• forpartners.spica.com (all together “our websites”), (b) by your registration to attend Špica online or offline events, (c) by your inquiry about our products and services, regardless of the form of such inquiry, including forms placed on our website; (d) by your download of products documentation, resources or other documents (e) by your use of Špica email delivery platform and related services/functionalities through the website, including newsletter, support and e-learning portals ; or (f) by your use of our online shop (g) through our social media pages and app; (h) by your use of any other, present or future, online or offline, programs, products, services, technical support or offerings of Špica and (i) by server log file that your browser automatically transmits to us (collectively, the “Services”).
The data controller in respect of our Services is Špica International, Ltd., Pot k sejmišču 33, Ljubljana, Slovenia (hereinafter: we). You can contact us by sending an email to firstname.lastname@example.org or call +386 1 568 08 00.
We are also the leading data controller regarding management and maintenance of shared CRM database in relation to the Špica Group companies.
How do we collect and use (process) personal data about you?
We collect personal data about you when you provide it to us, such as through your use of Services or through your browser or device.
Where permitted or authorized by law, we may also receive information about you from other sources, if so allowed by law and if such is necessary for the provision of Services.
What type of personal data we collect or obtain about you?
The type of information we collect about you may include information such as:
• your name;
• your business email address or other email address as you provide to us;
• company you work for or have worked for;
• your business position within the company;
• your phone number;
• information about your computer or your mobile device (e.g. your IP address and browser type);
• information about how you use our Services (e.g. which pages you have viewed, the time you viewed them and what you clicked on); and
• information about your mobile device (such as your geographical location).
We may also obtain personal data about you from certain publicly accessible sources, including (but not limited to) online customer databases, business directories, media publications, social media, websites and other publicly accessible sources.
In the shared CRM database the following personal data are processed by us and other Špica Group companies:
• your name;
• your business email address or other email address as you provide to us;
• company you work for or have worked for;
• your business position within the company;
• your phone number;
How we use your personal data
We may use your personal data for one or more of the following purposes:
1. In relation to the provision of Services and personalizing our Service for you
a.) Administering, running and improving our Services and our business, including personalizing our Services for you. This is necessary for our legitimate interest of better understanding our customers' and potential customers' preferences and tailoring our Services and general business to our customers’ needs and preferences.
b.) Communicating directly with you in relation to updates to our website, your purchase(s) of our Services, and in response to enquiries we receive from you and to send administrative information to you, for example, information regarding the website and changes to our terms, conditions, and policies. This will be necessary either to update you from time to time about changes to our website, to perform a contract which we have entered into with you (or to take steps, at your request, to enter into a contract with you) or for our legitimate interest of satisfying and confirming your requirements in order to provide you with our products or services and to answer questions we receive from you.
c.) Protecting our business and our business interests, including for the purposes of credit and background checks, fraud prevention and debt recovery. This is necessary for our legitimate interests of preventing criminal activity such as fraud or money laundering, for ensuring that our Services are not misused and protecting our business. We will only carry out such checks to the extent that we are permitted or authorized by law to do so.
d.) Communicating with our business advisors and legal representatives. This is necessary for our legitimate interests of obtaining legal or professional business advice, and we will only share your personal data where it is necessary to do so, to the minimum extent necessary and on an anonymized basis wherever possible.
e.) Sharing your personal data with affiliates and third - party business partners which are either related to or associated with us in relation to our provision of Services. List of our affiliates is here Third- party business partners include resellers, suppliers, independent contractors, email providers, web hosting providers, on line shop payment provider and other ITC services providers (collectively: Processing partners). This will be necessary either to perform a contract which we have entered into with you (or to take steps, at your request, to enter into a contract with you), for our legitimate interest of running and managing our business effectively, for compliance with a legal obligation to which we are subject, or for our own direct marketing purposes. Where we share your personal data, we will do so strictly on a need-to-know basis, subject to appropriate confidentiality restrictions, on an anonymized basis as far as possible and only to the extent strictly necessary for any of these purposes. We will not sell for profit purposes your data to any other 3rd party.
f.) Enforcing our legal rights and compliance. This is necessary for our legitimate interest of protecting our business and enforcing our contractual and other legal rights resolving disputes and making such disclosures as are required by law or which we consider, acting reasonably, are required by law. We may also need your personal data to comply with ongoing legal obligations, such as tax and accounting laws and regulations to which we are subject to.
g.) Ensuring physical, network and information security and integrity. This is necessary for our legitimate interest of ensuring that our IT systems and networks are secure and uncompromised, including, for example, backup and archiving, preventing malware, viruses, bugs or other harmful code, preventing unauthorized access to our systems, and any form of attack on, or damage to, our IT systems and networks.
h.) In connection with disclosure requests and in the case of a business or share sale or sale or purchase of a business and/or assets, whether actual or potential. This is necessary for our legitimate interests of selling and/or ensuring and promoting the success of our business.
i.) For statistical and research purposes. We will anonymize your data and use them for our legitimate interests of processing personal data for research purposes, including market research, better understanding our respective customers, and tailoring our respective products and services to their needs.
j.) Indicating possible criminal acts or threats to public security to a competent authority. This is necessary for our legitimate interest of promoting the success of our business, preventing crime, for compliance with a legal obligation to which we are subject, in the general public interest or for the legitimate interests of governmental bodies and competent authorities that prevent crime.
k.) Entering into and performing a contract with you or for measures preliminary to a contract. Where you wish to purchase products or services from us, we require your personal data in order to enter into and perform a contract with you. If you do not provide your personal data to us when it is required for such a purpose, we will not be able to enter into or perform a contract with you or to provide you with the products or services you have requested. We may also postpone or cancel any orders you place and enforce our legal rights against you (for example, where we have incurred costs or expenses in preparing or fulfilling any orders placed by you but are unable to deliver the order due to your failure to provide the necessary personal data).
2. In relation to marketing, including e-marketing
a.) To provide you with offers relating to goods or services we offer from time to time and inform you on our research, development and achievements.
b.) Automated decision-making, including profiling. We may analyze your personal data to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. We may also use your personal data to detect and reduce fraud and credit risk. This is necessary for our legitimate interest of promoting the success of Services and business.
c.) Shared CRM database. We may process your personal data for registration, organisation, storage, elaboration, selection, extraction and all other relevant CRM management purposes.
Where we process your personal data on the basis of your consent, you can withdraw your consent to such processing at any time by emailing us at email@example.com. The effective date of such withdrawal shall be 8 business days from the date we have received your request.
You may opt-out of receiving marketing messages from us by sending an email to firstname.lastname@example.org or by unsubscribing through the unsubscribe or opt-out link in an email. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages.
Data storage and retention
Your personal data is stored by us on our servers located in Slovenia and on servers of cloud providers located in the EU countries. It may also be that your data are processed outside of the EU, for this please refer below in our cookies section.
Špica will store your information for no longer than necessary, taking into account the following:
• the purpose(s) for which we are processing your personal data, such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or for our legitimate interests;
• whether we have any legal obligation to continue to process your information, such as any record-keeping, accounting or tax obligations imposed by applicable law; and
• whether we have any legal basis to continue to process your personal data, such as your consent.
For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at email@example.com.
How we secure your personal data
We take appropriate technical and organisational measures to secure your personal data and to protect it against unauthorised or unlawful use or processing as well as against the accidental loss or destruction of, or damage to, your personal data, including:
• only sharing and providing access to your personal data to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymized basis wherever possible;
• training our employees about the importance of confidentiality and maintaining the privacy and security of your information;
• committing to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities;
• updating and testing our security technology on an ongoing basis;
• using secure servers to store your personal data;
• requiring proof of identity from any individual who requests access to personal data; and
• using Transport Layer Security (TLS) software or other similar encryption technologies to encrypt any payment transactions you make on or via our website.
We are certified under ISO/ 27001. ISO /27001 is a security standard that brings information security under explicit management control. It also prescribes a set of best practices that include documentation requirements, divisions of responsibility, availability, access control, security, auditing, and corrective and preventive measures.
Transmission of information (including personal data) over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk. We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your transmission of information to us by such means.
Website’s Plugins and tools
Our website uses plugins from YouTube, which is operated by Google. The operator of the pages is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.
If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers is established. Here the YouTube server is informed about which of our pages you have visited.
If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account.
YouTube is used to help make our website appealing. This constitutes a legitimate interest pursuant to Art. 6 (1) (f) GDPR.
Further information about handling user data, can be found in the data protection declaration of YouTube under https://www.google.de/intl/de/policies/privacy.
Our website uses the Google Maps map service via an API. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
To use Google Maps, it is necessary to save your IP address. This information is generally transmitted to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer.
The use of Google Maps is in the interest of making our website appealing and to facilitate the location of places specified by us on the website. This constitutes a justified interest pursuant to Art. 6 (1) (f) GDPR.
Further information about handling user data, can be found in the data protection declaration of Google at https://www.google.de/intl/de/policies/privacy/.
We use the Slack Communication Tool of Slack Technologies, 500 Howard Street, San Francisco, CA 94105, USA (hereinafter: Slack Technologies) for internal communication. For this reason, personal data of customers, users and colleagues or contractual partners may be transferred to Slack Technologies servers located outside the European Economic Area.
We have concluded with Slack Technologies a contract on the processing of personal data, in which the latter undertakes to respect the EU law on the protection of personal data. With regard to international data transfers, we have concluded a data transfer agreement with the company in question with the so-called Standard Contractual Clauses, with which Slack Technologies undertakes that international transfers of personal data will be carried out in accordance with EU rules on personal data protection.
Slack Technologies is also registered for the EU-US Privacy Shield on international data transfers to the US.
The processing of personal data through Slack is carried out on the basis of our legitimate interest within the meaning of Art. 6 (1) (f) GDPR.
We use Intercom Inc.'s Intercom 98 Battery Street, Suite 402, San Francisco, CA 94111, USA tool to send you emails and for Live-Chat functionality regarding our cloud services and for managing customer relationships on Allhours.com and Myhours.com. In doing so, we transmit the following information:
•your E-mail address,
• your first and last name,
• your phone number,
• Technical contact information.
Intercom Inc. is registered with the EU-US Privacy Shield with regard to international data transfers to the United States and is therefore bound by the respected EU data protection rules.
Using the setting on your browser software may prevent you from using these cookies. This may impede the operation of certain services on our site (eg Live-Chat).
The use of the Intercom service is based on Art. 6 (1) (f) GDPR. We have a legitimate interest in optimizing the operation of our services. to better manage our customer relationships.
Payments for the products and services offered on Allhours.com and Myhours.com are made through Chargify, LLC, 118 Broadway Street, San Antonio, Texas 78205, USA. If you purchase our products or services, your purchase will be made through an SSL encrypted web site operated by Chargify and the information transmitted will be stored on US Chargify servers. As a result, Chargify is registered with the EU-US Privacy Shield with respect to international data transfers to the United States.
The use of Chargify services is based on Art. 6 (1) (f) and Art. 6 (1) (b) GDPR. We have a legitimate interest in optimizing the operation of our services. to better manage our customer relationships.
The use of Braintree services is made under Art. 6 (1) (f) and Art. 6 (1) (b) GDPR. We have a legitimate interest in optimizing the operation of our services. to better manage our customer relationships.
We use the GoToWebinar service of the Irish provider LogMeIn Ireland Limited (hereinafter: LogMeIn) to run the webinars. LogMeIn and its affiliates operate a global server infrastructure. Data processed in the framework of the implementation of individual webinars may be transmitted outside the European Economic Area, and thus subject to the law of the country where the individual LogMeIn servers are located, as LogMeIn processes the webinar participants' data depending on the type of participation. LogMeIn or. its US subsidiary LogMeIn USA, Inc. is registered as an EU-US Privacy Shield on international US data transfers.
With LogMeIn we have concluded a contract on the processing of personal data by which the latter is bound by the respected EU rules on the protection of personal data.
The use of the GoToMeeting services is based on Art. 6 (1) (f) GDPR. We have a legitimate interest in optimizing the operation of our services. to better manage our customer relationships.
For the www.myhours.com website, we use the Amplitude Analytical Tool of the American company Amplitude Inc. Amplitude uses device identifiers to process technical information stored on your mobile device such as device type (e.g. iPhone 6), operating system (iOS 8.4), vendor name (e.g. Vodafone), as well as events that occur in the MyHours application (use of certain application features such as start and end timekeeping or report generation), which allows us to analyze the use of the MyHours application by individual users in order to improve the functionality of the subject application and thereby enable a better user experience. Data processed by Amplitude is stored on servers in the United States.
By using MyHours, you consent to the processing of data by Amplitude in the manner described above. You can prevent Amplitude from participating in the email by emailing us at firstname.lastname@example.org.
The use of Amplitude services is based on Art. 6 (1) (f) GDPR. We have a legitimate interest in optimizing the operation of our services. to better manage our customer relationships.
With respect to www.spica.si, www.spica.com, blog.spica.com, katalog.spica.si, www.allhours.com, www.myhours.com and www.doorcloud.com, we use platform ActiveCampaign of a company named ActiveCampaign Platform, 1 N, Dearborn, Chicago, IL 60607, USA, where the following information is stored: e-mail and first and last name. This information is stored with ActiveCampaign on its servers in the US.
ActiveCampaign strives for the highest security of stored data through various physical, technical and organizational measures such as encrypting online connections, preventing unauthorized access, using secure passwords and preventing intrusion. ActiveCampaign monitors the delivery performance of sent emails by collecting open message data, clicks on links, email clients and browsers, approximate location, IP address, logins and logouts, and unsuccessful email delivery. This information shall be retained for a maximum of 6 months after unsubscribing from receiving emails.
We have a personal data processing agreement with ActiveCampaign. in which the latter undertakes to process the information of our users in accordance with our instructions and not to pass it on to third parties. E-newsletter transmission is carried out on the basis of your consent in accordance with Article 6 (1) (a) of the GDPR. Use of the ActiveCampaign service is made under Article 6 (1) (f) of the GDPR. We have a legitimate interest in selecting technology providers that provide tools that help us optimize our business, and provide a user-friendly way to send newsletters that meets your expectations.
Microsoft Dynamics CRM
Transfers of your personal data to other countries and safeguards used
When sharing your data outside the European Economic Area, the country to which it is transferred will either be subject to an adequacy decision by the European Commission, or if not (or if we transfer your personal data to an international organisation), we will ensure that the transfer takes place on the basis of one or more of the following safeguards:
• data protection policies adhered to by the data controller and other companies and entities within our corporate group from time to time, which comply with applicable laws, known as "binding corporate rules" or "BCRs";
• standard data protection clauses adopted by the European Commission or adopted by the Information Commissioner (Informacijski pooblaščenec) and approved by the European Commission in accordance with relevant law;
• a code or codes of conduct produced by an association or other body approved by the Information Commissioner;
• an approved certification mechanism (such as the EU-US Privacy Shield); or
• where authorised by the Information Commissioner, contractual clauses between the data controller or processor and the data controller, processor or recipient of the personal data in the third country or international organisation.
Your rights in relation to your personal data
You have the following rights in relation to your personal data, which you can exercise by sending an email to email@example.com.
• to request access to your personal data and information related to our use and processing of your personal data;
• to request the correction or deletion of your personal data;
• to request that we restrict our use of your personal data;
• to receive personal data which you have provided to us in a structured, commonly used and machine-readable format (e.g. an Excel spreadsheet) and the right to have that personal data transferred to another data controller (including a third-party data controller);
• to object to the processing of your personal data for certain purposes (for further information, see the section below entitled 'Your right to object to the processing of your personal data for certain purposes'); and
• to withdraw your consent to our use of your personal data at any time where we rely on your consent to use or process that personal data. If you withdraw your consent, this will not affect the lawfulness of our use and processing of your personal data on the basis of your consent before the point in time when you withdraw your consent.
You also have the right to lodge a complaint with a supervisory authority, which, for the purposes of Slovenia, the Information Commissioner, the contact details of which are available here: https://www.ip-rs.si/kazalo-kontakt-iskalnik/kontakt/.
For further information about your rights in relation to your personal data, including certain limitations which apply to some of those rights, please see Articles 12 to 23 of the General Data Protection Regulation (GDPR), which is available here: https://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf.
Your right to object to the processing of your personal data for certain purposes
You have the following rights in relation to your personal data, which you may exercise in the same way as you may exercise the rights in the preceding section (Your rights in relation to your personal data):
• to object to us using or processing your personal data where we use or process it in order to carry out a task in the public interest, where we do so in the exercise of official authority or for our legitimate interests, including 'profiling' (i.e. predicting your behavior based on your personal data) based on any of these purposes; and
• to object to us processing your personal data for direct marketing purposes (including any automated evaluation we make about you or any of your characteristics as a person, to the extent that it is related to such direct marketing).
You may also exercise your right to object to us using or processing your personal data for direct marketing purposes by:
• clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link; or
• sending an email to firstname.lastname@example.org asking that we stop sending you marketing communications or by including the words "OPT OUT".
Whenever you object to direct marketing from us by a different communication method to that of the marketing communications you have received from us, you must provide us with your name and sufficient information to enable us to identify you in relation to the communications you have received (for example, if you have received text messages from us and you wish to unsubscribe by email, we may need you to provide us with your phone number in that email).
Consequences of not providing your personal data to us
Where you wish to purchase goods or services from us, we require your personal data in order to enter into a contract with you. We may also require your personal data pursuant to a statutory obligation (in order to be able to send you an invoice for products and services you wish to order from us, for example).
If you do not provide your personal data, we will not be able to enter into a contract with you or to provide you with those products or services.
Where we intend to use your personal data for a new purpose other than the purpose(s) for which we originally collected it, we will provide you with information about that purpose and any other relevant information before we use your personal data for that new purpose and obtain your consent if required.
Changes to your information
Please inform us of any changes to any information (including personal data) which we hold about you so we can keep the information we hold about you accurate and up-to-date.