PRIVACY POLICY

ZA, trgovina in storitve, d.o.o., (hereinafter: the data controller) obtains and process personal data of individuals in its business proceeding. In order to provide you with basic information about the processing of your personal data at the data controller, we have drafted this Privacy Policy.

 

The policy contains information for the individuals that is provided under the General Data Protection Regulation (hereinafter: GDPR), which is sectioned according to the purpose for which the personal data is processed.

 

The controller processes your personal data when you:

use our website Sport to be (S2B)  on https://s2be.eu/, 

make an order in our online store, 

contact us via e-mail or when

subscribing to our newsletter. 

 

Data controller information:

 

ZA, trgovina in storitve, d.o.o.,

Celovška cesta 136, 1000 Ljubljana, Slovenija

e-mail: info@s2be.eu
phone nr.: +386 30 722 622 / +386 30 460 702



  • THE USE OF S2B WEBSITE

 

This information on the processing of personal data is intended for individuals who visit the website https://s2be.eu/.

 

  • Purpose of processing and types of personal data

The controller processes your personal data when visiting the website https://s2be.eu/ in order to monitor and ensure the operation and security of use of the website.

 

When visiting the website, data processing is performed and that includes:

– the time of access to the website,

– your IP address and

– the address of the (sub)website,

– browser settings and information about the operating system of the computer or mobile device,

– the content you access on the website.

 

In order to visit the website, the processing of the above stated personal data is necessary, as they represent the essential cookies, which you can read more about in the Cookie Policy.

 

  • Legal basis for the processing of personal data

This processing of your personal data is carried out on the basis of the controller’s own legitimate interest (point (f) of Article 6(1) of the General Data Protection Regulation (GDPR)).

 

  • Explanation of legitimate interests

The controller may process the personal data of an individual who uses the website due to:

 

  1. Ensuring information security and the operation of information systems

The controller performs the processing of personal data to ensure information security and operation of information systems, network and information security, prevention of unauthorized access to the controller’s information systems and response to computer security threats and incidents. To this end, the operator also performs technical maintenance of the websites and services. These measures and processing relate to the personal data of customers or third parties (such as website visitors).

 

  1. To prevent and detect abuse and conduct that may have signs of criminal conduct

In case of suspicion of abuse or criminal conduct, the controller may process data on users of websites and online services to an appropriate and proportionate extent for the purpose of identifying and preventing possible fraud or abuse (so-called black list) and may, if appropriate, provide this information to the competent authorities. 

 

  • Categories of recipients of personal data

The controller may provide the personal data of the individual visiting the website to the following persons:

– external IT website service providers,

– state authorities at their request or in case of suspicion of criminal conduct;

 

  • Period of personal data storage

When storing individual’s activity data on the website (IP address), the processing and storage will last only for the time specified in the Cookie Policy, except in the case of incidents and violations. Data collected at the time of the identified abuse may be kept permanently.

 

  • Rights of the data subject

An individual may request access to personal data, its rectification, to erasure (not when black-listed), restriction of processing and to object to processing under legitimate interest legal basis. To exercise your rights, contact us at ZA, trgovina in storitve, d.o.o., Celovška cesta 136, 1000 Ljubljana, Slovenija, or on e-mail info@s2be.eu.

 

  • The right to lodge a complaint with the supervisory authority

The controller strives to process your personal data legally and to protect it with appropriate technological and organizational means. If you believe that your personal data is processed by the controller in contravention of the applicable regulations governing the protection of personal data, you have the right to file a complaint with the Information Commissioner of the Republic of Slovenia (address: Dunajska cesta 22, 1000 Ljubljana, e-mail: gp.ip@ip -rs.si, phone: 012309730, website: www.ip-rs.si).

 

For more information on analytical and advertising cookies, please also follow the link to the Cookie Policy which is an integral part of this Privacy Policy.


  • SHOPPING AT ONLINE STORE

 

This information is intended for individuals who shop in the data cotroller’s online store S2B, available on https://s2be.eu/

 

  • Purpose of processing and type of personal data

The basic purpose of the processing of personal data is the conclusion and implementation of a contract which the individual concludes with the controller for the purchase of goods. The contract is governed by the controller’s General terms and conditions. 

 

The information that the controller obtains from an individual when concluding a contract are:

  • name and surname,
  • address,
  • e-mail address,
  • phone number,
  • delivery address,
  • order information (order status, ordered item, quantity, ordering date, purchase price),
  • method of payment, information on the provider of the means of payment, information on the successful / unsuccessful execution of the transaction,
  • other information that the individual provides to the controller when concluding the contract.

 

The listed personal data is obtained directly from the individual. The provision of the above stated information is an individual’s contractual obligation. The provision of data (excluding the un-mandatory data) is essential for the performance of the contract of ordering products in the online store. If the individual does not provide the information, he will not be able to make a purchase in the online store.

 

Personal data will be used to contact the individual, for example for additional information, coordinate the order, to pick up and deliver the goods and other communication related to the service order.

Due to the implementation of the contract, the controller may disclose the individual’s name, surname, address and telephone number to his delivery partner company.

The controller may also use the data on the electronic and physical address of an individual obtained in the course of performing his services for the purpose of carrying out direct marketing of his products.

The personal data of an individual may also be processed for the purpose of preventing and identifying abuses and conduct that may have signs of criminal conduct, to the extent necessary to achieve these objectives.

 

  • Legal basis for the processing of personal data

The legal basis for the processing of personal data in the online store is the performance of a contract to which the data subject is a party or the performance of an activity at the request of an individual before the conclusion of the contract (point (b) of Article 6 (1) of the GDPR). 

 

The personal data of an individual ordering  the products in online store may also be processed on the basis of legitimate interests pursued by the controller pursuant to point (f) of Article 6 (1) of the GDPR or pursuant to paragraph 2 of Article 158 of ZEKom-1 and are explained in the next section.

 

  • Explanation of legitimate interests

The controller may process the personal data of an individual who orders his product also for:


  • Implementation of direct marketing

For reasons of pursuing business objectives, the controller may process the personal data of customers for the purpose of sending advertising electronic messages (paragraph 2 of Article 158 of ZEKom-1) or physical mail (legitimate interest). In this case the controller is entitled to process the individual’s past or unfinished purchase orders and perform basic segmentation (such as type of purchased product and location), so he will be able to prepare a relevant message for the individual (for example offering new products, sending discount coupons, promotional gifts, invitations to events etc.). Such processing may be objected to by the individual at any time in accordance with the procedure described below. controller is also entitled to send its messages and correspondence equipped with marketing content.


  • For the purpose of preventing fraud and abuse

In its operations, the controller establishes and maintains a list of persons for whom, on the basis of past experience, it assesses that the conclusion of business relations with them is not appropriate. These are clients who have been suspected of fraud, fraud or other illegal conduct and abuse.

 

  • Measures taken to ensure safety od personal data

The online store and its downloads are electronically protected. The data that is entered in the online form by the individual is essential for the execution of the order and are stored in the online store management system for traceability. Access to it is password protected, and the online store also uses an access control system, firewall and SSL certificate to protect data traffic with encryption. The server hosting the online store is located in Slovenia and is regularly updated and protected according to internationally accepted standards and guidelines.

Personal data on invoices issued, in the invoicing and shipping program, shipping documents, e-mails, etc. are stored at the controller’s headquarters. The controller protects this information by locking the premises where it is stored, by passwords on computers, etc. 

 

  • Categories of personal data recipients

The controller may provide the data of the individual ordering his products to the following recipients:

 

product manufacturer,

providers of IT services (online store functioning, technical maintenance of equipment, direct marketing);

contractors for delivery services,

accounting service provider,

payment service providers (execution of transactions),

– public authorities at their request or in case of suspicion of criminal conduct,

state bodies in accordance with their legislative powers (such as Slovenian Tax Administration);

 

  • Information on transfers of personal data to a third country or international organization

Customer information may be transmitted in the United States of America through communication with the customer via email operated by Microsoft Corporation, One Microsoft Way, Redmond, Washington and in the execution of payments through payment processor providers (Google Payments, PayPal, Stripe Payments Europe Limited), taking into account the principles of the Privacy Shield and on the basis of standard EU contractual clauses adopted by these online service providers into their general terms and conditions.

The controller is using the online platform MailChimp to send newsleter to its clients, which takes into account the standard EU contractual clauses approved by the European Commission and included in the processing contract. The MailChimp platform privacy policy is available at https://mailchimp.com/legal/privacy/.

 

  • Period personal data storage 

Data on concluded contracts will be kept for 10 years from the fullfilment of the contractual obligation. Insofar as this is necessary for the conduct of legal proceedings, customer data may also be kept for a longer period of time. Data from t.i. black lists are kept permanently.

 

  • Rights of the data subject

An individual may exercise his rights by a written request submitted at the headquarters ZA, trgovina in storitve, d.o.o., Celovška cesta 136, 1000 Ljubljana, Slovenija or to our e-mail address info@s2be.eu. You may request the correction, access, restriction of processing or transfer of personal data processed in connection with you.

 

An individual may object to processing for the purposes of direct marketing on the basis of paragraph 2 of Article 158 of ZEKom-1. The latter does not affect the lawfulness of the processing carried out on that basis until the opposition was lodged and does not affect the processing of personal data processed on other legal bases. Exercise this right by unsubscribing from marketing messages by following the link in the marketing email or by reaching to us at info@s2be.eu

 

We will guarantee the exercise of your rights within one month of receiving the request, and this period may be extended by two months under certain conditions. If we extend the deadline, we will inform you about this and the reasons for this within one month of submitting the request.

 

  • The right to lodge a complaint with the supervisory authority

The controller strives to process your personal data legally and to protect it with appropriate technological and organizational means. If you believe that your personal data is processed by the controller in contravention of the applicable regulations governing the protection of personal data, you have the right to file a complaint with the Information Commissioner of the Republic of Slovenia (address: Dunajska cesta 22, 1000 Ljubljana, e-mail: gp.ip@ip -rs.si, phone: 012309730, website: www.ip-rs.si).



SUBMITTING A REQUEST ON OUR E-MAIL

 

This information on the processing of personal data is intended for individuals who contact us at info@s2be.eu.



  • Purpose of processing and type of personal data

 

The controller processes the personal data you have provided in you e-mail message sent to at info@s2be.eu, in order to provide you with the information you have requested from us. 

 

  • Legal basis for the processing of personal data

 

This processing is carried out on the basis of the controller’s own legitimate interest (point (f) of Article 6 (1) of the General Data Protection Regulation (GDPR)).

 

The information you provide via e-mail is:

contact details (personal name, company name, e-mail address, telephone number etc.) 

the content of your message;

 

The controller processes the data for the purpose of communication when you express such a request. Personal data from the contact forms are not used for other purposes.

 

  • Categories of personal data recipients

The controller cooperates with the processors on technical aspects of the establishment, operation and security of electronic communication.

The controller has concluded appropriate DPA contracts with service providers.

 

  • Information on transfers of personal data to a third country or international organization

Data from online communication can be transferred to the USA, as the controller uses the services of e-mail provider Microsoft Corporation, One Microsoft Way, Redmond, Washington, USA, on the basis of standard contractual clauses adopted by the web provider in addition to the general terms and conditions for its services.

 

  • Period of retention of personal data

The controller will process personal data from the contact forms until the purpose of their processing is achieved, i.e. completion of communication with the individual. If the communication is part of a contract, it is kept in accordance with the explanations in the section “Shopping in online store”.

 

  • Rights of the data subject

 

An individual may exercise the right of access to personal data, the right to rectification, restriction of processing, deletion or objection to the processing. The rights can be exercised by contacting us at ZA, trgovina in storitve, d.o.o., Celovška cesta 136, 1000 Ljubljana, Slovenija or by e-mail on info@s2be.eu.

 

We will guarantee the exercise of your rights within one month of receiving the request, and this period may be extended by two months under certain conditions. If we extend the deadline, we will inform you about this and the reasons for this within one month of submitting the request.

 

  • The right to lodge a complaint with the supervisory authority

The controller strives to process your personal data legally and to protect it with appropriate technological and organizational means. If you believe that your personal data is processed by the controller in contravention of applicable regulations governing the protection of personal data, you have the right to file a complaint with the Information Commissioner of the Republic of Slovenia (address: Dunajska cesta 22, 1000 Ljubljana, e-mail: gp.ip @ ip-rs.si, phone: 012309730, website: www.ip-rs.si).


  • SUBSCRIBING TO NEWSLETTER

 

 

This information on the processing of personal data is intended for individuals who subscribe to the controller’s electronic newsletter. 

 

  • Purpose of processing and type of personal data

 

The purpose of the processing is for the controller to inform the registered individuals about novelties and offers regarding its products. In addition to your IP number, the controller only processes your e-mail address, which you enter in the online form and the date and time of registration.

 

  • Legal basis for the processing of personal data

 

This processing is carried out on the basis of the given consent of the individual (point (a) of Article 6 (1) of the General Regulation on Personal Data Protection (GDPR)). When completing the online newsletter subscription form, you indicate that you agree to controller’s use your e-mail address for the purpose of receiving the newsletter and that you are aware that you can unsubscribe from the messaging system at any time by clicking the unsubscribe button in the received e-mail. 

 

  • Categories of personal data recipients 

 

The operator shall cooperate with processors on the technical aspects of the establishment, operation and security of direct marketing. The latter process personal data only exceptionally and to a limited extent (for example random access to data when solving technical problems). The operator has a relevant processing contract with the IT service providers.

 

  • Information on transfers of personal data to a third country or international organization

 

Data from e-mail communication is transferred to third countries, as the operator uses the services of Microsoft Corporation, One Microsoft Way, Redmond, Washington, USA, on the basis of standard contractual clauses adopted by the online service provider into their general terms and conditions.

 

The controller is using the online platform MailChimp to send newsleter to its clients, which takes into account the standard EU contractual clauses approved by the European Commission and included in the processing contract. The MailChimp platform privacy policy is available at https://mailchimp.com/legal/privacy/.

 

  • Period of retention of personal data

 

Your email information is stored until you unsubscribe from the email notification service.

 

  • Rights of the data subject



The individual may revoke the given consent at any time and without negative consequences. Consent is revoked by unsubscribing from the e-news with the link in the e-mail or by e-mail info@s2be.eu. The revocation does not affect the processing that took place until the revocation, nor does it affect the processing of data on another legal basis. 

An individual may exercise the right of access to personal data, the right to rectification, restriction of processing, deletion or transfer. You can exercise these rights by contacting us at ZA, trgovina in storitve, d.o.o., Celovška cesta 136, 1000 Ljubljana, Slovenija or by e-mail on info@s2be.eu.

 

We will guarantee the exercise of your rights within one month of receiving the request, and this period may be extended by two months under certain conditions. If we extend the deadline, we will inform you about this and the reasons for this within one month of submitting the request.

 

  • The right to lodge a complaint with the supervisory authority

The controller strives to process your personal data legally and to protect it with appropriate technological and organizational means. If you believe that your personal data is processed by the controller in contravention of applicable regulations governing the protection of personal data, you have the right to file a complaint with the Information Commissioner of the Republic of Slovenia (address: Dunajska cesta 22, 1000 Ljubljana, e-mail: gp.ip @, ip-rs.si, phone: 012309730, website: www.ip-rs.si).



Ljubljana, 7th of July 2022