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?

SVETLIK, investment management, LLC, Nazorjeva ulica 10, 1000 Ljubljana, Slovenia, registered at the District Court of Ljubljana under the number: 9285407000, tax number: SI 62392620 (hereinafter: the “Company“) is the data controller in the sense of the General Data Protection Regulation and as such determines the purposes and means of the processing of your personal data.

Should you have any question relating to processing of personal data, do not hesitate to contact us at any time via e-mail (gaja@svetlik-sfo.com).

WHICH PERSONAL DATA DO WE PROCESS?

Personal data is any information relating to an identified or identifiable natural person.

The Company processes your personal data mostly in the following cases:

• when you visit our website;
• when you make an inquiry using the contact form provided on our website or when you contact us over the e-mail or telephone;
• when we have an ongoing business relationship;
• when we process your job application or for the performance of an employment contract;
• when we need to comply with various legal obligations.

The Company will not process your personal data unless you provide it to us, except for certain personal data that we collect from public authorities and holders of public authorisations in accordance with the Attorneys Act as well as information collected from information systems and central registers that are available to us. We also process your personal data which is provided to us by clients where such information is needed to provide legal services, including for representation of our client before courts and other authorities.

COOKIES

In order to ensure the functioning of the Company website, we may store small files on your devices (e.g. computer, mobile device and any other device), also known as cookies during your visit to our website. Kindly note that we use strictly necessary cookies which 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 set analytical cookies to give you the best user experience and to help us to improve our website by collecting 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. More information on cookies are available here.

CONTACT FORM

We collect and process personal data (personal name, e-mail, telephone number, name of company) provided by you via our contact form on the Company website when you send us your inquiry. We only provide access to this personal data to our authorized personnel of Company who process your inquiry; and are bound by confidentiality.

HOW DO WE PROCESS YOUR PERSONAL DATA?

We collect your personal 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.

If you are our business partner or potential employee, the legal basis for the processing of personal data is the performance of a contract or taking steps on your request prior to entering into a contract (e.g. answering your questions and comments, meeting your requirements, submitting and receiving bids, communicating with you, processing an application or signing up for a job).

We also process your personal data in order to comply with legal obligations that are imposed on us.

In certain cases, we also process your personal 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).

You are obliged to provide your personal data in cases where the provision of your personal data is a statutory or contractual requirement, or a requirement necessary to conclude a contract or to sign up for a job. When you do not provide us with the requested information, we shall not be able to provide our services or receive and process your applications and inquiries.

The Company 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.

In certain 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 purposes of carrying out obligations and exercising rights in the field of employment or for reasons of substantial public interest.

WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

Your personal data are disclosed only to employees of Company and its permanent experts that are all bound by confidentiality. We also disclose your personal data to carefully selected outsourced service providers, i.e. processors and other recipients of personal 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 personal data to outside recipients (e.g. authorities and other controllers) but only if there is a lawful basis for doing so.

WHERE DO WE PROCESS YOUR PERSONAL 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 pertaining to data transfers 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 organisations for which the European Commission adopted an adequacy decision, or to one of the countries on the Information Commissioner’s list of third countries with an adequate level of data protection;
• 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 PERSONAL DATA?

The Company will process your personal data to the extent and for the time necessary to achieve the purposes of the processing. Personal data is thus processed 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, Company 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 of your personal data.

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 right to request from Company access to and rectification or erasure of personal data or restriction of processing concerning the data subject and to object to processing as well as the right to data portability. You can send us your request by e-mail or by registered mail.

More information on your rights are available here.

HOW DO WE PROTECT YOUR PERSONAL DATA?

The effective protection and safeguarding of personal data are of great importance to us, therefore we have implemented appropriate technical and organisational measures for protection of all personal data and to safeguard them against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data.

If you believe that a data breach has taken place, please let us know as it happens, and we will provide you in a timely manner 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: gp.ip@ip-rs.si, telephone: +386 (0)1 230 97 30.

In Ljubljana, 13 February 2023