Privacy policy
The company iTrade Online d.o.o., registration number: 8400253000 (hereinafter "we") pays great attention to the protection of personal data. Here in this document, we provide all information about which personal data we process, about the users of our online store, our customers and if we only process them with consent or on another legal basis. For what purposes we use them and to whom we can pass them on and what are your rights in this regard in relation to our processing of your personal data.
What personal data do we process?
We collect various types of data from you as a user of our services, such as your username and password, your contact information and other settings. We monitor which items you view in our online store, on which devices and which of our offers you are interested in, and we send them via e-mail. With the help of this, we create additional data and offers so that we can fulfill your wishes and improve our online store and services in the future. After making a purchase from us or creating an account, your first and last name, what you ordered and the information you set on your account are also processed.
Personal data is processed:
identification data; these represent your first and last name, username and password and, if you are a legal entity, your VAT ID;
Contact details; are personal data that enable us to contact you, at most e-mail address, telephone number, delivery address, billing address and your profiles on social networks;
your preferences; is your account information, stored shipping addresses, profiles, newsletter subscriptions, shopping lists, searched items ("interested in", "follow price"), loyalty program memberships, comments and ratings of items and services;
order information; are information about the ordered items, the method of payment, which includes the TRR number and information about complaints;
information about your online habits; even when you browse the web through our mobile application, mostly information about the items and services you searched for, the links you clicked, the ways you navigated and searched our website, and the devices you used used to access the web, device ID, its technical parameters, IP address and its associated location, operating system, version, selected browser and its version, as well as data obtained with cookies and similar technologies for device recognition;
behavioral data related to the reading of our messages that we have sent to you, the maximum time required to open only those and data about the devices with which you accessed the web, such as the IP address and the location associated with it, the device ID. its technical parameters, such as operating system, version, screen resolution, selected browser and its version;
data obtained; this includes personal information obtained from your preferences, about items you have purchased from us, about your online habits, behavior in relation to reading messages sent to you from our site; above all, this is data on gender and age, financial situation, consumer habits and attitude towards various items and services;
data related to the use of call centers; this includes in particular records of telephone calls with the call centre, identification of messages you send to us, including identifiers such as IP addresses.
Why do we process personal data and why do we have the right to do so?
Your personal data is processed in different cases for different purposes. When you visit our online store, where we also use cookies, your data is primarily used to determine the number of visitors and improve our services. If you register with us, this information is used to manage your account and enable related features. When you make a purchase from us, your data is used to process your order, to protect our legal requirements and to fulfill our legal obligations. At the same time, with the help of your contact information and other information, we can inform you and send you our customized offers. Only with your consent do we pass on your data to third parties to inform you about offers on other websites and to give you access to some additional services. We have the right to such processing of your personal data only on the basis of the preparation or conclusion of a contract with you, taking into account legal obligations, our legal claims or your consent.
As part of our activity, we process personal data to various extents for various purposes:
without your consent based on our legitimate interest or for the purposes of fulfilling legal obligations, fulfilling a contract or
based on your consent.
The data processing that we can carry out without your consent depends on the purpose for which the relevant processing is carried out and in what relationship you present yourself to us - whether you are just a visitor to our online store, have registered with us or even purchased something. We can also process your data in privatereceipt of goods or services you order from us or if you communicate with us.
If you visit our online store
Use of cookies and other technologies, transfer of data to advertising and social networks
When you visit our online store, small files such as cookies are stored on your device. These are small groups of letters and numbers that are stored in your web browser or on your computer's hard drive. Some cookies allow us to link your activities while browsing our pages from the time you open a web browser window to the time you close it. As soon as you close the web browser window, the associated cookies are deleted. Certain cookies remain on the device for a certain period of time and are activated every time you visit the websites that created the corresponding cookies. We also use web signals (known as "web beacons"). These are small images with a similar function to cookies. Unlike cookies, web beacons are an integral part of web pages. For ease of understanding, we will refer to all these technologies in this document as cookies. We only store and read cookies that our website has stored on your device.
Our websites store cookies directly on your device. Such cookies help us:
for identification when switching between web pages of our domain and on return visits. In this way, your shopping cart is not deleted, because in this way we remember your login through a specific device and re-entering your e-mail address and password is not necessary. At the same time, we also store information about which version of our website to display, if more than one is available;
to check whether you have already given us your consent in accordance with this document, whether you have e.g. decided to participate in a certain research;
help ensure security so we can verify that your connection to our web domain has not been misused and that someone else may not be doing business on your behalf;
as well as in the detection, study and elimination of possible errors and shortcomings of our websites.
Cookies and other similar files are absolutely necessary for the operation of our online store. If you do not enable them in your browser, it may happen that our websites will not work properly and therefore we will not be able to offer you the items and services from our offer. We also store on your device:
cookies from our websites that allow us to:
to track visits to our websites and individual contents, and in this way we create statistics and measure the effectiveness of various advertisements;
showing the various options of our websites when testing new implementations;
adapt the content of our pages to your needs, e.g. priority display of items that you have already searched for and display of other offers according to your preferences on our websites;
we enable the storage of cookies by third parties who can use them:
to collect information about your browsing on our or other websites;
to display ads, offers and personalized ads within advertising and social networks outside our domain on other websites
to connect with social networks such as Facebook, including automatic login, providing features such as "Like", displaying personalized offers and personalized advertisements on social networks and other websites outside of our website.
We transmit data about your online behavior to advertising and social networks for the purpose of displaying customized offers and customized advertisements in the context of advertising and social networks on other websites outside our domain. However, we do not pass on your identification data to these partners in any way. For a list of these advertising and social networks we use, see Who processes your personal data and with whom do we share it? If you do not disable the transfer of your data and the use of third-party cookies for advertising and social networks under the Privacy Settings tab and after the warning click on any link on our websites (outside the warning box) or click "I understand" which is an integral part of the warning, it is understood , to agree to the use of said cookies and the transmission of your data to advertising and social networks. You can also withdraw your consent at any time by disabling this feature in the Privacy Settings tab.
Use of personal data of website visitors
When you visit our itrade.si online store, based on a legitimate interest (without your consent), we process data about your online behavior for the purposes of:
obtaining data so that we can improve our online store for you in the future and thus create better shopping conditions for you; in this case yes, our legitimate interest in improving our services to you;
creating reviews and statistics, primarily tracking visits to our website and individual contents and measuring the effectiveness of advertisements; in this case, ours is legitimateinterest in measuring the effectiveness of our websites and advertising costs; for this reason, we may obtain and use other derived data through your online behavior; and we may share this collected information with our partners for billing purposes as described in the section "Who processes your personal information and with whom we share it".
to test new features and applications before implementation, to avoid problems with the operation of these innovations during actual operation, which could impair your shopping experience with us; our legitimate interest in this case is that we can perform our services for you as flawlessly as possible;
that we can take action against attacks on our websites and threats to their operation and ensuring the security of your data; our legitimate interest in this case is the security of your data and the flawless operation of our services for you.
In addition to cookies, we supplement the data about your behavior on the websites with the help of the following data:
IP address of your device (the address of your device through which you communicate with other devices on the Internet);
the operating system, version and language settings of your device;
the browser you use on the device, its version and language settings;
web address (URL address) of the page from which you access our website.
We use personal data for this purpose for a maximum of 38 months, and store the data in pseudonymized-encoded form. If you are concerned about this, you can find more information here (click). We also process data about your behavior on websites based on our legitimate interest (i.e. without your consent), for the purposes of preparing customized offers and advertisements that we display online. In this case, it is our legitimate interest to offer you the best possible and most efficient offer. For this purpose, we expand this data with the help of analyzes and thus prepare derived data from them. This allows us to classify our users into different groups, so that each group receives its own personalized offer. In the event that you subsequently purchase something from us, we will additionally use your order information for this purpose. us, this product may appear on the first page of our online store on your next visit. Depending on which product you searched for, we can estimate which customer group we can place you in. Based on this, we can also offer you other products in our online store that we think you might be interested in. Personal data is used for this purpose for 1 month. You can also turn this feature off at any time in the Privacy Settings tab.
If you register with us
To register, you must visit our online store, the processing described under the tab If you visit our website applies to you. Upon registration, data processing is extended; namely:
Processing based on contract performance
When you create an account online at itrade.si, we process your identification and contact information, your settings and information about your orders (if you make a purchase from us later) based on the performance of a contract concluded with you (without your consent), so that we can manage your user account. The contract on which our processing is based is created at the same time as your account. We use personal data for this purpose throughout the duration of your account, which you can delete at any time.
Processing based on legitimate interest
When you create an account in the itrade.si online store, we will collect your identification and contact information, your settings and information about your orders (if you make a purchase from us, even if you make a purchase without logging into the account) and information about your online behavior and behavior at reading e-mails, which are also processed on the basis of our legitimate interest (i.e. without your consent), for the purposes of:
obtaining data on the basis of which we can improve our services for you in the future with the aim of creating better conditions for shopping, especially by determining your satisfaction with our services; our legitimate interest in this case is to improve our services to you and
providing you with personalized offers and personalized advertisements that we may send you via e-mail, text messages and social networks, or communicate by telephone or other electronic devices, send by regular mail or display on our websites; our legitimate interest in this case is the effective promotion of our products and services.
In order to be able to prepare a customized offer for you, we analyze all the given data and obtain other derived data from them, which we use for this purpose. In this way, we can also use information about your online behavior that we obtained before your registration (if you have not previously disabled online personalization under the Privacy Settings tab), and we can collect information about your online behavior even if you have not logged into (e.g. if we identify you with the help of cookies). Based on this data, we can divide our users into different groups, each group receiving its own personalized offers. this householdthe device will appear on the first page of our online store on your next visit. Depending on what kind of household appliance you were looking for, we can estimate which group of buyers you belong to. Based on this, we may offer you other items on the website that we think may be of interest to you. You can turn this feature off at any time in the Privacy Settings tab. Based on our legitimate interest (that is, without your consent), we may also use your preferences to test new features and applications before they are introduced, as described in the section If you visit our websites. For this purpose, we use your personal data during the existence of your account, which you can delete at any time. If you are concerned about this, you can find more information here (click).
If you buy from us
To buy from us, you must visit our online store, so the processing described under the tab If you visit our websites applies to you. If you shop with us, data processing is extended as follows:
Processing based on contract performance
If you buy from us as a natural person, we process your personal data for the purpose of processing your order. This is identification and contact information, as well as information about your orders. If you have a user account with us, we can also use your settings for this purpose. If you purchase from us as a representative of a legal entity, we process the same data for the same purpose based on our legitimate interest based on the conclusion and performance of a contract with the entity you use. The use of data for the purpose of processing your order means that we use the data specifically for:
the possibility of completing the order online, i.e. that e.g. they do not delete the items you have added to the shopping cart or the data from the order in preparation;
possibility of communication with you, e.g. sending order confirmations or notification of shipment of items;
the need to pay for goods,
goods delivery needs; in this regard, we may also pass on your data to our transport partners, exclusively for the purpose of delivering these goods, as described in the section
Who processes your personal data and with whom do we share it?
in connection with the complaint of ordered goods or services; in this regard, we may also forward your data to the supplier of the goods or the service center, as described in the section Who processes your personal data and with whom do we share it?;
in relation to your other requests addressed to us, e.g. through the call center as described in If you communicate with us through different channels.
For this purpose, we use personal data for the time that is absolutely necessary to process your order or resolve contractual obligations, such as complaints.
Processing based on legitimate interest
If you make a purchase from us, we retain your identification and contact information and your order information based on our legitimate interest (without your consent) for the purposes of protecting legal claims and our internal records and controls. Our legitimate interest in this case is the protection of legal claims and control over the regular performance of our services. In addition, based on our legitimate interest (that is, without your consent), we process your identification and contact information, your preferences and your order information (if you subsequently make a purchase from us) for the purposes of:
obtaining data on the basis of which we can improve our services for you in the future with the aim of creating better conditions for shopping, especially by determining your satisfaction with our services; our legitimate interest in this case is to improve our services to you and
adapting the functionality of our web domain to your needs, so that we can offer you e.g. the nearest collection points, all based on our legitimate interest based on improving and customizing our services; for this purpose, we also process your IP address and the location derived from it,
providing you with personalized offers and personalized advertisements that we may send to you via e-mail, text messages and social networks or communicate by telephone or other electronic devices or send by regular mail; our legitimate interest in this case is the effective promotion of our products and services. In order to be able to prepare a customized offer for you, we analyze all of the above data (i.e. your identification and contact data and your order data) and obtain other derived data from the fabrics we use for this purpose. Based on this data, users can be segmented into different groups, with each group receiving its own personalized offer. If you are not registered with us, we do not use data about your behavior on the websites to prepare the offers we send you.
Therefore, if you bought a household appliance from us, wLahko will contact you with a customized offer for an extended warranty. Based on your purchase, we can also conclude which customer group you belong to. Based on this, we can send you an offer for related items that may be of interest to you. If you do not have an open account with us, we will not adjust the offersbased on what kind of goods you searched for on our websites, nor on which links you opened in the sent offers.
We also use the information about your orders for the purposes of creating customized offers and customized advertisements that we display on the websites, as described in the section If you visit our websites. We measure your satisfaction with our services based on the NPS survey that we send to you via email within Survey Monkey. We send the questionnaire to random users who have made a purchase from us in the past month. We keep the research results exclusively for our own use. In order to protect legal claims and maintain our internal records and controls, we process data for a period of 3 years and 1 year after that in relation to claims that are asserted until the expiration of the statute of limitations. In the case of judicial, administrative or other proceedings, we process your personal data for as long as is necessary for the duration of such proceedings and the remainder of the limitation period after its completion. In order to protect legal claims and our internal records and control, we process the data during the statute of limitations, which is 5 years, and if necessary, one more year after its expiration in the case of an asserted claim at the end of the statute of limitations. Upon initiation of a judicial, administrative or other procedure, we process your personal data for as long as is absolutely necessary to carry out these procedures, and until the end of the remaining part of the limitation period after its expiration. For the other stated purposes, we use personal data for a maximum of 6 months. which are carried out on the basis of our legitimate interest, you can object.
B.3.3 Processing based on the fulfillment of legal obligations
We must also fulfill certain statutory obligations. If we process your personal data for this reason, we do not need your consent for such data processing. On this legal basis, we process your identification and contact data, order data, namely in order to comply with the applicable legislation, which at the time of preparation of the memorandum in question is, in particular, the following:
Code of Obligations (OZ),
Consumer Protection Act (ZVPot),
Value Added Tax Act (ZDDV-1),
Act on Tax Verification of Invoices (ZDavPR),
Accounting Act (ZR),
Electronic Communications Act (ZECom),
Law on the Prevention of Money Laundering and Financing of Terrorism (ZPPDFT-1).
For this purpose, we use personal data for a maximum of 10 years (plus the current year) from the last document issued in connection with your order.
If you are the recipient of goods or services that you have ordered from us
If you are the recipient of goods or services that you have ordered from us, we process your identification and contact information:
based on our legitimate interest for the purposes of preparing, concluding and executing a contract with our client. The performance of this contract is also our legitimate interest;
based on our legitimate interest to obtain information on the basis of which we can improve our services to you in the future, or information for the preparation of our internal statistics and reviews; our legitimate interest in this case is to improve our services to our customers;
to fulfill the right obligations, in particular based on the applicable legislation, listed in point B.3.3. of the subject memorandum;
for the purpose of protecting legal claims and our internal records and controls; our legitimate interest in this case is the protection of legal claims and control over the regular performance of our services.
For the preparation, conclusion and execution of the contract with the client, we use personal data during the time that is absolutely necessary to process the order. After this time, we keep the data on the basis of our legitimate interest for the purposes of protecting legal claims and our internal records and control, namely for the duration of the statute of limitations, which is 5 years, and if necessary for another year after its expiration in the event of an established claim upon expiry of the limitation period. Upon initiation of a judicial, administrative or other procedure, we process your personal data for as long as is absolutely necessary to carry out these procedures, and until the end of the remaining part of the limitation period after its expiration. Our legitimate interest in this case is the protection of legal claims and control over the regular performance of our services. To fulfill legal obligations, we use personal data for a maximum of 10 years for an individual order. If you have any concerns about this type of processing based on a legitimate interest, please contact us here.
If you communicate with us through different channels:
If you communicate with us through various channels, in particular through call centers, e-mail, chat rooms and social networks, based on our legitimate interest, we process your identification and contact data and records of mutual communication, including recordings of speeches (that is, without your consent) for the purposes :
processing your requests; if you have purchased from us and your inquiry relates to an order, we may carry out processing based on the execution of a contract with you;
a record of your requests so that we can check their regular and timely fulfillment;
which provesthat we have received and processed your request, e.g. if you order goods from us in this way or make a complaint;
analysis of requirements to improve the quality of our services.
For these purposes, we store personal data for a period of 3 months. If you place an order through one of our channels, we may retain data for the protection of legal claims for a limitation period of 5 years and a further 1 year after expiry in relation to claims asserted at the end of the limitation period. In the case of judicial, administrative or other proceedings, we process your personal data to the extent necessary for the duration of these proceedings and the remainder of the limitation period after their completion. If you have any concerns about this type of legitimate interest processing, please contact us here.
Who processes your personal data and with whom do we share it?
We mostly process your data for our own purposes as their controller. In this case, we pass on your data to our partners for the purpose of ensuring payment, transport and other matters related to your order. We also forward them to our processors, who process them according to our instructions. If you agree, we may also share your information with advertising and social networks to display customized ads on other websites. We process all listed personal data as an administrator. Therefore, we determine the above-defined purposes for which we collect your personal data and processing methods, and are responsible for their correct implementation. We may also forward your personal data to other entities that have the same function of manager, namely:
in relation to the processing of your order to our partners who participate in the processing of the order, as stated in the section If you buy from us, specifically
partners who operate payment systems for the provision of payments, especially in relation to payment cards, and above all
GLS -
to the supplier of the goods or the service of the relevant manufacturer in connection with the complaint of the ordered goods or service;
on the basis of your consent for advertising and social networks, as described in the section Use of cookies and other technologies, transmission of data to advertising and social networks, namely:
Google Ireland Limited (registered number: 368047), with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland; The company's privacy policy is available here: https://policies.google.com/technologies/ads
Facebook Ireland Limited, with registered office at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, D02 X525, Ireland; The company's privacy policy is available here: https://www.facebook.com/about/privacy
To process personal data, we also use the services of other processors who process personal data exclusively in accordance with our instructions and for the purposes described in the chapter Why do we process personal data and why are we entitled to it?. Such processors include:
operators of marketing tools such as those that help us optimize the web and tailor content and offers to you;
Google Ireland based at Gordon House, Barrow Street, Dublin 4, Ireland (BigQuery Services, ChannelAdvisor),
From which sources do we obtain personal data?
We usually obtain your personal data directly from you through our online store or when communicating with you. You can also get some other information from our partners, e.g. banks or transport companies. We mostly process personal data that you provide us directly when ordering items and services, when creating and using an account, or when communicating with us, for example with the call center. We also obtain personal data directly from you by monitoring your online habits while browsing our online store or reading our messages, by recording calls through call centers. When you make a purchase from us, we may receive additional information about your orders by executing a mutual purchase agreement. by banks, our payment system partners and transport partners, e.g. information about the account number, successfully executed payments or delivery and collection of goods.
Data transfer outside EU countries
In some cases, we may transfer your personal data to countries that are not members of the European Economic Area. In connection with the transfer of data to the recipients listed in the chapter Who processes your personal data and with whom do we share it?, we may also forward your data to third countries. outside the European Economic Area, where an adequate level of personal data protection is not necessarily always guaranteed. This type of mediation will only take place if the recipient concerned undertakes to comply with the standard contractual clauses issued by the European Commission and available at http://eur-lex.europa.eu/LexUriServ/LexUriServ.do? uri=OJ:L:2004:385:0074:0084:CS:PDF
What are your rights regarding the processing of personal data?
You have a number of rights in relation to your personal data. Among other things, the right to access, review, deletion and restriction of processing, transfer, objection and complaint. Because we have our rights and obligations regarding the processing of your personal datav, you also have certain rights in this regard. These rights include:
The right to information
In other words, it is your right to find out what data we collect about you, for what purposes and for how long, where we obtain your personal data from, who we pass it on to, who processes it besides us and what your other rights are related to the processing of your personal data. You can read all this in the document "Protection of personal data of customers". However, if you are still not entirely clear about which personal data it is, you can request confirmation from us as to whether we are collecting personal data about you or not, and if so, you have the right to be informed about this data. In accordance with the right to information, you can request a copy of the processed data from us, whereby we will provide you with the first copy free of charge, and each subsequent copy for a fee.
Right to rectification
No one is infallible. If you notice that your personal data stored by us is incorrect or incomplete, you also have the right to request the correction of these errors or the addition of data.
The right to erasure
In certain cases, you also have the right to delete personal data. Your personal data will be deleted as soon as possible if any of the following reasons are met:
we no longer need your personal data for the purposes for which we processed them;
you have withdrawn your consent to the processing of personal data, in this case it is data for the processing of which your consent is required, but at the same time we have no other reason for further processing of this data;
you have exercised your right to object to data processing (see section Right to object to data processing below) for personal data that we process on the basis of our legitimate interest, and we acknowledge that we no longer have legitimate interests that would justify further processing of this data or
you assume that the processing of personal data carried out by us is no longer in accordance with generally binding legal regulations.
However, you should be aware that even if any of the above reasons are met, it does not mean that all of your personal data will be deleted immediately. Because this right cannot be exercised in the event that the processing of your personal data continues to be necessary to fulfill our legal obligations or to establish, exercise or defend our legal claims (see the section Why do we process personal data and why are we entitled to do so?).
The right to restriction of data processing
In addition to the right to deletion, in certain cases you can also exercise the right to limit the processing of personal data. This allows you, in some cases, to request that your personal data be specifically marked and thus exempted from all processing operations - this applies for a certain period of time (and not permanently as in the case of the right to erasure). We must limit the processing of personal data:
if you dispute the accuracy of your personal data until we agree which data is correct;
if we process your personal data without an appropriate legal basis (e.g. outside the intended scope) and instead of deleting this data you prefer to limit it (e.g. if you anticipate that you will continue to provide us with this data in the future);
if we no longer need your personal data for the purposes described above, but you need it to assert, exercise or defend your legal claims, or
if you object to data processing. The right to object is described in more detail below under the heading Right to object to data processing). We must limit the processing of your personal data during the processing of your objection.
The right to transfer data
You have the right to obtain from us all your personal data that you have provided to us and that we process on the basis of your consent (see section If you give us consent) and on the basis of the performance of contracts. We provide you with your personal data in a structured, validated and machine-readable format. Simple data transfer is only possible for data that is automatically processed in our electronic databases.
The right to object to data processing
Based on reasons related to your particular situation, you can exercise the right to object to the processing of personal data based on (e) or (f) Article 6(1) of REGULATION (EU) 2016/679 and to object to the processing of personal data. data processing for direct marketing purposes (see Why do we process personal data and why are we entitled to it?). We will immediately stop processing your personal data for marketing activities n; we will do the same in all cases, unless we have legitimate grounds for processing that override your processing rights or to exercise legal claims.
Right to appeal
The above rights do not in any way affect your right to file a complaint with the competent authority. You can exercise this right in particular if you believe that we are processing your personal data without a basis or contrary to generally applicable legal regulations. You can therefore complain about the data processing we carry out to the Information Commissioner at the address Zaloška cesta 59, 1000 Ljubljana.
Commissioner for vprotection of personal data
Our authorized personal data protection officer is at your disposal for all matters related to the processing of your personal data. You can contact the clerk at the e-mail address: dpo@itrade.si
What personal data do we process?
We collect various types of data from you as a user of our services, such as your username and password, your contact information and other settings. We monitor which items you view in our online store, on which devices and which of our offers you are interested in, and we send them via e-mail. With the help of this, we create additional data and offers so that we can fulfill your wishes and improve our online store and services in the future. After making a purchase from us or creating an account, your first and last name, what you ordered and the information you set on your account are also processed.
Personal data is processed:
identification data; these represent your first and last name, username and password and, if you are a legal entity, your VAT ID;
Contact details; are personal data that enable us to contact you, at most e-mail address, telephone number, delivery address, billing address and your profiles on social networks;
your preferences; is your account information, stored shipping addresses, profiles, newsletter subscriptions, shopping lists, searched items ("interested in", "follow price"), loyalty program memberships, comments and ratings of items and services;
order information; are information about the ordered items, the method of payment, which includes the TRR number and information about complaints;
information about your online habits; even when you browse the web through our mobile application, mostly information about the items and services you searched for, the links you clicked, the ways you navigated and searched our website, and the devices you used used to access the web, device ID, its technical parameters, IP address and its associated location, operating system, version, selected browser and its version, as well as data obtained with cookies and similar technologies for device recognition;
behavioral data related to the reading of our messages that we have sent to you, the maximum time required to open only those and data about the devices with which you accessed the web, such as the IP address and the location associated with it, the device ID. its technical parameters, such as operating system, version, screen resolution, selected browser and its version;
data obtained; this includes personal information obtained from your preferences, about items you have purchased from us, about your online habits, behavior in relation to reading messages sent to you from our site; above all, this is data on gender and age, financial situation, consumer habits and attitude towards various items and services;
data related to the use of call centers; this includes in particular records of telephone calls with the call centre, identification of messages you send to us, including identifiers such as IP addresses.
Why do we process personal data and why do we have the right to do so?
Your personal data is processed in different cases for different purposes. When you visit our online store, where we also use cookies, your data is primarily used to determine the number of visitors and improve our services. If you register with us, this information is used to manage your account and enable related features. When you make a purchase from us, your data is used to process your order, to protect our legal requirements and to fulfill our legal obligations. At the same time, with the help of your contact information and other information, we can inform you and send you our customized offers. Only with your consent do we pass on your data to third parties to inform you about offers on other websites and to give you access to some additional services. We have the right to such processing of your personal data only on the basis of the preparation or conclusion of a contract with you, taking into account legal obligations, our legal claims or your consent.
As part of our activity, we process personal data to various extents for various purposes:
without your consent based on our legitimate interest or for the purposes of fulfilling legal obligations, fulfilling a contract or
based on your consent.
The data processing that we can carry out without your consent depends on the purpose for which the relevant processing is carried out and in what relationship you present yourself to us - whether you are just a visitor to our online store, have registered with us or even purchased something. We can also process your data in privatereceipt of goods or services you order from us or if you communicate with us.
If you visit our online store
Use of cookies and other technologies, transfer of data to advertising and social networks
When you visit our online store, small files such as cookies are stored on your device. These are small groups of letters and numbers that are stored in your web browser or on your computer's hard drive. Some cookies allow us to link your activities while browsing our pages from the time you open a web browser window to the time you close it. As soon as you close the web browser window, the associated cookies are deleted. Certain cookies remain on the device for a certain period of time and are activated every time you visit the websites that created the corresponding cookies. We also use web signals (known as "web beacons"). These are small images with a similar function to cookies. Unlike cookies, web beacons are an integral part of web pages. For ease of understanding, we will refer to all these technologies in this document as cookies. We only store and read cookies that our website has stored on your device.
Our websites store cookies directly on your device. Such cookies help us:
for identification when switching between web pages of our domain and on return visits. In this way, your shopping cart is not deleted, because in this way we remember your login through a specific device and re-entering your e-mail address and password is not necessary. At the same time, we also store information about which version of our website to display, if more than one is available;
to check whether you have already given us your consent in accordance with this document, whether you have e.g. decided to participate in a certain research;
help ensure security so we can verify that your connection to our web domain has not been misused and that someone else may not be doing business on your behalf;
as well as in the detection, study and elimination of possible errors and shortcomings of our websites.
Cookies and other similar files are absolutely necessary for the operation of our online store. If you do not enable them in your browser, it may happen that our websites will not work properly and therefore we will not be able to offer you the items and services from our offer. We also store on your device:
cookies from our websites that allow us to:
to track visits to our websites and individual contents, and in this way we create statistics and measure the effectiveness of various advertisements;
showing the various options of our websites when testing new implementations;
adapt the content of our pages to your needs, e.g. priority display of items that you have already searched for and display of other offers according to your preferences on our websites;
we enable the storage of cookies by third parties who can use them:
to collect information about your browsing on our or other websites;
to display ads, offers and personalized ads within advertising and social networks outside our domain on other websites
to connect with social networks such as Facebook, including automatic login, providing features such as "Like", displaying personalized offers and personalized advertisements on social networks and other websites outside of our website.
We transmit data about your online behavior to advertising and social networks for the purpose of displaying customized offers and customized advertisements in the context of advertising and social networks on other websites outside our domain. However, we do not pass on your identification data to these partners in any way. For a list of these advertising and social networks we use, see Who processes your personal data and with whom do we share it? If you do not disable the transfer of your data and the use of third-party cookies for advertising and social networks under the Privacy Settings tab and after the warning click on any link on our websites (outside the warning box) or click "I understand" which is an integral part of the warning, it is understood , to agree to the use of said cookies and the transmission of your data to advertising and social networks. You can also withdraw your consent at any time by disabling this feature in the Privacy Settings tab.
Use of personal data of website visitors
When you visit our itrade.si online store, based on a legitimate interest (without your consent), we process data about your online behavior for the purposes of:
obtaining data so that we can improve our online store for you in the future and thus create better shopping conditions for you; in this case yes, our legitimate interest in improving our services to you;
creating reviews and statistics, primarily tracking visits to our website and individual contents and measuring the effectiveness of advertisements; in this case, ours is legitimateinterest in measuring the effectiveness of our websites and advertising costs; for this reason, we may obtain and use other derived data through your online behavior; and we may share this collected information with our partners for billing purposes as described in the section "Who processes your personal information and with whom we share it".
to test new features and applications before implementation, to avoid problems with the operation of these innovations during actual operation, which could impair your shopping experience with us; our legitimate interest in this case is that we can perform our services for you as flawlessly as possible;
that we can take action against attacks on our websites and threats to their operation and ensuring the security of your data; our legitimate interest in this case is the security of your data and the flawless operation of our services for you.
In addition to cookies, we supplement the data about your behavior on the websites with the help of the following data:
IP address of your device (the address of your device through which you communicate with other devices on the Internet);
the operating system, version and language settings of your device;
the browser you use on the device, its version and language settings;
web address (URL address) of the page from which you access our website.
We use personal data for this purpose for a maximum of 38 months, and store the data in pseudonymized-encoded form. If you are concerned about this, you can find more information here (click). We also process data about your behavior on websites based on our legitimate interest (i.e. without your consent), for the purposes of preparing customized offers and advertisements that we display online. In this case, it is our legitimate interest to offer you the best possible and most efficient offer. For this purpose, we expand this data with the help of analyzes and thus prepare derived data from them. This allows us to classify our users into different groups, so that each group receives its own personalized offer. In the event that you subsequently purchase something from us, we will additionally use your order information for this purpose. us, this product may appear on the first page of our online store on your next visit. Depending on which product you searched for, we can estimate which customer group we can place you in. Based on this, we can also offer you other products in our online store that we think you might be interested in. Personal data is used for this purpose for 1 month. You can also turn this feature off at any time in the Privacy Settings tab.
If you register with us
To register, you must visit our online store, the processing described under the tab If you visit our website applies to you. Upon registration, data processing is extended; namely:
Processing based on contract performance
When you create an account online at itrade.si, we process your identification and contact information, your settings and information about your orders (if you make a purchase from us later) based on the performance of a contract concluded with you (without your consent), so that we can manage your user account. The contract on which our processing is based is created at the same time as your account. We use personal data for this purpose throughout the duration of your account, which you can delete at any time.
Processing based on legitimate interest
When you create an account in the itrade.si online store, we will collect your identification and contact information, your settings and information about your orders (if you make a purchase from us, even if you make a purchase without logging into the account) and information about your online behavior and behavior at reading e-mails, which are also processed on the basis of our legitimate interest (i.e. without your consent), for the purposes of:
obtaining data on the basis of which we can improve our services for you in the future with the aim of creating better conditions for shopping, especially by determining your satisfaction with our services; our legitimate interest in this case is to improve our services to you and
providing you with personalized offers and personalized advertisements that we may send you via e-mail, text messages and social networks, or communicate by telephone or other electronic devices, send by regular mail or display on our websites; our legitimate interest in this case is the effective promotion of our products and services.
In order to be able to prepare a customized offer for you, we analyze all the given data and obtain other derived data from them, which we use for this purpose. In this way, we can also use information about your online behavior that we obtained before your registration (if you have not previously disabled online personalization under the Privacy Settings tab), and we can collect information about your online behavior even if you have not logged into (e.g. if we identify you with the help of cookies). Based on this data, we can divide our users into different groups, each group receiving its own personalized offers. this householdthe device will appear on the first page of our online store on your next visit. Depending on what kind of household appliance you were looking for, we can estimate which group of buyers you belong to. Based on this, we may offer you other items on the website that we think may be of interest to you. You can turn this feature off at any time in the Privacy Settings tab. Based on our legitimate interest (that is, without your consent), we may also use your preferences to test new features and applications before they are introduced, as described in the section If you visit our websites. For this purpose, we use your personal data during the existence of your account, which you can delete at any time. If you are concerned about this, you can find more information here (click).
If you buy from us
To buy from us, you must visit our online store, so the processing described under the tab If you visit our websites applies to you. If you shop with us, data processing is extended as follows:
Processing based on contract performance
If you buy from us as a natural person, we process your personal data for the purpose of processing your order. This is identification and contact information, as well as information about your orders. If you have a user account with us, we can also use your settings for this purpose. If you purchase from us as a representative of a legal entity, we process the same data for the same purpose based on our legitimate interest based on the conclusion and performance of a contract with the entity you use. The use of data for the purpose of processing your order means that we use the data specifically for:
the possibility of completing the order online, i.e. that e.g. they do not delete the items you have added to the shopping cart or the data from the order in preparation;
possibility of communication with you, e.g. sending order confirmations or notification of shipment of items;
the need to pay for goods,
goods delivery needs; in this regard, we may also pass on your data to our transport partners, exclusively for the purpose of delivering these goods, as described in the section
Who processes your personal data and with whom do we share it?
in connection with the complaint of ordered goods or services; in this regard, we may also forward your data to the supplier of the goods or the service center, as described in the section Who processes your personal data and with whom do we share it?;
in relation to your other requests addressed to us, e.g. through the call center as described in If you communicate with us through different channels.
For this purpose, we use personal data for the time that is absolutely necessary to process your order or resolve contractual obligations, such as complaints.
Processing based on legitimate interest
If you make a purchase from us, we retain your identification and contact information and your order information based on our legitimate interest (without your consent) for the purposes of protecting legal claims and our internal records and controls. Our legitimate interest in this case is the protection of legal claims and control over the regular performance of our services. In addition, based on our legitimate interest (that is, without your consent), we process your identification and contact information, your preferences and your order information (if you subsequently make a purchase from us) for the purposes of:
obtaining data on the basis of which we can improve our services for you in the future with the aim of creating better conditions for shopping, especially by determining your satisfaction with our services; our legitimate interest in this case is to improve our services to you and
adapting the functionality of our web domain to your needs, so that we can offer you e.g. the nearest collection points, all based on our legitimate interest based on improving and customizing our services; for this purpose, we also process your IP address and the location derived from it,
providing you with personalized offers and personalized advertisements that we may send to you via e-mail, text messages and social networks or communicate by telephone or other electronic devices or send by regular mail; our legitimate interest in this case is the effective promotion of our products and services. In order to be able to prepare a customized offer for you, we analyze all of the above data (i.e. your identification and contact data and your order data) and obtain other derived data from the fabrics we use for this purpose. Based on this data, users can be segmented into different groups, with each group receiving its own personalized offer. If you are not registered with us, we do not use data about your behavior on the websites to prepare the offers we send you.
Therefore, if you bought a household appliance from us, wLahko will contact you with a customized offer for an extended warranty. Based on your purchase, we can also conclude which customer group you belong to. Based on this, we can send you an offer for related items that may be of interest to you. If you do not have an open account with us, we will not adjust the offersbased on what kind of goods you searched for on our websites, nor on which links you opened in the sent offers.
We also use the information about your orders for the purposes of creating customized offers and customized advertisements that we display on the websites, as described in the section If you visit our websites. We measure your satisfaction with our services based on the NPS survey that we send to you via email within Survey Monkey. We send the questionnaire to random users who have made a purchase from us in the past month. We keep the research results exclusively for our own use. In order to protect legal claims and maintain our internal records and controls, we process data for a period of 3 years and 1 year after that in relation to claims that are asserted until the expiration of the statute of limitations. In the case of judicial, administrative or other proceedings, we process your personal data for as long as is necessary for the duration of such proceedings and the remainder of the limitation period after its completion. In order to protect legal claims and our internal records and control, we process the data during the statute of limitations, which is 5 years, and if necessary, one more year after its expiration in the case of an asserted claim at the end of the statute of limitations. Upon initiation of a judicial, administrative or other procedure, we process your personal data for as long as is absolutely necessary to carry out these procedures, and until the end of the remaining part of the limitation period after its expiration. For the other stated purposes, we use personal data for a maximum of 6 months. which are carried out on the basis of our legitimate interest, you can object.
B.3.3 Processing based on the fulfillment of legal obligations
We must also fulfill certain statutory obligations. If we process your personal data for this reason, we do not need your consent for such data processing. On this legal basis, we process your identification and contact data, order data, namely in order to comply with the applicable legislation, which at the time of preparation of the memorandum in question is, in particular, the following:
Code of Obligations (OZ),
Consumer Protection Act (ZVPot),
Value Added Tax Act (ZDDV-1),
Act on Tax Verification of Invoices (ZDavPR),
Accounting Act (ZR),
Electronic Communications Act (ZECom),
Law on the Prevention of Money Laundering and Financing of Terrorism (ZPPDFT-1).
For this purpose, we use personal data for a maximum of 10 years (plus the current year) from the last document issued in connection with your order.
If you are the recipient of goods or services that you have ordered from us
If you are the recipient of goods or services that you have ordered from us, we process your identification and contact information:
based on our legitimate interest for the purposes of preparing, concluding and executing a contract with our client. The performance of this contract is also our legitimate interest;
based on our legitimate interest to obtain information on the basis of which we can improve our services to you in the future, or information for the preparation of our internal statistics and reviews; our legitimate interest in this case is to improve our services to our customers;
to fulfill the right obligations, in particular based on the applicable legislation, listed in point B.3.3. of the subject memorandum;
for the purpose of protecting legal claims and our internal records and controls; our legitimate interest in this case is the protection of legal claims and control over the regular performance of our services.
For the preparation, conclusion and execution of the contract with the client, we use personal data during the time that is absolutely necessary to process the order. After this time, we keep the data on the basis of our legitimate interest for the purposes of protecting legal claims and our internal records and control, namely for the duration of the statute of limitations, which is 5 years, and if necessary for another year after its expiration in the event of an established claim upon expiry of the limitation period. Upon initiation of a judicial, administrative or other procedure, we process your personal data for as long as is absolutely necessary to carry out these procedures, and until the end of the remaining part of the limitation period after its expiration. Our legitimate interest in this case is the protection of legal claims and control over the regular performance of our services. To fulfill legal obligations, we use personal data for a maximum of 10 years for an individual order. If you have any concerns about this type of processing based on a legitimate interest, please contact us here.
If you communicate with us through different channels:
If you communicate with us through various channels, in particular through call centers, e-mail, chat rooms and social networks, based on our legitimate interest, we process your identification and contact data and records of mutual communication, including recordings of speeches (that is, without your consent) for the purposes :
processing your requests; if you have purchased from us and your inquiry relates to an order, we may carry out processing based on the execution of a contract with you;
a record of your requests so that we can check their regular and timely fulfillment;
which provesthat we have received and processed your request, e.g. if you order goods from us in this way or make a complaint;
analysis of requirements to improve the quality of our services.
For these purposes, we store personal data for a period of 3 months. If you place an order through one of our channels, we may retain data for the protection of legal claims for a limitation period of 5 years and a further 1 year after expiry in relation to claims asserted at the end of the limitation period. In the case of judicial, administrative or other proceedings, we process your personal data to the extent necessary for the duration of these proceedings and the remainder of the limitation period after their completion. If you have any concerns about this type of legitimate interest processing, please contact us here.
Who processes your personal data and with whom do we share it?
We mostly process your data for our own purposes as their controller. In this case, we pass on your data to our partners for the purpose of ensuring payment, transport and other matters related to your order. We also forward them to our processors, who process them according to our instructions. If you agree, we may also share your information with advertising and social networks to display customized ads on other websites. We process all listed personal data as an administrator. Therefore, we determine the above-defined purposes for which we collect your personal data and processing methods, and are responsible for their correct implementation. We may also forward your personal data to other entities that have the same function of manager, namely:
in relation to the processing of your order to our partners who participate in the processing of the order, as stated in the section If you buy from us, specifically
partners who operate payment systems for the provision of payments, especially in relation to payment cards, and above all
GLS -
to the supplier of the goods or the service of the relevant manufacturer in connection with the complaint of the ordered goods or service;
on the basis of your consent for advertising and social networks, as described in the section Use of cookies and other technologies, transmission of data to advertising and social networks, namely:
Google Ireland Limited (registered number: 368047), with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland; The company's privacy policy is available here: https://policies.google.com/technologies/ads
Facebook Ireland Limited, with registered office at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, D02 X525, Ireland; The company's privacy policy is available here: https://www.facebook.com/about/privacy
To process personal data, we also use the services of other processors who process personal data exclusively in accordance with our instructions and for the purposes described in the chapter Why do we process personal data and why are we entitled to it?. Such processors include:
operators of marketing tools such as those that help us optimize the web and tailor content and offers to you;
Google Ireland based at Gordon House, Barrow Street, Dublin 4, Ireland (BigQuery Services, ChannelAdvisor),
From which sources do we obtain personal data?
We usually obtain your personal data directly from you through our online store or when communicating with you. You can also get some other information from our partners, e.g. banks or transport companies. We mostly process personal data that you provide us directly when ordering items and services, when creating and using an account, or when communicating with us, for example with the call center. We also obtain personal data directly from you by monitoring your online habits while browsing our online store or reading our messages, by recording calls through call centers. When you make a purchase from us, we may receive additional information about your orders by executing a mutual purchase agreement. by banks, our payment system partners and transport partners, e.g. information about the account number, successfully executed payments or delivery and collection of goods.
Data transfer outside EU countries
In some cases, we may transfer your personal data to countries that are not members of the European Economic Area. In connection with the transfer of data to the recipients listed in the chapter Who processes your personal data and with whom do we share it?, we may also forward your data to third countries. outside the European Economic Area, where an adequate level of personal data protection is not necessarily always guaranteed. This type of mediation will only take place if the recipient concerned undertakes to comply with the standard contractual clauses issued by the European Commission and available at http://eur-lex.europa.eu/LexUriServ/LexUriServ.do? uri=OJ:L:2004:385:0074:0084:CS:PDF
What are your rights regarding the processing of personal data?
You have a number of rights in relation to your personal data. Among other things, the right to access, review, deletion and restriction of processing, transfer, objection and complaint. Because we have our rights and obligations regarding the processing of your personal datav, you also have certain rights in this regard. These rights include:
The right to information
In other words, it is your right to find out what data we collect about you, for what purposes and for how long, where we obtain your personal data from, who we pass it on to, who processes it besides us and what your other rights are related to the processing of your personal data. You can read all this in the document "Protection of personal data of customers". However, if you are still not entirely clear about which personal data it is, you can request confirmation from us as to whether we are collecting personal data about you or not, and if so, you have the right to be informed about this data. In accordance with the right to information, you can request a copy of the processed data from us, whereby we will provide you with the first copy free of charge, and each subsequent copy for a fee.
Right to rectification
No one is infallible. If you notice that your personal data stored by us is incorrect or incomplete, you also have the right to request the correction of these errors or the addition of data.
The right to erasure
In certain cases, you also have the right to delete personal data. Your personal data will be deleted as soon as possible if any of the following reasons are met:
we no longer need your personal data for the purposes for which we processed them;
you have withdrawn your consent to the processing of personal data, in this case it is data for the processing of which your consent is required, but at the same time we have no other reason for further processing of this data;
you have exercised your right to object to data processing (see section Right to object to data processing below) for personal data that we process on the basis of our legitimate interest, and we acknowledge that we no longer have legitimate interests that would justify further processing of this data or
you assume that the processing of personal data carried out by us is no longer in accordance with generally binding legal regulations.
However, you should be aware that even if any of the above reasons are met, it does not mean that all of your personal data will be deleted immediately. Because this right cannot be exercised in the event that the processing of your personal data continues to be necessary to fulfill our legal obligations or to establish, exercise or defend our legal claims (see the section Why do we process personal data and why are we entitled to do so?).
The right to restriction of data processing
In addition to the right to deletion, in certain cases you can also exercise the right to limit the processing of personal data. This allows you, in some cases, to request that your personal data be specifically marked and thus exempted from all processing operations - this applies for a certain period of time (and not permanently as in the case of the right to erasure). We must limit the processing of personal data:
if you dispute the accuracy of your personal data until we agree which data is correct;
if we process your personal data without an appropriate legal basis (e.g. outside the intended scope) and instead of deleting this data you prefer to limit it (e.g. if you anticipate that you will continue to provide us with this data in the future);
if we no longer need your personal data for the purposes described above, but you need it to assert, exercise or defend your legal claims, or
if you object to data processing. The right to object is described in more detail below under the heading Right to object to data processing). We must limit the processing of your personal data during the processing of your objection.
The right to transfer data
You have the right to obtain from us all your personal data that you have provided to us and that we process on the basis of your consent (see section If you give us consent) and on the basis of the performance of contracts. We provide you with your personal data in a structured, validated and machine-readable format. Simple data transfer is only possible for data that is automatically processed in our electronic databases.
The right to object to data processing
Based on reasons related to your particular situation, you can exercise the right to object to the processing of personal data based on (e) or (f) Article 6(1) of REGULATION (EU) 2016/679 and to object to the processing of personal data. data processing for direct marketing purposes (see Why do we process personal data and why are we entitled to it?). We will immediately stop processing your personal data for marketing activities n; we will do the same in all cases, unless we have legitimate grounds for processing that override your processing rights or to exercise legal claims.
Right to appeal
The above rights do not in any way affect your right to file a complaint with the competent authority. You can exercise this right in particular if you believe that we are processing your personal data without a basis or contrary to generally applicable legal regulations. You can therefore complain about the data processing we carry out to the Information Commissioner at the address Zaloška cesta 59, 1000 Ljubljana.
Commissioner for vprotection of personal data
Our authorized personal data protection officer is at your disposal for all matters related to the processing of your personal data. You can contact the clerk at the e-mail address: dpo@itrade.si
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