.
5.7. The processing of personal data permitted for distribution, which are among special categories of personal data, is permitted subject to compliance with the prohibitions and conditions.
5.8. The User’s consent to the processing of personal data permitted for distribution is issued separately from other consents to the processing of their personal data. The conditions must be met. Requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.
5.8.1 The User provides consent to the processing of personal data permitted for distribution directly to the Operator.
5.8.2 The Operator is obliged, no later than three working days from the date of receipt of the User’s consent, to publish information on the processing conditions, the existence of prohibitions and conditions for the processing of personal data by an unlimited number of persons, permitted for distribution.
5.8.3 The transfer (dissemination, provision, access) of personal data authorized for dissemination by the personal data subject must be terminated at any time upon the personal data subject’s request. This request must include the last name, first name, contact information (phone number, email address, or postal address) of the personal data subject, as well as a list of personal data whose processing is subject to termination. The personal data specified in this request may only be processed by the Operator to whom it is sent.
5.8.4 Consent to the processing of personal data authorized for dissemination terminates upon receipt by the Operator of the request specified in paragraph 5.8.3 of this Personal Data Processing Policy.

6. Principles of Personal Data Processing

6.1. Personal data shall be processed lawfully and fairly.
6.2. Personal data processing is limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes for which the personal data was collected is prohibited.
6.3. Combining databases containing personal data processed for incompatible purposes is prohibited.
6.4. Only personal data that is relevant to the purposes of processing may be processed.
6.5. The content and volume of processed personal data correspond to the stated purposes of processing. Processed personal data may not be excessive in relation to the stated purposes of processing.
6.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of the personal data in relation to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. Personal data shall be stored in a form that permits identification of the personal data subject for no longer than required for the purposes of processing the personal data, unless the storage period for personal data is established by federal law or an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the processing purposes or when the need to achieve these purposes is no longer necessary, unless otherwise provided by federal law.

7. Purposes of Processing Personal Data

7.1. Purpose of processing the User’s personal data:
– informing the User via email;
– concluding, executing, and terminating civil contracts;
– providing the User with access to services, information, and/or materials contained on the website https://vipslovenia.net.
7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always unsubscribe from receiving informational messages by sending an email to the Operator at info@vipslovenia.net with the subject line “Unsubscribe from notifications about new products and services and special offers.”
7.3. Anonymized User data collected using internet statistics services is used to collect information about User activity on the website and to improve the website’s quality and content.

8. Legal Basis for Processing Personal Data

8.1. The legal basis for processing personal data by the Operator are:
– agreements concluded between the Operator and the personal data subject;
– federal laws and other regulatory legal acts in the field of personal data protection;
– consent of Users to the processing of their personal data, as well as to the processing of personal data permitted for distribution.
8.2. The Operator processes the User’s personal data only if it is completed and/or submitted by the User independently through special forms located on the website https://vipslovenia.net or sent to the Operator via email. By completing the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized data about the User if this is permitted in the User’s browser settings (saving cookies and using JavaScript technology are enabled).
8.4. The personal data subject independently decides to provide their personal data and gives consent freely, of their own free will, and in their own interests.

9. Terms of Personal Data Processing

9.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
9.2. The processing of personal data is necessary to achieve the purposes stipulated by an international treaty or law, or to fulfill the duties imposed by law about operator’s functions, powers, and responsibilities.
9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, or the execution of an act of another body or official subject to execution in accordance with the legislation on enforcement proceedings.
9.4. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of an agreement initiated by the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
9.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
9.6. The processing of personal data is carried out if access to it by the personal data subject to an unlimited number of persons is granted by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
9.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

10. Procedure for the Collection, Storage, Transfer, and Other Processing of Personal Data

The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation on personal data protection.
10.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing it.
10.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the personal data subject has consented to the Operator’s transfer of data to a third party for the fulfillment of obligations under a civil law contract.
10.3. If any inaccuracies in personal data are discovered, the User may update them independently by sending a notification to the Operator’s email address info@vipslovenia.net with the subject line “Personal data update.”
10.4. The processing period for personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided by the agreement or applicable law.
The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator’s email address info@vipslovenia.net with the subject line “Revocation of consent to the processing of personal data.”
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User are obligated to independently familiarize themselves with these documents in a timely manner. The Operator shall not be liable for the actions of third parties, including the service providers specified in this paragraph.
10.6. Prohibitions on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution established by the personal data subject, shall not apply in cases where personal data is processed in the state, public, or other public interests defined by law.
10.7. The Operator shall ensure the confidentiality of personal data when processing personal data.
10.8. The Operator shall store personal data in a form that allows identification of the personal data subject for no longer than required for the purposes of processing the personal data, unless the storage period for personal data is established by law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.
10.9. Termination of personal data processing may be conditional on the achievement of the personal data processing purposes, expiration of the personal data subject’s consent or revocation of consent by the personal data subject, or the detection of unlawful processing of personal data.

11. List of actions performed by the Operator with received personal data

11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.
11.2. The Operator carries out automated processing of personal data, receiving and/or transmitting the received information transferred via information and telecommunications networks, whether or not transmitted.

12. Cross-Border Transfer of Personal Data

12.1. Prior to commencing the cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to which the personal data is to be transferred ensures reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements may only be carried out with the personal data subject’s written consent to the cross-border transfer of their personal data and/or the execution of an agreement to which the personal data subject is a party.

13. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by law.

14. Final Provisions

14.1. The User may obtain any clarification on any questions regarding the processing of their personal data by contacting the Operator by email at info@vipslovenia.net.
14.2. This document will reflect any changes to the Operator’s personal data processing policy. This policy is valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is publicly available online at https://vipslovenia.net/privacy-policy/.