This Privacy Protection Policy applies to anyone using the inotherm.si, inotherm-tuer.de, inotherm.com, inotherm.hr, inotherm.fr, inotherm.it and inotherm.nl websites.
A user is any legal or natural person who uses or visits these websites (hereinafter: user).
Personal data protection
We at Inotherm, d.o.o., respect your privacy and the security of your personal data. We undertake to use your personal data solely for the purposes listed below in this Privacy Protection Policy. We protect your personal data carefully and in compliance with the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC) (hereinafter: GDPR), and other regulations governing personal data protection.
Personal data controller
Inotherm, d.o.o. Prigorica 98, 1331 Dolenja vas, Slovenia (hereinafter: the controller), is the controller of personal data obtained from the above websites that we process in accordance with our in-house Personal Data Protection Rules.
Disclosing personal data to third parties, third countries or international organisations
Inotherm, d.o.o., does not disclose personal data to third parties, third countries or international organisations.
An exception to this is the statistics on the visits to and the use of the websites for which Google Analytics online platforms are used.
Google Analytics allows users to edit their own data processing settings by using the Google Analytics tool. For more information about Google’s terms of service and privacy rules, please see the following online links.
Types of personal data, legal basis and purpose of data use
Inotherm, d.o.o. collects and processes personal data on the basis of individual consents or contracts entered into or for the performance of activities prior to entering into a contract, on the basis of the legitimate interests which we pursue, and for the fulfilment of legal obligations that apply to us.
Consent-based data processing
An individual whose personal data are processed on the basis of consent may consent to the processing of his or her personal data for each particular purpose separately.
The data subject may cancel his or her consent for each specific purpose in a simple and easily accessible way at any time.
Sending the Inotherm, d.o.o. product catalogue
On the basis of consent during the sending of an inquiry, Inotherm, d.o.o. collects and processes the following user data: first name and surname (company), e-mail address, street and house number, postal code, city/town, and telephone number, if provided by the user.
Contact related to consulting, sales and installation
On the basis of consent to the establishment of contact in relation to consulting, sales and installation, during the sending an inquiry, Inotherm, d.o.o. collects and processes the following user data: first name and surname (company), e-mail address, street and house number, postal code, city/town, and telephone number, if provided by the user. In some cases (when a Web configurator is used) also the image of the building, if provided by the user.
Forwarding personal data to the user closest to the business partner
On the basis of consent by the individual, we provide personal data to the business partner who is closest to the user and who processes personal data on our behalf for the purpose of preparing an offer or establishing contact with the user in relation to consulting, sales and installation, etc. The following personal data is forwarded to the business partner: first name and surname (company), e-mail address, street and house number, postal code, city/town, and telephone number, if provided by the user, and in some cases (when a Web configurator is used) also the image of the building, if provided by the user.
Sending e-mail and snail mail
On the basis of the express wish of users, who have in different ways indicated their wish to collaborate or receive notifications of news, fairs, campaigns, etc. Inotherm, d.o.o., processes the following personal data: first name and surname (company), e-mail address, street and house number, postal code, city/town, and phone number.
Contract-based data processing
Inotherm, d.o.o. collects and processes the personal data of the individuals on the basis of a contract or for the purpose of performing actions before a contract is entered into, such as the purchase of an Inotherm product, or the preparation of an offer for an Inotherm, d.o.o. product. On the basis of a contract, personal data is processed in order to fulfil contractual provisions, such as those relating to assembly, complaints, servicing, warranty claims, etc.
Data processing based on legitimate interests
Inotherm, d.o.o. collects and processes personal data on the basis of the legitimate interests we pursue. Personal data based on legitimate interests is processed for the following purposes:
- Users of INOPORTAL services (please see below)
- Statistical analysis of the Inotherm, d.o.o. website traffic
- Providing and improving our services
- Providing and developing innovative and customised services for our clients and users of Inotherm, d.o.o. websites
- Ensuring the security of our services and website, and protection against fraud, spam, abuse, etc.
For these purposes, we collect the following personal data: IP address, Inotherm, d.o.o. website statistics, data on the number of clicks, the click time, data on what sites visitors are coming from or going to, data on the types of clients.
For the personal data we collect and process for the purpose of providing the INOPORTAL service, please see the section Users of the INOPORTAL service.
Data processing on the basis of statutory obligations that apply to the data controller
Inotherm, d.o.o. collects and processes personal data of individuals in compliance with statutory obligations that apply to the data controller for the following purposes: keeping financial records, invoicing, debt collection, etc.
We collect and process the following personal data for these purposes: first name and surname, address, bank details, tax number, e-mail address.
Users of the INOPORTAL service
The INOPORTAL service is intended for business partners and their employees, and we use it to communicate with business partners.
Personal data in the INOPORTAL service is also processed on the basis of the legitimate interests pursued by Inotherm, d.o.o. The legitimate interests we pursue include the following:
- exchanging information required for carrying out our activities;
- expanding and/or upgrading business relations with business partners;
- adapting the content of activities to business partners;
- statistical processing;
- using the INOKALK service;
- sending offers, advertising materials and invitations to events;
- notifying partners of possible defects in Inotherm, d.o.o. products.
Inotherm, d.o.o. will allow users to stop receiving marketing messages in a simple manner. Users will be able to opt out at any time using a simple “unsubscribe” function at the end of each email message.
Personal data protection
To ensure the protection of personal data, Inotherm, d.o.o. implements all the necessary physical, technical, logistical and organisational procedures and measures, based on in-house regulations and in compliance with good practices in the field of information security or through contractual partners, so as to:
- protect the application software used for processing personal data;
- prevent unauthorised access to personal data when it is transmitted, including transmission via telecommunications devices and networks;
- provide an effective way of archiving, destroying, deleting or anonymising personal data;
- protect spaces, hardware and software;
- enable the subsequent determination of such facts as when individual personal data was processed in whatever manner or who it was processed by for the duration of the storage of data.
Automated processing of personal data
Inotherm, d.o.o. automatically processes personal location data for users who complete one of the following forms: ‘Configurator’, ‘Send an inquiry’, ‘Find a partner’. Automated processing works by sending the completed personal data of an individual to the controller (Inotherm, d.o.o.) or the business partner who is closest to the user based on the address provided (street, house number, postal code, city/town).
The automated processing of personal data described above is based on the consent of the individual (user).
Further processing of personal data
In some cases Inotherm, d.o.o. processes personal data for purposes other than those for which such data was originally collected. An example of such further processing of personal data is an inquiry about a product when, at the request of the user, we process previously provided personal data for the purpose of making an offer, and subsequently for possible confirmation of a contract and the stipulation of contractual terms between two parties.
Timeframe for storing personal data
Individual personal data obtained on the basis of consent are stored for 5 years after the cancellation of your consent.
Individual personal data processed on the basis of a contract may be stored for 10 years from the fulfilment of the contractual obligations by both parties, and in the event of the recovery of unpaid contractual obligations, for 10 years following the completion of legal proceedings.
Personal data collected on the basis of legitimate interests will be kept until the enforcement of the rights of the individual to whom they relate or as long as the purpose for which they were originally collected exists.
Rights of the individual
Under the applicable legislation governing the field of personal data protection, individuals have the following rights:
- Right of access by the data subject
The data subject has the right to receive confirmation from the data controller that personal data related to the data subject is being processed and, if so, the right of access to such personal data.
- Right to correct
The data subject has the right to have the data controller correct inaccurate personal data relating to the data subject without undue delay. Bearing in mind the purposes of data processing, the data subject has the right to amend incomplete or inaccurate personal data.
- Right of deletion
The data subject has the right to have the data controller delete personal data relating to the data subject without undue delay, and the controller has the obligation to delete personal data without undue delay as long as the reasons for such deletion are in compliance with the provisions of the General Data Protection Regulation (GDPR).
- Right to limit data processing
The data subject has the right to have the data controller limit data processing when the data subject disputes the accuracy of the data, when such processing is illegal and when the data subject opposes the deletion of data, and requests the restriction of their processing instead, when the data subject files an objection concerning the processing of data, and when the controller no longer requires personal data for the purposes for which they were originally collected, but the data subject requires them for the enforcement, implementation or defence of claims.
- Right to data transferability
The data subject has the right to receive personal data relating to the data subject, which the data subject has communicated to the controller in a structured, generally used and machine-readable form, and the right to forward such data to another controller, without being prevented from doing so by the controller to whom the personal data were provided.
- Right to a contract
The data subject has the right, for reasons relating to his or her particular situation, to object at any time to the processing of personal data relating to the data subject, based on the processing necessary for the legitimate interests of the controller, including the creation of profiles.
- Automated decision making, including profiling
The data subject has the right not to be subject to a decision that is based solely on automated processing, including the creation of profiles, that has legal effects related to the data subject or that has a significant effect on the data subject in a similar manner.
- Right to file a complaint with a supervisory authority
The data subject may file a complaint concerning the processing of his or her personal data directly to the competent supervisory authority, i.e. the Information Commissioner of the Republic of Slovenia.
- Method of exercising the rights of individuals
The data subject may exercise his or her rights at any time, in accordance with the General Data Protection Regulation.
This is done by sending an email with a request to the e-mail address firstname.lastname@example.org. The request must be sent from the e-mail address that the individual provided with his or her personal data.
If you have any questions regarding the Privacy Protection Policy, kindly submit your questions to us at the e-mail address email@example.com.
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Amendments and Validity
Inotherm, d.o.o. reserves the right to amend its Privacy Protection Policy, of which we will notify you in due course.
The Privacy Protection Policy is effective from 25 May 2018.