Pursuant to Articles 12, 13 and 14 of the Regulation (EU) 2016/679 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: the “General Data Protection Regulation“), we, the data controller, are providing you, the data subject, with information on the identity of the data controller, the purposes of the processing of personal data as well as the legal basis for such processing, categories of recipients of the personal data, data retention periods and your rights under the General Data Protection Regulation.
Who is the data controller?
The data controller in the sense of the General Data Protection Regulation is TRIGAL, upravljanje naložb in svetovalne storitve, d.o.o., Dunajska cesta 22, 1000 Ljubljana, Slovenia, telephone: +386 (0) 8 200 73 48, registered at the District Court of Ljubljana under the number: 7235232000, tax number: SI 45514992, LEI code: 4851006WX9ON1MWW9471 (hereinafter: the “TRIGAL“). As such, TRIGAL determines the purposes and means of the processing of personal data which it collects.
Should you have any questions relating to the processing of personal data, do not hesitate to contact us at any time via e-mail (firstname.lastname@example.org).
Which personal data do we process?
Personal data is any information relating to an identified or identifiable natural person. TRIGAL processes your data mostly in the following cases:
- when you visit our website;
- when you make an inquiry using the contact forms provided on the TRIGAL website or when you contact us over e-mail or telephone;
- when we are providing you with our services;
- when we process your job application or for the performance of an employment contract;
- when we need to comply with various legal obligations.
TRIGAL will not process your data unless you provide it to us, except for certain personal data that we might collect from public authorities and holders of public authorizations under statutory or personal authorization as well as information collected from information systems and central registers that are available to us.
|To ensure the functioning of the TRIGAL website, we store small text files (also known as cookies) on your devices (e.g. computer, mobile device and any other device) when the website is loaded on your browser. We use strictly necessary cookies that are essential for the website to work and for which, according to the Electronic Communications Act, we do not require your consent. We would also like to install analytical cookies to give you the best user experience and to help us to improve our website by collecting statistical information on how you use it. We will only set analytical cookies if you enable them. If you do not click »Accept« on the cookie banner and continue using the website or when you click »Close«, only strictly necessary cookies will be installed on your device. You can find more information on cookies here.
You can manage your cookie preferences at any time by clicking on the Cookie Consent tab at the bottom left of your screen.
|Whenever you might be interested in our services (e.g. you wish to lease business premises that we manage) you can send us inquiries via forms on our website. You may also contact us directly. In such cases, we collect and process personal data (name of the company your work for or represent, the business activity of the company, your name, e-mail, telephone number, lease preferences and special requirements etc.) provided with your inquiry.|
How do we process your data and on what legal basis?
We collect your data only when this is strictly necessary and in accordance with the purpose for which they have been provided. We will not use personal data for any other purpose.
|Performance of a contract||If you are our client or potential employee (natural person), the legal basis for the processing of personal data is the performance of a contract or taking steps on your request before entering into a contract (e.g. answering your inquiries, meeting your requirements, submitting and receiving bids, receiving bids, communicating with you, processing an application or signing up for a job).|
|Compliance with legal obligations||We also process your data to comply with legal obligations that are imposed on us (e.g. reporting to tax and other competent authorities and for other disclosures prescribed by law, carrying out customer due diligence and other tasks and measures stipulated in anti-money laundering legislation).|
|Legitimate interests||In certain cases, we also process your data for the purposes of legitimate interests pursued by us or by a third party, except where your interests or fundamental rights and freedoms override such interests (e.g. preventing fraud and misuse of services, maintaining physical and IT security, enforcing legal claims).|
|Consent||TRIGAL will, in certain cases and if appropriate, ask you to give consent to the processing of personal data. In such cases, you have the right to withhold or withdraw consent at any time without detriment, whereby the withdrawal of consent shall not retrospectively render processing unlawful. Providing personal data is voluntary and the supply of services will never be made contingent on consent to the processing which is not necessary for the service being supplied.|
You are obliged to provide your personal data in cases where the provision of your data is a statutory or contractual requirement, or a requirement necessary to conclude a contract. When you do not provide us with the requested information, we shall not be able to provide our legal services, receive and process your applications and inquiries, and to fully adhere to legal obligations.
In rare cases, we also process special categories of personal data (e.g. racial or ethnic origin, medical diagnosis and other data concerning health, information on trade union membership, biometric data etc.), especially when such processing is necessary for the establishment, exercise or defence of legal claims, to carry out obligations and exercise rights in the field of employment or for reasons of substantial public interest.
With whom do we share your data?
Your data are disclosed only to TRIGAL employees that are all bound by confidentiality. We also disclose your data to carefully selected advisors or other service providers, i.e. data processors and other recipients of personal data. Data processors are our business partners which provide us with certain services and process personal data on our behalf and based on our instructions. In such cases, we always enter into appropriate data processing agreements in which the recipients are bound by the same level of data protection as if we were processing the data ourselves. We also disclose your data to independent data controllers (e.g. attorneys-at-law) and outside recipients (e.g. authorities and other controllers) but only if there is a lawful basis for doing so.
Where do we process your data?
As a rule, we only process your personal data within the EU and EEA. In certain cases, however, we may also transfer your personal data to recipients in third countries, whereby we guarantee that an adequate level of data protection shall be ensured and that all legal conditions for transferring data to third countries shall be met.
We can only transfer personal data if:
- we carry out the transfer to one of the countries or international organizations for which the European Commission adopted an adequacy decision;
- the transfer is subject to appropriate safeguards under Article 46 of the General Data Protection Regulation (e.g. standard data protection clauses, binding corporate rules);
- conditions for derogations for specific situations under Article 49 of the General Data Protection Regulation are met.
How long do we keep your data?
TRIGAL will process your personal data until the purpose is fulfilled or within the limits of the limitation periods for obligations that could arise from the processing of these personal data. In cases when the retention period of the personal data is prescribed by law, TRIGAL will keep the personal data in line with the retention periods prescribed by law.
In specific cases, where the legal basis for processing is your consent, we will keep your personal data until such consent is withdrawn. Once that consent is withdrawn, we will also stop processing your personal data if there is no other lawful basis for further processing.
What are your rights?
The existence and extent of your rights depend on the circumstances of a case. In accordance with the conditions set out in the General Data Protection Regulation, you have the following rights:
|Access||You have the right to ask us for copies of your personal information.|
|Rectification||You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete the information you think is incomplete.|
|Erasure||You have the right to ask us to erase your personal information in certain circumstances.|
|Restriction of processing||You have the right to ask us to restrict the processing of your information in certain circumstances.|
|Objection to processing||You have the right to object to the processing of your personal data in certain circumstances.|
|Data portability||You have the right to ask that we transfer the information you gave us to another organization, or you, in certain circumstances.|
Please contact us by e-mail or by registered mail should you wish to make a request. You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond.
How do we protect your data?
We value your personal data immensely and have implemented effective measures to safeguard all confidential information. Should you believe that a data breach has taken place, please let us know as it happens, and we will provide you with an appropriate answer. If needed, we will also immediately undertake measures to remedy the situation.
You also have the right to lodge a formal complaint with the Information Commissioner (Information Commissioner of the Republic of Slovenia, Dunajska cesta 22, 1000 Ljubljana, e-mail: email@example.com, telephone: +386 (0)1 230 97 30.
Ljubljana, 22 October 2020