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Privacy Policy

Last update: September 2022

The owner of Mediately Business and related products, trademark and software, Modra Jagoda d.o.o., respects and protects your privacy. In the following, you can read about how we handle your personal data.

This Statement describes the treatment of data provided on or collected at our digital platforms, which gives a visitor the possibility to access our online presence and use our services. This Privacy Policy Statement complies with the general regulation of EU data protection as well as local legislation of the Republic of Slovenia. Unless otherwise specified on individual pages, Modra Jagoda d.o.o. is the Data Controller for your personal data. Modra Jagoda d.o.o. is registered in Slovenia under registration number 6071805000 with its registered office at Cigaletova ulica 9, 1000 Ljubljana.

1. Lawful basis for our data processing 

We process your personal data in accordance with the General Data Protection Regulation (GDPR), the Personal Data Protection Act and other regulations governing the field of personal data protection. When we process personal data in relation to a contract or a potential contract with you, the lawful basis for the processing is that it is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract. If the lawful basis for processing is consent, you have the right to withdraw your consent as mentioned hereafter at any time, but this does not affect the legitimacy of the processing by Modra Jagoda d.o.o. before you withdraw your consent. If we provide personal information to law enforcement or other government agencies, we share your personal information because we have a legal obligation to do so.

2. Our reason and purpose for collecting personal data

The following are the main categories of data collected by Modra Jagoda d.o.o. and the main purposes for collecting the personal data:

2.1 To assist with queries 

You may choose to provide us with personal data including your name, e-mail address or other contact details when you contact us by telephone, e-mail, post, our chatbot or by using our digital platforms. This personal data enables us to respond to requests for information on such matters as Modra Jagoda d.o.o. products, to arrange a quote for purchasing of Modra Jagoda d.o.o. products. The legal basis for the processing of this personal data is a pre-contractual or contractual relationship pursuant to Article 6 (1) (b) of the GDPR. In the event that you wish to receive only some general information and there is no specific inquiry into our products or services, the legal basis for the processing of your personal data is our legitimate interest under Article 6 (1) (f) of the GDPR. When you allow us to store and process your data for further marketing communication outside and independent of your demand, the legal basis for processing is the consent of the individual under Article 6 (1) (a) of the GDPR. The transfer of personal data is in any case voluntary.  However, if you do not provide us the information, then you cannot receive an offer from us or enter into a contract.

2.2 Customers and prospective customers

We may collect personal data of customers and prospective customers, including name, contact details, payment and credit card details, credit information and other information necessary for us to conduct business with the person or organisation.  The legal basis for the processing of this personal data is a pre-contractual or contractual relationship under Article 6 (1) (b) of the GDPR. When you allow us to store and process your data for further marketing communication outside and independently of the contract, the legal basis for processing the individual's consent is under Article 6 (1) (a) of the GDPR. The transfer of personal data is in any case voluntary. However, if you do not provide the information, then you cannot receive an offer from us or enter into a contract.

2.3 Business development

The personal data you provide to us and personal data collected at our digital platforms will be used to enhance our consumer insight and drive relevant communication and offers across all touch points you may have with Modra Jagoda d.o.o. Personal data will also be used for product and service development. The legal basis for the processing of personal data of website visitors is the consent of the individual pursuant to Article 6 (1) (a) of the GDPR. Some information is also collected on the basis of the legitimate interest of the company in accordance with Article 6 (1) (f) of the GDPR in order to prevent abuse.

2.4 Marketing

Based on your consent, we process your personal data for the purpose of informing you of Modra Jagoda d.o.o. business operations, products and services. For the above purposes, we create marketing, tailored to your preferences and profile which will be based on your contact information, browsing history, sales and subscription service information; such as name, address, e-mail, phone number, purchase history, unique identifiers such as cookie IDs or device IDs and tracked browsing history based on these IDs. Please be aware that this list is not exhaustive as we may use any personal information collected in connection with your interactions with Modra Jagoda d.o.o. and its websites, mobile applications, products and services. If you do not wish to receive any further information, you can easily and free of charge unsubscribe from our marketing communication anytime. At the bottom of the various communication channels you will find a link to unsubscribe or contact us via unsubscribe via email or mail. We will delete your data from our systems no later than one month after receiving the unsubscription, unless another unsubstantiated legal basis for the processing of your personal data is provided after the unsubscription (eg if you become our customer, such legal basis is the Electronic Communications Act, which allows to notify you electronically of similar products or services, with the option to easily prohibit such notification at any time). The legal basis for data processing is the consent of the individual under Article 6 (1) (a) of the GDPR

2.5 Visitor and customer surveys

To develop our products and services, we may collect personal data from digital platform visitors or customers as part of surveys. We will contact you with a survey and process personal data as part of surveys through either consent or legitimate interests. Surveys processing personal data for marketing purposes will be used only with your consent. The legal basis for the processing of website visitors' data is the consent of the individual pursuant to Article 6 (1) (a) of the GDPR.

2.6 Prospective employees and contractors

When a person applies for a job or enters into a contract with us, we may collect certain information such as name, contact details, information about working history, educational diplomas, relevant record checks and information about professional interests. This may be collected from the person directly, from a recruitment consultant and from the person’s previous employers and others, including references and publicly available sources. This information is used to inform or assist us in the decision as to whether to make the person an offer of employment or engage the person under a contract. The legal basis for the processing of candidates' personal data is the Employment Relationships Act and the Labor and Social Security Records Act pursuant to Article 6 (1) (c) of the GDPR.

 2.7 To comply with the law 

We may collect personal information as required or permitted by law. The personal and non-personal information we collect is treated as confidential and will not be sold or passed on to third parties, except as provided in this statement.

2.8. Data retention period

Personal data obtained on the basis of the consent of the individual shall be kept until the revocation of the consent, unless the purpose for which they were collected has previously been achieved and has not been further processed. An individual may revoke his or her consent to the processing of data at any time.  

Data on customers from the sales contract and credit agreement may be kept for 5 years after the fulfillment of obligations from the contract on the basis of Article 346 of the Code of Obligations (OZ, Ur. L RS No. 97/2007 et seq.).

Invoices (and personal data contained therein) are kept for 10 years after the end of the year to which the invoices relate, pursuant to paragraph 5 of Article 86 of the Value Added Tax Act (ZDDV-1-UPB3, Ur.l. RS, No. 13/2011, et seq.).

3. How we collect your personal data 

We collect personal data, you provide to us, when you request products, services or information from us, register with us, participate in public forums, use a chatbot or other activities on our digital platforms, respond to customer surveys, or otherwise interact with us. We collect information through various technologies. We refer to our Cookie policy.

3.1 Links to other websites

This website contains links to other websites (such as Linkedin and Facebook) to which this Privacy Statement does not apply. Please note that we do not endorse other websites and their content. We encourage you to read the privacy statements of each website you visit.

4. Sharing your data with other companies

We will not share your personal information with others, except in the following cases:

When affiliated companies or third parties provide services on our behalf. These companies are prohibited from using your personal information for purposes other than those required of us by law or required by law.

•Technology providers, for example analytics, tracking technologies, targeting and re-targeting technologies and search engine providers that assist us in the improvement and optimisation of our platforms.

• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others, if you have given consent.

• Social networking sites, if required when processing and if you have given your consent

• With other third parties to ensure the safety and security of our customers, to protect our rights and property to comply with legal processes or in other cases if we believe in good faith that disclosure is required by law.

When we cooperate with external service providers, we enter into a data processor agreement concerning the processing of your personal data by the service providers. These service providers are prohibited from using your personal data for purposes other than those requested by us or required by law. We store your personal data on servers located in the EU.

5. Your controls and choices (your data protection rights).

Information and access to personal data:

As a data subject, you have the right at any time to obtain confirmation from the controller as to whether personal data are being processed in relation to you and, where applicable, access to personal data and the following information:

  • processing purposes;
  • the types of personal data concerned;
  • users or categories of users to whom personal data have been or will be disclosed, in particular users in third countries or international organizations;
  • where possible, the envisaged retention period of personal data or, if that is not possible, the criteria used to determine that period;
  • the existence of a right to require the controller to rectify or delete personal data or to restrict the processing of personal data in relation to the data subject, or the existence of a right to object to such processing;
  • the right to file a complaint with the supervisory body (Information Commissioner of the Republic of Slovenia);
  • where personal data are not collected from the data subject, all available information regarding their source;
  • the existence of automated decision-making, including the profiling referred to in Article 22 (1) and (4) of the GDPR, and at least in such cases meaningful information on the reasons for it, as well as the significance and intended consequences of such processing for the data subject.

The right of correction:

The individual has the right for the controller to correct inaccurate personal data concerning him without undue delay. Subject to the purposes of processing, the individual has the right to supplement incomplete personal data, including the submission of a supplementary statement.

The right to erasure ("the right to be forgotten"):

The individual has the right to have the controller delete personal data relating to him without undue delay, and the controller has the obligation to delete personal data without undue delay under certain conditions.

The right to limit processing:

The individual has the right to restrict the processing of personal data by the controller under certain conditions.

The right to data portability:

The data subject has the right to receive personal data concerning him or her held by the controller in a structured, commonly used and machine-readable form, and the right to pass this data on to the other controller without being obstructed by the controller to whom the personal data were provided.

The right to object:

An individual has the right to object at any time to the processing of personal data concerning him or her, including the creation of profiles, on grounds related to his or her specific situation. The controller shall cease the processing of personal data unless it proves compelling legitimate reasons for the processing overriding the interests, rights and freedoms of the data subject or for asserting, enforcing or defending legal claims.

The automated decision making, including profiling:

The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which has or has a significant effect on him or her with legal effects in relation to him or her.

We give you some control and decisions regarding our collection, use and sharing of your data. In accordance with local law, your control and decision-making may include the following points:

  • You can change your decision about subscribing, receiving news, and notifications.
  • You can decide whether you want to receive marketing messages from us about products and services that we think may be of interest to you.
  • You can choose to allow us to share your personal information with other companies to send you marketing messages about their products and services, such as contractors or architects.
  • You can choose to receive notifications from targeted advertising by ad networks, data exchange and market analytics providers, and other services.
  • You may request access to your personal information we hold in order to correct inaccurate or incomplete information, and in certain circumstances you may request that we delete the information we hold about you from our records (the rights of individuals).
  • You can always unsubscribe from receiving news via the unsubscribe form in an e-mail or by telephone, without prejudice to the lawfulness of the processing of data carried out on the basis of consent until its revocation.

You can exercise your control and decisions or request access to your personal information by contacting the company at info@mediately.com or by following the instructions in the messages you have received. Please note that we may not be able to provide you with certain products and services if you do not allow us to collect your personal information, and some of our services may not be able to take your interests and preferences into account. If you have any questions about specific personal information about you that we process or store, please contact the company at info@mediately.com.

We will respond to your request within one month with the possibility of extending the deadline for an additional month. In the event of an extension, we will notify you within one month of receiving your request.

6. Data security, integrity and retention

The security, integrity and confidentiality of your personal data are extremely important to us. We have implemented technical, administrative and physical security measures that are designed to protect your personal data from unauthorised access, disclosure, use and modification. From time to time, we review our security procedures to consider appropriate recent technology and methods. Please be aware that despite our best efforts, no security measures are perfect or impenetrable. We will retain your personal data for the length of time needed to fulfil the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law. We will routinely refresh the information to ensure we keep it up to date.

7. Changes to this Privacy Statement

From time to time, we may change this Privacy Statement to accommodate latest technologies, industry practices, regulatory requirements or for other purposes. At all times, we will post the most recent version on our digital platforms. We therefore advise you to read the Privacy Statement regularly. Where required by applicable law, we will obtain your consent.

8. Comments and questions 

If you have a comment or question about this Privacy Statement, please contact info@mediately.com. You may file a complaint about the way we process your personal data. You can contact us by using the contact details stated at the end of this Privacy Statement. If a complaint is made, the name and contact details of the complainant must be provided to Modra Jagoda d.o.o. We will investigate the complaint and respond within one month. If you consider that we have failed to resolve the complaint satisfactorily, you may file a complaint to: If you believe that Modra Jagoda d.o.o. has not resolved the complaint properly, you can complain to the Information Commissioner, Dunajska cesta 22, 1000 Ljubljana, gp.ip@ip-rs.si, https://www.ip-rs.si/.

9. Contact details

Email us at: info@mediately.com

Or write to us at: Modra Jagoda d.o.o., Cigaletova ulica 9, 1000 Ljubljana