Data protection is of a particularly high priority for the management of ALFIS IT j.d.o.o.. The use of the Internet pages of ALFIS IT j.d.o.o. is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
Personal information is defined as “any information relating to an identified or identifiable natural person”. The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to ALFIS IT j.d.o.o.. All of the above information will be collected, processed and used in full accordance with applicable legal provisions and in a legally prescribed manner, and all users of website by accessing and using give their express consent to the collection, processing and use of personal information in the manner and with the conditions set out below.
By means of this data protection declaration, ALFIS IT j.d.o.o. would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
In case of any changes to the legislation related to the protection of personal data of ALFIS IT j.d.o.o. will make any necessary changes or adjustments to this Part so that at all times users of this Service and their personal information are protected in accordance with applicable legal provisions. Such changes or reconciliations do not require the consent or approval of the users of website, as these are necessary changes or reconciliations in order to comply fully with the legal provisions.
The ALFIS IT j.d.o.o. data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to begin by explaining the terminology used.
In this data protection declaration, we use, inter alia, the following terms:
Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Usage data is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).
Cookies are small files stored on your device (computer or mobile device).
Data processors (or service providers) means any natural or legal person, , public authority, agency or other body who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
NAME AND ADDRESS OF THE CONTROLLER
Controller for the purposes of data protection laws applicable and other provisions related to data protection this is:
Considering that personal information is any information relating to an identified or identifiable natural person (in the context of this website, such information would include, for example, the name of the user, the date and place of birth of the user, the address of the user, mobile or landline phone number, user e-mail address, personal identification number, etc.), users of website confirm that by accessing and using this site, they are fully acquainted with the method of collecting personal information and give their consent or consent for the processing of their personal data for specific purposes, which will be presented to the users of this Service in each specific case when they are asked for certain personal information (eg to inform about products, respond to customer inquiries, employment applications, etc.) . If for any reaction on the part of ALFIS IT j.d.o.o. necessary for the users of this site to provide their particular personal information and do not do so, then ALFIS IT j.d.o.o. will not be able to provide them with the requested service or respond to their eventual inquiry or request. Each user is free to decide whether or not to provide his or her personal information when requested to do so.
METHOD OF COLLECTING PERSONAL INFORMATION
The personal information of users is collected through their voluntary disclosure by the user, as well as by automatically collecting information that is created when accessing website (IP addresses, cookies and the like). But personal data in the strict legal sense, that is, data that can be used to identify an individual, will be collected exclusively on the basis of the user’s consent (by registering on this site, sending an e-mail, etc.), while the automatically collected data will serve the purpose of obtaining data on the frequency of site visits, statistical surveys and the like.
ALFIS IT j.d.o.o. warrants to users of website that they will not in any way misuse their personal information and that they will not in any way be unauthorized to third parties. User Personal Information may be shared with third parties with whom ALFIS IT j.d.o.o. cooperates in the performance of its business when it may be related to the fulfillment of obligations towards users of website (delivery, etc.). Such third parties will then abide by all of the privacy policies set out here. Also, this information may be made available to third parties regarding the audit of ALFIS IT j.d.o.o. as well as for the purpose of fulfilling legal obligations in accordance with the requirements of the authorized institutions of the Republic of Croatia (courts, police, public prosecutor’s office, etc.), and in other cases when required by special regulations of the Republic of Croatia.
When collecting personal information, ALFIS IT j.d.o.o. uses common security technologies and procedures (firewall, password protection). When using and processing personal data, the technical, personnel and organizational measures of protection of personal data that are necessary to protect personal data from accidental loss or destruction and from unauthorized access, unauthorized alteration, unauthorized disclosure and any other misuse are used.
COLLECTION OF GENERAL DATA AND INFORMATION
The website of ALFIS IT j.d.o.o. collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time (so-called timestamp) of access to the Internet site, (6) an Internet protocol address (IP address), (7) the internet service provider (ISP) of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, ALFIS IT j.d.o.o. does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, ALFIS IT j.d.o.o. analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
LINKS TO OTHER WEB SITES
Personal data protection provided by ALFIS IT j.d.o.o. applies exclusively to this site and not to other websites to which this site may link. References to other web sites are used to provide complete information to our users as well as to provide the best possible service, but users are advised to review the data protection policies found on those web sites before accessing those other web pages.
This website uses browser cookies. Cookies are small text files stored locally in the cache of the user’s browser. These cookies make it possible to recognise the browser. The files are used to help the browser navigate the website, and so that all functions can be used to their full extent.
The data subject may, at any time, prevent the setting of cookies through website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.
USE OF GOOGLE ANALYTICS
On this website, the controller has integrated the component of Google Analytics. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.
The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.
USE OF GOOGLE TAG MANAGER
This website uses Google Tag Manager. Google Tag Manager only implements tags. No cookies are set and no personal data is recorded. Google Tool Manager triggers other tags that may record data. Google Tag Manager does not access this data. In case of deactivation at the domain or cookie level, all tracking tags remain active if they are implemented with Google Tag Manager. The user can prevent the transfer of all Google Tag Manager tags.
USE OF GOOGLE MAPS
ALFIS IT j.d.o.o. uses Google Maps (API) from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (‘Google’). When sub-pages in which the map from Google Maps is integrated are called up, information about the use of the ALFIS IT j.d.o.o. website (such as the user’s IP address) is transmitted to Google servers in the USA where it is stored.
USE OF GOOGLE ADWORDS – CONVERSION TRACKING
ALFIS IT j.d.o.o. uses Google AdWords and conversion tracking within the scope of Google AdWords. The cookie for conversion tracking is set when a user clicks on a Google ad. These cookies lose their validity after 30 days and are not used for personal identification. When the user visits pages on this website and the cookie has not expired yet, Google and ALFIS IT j.d.o.o. can detect that the user clicked the ad and was redirected to this page. Thus cookies cannot be tracked via the websites of AdWords users.
The information collected with the help of the conversion cookie is used to prepare conversion statistics for AdWords users who have opted for conversion tracking. ALFIS IT j.d.o.o. obtains the total number of users who have clicked its ad and were redirected to a page with a conversion tracking tag. ALFIS IT j.d.o.o. does not receive any information that allows the user to be personally identified. If the user does not want to take part in tracking, they can object to this use by deactivating the Google conversion tracking cookie in the user settings of the browser. Subsequently, the user is not included in the conversion tracking statistics.
REGISTRATION ON WEBSITE
The data subject has the possibility to register (sign up for a Trial account) on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask (sign-up form) used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.
By registering on the website of the controller, the IP address—assigned by the internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.
The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations
SUBSCRIPTION TO NEWSLETTERS
On the website of ALFIS IT j.d.o.o., users are given the opportunity to subscribe to our enterprise’s newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.
ALFIS IT j.d.o.o. informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise’s newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. During the registration for the newsletter, we also store the IP address of the computer system assigned by the internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller. The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link (‘unsubscribe’) is found in each newsletter.
The newsletter of ALFIS IT j.d.o.o. contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, ALFIS IT j.d.o.o. may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up (clicked on) by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to continuously adapt the content of future newsletters to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. ALFIS IT j.d.o.o. automatically regards a withdrawal from the receipt of the newsletter as a revocation.
CONTACT POSSIBILITY VIA THE WEBSITE
The website of ALFIS IT j.d.o.o. contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties. The user agrees to electronic communication by making contact with ALFIS IT j.d.o.o. via electronic means. The user is advised that e-mails may be read without authorisation or changed in the course of transmission. ALFIS IT j.d.o.o. uses software to filter out unwanted e-mails (spam filter). This spam filter may reject e-mails incorrectly identified as spam due to certain characteristics.
DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF LINKEDIN
The controller has integrated components of the LinkedIn Corporation on this website. LinkedIn is a web-based social network that enables users with existing business contacts to connect and to make new business contacts. LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world.
With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a LinkedIn component (LinkedIn plug-in) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to the download of a display of the corresponding LinkedIn component of LinkedIn. Further information about the LinkedIn plug-in may be accessed under https://developer.linkedin.com/plugins. During the course of this technical procedure, LinkedIn gains knowledge of what specific sub-page of our website was visited by the data subject.
If the data subject is logged in at the same time on LinkedIn, LinkedIn detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-page of our Internet page was visited by the data subject. This information is collected through the LinkedIn component and associated with the respective LinkedIn account of the data subject. If the data subject clicks on one of the LinkedIn buttons integrated on our website, then LinkedIn assigns this information to the personal LinkedIn user account of the data subject and stores the personal data.
LinkedIn receives information via the LinkedIn component that the data subject has visited our website, provided that the data subject is logged in at LinkedIn at the time of the call-up to our website. This occurs regardless of whether the person clicks on the LinkedIn button or not. If such a transmission of information to LinkedIn is not desirable for the data subject, then he or she may prevent this by logging off from their LinkedIn account before a call-up to our website is made.
RIGHTS OF THE DATA SUBJECT
Right of confirmation Each data subject shall have the right to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.
Right of access Each data subject shall have the right granted to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, directives and regulations grant the data subject access to the following information:
the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
the existence of the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from the data subject, any available information as to their source;
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may at any time contact our Data Protection Officer or another employee of the controller.
Right to rectification Each data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact us.
Right to erasure (Right to be forgotten) Each data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by ALFIS IT j.d.o.o., he or she may at any time the controller who shall promptly ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required.
Right of restriction of processing Each data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by ALFIS IT j.d.o.o., he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of ALFIS IT j.d.o.o. or another employee will arrange the restriction of the processing.
Right to data portability Each data subject shall have the right, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact the ALFIS IT j.d.o.o.
Right to object Each data subject shall have the right to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
ALFIS IT j.d.o.o. shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.
If ALFIS IT j.d.o.o. processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to ALFIS IT j.d.o.o. to the processing for direct marketing purposes, ALFIS IT j.d.o.o. will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by ALFIS IT j.d.o.o. for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may directly contact the ALFIS IT j.d.o.o.. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
Automated individual decision-making, including profiling Each data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, ALFIS IT j.d.o.o. shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact ALFIS IT j.d.o.o. or another employee of the controller.
Right to withdraw data protection consent Each data subject shall have the right to withdraw his or her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact ALFIS IT j.d.o.o. or another employee of the controller.
LEGAL BASIS FOR THE PROCESSING
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
THE LEGITIMATE INTERESTS PURSUED BY THE CONTROLLER OR BY A THIRD PARTY
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.
22. Period for which the personal data will be stored
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
PROVISION OF PERSONAL DATA AS STATUTORY OR CONTRACTUAL REQUIREMENT; REQUIREMENT NECESSARY TO ENTER INTO A CONTRACT; OBLIGATION OF THE DATA SUBJECT TO PROVIDE THE PERSONAL DATA; POSSIBLE CONSEQUENCES OF FAILURE TO PROVIDE SUCH DATA
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded.
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