Compliance with data protection regulations
Users’ rights regarding the protection of personal data
In accordance with the General Regulation on Personal Data Protection, Insem – Atmos guarantees you the following rights regarding the protection of personal data, which are elaborated in more detail below:
- the right of access to data,
- the right to rectification,
- the right to erasure (the “right to be forgotten”),
- the right to restrict processing,
- the right to data portability,
- the right to object.
Right of access to data
You have the right to receive confirmation from Insem-Atmos whether Insem-Atmos is processing your personal data, and where this is the case, you have the right to access your personal data and the following information regarding the processing of personal data:
- purposes of processing,
- types of personal data,
- users or categories of users to whom your personal data have been or will be disclosed, in particular users in third countries or international organizations,
- where possible, the envisaged retention period of the personal data or, if this is not possible, the criteria used to determine that period,
- the existence of a right to require the controller to correct 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 lodge a complaint with the supervisory authority,
- where personal data are not collected from the user, all available information regarding their source,
- The existence of automated decision-making, including profiling, and meaningful information about the reasons for it, as well as the importance and intended consequences of such processing for the user.
Upon your request, Insem – Atmos will provide you with one free copy of your personal data being processed. For additional copies of the information you may request, Insem – Atmos will charge you a reasonable price, taking into account administrative costs.
Right of rectification
You have the right to ask Insem – Atmos to correct inaccurate personal data about you without undue delay. Subject to the purposes of the processing, you have the right to supplement incomplete personal data, including the submission of a supplementary statement.
Right to erasure (the “right to be forgotten”)
You have the right to request Insem – Atmos to delete personal data concerning you without undue delay, and Insem – Atmos must delete your personal data without undue delay in the following cases:
- where personal data are no longer needed for the purposes for which they were collected or otherwise processed,
- when you revoke the consent that is the basis for the processing of your personal data, and there is no other legal basis for the processing,
- when you object to the processing on the basis of the legitimate interest of the controller, but there are no overriding legitimate reasons for their processing,
- when you object to processing for direct marketing purposes,
- when personal data must be deleted in order to fulfill a legal obligation in accordance with EU law or Slovenian law.
Right to restrict processing
You have the right to request that Insem – Atmos restrict the processing of your personal data when one of the following cases applies:
- when you dispute the accuracy of the data, for a period that allows the controller to verify the accuracy of your personal data, • when the processing is illegal and you object to the deletion of personal data and instead request a restriction on their use,
- when Insem – Atmos no longer needs personal data for the purposes of processing, but you need them to assert, enforce or defend legal claims,
- when you have lodged an objection to the processing until it is verified that the legitimate reasons of the controller outweigh your reasons.
Right to data portability
You have the right to receive personal data concerning you held by Insem – Atmos in a structured, commonly used and machine-readable form, and the right to pass this information on to another controller without Insem – Atmos having personal data that have been provided to it, impeding it where: • processing is based on your consent or contract, and
- processing is performed by automated means.
Right to object
For reasons related to your particular situation, you have the right to object to the processing of personal data at any time if it is based on legitimate interests pursued by Insem – Atmos or a third party. Insem – Atmos will stop processing personal data unless it proves compelling reasons for processing that outweigh your interests, rights and freedoms or for asserting, enforcing or defending legal claims. When personal data is processed for the purposes of direct marketing, you have the right to object at any time to the processing of your personal data for the purposes of such marketing, including profiling if it is related to such direct marketing. If direct marketing is based on consent, the right to object may be exercised by revoking the personal consent given.
Procedure for exercising rights
All of the above requirements regarding the exercise of rights in relation to your personal data can be exercised by addressing them in writing to the controller, to the e-mail address email@example.com with a return receipt (request a certificate of reading) or by registered mail to the address Insem-Atmos d.o.o., Slivniška cesta 6, 2311 Hoče. If you submit a request in accordance with the above paragraph by electronic means, the information will, as far as possible, be provided to you by electronic means, unless you request otherwise.
For the purpose of reliable identification in the event of exercising your rights with regard to personal data, the controller may request from you additional data necessary to confirm your identity, and may refuse to act in accordance with this chapter only if it proves that you cannot reliably be identified.
The controller will respond to a request to exercise your rights in relation to your personal data without undue delay and at the latest within one month of receiving the request. Insem – Atmos may extend the deadline for exercising the rights by a maximum of two additional months, taking into account the complexity and number of requests. If Insem – Atmos extends the deadline, it will notify you of any such extension within one month of receiving the request along with the reasons for the delay.
If your requests under this chapter are obviously unfounded or excessive, in particular because they are repetitive, Insem – Atmos may:
- charge a reasonable price, taking into account the administrative costs of providing the information or communication or implementing the required action,
- refuse to act on the request.
The right to lodge a complaint regarding the processing of personal data
Any complaint regarding the processing of your personal data can be sent to the e-mail address firstname.lastname@example.org with a return receipt (request a reading certificate) or by registered mail to the address Insem – Atmos d.o.o., Slivniška cesta 6, 2311 Hoče. You also have the right to lodge a complaint directly with the Information Commissioner if you believe that the processing of personal data concerning you violates Slovenian or EU regulations in the field of personal data protection.
Basis for processing and purposes of personal data processing
Insem – Atmos will process your personal data for one of the following purposes on the basis of the following legal bases:
- your consent or agreement,
- fulfillment of legal obligations of the operator,
- on the basis of a legitimate interest,
- fulfillment of a contractual obligation.
Insem – Atmos will only process your personal data for the purposes for which it was obtained and will not process it for purposes incompatible with the purposes for which it was collected. Insem – Atmos collects from the user only those personal data that are strictly necessary to achieve a particular purpose.
Processing to fulfill contractual obligations
In certain cases, the processing of personal data is strictly necessary to fulfill the controller’s contractual obligations. In the event that the user does not provide the necessary information, the operator cannot conclude a contract with the user or perform the service.
The controller will process your personal data to fulfill contractual obligations for the following purposes:
- contractual arrangement of business cooperation,
- implementation of activities specified in the cooperation agreement,
- communication with contractors and other contact persons of the client for the purpose of carrying out the activities specified in the cooperation agreement.
Processing on the basis of consent or agreement
Insem – Atmos will process your personal data for the following purposes with your written consent:
- to send e-mails for the purpose of informing about news and interesting things in our offer, events, business opportunities and also about our absence,
- to monitor the reading of sent e-mails, namely which e-mail message you have opened or not opened, which links you have opened or clicked on (which content you have read or viewed), how long you have read or viewed individual content,
- for the purposes of analyzing the user’s life path on the website: from where the user arrived on the website (source of traffic), to monitor the stay on the website, which websites he or she visited, what content he or she downloaded or viewed,
- for any other purpose for which you specifically agree to cooperate with the operator.
In all cases when you give consent for the processing of your personal data, you can revoke this consent at any time via e-mail address email@example.com. The user can revoke the given consents for individual purposes of processing or give consent for other purposes of processing their personal data via e-mail firstname.lastname@example.org.
Processing is required to meet the legal obligations of Insem – Atmos
We also process your personal data when required to do so by law. An example of the purpose of such processing is the processing of your personal data for the purposes of judicial or administrative proceedings.
Processing based on a legitimate interest pursued by Insem – Atmos
The controller may also process data on the basis of a legitimate interest, except where such interests are outweighed by the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data. In the event of a legitimate interest being exercised, the controller shall always carry out an assessment in accordance with the General Data Protection Regulation.
Insem – Atmos will process your personal data on the basis of a legitimate interest for the following purposes:
- Marketing, business and other technical analyzes, such as analyzing and identifying which organizations the business partners come from and what functions they hold in those organizations.
- Preventing abuse, providing security, enforcing claims or defending against claims in administrative and judicial proceedings. Thus, in the event of suspected abuse, the controller may process your personal data to an appropriate and proportionate extent for the purpose of identifying and preventing possible fraud or abuse and may, if appropriate, pass this information to the police, public prosecutor’s office or other competent authorities.
- Direct marketing, including the creation of user profiles, based on previously legally obtained personal data. You may object to this processing at any time in accordance with your rights.
Valid from 11 September 2020 onwards and may be amended or supplemented at any time.