Privacy Policy on the website https://www.myvipguest.com, https://myvipguest.com, https://online.myvipguest.com/

Effective 29.08.2024.

Who is the manager of your personal data processing?

CET4Biz d.o.o., Celje, Aškerčeva ulica 15, VAT-ID: SI13181033, Company Registration Number: 6836321000, e-mail: office@cet4biz.com (hereinafter: “Controller” or “we”) respects your privacy and is committed to protecting it during and after your visit to this website site (hereinafter: ” Website”), visiting our business locations and when you use any of our products or services. We have set up appropriate physical, electronic and management procedures to protect the processing of personal data. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and us or information stored on this Website or on our servers will be completely secure from unauthorized access by third parties. Therefore, we have policies in place to determine how your personal data shall be processed and protected.

By accessing the Website, entering our business locations and purchasing any of our products or using our services, you accept this Privacy Policy and understand and acknowledge that we collect and use your personal data as specified in this Policy. This Privacy Policy is subject to change, and the date of the last change is indicated at the top.

As a Controller, we process your personal data in accordance with the applicable rules on personal data protection, in particular in accordance with the General Data Protection Regulation (EU) 679/2016 (hereinafter: GDPR) and the Law on the Implementation of the Slovenian Data Protection Act (Zakon o varstvu osebnih podatkov, ZVOP-2, "ZVOP-2").

Types of personal data that will be processed, purpose and legal basis of personal data processing

As a Controller we process your personal data, that is information that can directly or indirectly identify you, in particular through identifiers such as your first name, last name, email address, phone number, date of birth, address, credit card number, opinions about our services, IP address and other personal information when communicated with us when contracting (hereinafter: “Personal data”), especially when:

• you contact us via e-mail or connect with us via social networks,
• make comments or ask questions,
• we process your application or job application
• you access our Website
• you are a visitor to our business locations
• we photograph the events and activities we organize
• we send the newsletter
• we issue an invoice for products/services
• we cooperate with you as our suppliers and business partners

We process personal data on the basis of your consent, legitimate interest, for the performance of a contractual obligation, and on the basis of a legal obligation. The processing of Personal Data is limited only to the purpose for which it was collected in accordance with the terms of this Privacy Policy.

When we process data on the basis of your consent, we process only those personal data that you have voluntarily given us when communicating with us, in order to answer your questions or process your job application. The purpose of the processing is to take steps according to your request, for example, answering questions and comments, receiving offers, communicating about your activities on the site, processing open applications and applications for tenders, as well as when you are subscribed to receive the newsletter. We also process your data for marketing and advertising purposes, but only on the basis of your consent, which you can withdraw at any time, and in connection with which processing we will specifically ask for your consent.

On the basis of legitimate interest, we process Personal data when you access our Website (IP address), when we photograph the events and activities we organize. If we organize an event and other activities during which we will photograph and record guests, we will do so either on the basis of legitimate interest, of which you will be informed in advance and before entering the recording/photographing area, or you will be asked for your consent beforehand. It is our legitimate interest to deliver a newsletter to existing users of our services and customers of our products. The purpose of this processing includes the investigation of suspected fraud, harassment, physical threats or other violations of the Website’s rules, or any suspicious behaviour that we consider indecent. We process the recordings/pictures of the participants at our events for the purpose of promoting the event.

In order to fulfil contractual obligations and on the basis of legal and by-law regulations, we are obliged to process your personal data when you buy our products or use our services. The data of business partners is specially processed (e.g. agreements regarding the execution of services), in addition, we also process the contact data of business partners who are natural persons and their employees (e.g. first and last name, official telephone / mobile phone number, e-mail address), as well as customers who request the issuance of an invoice.

Newsletter

Through the Newsletter, we provide you with information related to events that we organize independently or in cooperation with business partners. The newsletter is sent when a certain event or other activity that we organize is approaching, or some benefits related to the sale of our products. Each Newsletter recipient is provided with a simple and quick unsubscribe with the oneclick unsubscribe feature included in each Newsletter.

We send the newsletter on the basis of either consent or legitimate interest. Data is kept until the respondent withdraws consent or objects to the sending of the Newsletter based on legitimate interest.

Open job applications and announced tenders

We process open applications from candidates who want to work with us and applications from candidates for tenders that we announce in such a way that only authorized persons have access to these personal data, and the data is kept for 2 years from the date of receipt of the open application.

Storage of personal data

We process Personal data only for the time necessary to achieve the purpose of processing them. We only process personal data that we process on the basis of consent until you withdraw your consent, while you can object to the processing of personal data on the basis of legitimate interest.

We store all other personal data that we process on the basis of the execution of the contractual relationship and on the basis of legal obligations in accordance with positive regulations in which the storage time is determined (e.g. the Accounting Act). Exceptionally, we will keep your personal data longer than the stated deadlines when it is necessary to fulfil mutual legal requirements.

At the end of the term, we will destroy stored personal data printed on paper in a safe way, for example by shredding, while we will irreversibly delete data in electronic form.

Your Personal Data may be disclosed in the following cases:

• entities necessary for the execution of the event - photography of the event,
• authorized PR and marketing agencies and entities that are directly involved in implementation and realization of certain event,
• entities that maintain our IT systems,
• entities that we have authorized to process Personal Data, which are subject to the appropriate legal obligation of confidentiality (e.g. bookkeeping service),
• law enforcement services and public authorities when required by applicable law or in good faith (for the purpose of protecting and defending our rights and/or property or to act in urgent circumstances to protect the personal safety of our guests, employees, the Site or the public),
• to our legal advisors in case of the need to forward data for legal procedures,
• to business partners for their needs only in accordance with appropriate legal grounds,
• media houses and digital marketing agencies for the purpose of publishing photos in print media, on websites and social networks

Transfer of Personal Data to third countries

The information we collect is stored within the European Union (EU) and the European Economic Area (EEA) excluding Switzerland, but may also be transferred to and processed in a country outside the EU and EEA. Any such transfer of personal data will be carried out in accordance with applicable legal regulations. For transfers outside the EEA, we use Standard Contractual Clauses, adequacy decisions, appropriate protective measures, which guarantee adequate protection of Personal data.

Cookies

Our Website uses cookies. We use cookies to provide you with the service and fulfil legal obligations. We may, with your consent, use cookies to analyse traffic on our pages or to provide support.

Cookies are text files that are stored in the computer system via the internet browser.

The Electronic Communications Act stipulates that we can store cookies on your device if they are absolutely necessary for the operation of this site. We need your consent for all other types of cookies. This Website uses different types of cookies. Some cookies are set by third parties that appear on our pages.

Necessary cookies

Necessary cookies help make the Website to be useful, enabling basic functions such as navigating the Website and accessing secure areas of the Website. Website cannot function properly without these cookies. In accordance with the law, necessary cookies can be stored independently of the consent of the Website user.

Third party cookies – analytics cookies

These cookies collect information about how visitors use the Website, for example which pages visitors visit most often. We use them to improve the functioning of our Website. However, some of them may be third-party cookies, and the data we collect may be used for purposes unknown to us as the owner of the Website. For more information, please see the privacy policies of those thirdparty processors.

„performance cookies“

These cookies collect information about how visitors use the Website, for example which pages visitors visit most often, and whether they receive error messages from websites. These cookies do not collect information that could identify the visitor. All information collected by these cookies is grouped and therefore anonymized. They are used only for the better functioning of the Website.

Provisions on the protection of data on the application and use of: Facebook, Instagram, TikTok, Discord, Twitter

On its Websites, the data controller can integrate or has integrated components of social networks Facebook, Instagram, TikTok, Discord.

Facebook and Instagram are social networks operated by Meta Platforms, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States of America. If the individual resides outside the United States of America or Canada, the controller is Meta Platforms Ireland Ltd., 4 Grand Canal Square Grand Canal Harbor Dublin 2 Dublin 662881, Republic of Ireland. The data protection policies published by Facebook, Instagram are available at https://facebook.com/about/privacy/ and https://help.instagram.com/519522125107875?helpref=page_content- and provide information on the collection, processing and use of personal data on these social networks.

TikTok is a social network engaged in short-form video hosting services owned by the Chinese company ByteDance, and for respondents in the EU the operating company is the Irish company TikTok Technology Limited, 2 Cardiff Lane Grand Canal Dock, Dublin 2 DUBLIN, D02 E395 Ireland. The privacy policy is available at: https://www.tiktok.com/legal/page/eea/privacy-policy/hr-HR.

Discord is a freeware VoIP application designed for the gaming community. Privacy Policy available at: https://discord.com/privacy.

Twitter is a social network operated by X Corp. The Privacy Policy is available at: https://twitter.com/en/privacy.

Provisions on the protection of data on the application and use of the Google Analytics service (with anonymization function)

On its Websites, the controller has integrated Google Analytics components (with anonymization function). Google Analytics collects and analyses data about the behaviour of Website visitors. The web analysis service collects, among other things, data about the website from which the person came (so-called referrer), which subpages were visited or how often and for how long the subpages were viewed. Web analytics is mainly used to optimize a Website and to conduct a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics service component is Alphabet Inc., Googleplex, Mountain View, California, United States.

For web analytics through the Google Analytics service, the Company uses the application "_gat. _anonymizeIp”. With this application, the IP address of the internet connection of the data holder is shortened and anonymized when accessing our Websites from a member state of the European Union or another contracting state to the Agreement on the European Economic Area.

The purpose of the Google Analytics service component is to analyse the traffic on our Website. Alphabet Inc. collects collected data and information, among other things, to evaluate the use of our Website and provide online reports that show activity on our Websites and provide other services related to the use of our Website for us.

When you visit our Website, we will ask you to give us your consent to the use of certain types of cookies, including the use of Google Analytics. In case of your consent, Google Analytics places a cookie on the information technology system of the respondent. By setting cookies Alphabet Inc. may analyse the use of our Website.

A cookie is used to store personal data, such as the time of access, the location from which the access was made and the frequency of visits to our Websites by the data subject. With each visit to our site and with your consent, such personal data, including the IP address of the Internet access used by the respondent, will be transferred to Alphabet Inc. in the United States of America. Alphabet Inc. may transfer this personal data collected by the technical process to third parties.

The respondent can, as previously stated, prevent the setting of cookies at any time by consenting or withholding consent to the use of these cookies.

Additional information and applicable data protection provisions from Alphabet Inc. can be downloaded at https://policies.google.com/privacy?hl=en-US. Google Analytics is further explained in the following link https://www.google.com/analytics/.

Management of consents

You can always revoke the permissions granted to us.

If you revoke your consent, we will no longer process your data for the stated purposes, but this does not affect the legality of the processing before the consent was revoked.

Your rights

a) Right to correction:

If we process your personal data that is incomplete or incorrect, you can ask us to correct or supplement it at any time.

b) Right of access:

You have the right to receive a confirmation about whether we process your personal data or not, and where this is the case you have under the conditions of Art. 15 of the General Regulations to request access to this data.

c) Right to erasure:

You can ask us to delete your personal data if we have processed them illegally or if this processing represents a disproportionate intrusion into your protected interests. Please take into account that there are reasons that prevent immediate deletion, for example to comply with a legal obligation that requires processing.

d) Right to restriction of processing:

You can ask us to limit the processing of your data:

• if you dispute the accuracy of the data during the period that allows us to check the accuracy of the data;
• if the processing of the data was unlawful, but you refuse the deletion and instead request the restriction of the use of the data;
• if we no longer need the data for the intended purposes, but you still need them to meet legal requirements or;
• if you have filed an objection regarding the distribution of this data.

e) The right to data portability:

You can ask us to deliver the data you have entrusted to us for archiving in a structured form, in the usual machine-readable format:

• if we process this data on the basis of the consent you have given us and which you can revoke or for the purpose of executing a contract i
• if the processing is done using automated processes.

f) The right to object:

If we distribute your data for the purpose of performing tasks of public interest or tasks of public bodies, or when processing them, we refer to our legitimate interests, you can file a complaint against such data processing if there is an interest in protecting our data.

g) The right to object:

If you are of the opinion that we have violated Slovenian or European data protection regulations when processing your data, please contact us in order to clarify any questions. You certainly have the right to file a complaint with the competent supervisory body, which is the Information Commissioner of the Republic of Slovenia, Dunajska cesta 22, SI-1000 Ljubljana.

Exercising your rights

If you wish to exercise any of the above rights, please contact us using our contact details in this privacy policy.

When you submit a request in order to exercise your rights, we are obliged to establish your identity first, and for this purpose we will ask for additional information to verify it. This serves to protect your rights and private sphere.

If you use any of the above rights too often and with the obvious intent of abuse, we may charge an administrative fee or refuse to process your request.

Changes and updates to our privacy policy

We reserve the right to change or update this Privacy Policy at any time and without prior notice. Please check back from time to time for any changes or updates to our Privacy Policy.