The brand KLAVDIJA. and the website www.klavdijaverlak.com through which the brand is being presented to the public is owned by HOLIMAR, Klavdija Verlak s.p.
HOLIMAR Klavdija Verlak s.p., Stojnci 140 b, 2281 Markovci; Slovenian e-mail address email@example.com (hereinafter: HOLIMAR or the company or provider or personal data controller) ensure the protection of your personal data and guarantees safety throughout the business interaction.
All our online activities, connected to the collection and processing of data, are in accordance with European legislation (Regulation (EU) 2016/697 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (The EU General Data Protection Regulation (GDPR)) and Treaty Conventions ETS 108, ETS 181, ETS 185, ETS 189) and national legislation of the Republic of Slovenia (Personal Data Protection Act (ZVOP-1, Ur. l. RS, no. 94/07), Electronic Commerce Market Act (ZEPT, Ur. l. RS, no. 96/09 in 19/15) etc.).
Controller and authorized person for data protection
The personal data controller is the company HOLIMAR, Klavdija Verlak s.p., Stojnci 140 b, 2281 Markovci.
The authorised person in charge of data protection is available at the following e-mail address: firstname.lastname@example.org.
If you have any questions regarding the use of this policy or in connection with the exercising of your rights under this policy, please contact the Data Protection Officer through the contact listed below.
Data Protection Officer: Klavdija Verlak, email@example.com
Personal data or personal information is all information by which an individual can be identified (such as name, surname, e-mail address, telephone number, etc.).
The controller is a legal entity that determines the purposes and means of processing personal data.
The processor is a legal or private individual who processes personal data on behalf of the controller.
Processing is the collection, storage, access and all other forms of use of personal data.
EEA is the European Economic Area, which consists of all members of the European Union, Iceland, Norway and Lichtenstein.
Personal data is a piece of information that identifies you as an individual. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
The provider, according to purposes as defined in this policy, collects the following personal data:
- basic data about the user (name, last name, residential address, date of birth, location)
- contact information and information about the user’s communication with the provider (e-mail, phone number, date, time and content of the mail or e-mail communication, date, time and duration of phone calls, recording of phone calls), channel and campaign – manner of acquirement or the source through which the user came into contact with the provider (website and advertising campaign, call centre, physical shop)
- data about all the user’s purchases and issued invoices (date and place of purchase, purchased products, prices of purchased products, total purchase value, manner of payment, delivery address, number and date of the invoice, code of the person who issued the invoice, etc.) and data about resolving reclamations of products
- data about the user’s usage of the provider’s website (dates and times of visits, visited pages or URLs, time spend on individual pages, the number of visited pages, total time spent on the website, settings modifications on the website) and data about the user’s use (reading) of received messages (e-mail, SMS) from the provider.
- data from forms that the user has voluntarily filled out, e.g. within prize games or using configurators for identifying the optimal products for the user’s needs;
- other data that the user voluntarily provides to the controller when they are required for specific services.
The controller does not collect personal data unless you enable it or consent to it, for example, when ordering products or services, subscribing to an e-mail newsletter, taking part in a prize game, etc., or when there is a legal basis or a legal interest by the controller for data processing.
The controller only collects the data that is relevant and necessary for the fulfilment of the purposes for which the data is processed.
The period of data for which the provider stores collected data is further defined in the chapter “Storing personal data” of this Policy.
The legal basis for data processing
The provider collects and processes your personal data based on the following legal grounds:
- Law-based processing
- Contract-based processing
- Processing based on the individual’s consent
- Processing on the basis of legitimate interest
The legal basis for data processing
Information is collected when it is necessary for entering into, executing and fulfilling contractual obligations. In this case, providing personal information is voluntary.
If you choose to not provide the company with the necessary personal data, you cannot enter into a contract with them, nor can the company provide the services or supply of products, as the company lacks the information necessary to fulfil the contract.
Processing based on the individual’s consent
Data is processed only with your explicit consent. When processing is subject to consent, we will first make sure that you have all the necessary information needed for making a decision. You can withdraw your consent at any time. If you withdraw consent, the company may not be able to provide you with their services or products.
Processing on the grounds of legitimate interest
The provider can process data on the grounds of legitimate interest for which the provider is striving, provided that the interests or the fundamental rights and freedoms of the data subject are not overriding. When using legitimate interest, the provider always makes a judgement in accordance with the General regulation on data processing.
When processing data on the grounds of legitimate interest, the user has the right to object to the data processing. You can read more about your rights below.
We process your personal information when we are required to do so by the law that binds us (for example, tax law mandates the retention of invoices). We process the needed information in accordance with the requirements of the law.
The purpose of data processing
The company collects and processes data for the following purposes:
Purpose of data processing
Communication regarding services or responding to requests
Notices to users, responses, resolving complaints, completing satisfaction surveys, etc. Processing is carried out on the basis of a legitimate interest in ensuring effective communication and successful transactions.
Entering agreements and the execution of obligations based on the contract
Entering and executing the contract with the provider, including the provider’s fulfilment of your orders (supply of products and provision of services), communication with you, verification of your payments and fulfilment of other obligations of the provider and/or your obligations. We process personal information on a contractual basis and a pre-contractual relationship.
In the event that you do not provide us with all the information necessary for the execution of the contractual obligations, we reserve the right to suspend or cancel the order.
Informing customers about special offers, discounts and other content via e-mail
At HOLIMAR, Klavdija Verlak s.p. we inform our customers of our products, services and contents. You may at any time request the discontinuation of such communication and processing of personal data (right of objection).
Direct contact about special offers and other content via e-mail
Based on your consent, we will notify you of your products, services, discounts and content via e-mail.
You may at any time request the discontinuation of such communication and processing of personal data by withdrawing consent.
You can withdraw your consent at any time through the e-mail firstname.lastname@example.org or email@example.com
Direct contact about special offers and other content via phone calls and regular mail
Based on customer consent, we also periodically inform customers about our products, services, discounts and content by telephone and regular mail.
You may at any time request the discontinuation of such communication and processing of personal data by withdrawing consent.
You can withdraw your consent at any time through at firstname.lastname@example.org or email@example.com
General statistical processing of data about buyers and their orders and potential buyers (contacts) for the purposes of internal analyses of sales, repeated purchases, aggregate buyers’ behaviour, advertising and business optimisation
At HOLIMAR, Klavdija Verlak s.p. we conduct general statistical processing of data about buyers and their orders, as well as potential buyers (contacts). Based on this processing we conduct internal analyses of sales, repeated purchases and aggregate buyers’ behaviour and monitor and optimise our business efficiency and optimise our advertising, e.g.:
- monitoring sales through our sales channels (internet, stores, call centre),
- monitoring the number of buyers who make repeated purchases, the time span and the value of the purchases,
- monitoring general statistical sales data like average shopping cart value, number of products per order and similar,
- monitoring responses to e-mail, SMS, phone calls and various advertising messages (TV, radio and online advertising) in order to optimise advertising (decisions about what, where, to whom and how we advertise)
This type of statistical monitoring allows us to optimise our business and advertising in general and allows us to offer affordable products and services to users. This processing of personal data is based on the legitimate interest of the company to provide quality services and products to users.
Automated e-mail communication with the user based on her or his start of the online purchase process
At HOLIMAR, Klavdija Verlak s.p., based on our legal interest, we occasionally send reminder e-mails to potential buyers that have put products into their shopping cart but never completed the purchase, with the purpose of reminding them to complete the purchase or offering them help or information in regards to doing so.
You can stop this type of data processing at any time by sending us a written request to our e-mail address firstname.lastname@example.org .
Basic customized communication (through e-mail, phone calls, mail, browser notifications, information at websites, social networks), with discounts, orders and content.
Within the basic customised communication (through e-mail, SMS, phone calls, mail, information at websites, social networks) we try to present relevant offers, discounts and other content that might be of interest to you, based on your past interactions with us.
For this, we use the following data about you:
- demographic data (gender, age)
- history of purchases (products purchased, number of purchases),
- simple processing of your behaviour at www.klavdijaverlak.com website (viewing individual products or content that may trigger sending of customised messages), without the use of these data for user profiling
During this process we do not use any type of automated or semi-automated profiling, we only collect suitable user sets for individual messages. We never focus on individual user’s data, we only conduct aggregate processing of large groups.
What messages you get from us is dependent on this data.
You can stop this type of data processing at any time, either by clicking the unsubscribe link in received messages, or by written request sent to this e-mail address email@example.com .
Using the Facebook Custom Audiences advertising tool
We at HOLIMAR, Klavdija Verlak s.p. use the Facebook
Custom Audiences service. We use it based on the acquired agreement to communicate through customised offers and content based on the user’s profile.
The service functions in the following way:
1. We upload the e-mail address that we acquired from you through your purchase or you provided it voluntarily, to Facebook.
2. Facebook conducts a comparison between your e-mail address and its user database and determines whether you are a Facebook user.
3. If you are not a Facebook user, then nothing further is done with your e-mail address and Facebook conducts no activities with it.
4. If you are a Facebook user, Facebook will add you to a newly created list of custom audiences that will allow us, and only us, to show this group of users customised advertisements on Facebook.
5. Based on this, we can show you ads that are more targeted and customised to you, as well as extra discounts.
This type of data processing can be stopped at any time by either sending us a written request to our e-mail address firstname.lastname@example.org .
Use of an online account and access to GDPR information
We process your personal data in order to provide access to your user account, which allows you to access your personal information and regulate the consent given.
You can also access past order information. We process personal information on the basis of legitimate interest.
Communicating custom offers and content based on your user profile
Based on consent, the provider can personalise the communication which is carried out through various communication channels (e-mail, phone calls, mail, browser notifications, website information, social networks).
We want to present you with the best possible offers and content tailored to your needs, which is why we use your profile as the basis for personalised communication.
We may use the following information for this purpose:
- Demographics (gender, date of birth, age, address)
- Purchase history (products, purchase time, number of purchases)
- Answers in questionnaires on KLAVDIJA. website
- Behaviour on KLAVDIJA. website (views of products or content, adding products to the shopping cart, online transactions)
- Your responses to the messages we send you (opening messages, clicking on links, buying)
Based on this user profile, it may then affect the content and offers you receive from us:
- Presenting products and content that will be of maximum interest to you
- What offers you receive
- How often we send you messages and through what channels
If you wish to revoke your consent at any point, you can terminate this data processing at any time via the unsubscribe link in your inbox or by sending a written request to email@example.com or firstname.lastname@example.org.
Legal claims, rights protection and dispute resolution
Data collection for the stated reason occurs in accordance with the law.
We collect your information in order to fulfil our legal obligations, e.g. saving invoices for tax purposes. We process your data only to the extent necessary to comply with legislation.
Storing personal data
The provider will store your personal data only for the time necessary to realise the purpose for which the personal data was collected and further processed.
The personal data that are being processed on a legal basis the provider stores for the time period defined by law.
The personal data that are being processed based on a contract with the individual, the provider stores for the duration of the contract and 5 years after its expiration, unless there has been a dispute about the contract between the user and the provider. In this case, the provider stores data for 5 years after the finality of the court or arbitrary ruling or settlement or, if there was no judicial dispute, 5 years from the day of an amicable settlement.
The provider stores the data that are processed based on personal consent, until the revocation of such consent from the user. The provider deletes these data before objection only when the purpose of storing data had already been fulfilled.
After the end of the period of personal data being stored, the controller effectively and permanently erases or anonymises the personal data so that they cannot be linked to an individual.
Detailed overview of the deadlines for data storing are listed in the table below:
Purpose of data processing
Time period of data being stored
Communication regarding our services or responding to requests
6 months from the end of the communication
Conclusion and fulfilment of obligations arising from entering a contract
5 years from the execution of the contract
Directly notifying customers about special offers, discounts and other content via e-mail or SMS
Directly notifying customers about special offers, discounts and other content by phone or regular mail
Access to past orders and other information by customer support consultants in order to provide a better service
Processing data on undelivered parcels with the purpose of fraud prevention
5 years from the start of processing
Automated e-mail communication with the user based on the beginning of the online buying process
Basic personalised communication (e-mail, SMS, phone calls, mail, browser notifications, website information, social networks) with personalised offers and content
Facebook Custom Audiences Advertising Tool
Using an online account
Access to specific information on the website
Market communication using user profiles
Contractual processing of personal data
Contractual processors that the controller transmits personal data are:
- an accounting service, law firms and other providers of legal counsel;
providers of data processing and analytics;
- maintenance of IT systems,
- e-mail marketing services (e.g. ActiveCampaign);
- providers of payment systems (e.g. Stripe, PayPal and others);
- providers of systems for managing customer relations (e.g. Microsoft);
- providers of solutions for online advertising (e.g. Google, Facebook)
The provider will not forward your personal information to third unauthorized parties.
Contractual processors can only process personal data within the framework of the controller’s instructions and must not use it to pursue any interests of their own.
The controller and recipients of personal data do not transmit personal data to third countries (outside of member countries of the European economic area – members of EU and Iceland, Norway and Liechtenstein) and to international organisations, except the USA – all contractual processors in the USA are in the Privacy Shield programme.
Freedom of choice
You are in control of any information you give out about yourself. If you decide you do not wish to share your data, we may not be able to provide you with certain services.
Individuals that wish to unsubscribe from the e-newsletter, please notify us through our e-mail address email@example.com . If there are any changes to your personal information (zip code, e-mail address, physical address, phone number), please notify us through our e-mail address firstname.lastname@example.org.
Automatically recorded information (non-personal information)
Whenever you visit our website, the general, non-personal information (browser users, number of visits, the average duration of the visit, pages visited) are being automatically recorded (not as a part of registration). This information is used to measure the attractiveness of our website and to improve the content and usability. Your information is not subject to further examination and is not disclosed to a third party.
The provider is strongly committed to ensuring personal data security. Your data is, at all times, protected from loss, destruction, falsification, manipulation and unauthorized access and unauthorized disclosure.
In order to protect personal data, we take organisational and technical measures, such as:
- Employee education
- Supervision of employees and regular reviews of individual employees
- Careful selections and overview of contractors
- A backup of electronically stored data
- Regular maintenance and updating of technical equipment
- Adopting appropriate internal policies and instructions for the protection of personal data
Consent of a minor in relation to the services of the information society
Minors under 16 years of age should not transmit any personal data to websites without the permission (consent or approval) of a parent or a legal guardian. The provider will never knowingly collect personal information from minors (under 16 years of age) or in any way use or disclose them to an unauthorised third party without their parent’s or legal guardian’s permission.
The above does not affect the general law of contract of member states, like regulations about validity, drawing up or effects of the contract regarding minors.
Bearing in mind the available technology, the provider will show reasonable efforts to verify that a parent of a legal guardian gave or approved consent.
Rights of the individual regarding data processing
As an individual, you have the following rights regarding fair and transparent processing, based on regulation:
The right to withdraw consent: if you have, as an individual, consented to the processing of personal data (for one or more purposes), you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
Withdrawal of consent for personal data processing has no negative consequences or sanctions for the individual. However, it is possible that the controller may not be able to offer one or more of its services after the withdrawal of consent if those services cannot be performed without personal data (e.g. the benefit club or customized communication).
The right to access personal data: as an individual, you have the right to obtain from confirmation from the provider (processor of personal data) as to whether or not your personal data are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing, the categories of personal data concerned, its users, the period for which the personal data will be stored, or the criteria used to determine that period, the right to request rectification or erasure of personal data or restriction of or objection to processing of personal data, the right to lodge a complaint with a supervisory authority, the source of the data if the data were not collected from you, the existence of automated decision-making, including profiling and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you, in accordance to Article 15 of GDPR.
The right to rectify personal data: as an individual, you have the right to obtain from the provider without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement;
The right to deletion of personal data (“the right to be forgotten”): you have the right to obtain from the provider without undue delay the deletion of your personal data when one of the below reason exists:
(a) the personal data are no longer necessary in relation to the purposes for which they are collected or otherwise processed,
(b) you have withdrawn your consent, and there is no legal basis for further processing,
(c) you have objected to the processing of your personal data, and there are no overriding legitimate grounds for the processing,
(d) your personal data have been unlawfully processed,
(e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the provider is subject,
(f) the personal data has been collected in relation to the offer of an information society.
As an individual under certain circumstances, as defined in Article 17, paragraph 3, you do not have the right to data deletion;
The right to restriction of processing: as an individual, you have the right to obtain from the provider restriction of processing where one of the following applies:
(a) you contest the accuracy of the personal data for a period enabling the provider to verify the accuracy of the personal data,
(b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead,
(c) the provider no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims,
(d) you have objected to processing pending the verification whether the legitimate grounds of the provider override yours;
The right to data portability: you have the right to receive the personal data concerning you, which you have provided to the provider, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the provider to which the personal data have been provided, where:
(a) the processing is based on consent or on a contract; and
(b) the processing is carried out by automated means.
In exercising your right to data portability, you have the right to have your personal data transmitted directly from one controller (provider) to another, where technically feasible;
The right to object to data processing: as an individual, you have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data that is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the provider (Article 6 (1), point (e) of GDPR), processing is necessary for the purposes of the legitimate interests pursued by the provider or by a third party (Article 6 (1) point (f) of GDPR), including profiling based on the data; the provider shall no longer process your personal data unless the provider demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing; where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
Where data are processed for scientific or historical research purposes or statistical purposes, you have the right, on grounds relating to your particular situation, to object to the processing of your data, unless it is necessary for the performance of a task carried out in the public interest;
The right to lodge a complaint with a supervisory authority: without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes data protection regulations.
Without prejudice to any other administrative or non-judicial remedy, you have the right to an effective judicial remedy, against a legally binding decision of a supervisory authority concerning it, as well as where the supervisory authority which is competent does not handle a complaint or does not inform you within three months on the progress or outcome of the complaint lodged. Proceedings against a supervisory authority shall be brought before the courts of the Member State where the supervisory authority is established.
The individual may address all her or his requests regarding personal data in written form to the provider, through an e-mail: email@example.com or firstname.lastname@example.org.
In order to ensure reliable identification in case of a user exercising his or her rights regarding personal data, the provider may request additional data from the user and shall not refuse to act on the request of the individual, unless the provider demonstrates that it is not in a position to identify the user.
The provider must, by user’s request to exercise his or her rights in regards to data processing, provide information without undue delay and in any event within one month of receipt of the request.
Notifying the supervisory authority of personal data breach
In the case of a personal data breach, the provider is obligated to notify the supervisory authority without undue delay, unless the provider is able to demonstrate that the data breach is unlikely to result in a risk to the rights and freedoms of individuals. When there is a suspicion of a criminal offence, the provider is obligated to notify the police and/or prosecutor.
In the case of a breach that is likely to result in a high risk to the rights and freedoms of natural persons, the provider is obligated to notify the individual immediately or, if that’ is not possible, without undue delay. The notification should be in clear and comprehensible language.
Social media access
Through our website, you can access the following web pages, which the provider utilizes in their work:
The privacy policies are available at the links below:
Publishing of changes