Privacy Policy and Protection of Personal Data

We at the company SOLINE Pridelava soli d.o.o. (hereinafter Soline) and the Sečovlje Salina Natural Park (hereinafter SSNP) are aware of the responsibility for handling personal data and we respect your privacy. We process personal data carefully in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) (General Regulations GDPR) which allows you more control over the use of your personal data and the Personal Data Protection Act (Zakon o varstvu osebnih podatkov; ZVOP-1).

1.    Personal data controller

Name: SOLINE Pridelava soli d.o.o.

Address: Seča 115, 6320 Portorož, Slovenia

Phone: +386 5 6721 330

Websites: www.soline.si www.kpss.si www.thalasso-lepavida.si

This Privacy policy is published on the websites of SOLINE d.o.o. and applicable as of 15/03/2021. This policy contains general information on personal data processing by company SOLINE d.o.o. Individual services may have their own conditions, determining special rules for personal data processing.

2.    Your rights

Soline provides you with rights in accordance with the GDPR and ZVOP. In the event of a violation of your rights, you can contact the personal data controller (#EM#696f646c4476696b61676f257f64#EM#). The method of exercising rights is given below.By agreeing to this Privacy Policy, you agree that you are also familiar with your rights and how to exercise them.

3.   Types of personal data, legal basis and purposes of their processing

Soline collects and processes personal data on the basis of: the consent of individuals, concluded contracts or for the implementation of activities prior the conclusion of the contract, legitimate interests we strive for, and to meet legal obligations applicable to our company.

3.1    Consent-based processing

An individual whose personal data is processed on the basis of consent may give consent to the processing of personal data for each individual purpose separately.

The data subject may at any time revoke the consent given for each individual purpose separately, in a simple and easily accessible manner.

You have given us your consent to the processing of personal data by agreeing on our website, via one of the forms or via e-mail that we may provide the service to you for the stated purpose. For example, if you sign up to receive content such as e-newsletters, invitations to events, publications and services, or if you register to use certain services. Consent can also be obtained at certain other business contacts. Any consent we require from you must be explicit and unambiguous. You can revoke your consent at any time, as easily as you gave it. In our database, we will document information on the revocation of consent (for example, on your registration and unsubscription from e-newsletters). The retention period, separate purpose(s) and revocation option are always clearly defined at each consent. In the event of revocation of your consent, we will no longer use your personal data for the purpose for which the consent was revoked. Prior to giving consent, the individual is informed in writing or in another appropriate manner of the purpose of processing his / her personal data. Any withdrawal of consent does not affect the lawfulness of the processing of your personal data at the time before the withdrawal was given.

3.1.1    Sending news, notifications, promotions, etc.

As part of the consent to sending news, notifications, promotions, we will inform you about:

•    Sending electronic notifications about current prize games and promotional campaigns

•    Electronic notification of news and offers

•    Sending electronic invitations to events

•    Sending invitations to events by mail

•    Telephone and electronic collection of orders or event registrations

•    Sending e-publications

When giving consent, it will be stated whether this applies to all the abovementioned types of news, notifications, promotions or only to some of them. You can also let us know at any time whether you would like to receive only notifications of a particular category (or choose to do so on websites).

3.1.2    Participation in prize games

By participating in the prize game, the individual gives consent for the processing of personal data for the purposes of conducting the prize game of the company SOLINE d.o.o., which includes informing the winners of the prize game.To carry out the prize game, the company SOLINE d.o.o. collects and processes the following personal data: name, surname, full address, e-mail, telephone number and date of birth. Regarding the prize winners, there is also a tax number and a bank account number in accordance with the General Terms and Conditions.

3.2 .   Contract-based processing

SOLINE d.o.o. collects and processes personal data of individuals on the basis of a contract or for the performance of activities prior to the conclusion of a contract for the purpose of performing contractual obligations. We process your personal data in order to fulfil the concluded contract. This includes concluding and executing a contract, managing a user account, selling, supplying, charging for goods and services, resolving complaints and appeals, enforcing claims for payment of goods and services, and fulfilling or enforcing other rights and obligations under the contract.

The contract with you is created upon:

1.    Registration of a user account on the website or in the online shop.

2.    Placing an order for an online purchase or purchase via email

3.    Purchase of gift certificates and annual tickets for SSNP

4.    Reservation or purchase of guided tours and reservation or purchase of Thalasso Spa Lepa Vida services

5.    Conclusion of a contract on the use of berths

6.    Conclusion of a contract of employment

3.3    Processing on the basis of legitimate interests

Legitimate interest is the legal basis on which we process personal data of individuals with whom we have made contact in various situations for the purpose of informing about our services, when individuals justifiably expect to be informed (journalists, media), or in cases of certain business contacts. We also inform individuals about this. We always consider whether our legitimate interest is justified and take your interests into account in any processing.

When registering a user account on the website or in the online shop, or when placing an order for online purchase or purchase via e-mail, we will process your data, in addition to processing for the purpose of fulfilling the contract and based on our legitimate interest, for the following purposes:

Data collected at the time of registration or purchase is also used for the following legitimate interests pursued by the controller:

•    analysis;

SOLINE is constantly adapting and improving its services and the offer of goods and services. Therefore, it has a legitimate interest to monitor the use of its websites and the sale of goods and services and analyse their use for planning and development of services and products, market assessment and measuring sales performance and marketing activities. Data processing for analysis does not affect the rights of users arising from contractual relationships

•    prevention of abuse;

When concluding contractual relations and purchasing of goods or services, SOLINE implements procedures and measures to prevent abuse. The legitimate interest of SOLINE to prevent abuse, as a rule, always prevails over user’s interests, fundamental rights or freedoms. On the basis of processing, the company may take measures to prevent abuse, which may include account termination, prohibition of conclusion or termination of the purchase agreement, termination of contractual relationship, activities necessary to identify users or violators, initiation of appropriate civil, inspection or criminal proceedings to prevent or limit abuses and other legal measures.

•    direct marketing;

A legal basis for direct marketing may also be a legitimate interest in accordance with personal data protection rules. Based on a legitimate interest and for the purpose of direct marketing, SOLINE will process the personal data of users and customers of the online shop in order to inform them about the company SOLINE offer via e-mail, regular mail.

•    customer segmentation;

In direct marketing, SOLINE wants to provide its users with the best possible service, offer and user experience, so the company strives to provide users with a suitable personalised offer. For this purpose, the company will process user and purchase data for automated determination of whether an individual offer is interesting to the user and for the formation of user segments (e.g. according to demographic, sociographic and behavioural data and criteria such as gender, age, place of residence, service usage frequency, manner and time of use of services, websites and applications, past shopping habits, location, online identification), on the basis of which it will provide offers to its users.

•    event invitations;

SOLINE wants to provide its users with the best possible service, offer and user experience, so the company strives to provide users with a suitable personal offer. For this purpose, SOLINE organises events where they present products and services with the possibility of testing a product or service. Based on personal experience, SOLINE can adjust the offer to the user.

The user may at any time request in writing that the company permanently or temporarily cease to use his personal data for the purpose of direct marketing, segmentation or invitation to events. The company is obliged to properly prevent the use of personal data for such purposes within fifteen days.

3.4    Processing on the basis of legal obligations applicable to the controller

SOLINE d.o.o. collects and processes personal data of individuals on the basis of legal obligations that apply to the controller, for the following purposes: keeping accounting records, invoicing, debt collection, personnel matters. For the stated purposes, we collect and process the following personal data: name, surname, address, bank details, tax number, personal identification number, e-mail, telephone number.

The legislation allows us to collect certain personal data for clearly defined purposes, it also determines the retention period, the method of handling this data and meeting other security requirements (video surveillance, employees, salaries, etc.).

We process personal data on employees of Soline in accordance with the law, and collect and process personal data on the basis of the Labour and Social Security Registers Act (Zakon o evidencah na področju dela in socialne varnosti; ZEPDSV) and other laws governing employment relationships.

In order to ensure the necessary level of security of people and property, personal data of individuals in the area subject to video surveillance are processed on the basis of the Constitution and the Personal Data Protection Act (Zakon o varstvu osebnih podatkov; ZVOP-1), namely video record and date and time of entry to the premises and exit from the premises. Personal data is kept for a maximum of one year after creation.

4.   To whom do we transfer your personal data?

As a rule, we do not share your personal data with third parties. Only in rare cases, when you have agreed to it yourself (we will clearly inform you about it) or when we can ensure that the recipient provides an appropriate level of data protection, we do so if it is necessary to perform the contract or provide the service.

In cases where this is required by law, we are also obliged to provide your personal data to official authorities.

In carrying out our business, your personal data may sometimes be processed by our contractual processors. As a controller, we are responsible for the careful handling of your personal data, so we enter into personal data protection contracts or amendments to contracts with contractual processors as stipulated in the General Data Protection Regulation. Thus, we specifically commit them to the protection of personal data that you provide to us or we have received.

As a rule, Soline does not export personal data to third countries. In cases where Soline's suppliers or contractual partners are from third countries and the provision of their services to Soline or users may lead to the processing of personal data, Soline shall allow this subject to the conditions laid down in the GDPR—in particular by applying appropriate protective measures in accordance with the GDPR (which may include the conclusion of an appropriate personal data processing contract or other protective measures provided for in the GDPR).

5.    Retention period of personal data

The personal data of an individual obtained on the basis of consent is kept for five years from the revocation of your consent.

Personal data of an individual processed on the basis of a contract may be kept for 10 years from the fulfilment of the contractual obligations of both parties, and in the case of recovery of unpaid contractual obligations for 10 years after the conclusion of court proceedings.

Personal data collected on the basis of legitimate interests are kept until the exercise of the rights of the individual to whom they relate to or as long as there is a purpose which they were originally collected for. If the data has been collected on another legal basis, it is kept for as long as the legal basis exists, or if the regulations so provide. During this time it can also be processed for purposes where the basis for processing is a legitimate interest.

In cases of legal provisions, enforceable administrative, court orders, storage of your personal data on the invoice, SOLINE as a taxable person must ensure the storage of invoices relating to supplies of goods or services in the territory of Slovenia for at least 10 years after the end of the year which the invoices relate to - this also means storing of the data on the account.

6.   What personal data about you do we collect and process, for what purpose and for how long do we keep your personal data?

The data we process, the purposes of processing and the legal basis as well as the estimated data retention periods are stated in the individual records of personal data processing, which are published on the company's website.

7.    Rights of individuals

Users may request:

•    A printout or access to data, which allows them to familiarise themselves with the personal data processed by Soline about the user

•    Correction of data in cases where users believe that the personal data processed by Soline are incorrect

•    Deletion or restriction of the processing of their personal data if they want Soline to stop or limit the processing of all or part of their personal data

In addition, users can:

•    Object to the processing of personal data on the basis of a legitimate interest or for direct marketing purposes

•    Exercise the right to transferability of personal data provided to Soline

Users exercise their rights by sending a request to Soline in writing, to the e-mail address: #EM#696f646c4476696b61676f257f64#EM# or postal address: SOLINE d.o.o., Seča 115, 6320 Portorož, Slovenia.

The user must properly identify him/herself and clearly define his/her request in the application when exercises his/her rights. Data corrections can be communicated to Soline in writing or by signing a new contractual relationship document stating the corrected data. Certain rights of users may be restricted in individual cases on the basis of regulations.

(e.g. prohibition of notification of a possible investigation, etc.). As a rule, Soline will provide the individual with information on the measures taken on the basis of the received requests within one month, and in no case later than within three months.

The right to appeal: In the event that the user considers that Soline violates his/her rights in processing of personal data, he/she may lodge a complaint with Soline. The user sends the complaint to the address: SOLINE d.o.o., Seča 115, 6320 Portorož, Slovenia, or to the e-mail address: #EM#696f646c4476696b61676f257f64#EM#.

Users can also file a complaint with the supervisory body for the protection of personal data. The supervisory body for the protection of personal data in the Republic of Slovenia is the Information Commissioner.

8.    Non-provision of data and consequences

When concluding contractual relations with users, Soline only requires information that may be requested in accordance with regulations or that information that is necessary for the conclusion and implementation of the contract. The required information is stated in the contract or in this policy. In the event that the user does not provide the data or Soline cannot obtain them, Soline may refuse to conclude the contract or withdraw from the contract. Individuals may also provide Soline with other, additional information.

9.    Final provisions

In addition to this privacy policy, the processing of data within an individual contractual relationship is also governed by the contract and any conditions that further govern the individual contractual relationship.

This policy is published and is available on the company's website and at Soline points of sale.

This policy applies from the date of publication on the company's website. The Privacy Policy, which applies from 20 February 2019, expires on the day this policy comes into effect.



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