Privacy Policy and Personal Data Protection

Privacy Policy and Personal Data Protection

(hereinafter: this “Privacy Policy“)

1. PRIVACY POLICY – GENERAL

At INACHI d.o.o., we recognize the importance of your privacy. We handle individuals’ personal data carefully and responsibly, complying with the requirements of the current data protection legislation. This Privacy Policy aims to help you understand what personal data we collect, why we collect it, how we use it, on what legal basis, and what your rights are in this area. It is important to read this Privacy Policy along with any other notices we may provide occasionally or those available on our website https://njamito.com and https://njamito.com/zafirme/ so that you are fully informed about how and why we use your personal data. Any questions regarding personal data processing can be sent to our email address: info@njamito.com.

2. DATA CONTROLLER

The data controller is INACHI, raziskave in razvoj, d.o.o., Vilharjeva cesta 3, 1000 Ljubljana (“INACHI”, “Controller” or “we”). INACHI ensures that personal data of customers, website users, and all other data collected during visits, registrations, or online purchases are protected against unauthorized disclosure and access by third parties.

3. LEGAL BASIS FOR PERSONAL DATA PROCESSING

The legal basis on which we process your personal data can be found below:

a) Performance of a contract

If you are our customer and you make a purchase or use any other service from us, providing your personal data is necessary for fulfilling the rights and obligations arising from the concluded sales contract, such as customer identification, delivery of goods, order execution (including the feature that ensures items added to the cart or order details are not deleted, allowing us to complete the order), communication related to the contractual relationship, handling objections or complaints, and conducting potential debts recovery procedures.

b) Compliance with Legal Obligations

In certain cases, processing your personal data is a requirement imposed on us by applicable laws (e.g., tax laws). For instance, we must provide the personal data of prize winners in competitions / contests with prizes exceeding 42 EUR to the Financial Administration of the Republic of Slovenia. The personal data obtained on this basis must also be retained by INACHI in case of withdrawal of consent for processing, request for restriction of processing, or termination of the contractual relationship. After the legally mandated period expires, INACHI will destroy these personal data.

c) Legitimate Interest

We may process some of your personal data based on legitimate interest when our interests, after careful assessment, outweigh your fundamental rights and freedoms, considering your reasonable expectations regarding the processing of personal data based on your relationship with the controller – INACHI. Based on legitimate interest, we may process your data to develop and improve our services and products, ensuring our offer meets your expectations (including market research and satisfaction surveys), for handling product purchases, including notifying you that you left items in the cart without checkout, for technical maintenance and operation of the websites, protecting and ensuring the security of our information system, confidential information, employee safety, and company assets. Our legitimate interest in processing your personal data also includes preventing fraud and potential crimes, resolving disputes and complaints, and protecting legal claims.

We also process personal data of employees of our business customers, suppliers, or partners based on legitimate interest for fulfilling contracts we enter into with such business customers, suppliers, or partners.

On the basis of legitimate interests, customer email addresses may also be processed for direct marketing purposes in accordance with the Slovenian Electronic Communications Act (ZEKom-2), but only for a limited period (up to five years from the last purchase) and to a limited extent, without processing special categories of personal data, and in a manner that does not significantly affect the individual’s profile or position in relation to the controller, and is never used for automated or other decisions regarding their rights in relation to the controller. Individuals can object to such processing at any time.

d) Processing Based on Consent

INACHI may process personal data based on consent for the following purposes:

• to identify individuals, carry out marketing activities such as general notifications about offers, news, benefits (including sending codes and coupons), news, events organized by INACHI, and other similar information; and
• to analyze behavior and responses to targeted offers, participation in competitions, contests, surveys, chats, customer research, and tests organized by INACHI.

Individuals can provide and withdraw consent at any time as follows:

1. In writing to the address: INACHI, raziskave in razvoj, d.o.o., Vilharjeva cesta 3, 1000 Ljubljana, or
2. To the email address: info@njamito.com

Withdrawal or change of consent only applies to the personal data that were processed based on such consent. Withdrawal does not affect the lawfulness of data processing that took place based on such consent before its withdrawal. The possibility of withdrawing consent does not represent a right to terminate any existing business relationship with INACHI.

e) Processing for the purpose of informing the public  

In accordance with ZVOP-2, INACHI may process the following personal data collected at events (where INACHIi is present as a (co-)organizer or sponsor): (1) personal name, (2) title, (3) photograph, and (4) video recordings, for the purpose of informing the public. This does not apply if you have expressly prohibited such use or publication (e.g., by notifying the photographer, etc.).

4. DISCLOSURE OF PERSONAL DATA

INACHI may disclose your personal data to the following legal or natural persons to fulfill the purpose for which they are processed:

• Public authorities, if necessary to comply with our legal obligations or perform their official duties, such as the police, courts, tax authorities, and others;
• Auditors, inspectors, and lawyers, debt collection companies;
• Providers of technical support and security maintenance;
• Marketing and advertising service providers;
• Providers of communication concept development;
• Providers of surveys or market research;
• Contest / competition organizers;
• Providers of web analytics;
• Providers of IT, cloud, and server services used by INACHI;
• Software solution developers;
• Payment service providers and banks;
• Postal service providers, delivery and courier services;
• Third-party services (e.g., Google); and
• Social media platforms (e.g., Facebook, Instagram, LinkedIn).

Third-party services. On the website https://njamito.com/, we also use certain third-party solutions (e.g., Google Maps, Google Analytics, Hotjar) to enhance user experience. When using these, we alert you that the data will also be processed by the owners of these solutions. General terms of use are available on the providers’ websites.

Social media platforms. On the website https://njamito.com/, there may also be links to external websites (Facebook, Instagram, LinkedIn, YouTube). These act as independent data controllers. We warn you that by clicking on these links, you will visit these websites and thereby also provide your personal data to them in accordance with their privacy policies.

Transfer to the USA. By using https://njamito.com/, and participating in competitions and similar activities conducted on social media platforms, your personal data may be transferred and processed in the USA, or such a transfer and processing by social media platforms cannot be prevented. 

We wish to let you know that on July 10, 2023, the European Commission (EC) adopted an adequacy decision based on the EU-US Data Privacy Framework (DPF). Based on this adequacy decision, personal data from the EU can be safely transferred to those US companies that participate in the EU-US Data Privacy Framework without needing to implement additional data protection measures in accordance with Article 46 of the General Data Protection Regulation (GDPR).

We will strive to ensure that your personal data is processed as much as possible within the territory of the European Union and the European Economic Area and is not transferred to the USA. If the transfer cannot be avoided, we will strive to transfer personal data only to providers properly certified under the DPF. Whenever possible, we will request your consent before using tools originating from the USA and transparently inform you about the service’s operation.

5. CATEGORIES OF PERSONAL DATA

In accordance with the principle of proportionality, we collect only the personal data that we need for the purpose pursued with the processing. We collect various personal data about you, depending on the nature of our business relationship with you and the legal basis we use for the processing, as follows:

• When visiting the website

When visiting the websites https://njamito.com/ and https://njamito.com/zafirme/, we process certain data about you (IP address, browser settings, content accessed on the said websites, user paths on the website (e.g., source of traffic, access date, and duration of visit)) through cookies for the smooth and correct operation of the website, improving the user experience on the website, and analyzing user behavior on the site. Cookies remember your preferences and experiences, saving you time and making browsing more efficient and pleasant for the user. Personal data processed through cookies is processed based on our legitimate interest or your consent, if provided. Cookie settings can be changed at each visit.

• When registering on our website

If you wish to become a registered user of our website/online store, you must provide the following personal data: email address, password, and password confirmation. Without providing this data, you cannot create an account and become a registered user. As a registered user, you can make purchases faster and without having to provide your requested personal data every time. If you make a purchase as a registered user, you can track past purchases in our online store and have the option to subscribe to our programs and other benefits described in the General Terms of the online store: https://njamito.com/pogoji-poslovanja/.

Upon registration on the website  https://njamito.com/, the Controller processes, in addition to the personal data provided in the registration form, the registration date, the date of the last visit, and in the case of an online purchase, data on orders and purchases (purchase history), reviews if provided, and wishes if you add any items to the wish list. As part of the purchase process, we may also send you an email if you left items in the cart without checkout.

Your personal data is processed only for managing your user profile or based on your consent and legitimate interest for sending advertisements.

• When making an online purchase

For the purpose of fulfilling the purchase order, we process the following personal data:

• Email address;
• Name;
• Surname;
• Address;
• Contact phone;
• Purchased item and amount;
• Total order amount;
• Delivery method;
• Any benefits used (e.g., coupon, discount, etc.);
• Payment method;
• Credit card details in case of credit card payment; and
• If the buyer is a legal entity: company name, tax number (optional), contact details of the contact person.

Without providing this personal data, we cannot fulfill the obligations arising from the (purchase) order.

If you made a purchase as a registered user on the website https://njamito.com, we also collect data on orders and purchases (purchase history).

Certain personal data you provide during online purchases may also be accessed by third parties, such as business partners who will deliver the goods on our behalf.

If you choose to pay by credit card during an online purchase, you will be redirected to the payment system provider’s website to ensure payment. These providers are independent data controllers for the data you provide for the purpose of completing the payment.

• When filing a complaint or exercising withdrawal rights

In the event that you file a complaint about a purchased item or exercise the right to withdraw from the contract, we process the following personal data:

• First and last name;
• Address;
• Email address;
• Phone number;
• Product or order number (with receipt) for which you are exercising the right of withdrawal or filing a complaint;
• Bank account number (IBAN); and
• Reason

We require and process the above personal data solely for the purpose of resolving and optimizing the complaint or withdrawal process and for communication with you.

• When subscribing to newsletters

By subscribing to newsletters on https://njamito.com/ or at events, you agree to receive offers, updates, promotions, news, and events organized by INACHI, and other similar information. For this purpose, we process your email address. You can revoke your consent for data processing at any time by clicking the Unsubscribe link available in each newsletter or by sending a request to: info@njamito.com or INACHI, raziskave in razvoj, d.o.o., Vilharjeva cesta 3, 1000 Ljubljana.

• When participating in a prize draw /  competition / contest

If you participate in a prize draw, competition or contest, the personal data you provide (as specified in the general terms and conditions of each such prize draw, competition or contest), will be processed only for the purpose of conducting the prize draw, competition or contest (e.g. to verify eligibility to participate, contacting winners, and publicly announcing the winners on our online network). If the value of the prize exceeds 42 EUR, we will also require your tax number in accordance with Slovenian tax legislation, and your data will be submitted to the Financial Administration of the Republic of Slovenia.

• When contacting us via forms

If you have filled out a contact request or inquiry form, or contacted us via the chat at https://njamito.com/zafirme/, the personal data provided, such as the contact person’s email, will be used solely for processing your request. Personal data is obtained based on your consent or request. Without your personal data, we cannot inform you about the resolution of your request.

• If you are a contact person for our business partner

If you are employed by a company that is our current or potential business partner, we process your personal data such as: first and last name, the name of the legal entity you are employed by, job title, phone number, and email address. We process the personal data based on legitimate interest solely for the purpose of business operations.

• At event participation  

If you attend an event where we are present, we may process some of your personal data (personal name, title, photographs, video recordings) for the purpose of informing the public, unless you explicitly prohibit us from doing so.

6. RETENTION PERIOD OF PERSONAL DATA

We retain your personal data only for as long as necessary to achieve the purpose for which it was collected, or as long as required by applicable law. After the retention period expires, we will securely delete or anonymize your personal data.

In certain cases, the retention period is determined by legislation; therefore, personal data is retained for as long as necessary to fulfill legal obligations (e.g., issued invoices are retained for 10 years from their issuance in accordance with applicable Slovenian legislation).

If your personal data is processed for the purpose of the contract fulfilment, the data is retained for the duration of the contractual relationship and, based on legitimate interest, for as long as any legal claims related to the contract can be asserted.

Personal data processed based on your consent is retained until your consent is withdrawn or you request the deletion of the personal data.

7. RIGHTS OF INDIVIDUALS

You can submit a request to exercise the rights mentioned below to: info@njamito.com. If there is a legitimate doubt regarding the identity of the individual making a request concerning their rights, INACHI may request additional information necessary to verify or confirm the identity of the individual whose personal data is being processed.

Regarding personal data, you have the following rights:

• Right of access: Upon request, we will inform you whether your personal data is being processed and, if so, provide the following information:
  – types of personal data;
  – categories of users to whom personal data has been or will be disclosed;
  – retention periods;
  – the existence of the right to request correction or deletion of personal data or restriction of processing, or the right to object to such processing;
  – the right to lodge a complaint with the Information Commissioner;
  – where personal data is not collected from the individual, any available information regarding their source; and
  – the existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and intended consequences of such processing for the individual.

Based on the request, INACHI will prepare a copy of your personal data being processed and provide it to you.

• Right to rectification: You can request at any time that INACHI corrects inaccurate personal data or completes your incomplete personal data.

• Right to erasure (right to be forgotten): You can request the deletion of your personal data in the following cases:
  – the personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
  – you withdraw consent on which the processing is based, and there is no other legal basis for the processing;
  – you object to the processing of personal data, and there are no overriding legitimate grounds for the processing;
  – the personal data has been unlawfully processed; 
  – the personal data must be erased to comply with a legal obligation under EU or Slovenian law.

• Right to restrict processing: You can request that the processing of you personal is restricted when:
  – the data is not accurate;
  – the processing is unlawful, and you don’t not want the data to be deleted;
  – INACHI no longer needs the data for processing purposes, but you need them for asserting, exercising, or defending legal claims;
  – the individual has objected to the processing.

• Right to data portability: You can request an export of the provided personal and the personal data generated by purchases in the online store, where the processing is based on a contract or consent. The data export will be prepared in a machine-readable format.

• Right to object: You can object to the processing of personal data. This right only applies to the processing of your personal data carried out based on legitimate interest, which overrides your interests—specifically, processing for the purpose of contacting for surveys and direct marketing using only basic data. Obrazec zahteva po pravici iz GDPR.

• Right to withdraw consent: You have the right to withdraw consent for the processing of your personal data when processing is based on consent, without affecting the lawfulness of processing based on consent before its withdrawal.

• Right to lodge a complaint regarding the processing of personal data: You can send any complaint regarding the processing of your personal data to the email address info@njamito.com or by mail to the address: INACHI, raziskave in razvoj, d.o.o., Vilharjeva cesta 3, 1000 Ljubljana.

Every individual whose personal data is processed also has the right to lodge a complaint directly with the Information Commissioner if they believe that the processing of personal data concerning them violates applicable legislation.

8. SOURCES OF PERSONAL DATA ACQUISITION

In most cases, the personal data we process is provided directly by you when you fill out forms or contact us by mail, phone, email, chat, or social media. To a limited extent, we may also obtain personal data indirectly from other sources. For example, if you choose to pay by card in our online store, the payment system providers will inform us whether the payment was successfully completed.

9. SECURITY OF PERSONAL DATA

INACHI ensures appropriate technical, organizational, and logical-technical procedures and measures to protect personal data. To maintain an adequate level of protection for your personal data, INACHI implements the following measures:

• protecting the application software used to process personal data;
• preventing unauthorized access to personal data during transmission, including transmission over telecommunication networks;
• ensuring effective methods for blocking, destroying, deleting, or anonymizing personal data; and
• enabling the subsequent determination of when individual data was entered into the personal data collection, used, or otherwise processed and who did it.

10. COOKIE POLICY

Websites: https://njamito.com in https://njamito.com/zafirme/  use cookies to display relevant and interesting content, thereby providing a more pleasant user experience. Users are informed about the use of cookies upon their first visit to the website. Users can change their decision regarding the use of cookies at any time when they visit the website.

What are cookies?

Cookies are text files that a website stores on your device during your visit. The interaction between the user and the website is faster and easier with the help of cookies. They help the website remember the user’s preferences and experiences, saving time and making browsing more efficient and user-friendly. Withdrawing consent may change the operation of certain parts of the website or disable the use of certain services.

Why are cookies necessary?

Depending on their purpose, cookies are classified into four categories:

• Strictly necessary cookies: These are crucial as they enable navigation on our websites, the use of basic functions of the website, or the provision of requested services (e.g., saving items added to the cart by a customer). Without these cookies, the use of the websites would not be possible.
• Functional cookies: Some third-party software used on our websites stores cookies through our websites. These are third-party cookies that enable the operation/functionality of our websites. INACHI provides only the platform and cannot control the use or influence the use of these cookies and/or the use of information collected by these cookies by third parties. The use of data collected by these cookies may be subject to further third-party terms.
• Web analytics cookies: These help us understand how users use the websites. With their help, INACHI improves the user experience and identifies user needs and trends.
• Targeting cookies or third-party advertising cookies: These track users across websites to display ads that are relevant and interesting to the individual user. This category also includes social media cookies.

List of cookies used by INACHI websites:

In most web browsers, you can set rules for managing cookies. Instructions for managing cookies in different browsers:

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

Firefox Mozilla: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer

Microsoft Edge: https://support.microsoft.com/en-us/windows/manage-cookies-in-microsoft-edge-view-allow-block-delete-and-use-168dab11-0753-043d-7c16-ede5947fc64d

Opera: https://help.opera.com/en/latest/web-preferences/

Safari: https://support.apple.com/en-gb/guide/safari/ibrw850f6c51/mac#:~:text=You%20can%20change%20Safari%20settings,blocks%20cookies%20and%20website%20data.&text=In%20the%20Safari%20app%20on,other%20data%20on%20your%20Mac.

11. VALIDITY

This Privacy Policy is published on: https://njamito.com/. 

Last update: October 2024.

Change against the previous version (December 2023): Change of address of Inachi (Vilharjeva cesta 3, Ljubljana)