Privacy policy

Smartpa d.o.o. (Smartpa) is comitted to protecting and respecting your privacy. This Privacy Policy describes Smartpa’s policies and procedures on the collection, use and disclosure of your information, which we have gathered untill now through publicly available sources on the internet and of your information when you use our services, websites, and applications offered by Smartpa (the “Services”). By using the Services, you consent to our use of your information in accordance with this Privacy Policy. We will not use or share your personal information with anyone except as described in this Privacy Policy.

This Privacy Policy is issued on behalf of Smartpa so when we mention "Smartpa", "we", "us" or "our" in this Privacy Policy, we are referring to SMARTPA d.o.o. acting as the controller and responsible entity for your personal information shared with us.

We may amend this privacy policy at any time. Any changes or updates will be effective immediately upon posting to this page. You should review this Privacy Policy regularly for changes. You can determine if changes have been made by checking the Effective Date below. Your continued use of our website after posting will constitute your acceptance of, and agreement to, any changes.

The data controler is SMARTPA d.o.o., Leskoškova cesta 9E, 1000 Ljubljana, Slovenia.

1. Information We May Have About You

1.1. Information We Collected About You

We may have collected information about you from publicly available sources up until May 25th 2018 from the internet sources, such as: LinkedIn, Viadeo, Xing, your company's websites and other. The personal information we collected may include your name, your business email address, job title and link to your LinkedIn or other social network's profile.

As part of our activities, we obtain information about you from the business register of Slovenia. Personal information that we obtain this way may include your name, position in company and company information you entered when signing in the register (e-mail address, telephone number, URL to your company's website).

1.2. Information you provide to us

You may provide us with information by filling in forms on our website or by corresponding with us by phone, e-mail, live-chat or otherwise. This includes information you provide when you register for an account, search for a price comparison, enter into a contract for the supply of services and when you report a problem with our site, provide payment instructions, provide us with access to your profiles on third party sites. The personal information you provide may include your name, address, e-mail address, IP address, job title, phone number, and other information about the company you work in.

1.3. Information You Automatically Provide To Us When You Use the Service

Smartpa collects non-personally identifiable information regarding your usage of the Services, including the pages, articles and presentations you viewed, time spent using certain features of the website, demographic data such as server locations, connection speed and other information that does not identify you. Like most online services, we may use technologies such as cookies, log files, clear GIFs, tracking pixels and web beacons. This information may be combined with other information you provide to us, as described above.

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.

2. How We Use Information About You

2.1. Smartpa uses collected personal information to provide the Services, to verify your identity and prevent fraud or other unauthorized or illegal activity, to personalize content, remember information to help you efficiently access your account, analyze how the Services are used, diagnose and fix service or technical problems, maintain security, monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns, and track user Content and users as necessary to comply with applicable laws.

2.2. We may use your email address to send you Services-related notices, including any notices required by law.

2.3. We may also use your contact information to:

  • send you marketing messages, which include providing you with information about our services that might interest you, make suggestions and recommendations to you of our services;

  • to measure or understand the effectiveness of advertising we serve to you and to deliver relevant advertising to you, which may be based on your activity on our website and your activity regarding our marketing messages;

2.4. If you correspond with us by email, we may retain the content of your email messages, your email address and our responses.

2.5. The data we have obtained from the business register of Slovenia can be transferred to our partner Kompass International, which is based in France. Kompass International uses your data on its platform, which enables companies to establish business communication with one another. You can find out more about Kompass International on their website: https://si.kompass.com.

3. Retention of your information

We will retain your information for as long as your account is active or is needed to provide you the Services and may retain Data after you discontinue use of the Services or until you withdraw your consent. We will retain and use your information as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements.

4. Your rights

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. You have the right to access the information we hold about you and the right to correction or erasure of your data. You also have the right to restrict the use of your information and the right to transfer your personal data to the third party.

If you think that we are violating your rights, you have a right to complain with a supervisory authority.

To better understand your rights, see their descriptions below:

The right to access ​to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

The right to correction ​of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

The right to erasure ​of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

The right to object to processing ​of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

The right to restriction of processing ​of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

The right to the transfer ​of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

The right to withdraw consent at any time ​where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.

If you wish to exercise these rights please contact us at gdpr@smartpa.si.

5. Sharing your personal information

We keep your information in customer relationship management platform called Platformax and we might keep your information in an e-mail marketing platform called Mailchimp. We consider this information to be a vital part of our relationship with you.

6. Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. How We Protect Your Information

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. How to Contact Us

If you have any questions about our practices or this Privacy Policy, please send mail to gdpr@smartpa.si

Effective Date

This Privacy Policy was last updated on June 22, 2018.