Privacy Policy – DIRECT ND d.o.o.

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The company Direct ND d.o.o., with headquarters at Sajovčevo naselje 69, 4208 Šenčur, Republic of Slovenia, registration number: 9195815000, tax number: SI96565292, is constantly striving to develop and improve the services, as we want to adapt them to the needs of our customers. To achieve the set goals and perform the contractually agreed works or services, in most cases we have to collect and process some personal data of our customers or personal data of family members of our customers.

This policy is intended for everyone who has ordered or uses the services of Direct ND d.o.o., as well as for those who visit our website.

This Policy on the protection of personal data (hereinafter the "Policy") refers to the following information:
- which of your personal data we collect and purposes of its collection;
- what we do with your personal data,
- how we take care of the security of your personal data,
- which rights you can exercise in relation to the processing of your personal data.

We take the protection of your personal data extremely seriously and responsibly. We fully respect our obligations regarding legal, fair, and transparent processing of personal data. We advise you to familiarize yourself with the content of this Policy in detail.

To ensure compliance of theis Policy with the current regulations in the field of personal data protection, the company Direct ND d.o.o. has the right to make changes or additions to it. We will inform you about the changes in a timely manner from our official email address.

1. WHO IS RESPONSIBLE FOR MANAGING YOUR PERSONAL DATA?

Direct ND d.o.o., Sajovčevo naselje 69, 4208 Šenčur, is responsible for managing personal data processed in accordance with these Policy. If you have any questions or requests regarding your personal data processing, please send them to the e-mail address info@directslovenia.com.

2. WHEN CAN WE PROCESS YOUR PERSONAL DATA?

We collect your personal data only when it is absolutely necessary for the provision of our services and you have expressly consented to this yourself. We will not process your personal data if the purpose or the grounds for its processing are not adequately justified by the applicable regulations in the field of personal data protection: Personal Data Protection (Official Gazette of the Republic of Slovenia, No. 163/22 - official consolidated text; ZVOP-2) and Regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016 on the protection of individuals in the processing of personal data and on the free flow of such data (GDPR) and with our internal policies.

Direct ND d.o.o. will process your personal data on the following legal bases:

- After accepting this Policy, familiarizing yourself with its content and putting your signature to confirm your consent to personal data processing, you are considered to enter a contract with the company Direct ND d.o.o., which is used as the legal basis for your personal data processing.

- Direct ND d.o.o. processes your personal data on the statutory legal basis, namely national legislation, including the Personal Data Protection Act (Official Gazette of the Republic of Slovenia, No. 163/22 - official consolidated text; ZVOP-2), the Consumer Protection Act (Official Gazette of the Republic of Slovenia, No. 130/22 – official consolidated text; ZVPot-1), and others.

3. HOW DO WE COLLECT YOUR PERSONAL DATA AND WHAT TYPES OF PERSONAL DATA DO WE PROCESS?

We obtain personal data exclusively and directly from you. The process of obtaining your personal data starts with a meeting with you, where you are presented with a form prepared in advance (Consent on personal data processing), which you are obliged to carefully read and fill in and sign it. We do not use any other sources to obtain personal data, unless otherwise agreed in writing.

Direct ND d.o.o. processes the following types of personal data:

• Contact information: This includes all personal information that you provide to us when you fill out the form at your first meeting with us. In this case, we collect and store data that includes your first and last name, place of residence or address, e-mail address, and telephone number.
• Information required to provide our services: This includes data on your nationality, education, birth, marital status, tax and registration number, types and amounts of income, number of family members, personal data on your family members (children, partners, parents) and any other relevant information.
• Information on our interactions: We keep records of your interactions with us, especially the date and time of the interaction and the reason for it. This applies in particular to e-mails.

4. WHO CAN USE THE PERSONAL DATA YOU HAVE PROVIDED TO US? WILL WE DISCLOSE YOUR PERSONAL INFORMATION TO THE THIRD PARTIES OR TRANSFER IT OUTSIDE THE EU?

The users of your personal data are Direct ND d.o.o. and people employed at Direct ND d.o.o.

Subject to a reasonable request, personal data may also be forwarded to the competent state authorities, which have a legal ground for this and to which it is necessary to deliver or disclose your personal data for the purposes of performing the contractually agreed services of our company.

If it is necessary to perform certain works or services that contribute to our services, we authorize other companies and individuals. In this case, Direct ND d.o.o. may forward personal data to carefully selected external processors within the frame of the contract on personal data processing, or an agreement or other binding document with the same content. We will forward this data or make it accessible to external processors only if you agree to this and only to the extent required by a specific purpose. This data may be used by an external processor only for the specific purposes, in accordance with all personal data processing standards provided by applicable legislation. External processors are contractually bound by Direct ND d.o.o. to respect the confidentiality of your personal data.

We take your privacy very serious. We will not disclose your personal data to the third parties unless it is necessary or if you have explicitly expressed your permission to do it.

Your personal information is considered a proprietary information. Employees of our company process your personal data in accordance with authorizations provided and our internal policies. Employees of our company are committed to protecting confidential information and respecting the individual rights.

We do not transfer your personal data outside the EU.

5. HOW WILL WE SECURE YOUR PERSONAL DATA?

Direct ND d.o.o. will use all organizational, technical, and other appropriate procedures and measures to secure personal data in order to prevent its unauthorized destruction, change or loss and any unauthorized processing. Measures include, but are not limited to, internal regulations on the protection of personal data, additional training of employees, internal audit of processing activities. Other possible measures may include minimizing the collection of personal data, pseudonymization, transparency, allowing individuals to monitor processing, and the constant upgrading of security measures.
6. HOW LONG DO WE STORE YOUR PERSONAL DATA?

The retention period of personal data depends on the grounds and purpose of processing each category of personal data. Personal data is kept only as long as it is recommended or permitted and necessary to achieve the purpose for which it was collected or further processed. After the purpose has been fulfilled, we will keep only personal data that we are obliged to keep according to the law or that we might need for evidentiary or defensive purposes, in case of any legal claims. Other data that we have not expressly agreed to store may be deleted, destroyed, blocked, or anonymized, unless the law provides otherwise for individual types of personal data.

We keep your personal data, which we use for sending offers and informing you about news, until you sign out, or a maximum of ten years from the date of consent. After this period, we will ask you for your consent again if necessary.

7. WHAT ARE YOUR RIGHTS IN TERMS OF PERSONAL DATA PROCESSING?

The rights regarding your personal data processing are as follows:

- the right to access
- the right to correct
- the right to erase ("right to be forgotten")
- the right to limit processing
- the right to data portability
- the right to object
- the right to appeal.

We will inform you if a certain data processing request will affect the possibility of further business cooperation.

You can revoke your consent to process your personal data for the purpose of sending offers at any time, the withdrawal of your consent does not affect the legitimacy of personal data processing based on this consent for the period before the withdrawal.

The company Direct ND d.o.o. does not bear responsibility for the authenticity, accuracy and up-to-dateness of the personal data you provide to us. The user is obliged to ensure the accuracy and up-to-dateness of all provided data and also bears all material and criminal responsibility for the provided data.

In the event of a breach of personal data protection, we will notify you under the conditions set by the applicable legislation.

We will fulfill your requests without undue delay and in any case within one month of receiving the request, unless otherwise provided by applicable law. Taking into account the complexity and number of requests, this deadline can be extended by a maximum of two months. We will notify you of any such extension within one month of receiving the request along with the reasons for the delay.

If you believe that we are not processing your personal data in accordance with applicable legislation, you can file a complaint with the Information Commissioner at the email address gp.ip@ip-rs.si or by regular mail to the address Zaloška cesta 59, 1000 Ljubljana, Slovenia.

8. FINAL PROVISIONS

This Policy is a mandatory document presented and explained by the company Direct ND d.o.o. to each of our future or potential clients, before we start cooperation. It can also be found on the website https://directslovenia.com/.
This Policy is valid since 26 August 2022.
Šenčur, on 26/08/2022

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