NETIS d.o.o. PRIVACY POLICY
LAST MODIFIED: 10.12.2020
ATTENTION: PLEASE READ THIS NETIS d.o.o. (“Netis”, “Company”, “WE”, OR “US”) PRIVACY POLICY (“PRIVACY POLICY”) carefully, BEFORE YOU (“YOU”) ACCESS, DOWNLOAD OR OTHERWISE USE THE http://ACEBLOCK.COM or NETIS.SI WEBSITE; mobile applications; other online services; OUR PRODUCTS AND SERVICES INCLUDING ACEBLOCK, ACEID, ACESPACE and ACEIoT (COLLECTIVELY, THE “SERVICE”; OTHER INTERACTIONS (INCLUDING EMAIL, ONLINE, OFFLINE AND BY PHONE OR MAIL) BETWEEN YOU AND US; AND/OR OUR SOCIAL MEDIA ACCOUNTS INCLUDING ALL CONTENT AVAILABLE THROUGH THESE PLATFORMS (COLLECTIVELY, THE “DIGITAL CHANNELS”).
1. Introduction
We respect your right to privacy and comply with its obligations under the General Data Protection Regulation (GDPR). Our Privacy Policy explains how we collect, safeguard and disclose information that results from your use of our Service or Digital Channels.
By using Service or Digital channels you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.
Our Terms of Service (“Terms”) together with the Privacy Policy constitutes your agreement with us (“agreement”).
2. Definitions
PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).
COOKIES are small files stored on your device (computer or mobile device).
DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.
DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
DATA SUBJECT is any living individual who is the subject of Personal Data.
THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.
3. Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service or Digital Channels to you.
4. Types of Data Collected
Personal Data – While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
0.1. Email address
0.2. First name and last name
0.3. Phone number
0.4. Address, Country, State, Province, ZIP/Postal code, City
0.5. Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or by sending us the email to [email protected].
Usage Data – We may also collect information that your browser sends whenever you visit our Service or when you access Service by or through any device (“Usage Data”).
This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access Service with a device, this Usage Data may include information such as the type of device you use, your device unique ID, the IP address of your device, your device operating system, the type of Internet browser you use, unique device identifiers and other diagnostic data.
Tracking Cookies Data – We use cookies and similar tracking technologies to track the activity on our Service and Digital Channels, and we hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
0.1. Necessary Cookies – help make a website usable by enabling basic functions like page navigation and access to secure areas of the website.
0.2. Statistics Cookies – Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
0.3 Marketing Cookies – are used to track visitors across websites.
0.4 Unclassified Cookies – are cookies that we are in the process of classifying, together with the providers of individual cookies.
Other Data – While using our Service or Digital Channels, we may also collect the following information: sex, age, date of birth, place of birth, passport details, citizenship, registration at place of residence and actual address, telephone number (work, mobile), details of documents on education, qualification, professional training, employment agreements, NDA agreements, information on bonuses and compensation, information on marital status, family members, social security (or other taxpayer identification) number, office location and other data.
5. Use of Data
Netis d.o.o. uses the collected data for various purposes:
0.1. to provide and maintain our Service;
0.2. to notify you about changes to our Service;
0.3. to allow you to participate in interactive features of our Service when you choose to do so;
0.4. to provide customer support;
0.5. to gather analysis or valuable information so that we can improve our Service;
0.6. to monitor the usage of our Service;
0.7. to detect, prevent and address technical issues;
0.8. to fulfil any other purpose for which you provide it;
0.9. to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
0.10. to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;
0.11. to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
0.12. in any other way we may describe when you provide the information;
0.13. for any other purpose with your consent.
6. Retention of Data
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods
7. Transfer of Data
We may transfer the Personal Information we collect to and store such information in other countries which may have different privacy or data protection laws than the country in which the information was provided.
This means that your Personal Information also may be transferred to and/or processed by Netis d.o.o. or (on their behalf) by third party service providers outside the European Union (“EU”) or the European Economic Area (“EEA”). The data protection regulation in the relevant countries where your Personal Information is collected or processed might deviate from the level of protection granted by legislation in the EU/EEA. However, Netis d.o.o. will ensure the adequate protection of your Personal Information in accordance with the applicable laws and the principles set out herein. By using our Service and Digital Channels, you agree with the collection and transfer of your Personal Information outside the EU/EEA as described herein.
8. Disclosure of Data
We will not disclose or supply, share or otherwise distribute your Personal Information to third parties except as described in this Privacy Policy. We may disclose personal information that we collect, or you provide when::
0.1. Disclosure for Law Enforcement.
Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.
0.2. Business Transaction.
If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.
0.3. Other cases. We may disclose your information also:
0.3.1. to our subsidiaries and affiliates;
0.3.2. to contractors, service providers, and other third parties we use to support our business;
0.3.3. to fulfill the purpose for which you provide it;
0.3.4. for the purpose of including your company’s logo on our website;
0.3.5. for any other purpose disclosed by us when you provide the information;
0.3.6. with your consent in any other cases;
0.3.7. if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.
9. Security of Data
We take measures to protect personal data you provide through the Services against loss, theft, and unauthorized access, use, disclosure or modification. These include physical, technological and administrative measures. However, We cannot ensure or warrant the security of any information you transmit to us or guarantee that information on the Service or Digital Channels may not be accessed, disclosed, altered or destroyed.
10. Your Data Protection Rights under European GDPR law
You have the right to request from us access to and rectification or erasure of personal data, to restrict processing of your personal data, to object to such processing and to exercise your right to data portability in accordance with the GDPR and applicable laws.
You have the right to lodge a complaint with a competent supervisory authority in accordance with the GDPR and applicable laws if you consider that the processing of personal data relating to you infringes the GDPR. For this purpose, you can contact in particular the supervisory authority in the EU Member State of your habitual residence or the place of the alleged infringement. A list of the national Data Protection Authorities can be found here https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
11. Service Providers
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
12. Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service.
13. CI/CD tools
We may use third-party Service Providers to automate the development process of our Service.
14. Behavioral Remarketing
We may use remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and srve ads based on your past visits to our Service.
15. Payments
We may provide paid products and/or services within Service. In that case, we may use third-party services for payment processing (e.g. payment processors) or P2P payment solutions.
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy.
16. Links to Other Sites and Service
Our Service or Digital Channels may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site or service. We strongly advise you to review the Privacy Policy of every site or service you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
17. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
18. Contact Us
If you have any questions regarding this Privacy Policy, you may email us at [email protected] or contact us by mail at:
Netis d.o.o.
Tržaška cesta 118
SI-1000 Ljubljana
Europe