AVC Group

Privacy policy

What is the Aim and Scope of this Privacy Policy

This Privacy Policy aims to inform the individuals, i. e. natural persons (hereinafter: Users) who visit and use the AVC Group website (http://www.avc-group.com/) (hereinafter: Website) about collecting, storing and other types of processing of their personal data, by AVC Group d. o. o. (hereinafter AVC Group).

All our personal data processing activities are carried out according to Regulation (EU) 2016/697 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (The EU General Data Protection Regulation (hereinafter: GDPR)).

About the Processor (AVC Group)

Name: AVC Group d.o.o.

Business address: Tržaška cesta 126, 1000 Ljubljana, Slovenia

Reg. No.: 5776813000

Email address (for any inquiries about personal data, including claims and demands): info@avc-group.com.

 
What Personal Data is Being Collected and Further Processed

AVC Group collects and further processes the following Users’ personal data:

From all Website Users:

From Newsletter Subscribers:

  • Language chosen by the User,
  • Email address,
  • Date and time of subscription,
  • Date and time of receiving each newsletter,
  • The data about opening the received newsletter (whether and when the Subscriber has opened the newsletter),
  • Data about clicking on links within the newsletter (what links the Subscriber has clicked and when),
  • Data about whether the Subscriber is an end-buyer or reseller,
  • Date and time of signing-out from further receiving of newsletter.

From Newsletter Receivers (Existing Buyers):

  • Language chosen by the User,
  • Email address,
  • Date and time of receiving each newsletter,
  • The data about opening the received newsletter (whether and when the Subscriber has opened the newsletter),
  • Data about clicking on links within the newsletter (what links the Subscriber has clicked and when),
  • Data about whether the Subscriber is an end-buyer or distributor,
  • Date and time of signing-out from further receiving of newsletter.

 
What are the Legal Grounds for Personal Data Processing

AVC Group collects, stores and processes Users’ personal data based on the following legal grounds:

Personal Data Processing Based on User’s Consent

The following personal data is being processed based on User’s consent:

Personal Data Processing Based on Legitimate Interest of AVC Group

The following personal data is being processed based on legitimate interest of AVC Group:

  • The following personal data from newsletter subscribers:
    • Language chosen by the User,
    • Date and time of receiving each newsletter,
    • The data about opening the received newsletter,
    • Data about clicking on links within the newsletter,
    • Data about whether the Subscriber is an end-buyer or reseller,
  • The following personal data from newsletter receivers (existing buyers):*
    • Email address,
    • Date and time of receiving each newsletter,
    • The data about opening the received newsletter,
    • Data about clicking on links within the newsletter (what links the Subscriber has clicked and when),
    • Data about whether the Subscriber is an end-buyer or reseller.

* The Electronic Communications Act (ZEKom-1) allows for sending of electronic marketing messages to existing buyers of products or services.

Personal Data Processing Based on Compliance with a Legal Obligation

AVC Group processes the data about the date and time of signing-out from further receiving of newsletter because it is its legal obligation under ZEKom-1. Namely, AVC Group must comply with any such request from any newsletter subscriber.

What are the Purposes of Personal Data Processing

The purposes of processing personal data collected through cookies are detailed here.

The purposes of processing personal data collected from newsletter subscribers are:

  • marketing communication: sending of messages to Subscribers, in their own (chosen) language,
  • segmentation of messages based on the status of Subscribers (end-user or reseller),
  • statistical analyses of the Subscribers’ reception of, and attitude towards, the received messages; this data is not being used for any further (deeper) segmentation of Subscribers,
  • compliance with legal obligation in case of Subscriber’s opt-out.

What are Cookies and How We Use Them

In the below table, the names of cookies (files), the use (purpose) of data collected through cookies, and the duration of cookies placed on Users’ devices by the Website is provided:

Strictly Necessary Cookies

The necessary cookies enable basic functions such as navigating the website and accessing specific parts of the website. A website cannot guarantee the user full activity without these cookies. Cookies, which are intended for adaptation of behaviour and imaging of a website when visiting the next time, for example a display in a selected language, also fit into this category.

Cookies for Statistics Monitoring

Cookies for statistical purposes collect and report information anonymously to the owners of the websites. They help understand, how the visitors use the website and improve the user experience based on such information.

How Long is the Storage Period and what Happens Thereafter

The following categories of personal data are being stored for time stated hereunder:

After the expiry of the Storage Period, AVC Group effectively and permanently deletes or anonymises the personal data so that, in any case, they can no longer be linked to an individual User.

Who Has Access to Personal Data (Contractual Processing)

At AVC Group, only persons who have been authorised, in writing, by the CEO have access to personal data.

Certain processing operations related to personal data are being carried out by third parties on behalf of AVC Group (hereinafter Processors). Processors may process Users’ personal data exclusively within the limits of AVC Group’s mandate (written contract or other legal act) and for the purposes as defined in this Privacy Policy. Under no circumstances may the Processors process Users’ personal data for their own purposes or to pursue any interests of their own or of third parties other than AVC Group.

Processors include the following:

  • Website hosting provider,
  • Email storage, sending and email marketing provider,
  • Facebook, Google, LinkedIn and Youtube.

AVC Group and Processors do not transmit personal data to third countries (outside of the European economic area or to international organisations; the only exception being the email storage, sending and email marketing provider, whose servers are based in the United States of America. The transfer of personal data to that Processor is based on Standard Contractual Clauses with additional safeguards. You can get more detailed information here.

Security of Processing Personal Data

AVC Group uses all reasonable efforts to ensure security of Users’ personal data. Personal data is, to the maximum extent reasonable – based on the risks involved by the processing – protected from loss, destruction, falsification, manipulation, processing for purposes for which it has not been collected and from unauthorised access and disclosure.

AVC Group has in place strict internal procedures in case of security incidents relating to personal data.

Rights of Users Regarding Personal Data

If you have any questions about this Privacy Policy or regarding the processing of your personal data or if you wish to exercise any of the right hereunder, you can contact us at info@avc-group.com.

In order to ensure reliable identification in case of a User exercising their rights regarding personal data, AVC Group may request additional data from the user. AVC Group may refuse to act on User’s request if it can demonstrate that it is not in a position to identify the User.

AVC Group shall provide information or feedback without undue delay and in any case within one month of receipt of the request.

Users you have the following rights regarding fair and transparent processing, based on the GDPR:

The Right to Withdraw Consent

Users have the right to withdraw your consent to processing of your personal data at any time, including the unsubscribing from receiving the newsletter. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Consent can be withdrawn through a written statement that is sent to AVC Group at info@avc-group.com or (in case of newsletter) by clicking on the unsubscribe link.

Withdrawal of consent bears no negative consequences or sanctions for the User. It is however possible that AVC Group may not be able to provide some of its services to User after the withdrawal of consent, if such services cannot be performed without the processing of personal data in question.

The Right to Access Personal Data

Users have the right to obtain confirmation from AVC Group as to whether or not their personal data are being processed, and, where that is the case, right to access to the personal data and the following information: the purposes of the processing, the categories of personal data concerned, its users, the period for which the personal data will be stored, or the criteria used to determine that period, the right to request rectification or erasure of personal data or restriction of or objection to processing of personal data, the right to lodge a complaint with a supervisory authority, the source of the data if the data were not collected from Users, the existence of automated decision-making, including profiling and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for Users.

The Right to Rectify Personal Data

Users have the right to request from AVC Group without undue delay the rectification of inaccurate personal data.

The right to Deletion of Personal Data (Right to be Forgotten)

Users have the right to request AVC Group to delete without undue delay their personal data when one of the below reasons exists:

  • the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed,
  • User has withdrawn their consent, and there are no other legal grounds for further processing,
  • User has objected to the processing of their personal data, and there are no overriding legitimate grounds for processing,
  • User’s personal data has been unlawfully processed,
  • the personal data has to be erased for compliance with a legal obligation in Union or Member State law to which AVC Group is subject,
  • the personal data has been collected in relation to the offer of information society.

As an individual under certain circumstances, as defined in Article 17, paragraph 3 GDPR, you do not have the right to data deletion.

The Right to Restriction of Processing

Users have the right to request from AVC Group restriction of processing where one of the following applies:

  • User contests the accuracy of the personal data for a period enabling AVC Group to verify the accuracy of the personal data,
  • the processing is unlawful, and User opposes the erasure of the personal data and requests the restriction of their use instead,
  • AVC Group no longer needs the personal data for the purposes of the processing, but they are required by User for the establishment, exercise or defence of legal claims,
  • User has objected to processing pending the verification whether the legitimate grounds of AVC Group override User’s rights.

The Right to Data Portability

Users have the right to receive the personal data concerning them, which they have provided to AVC Group, in a structured, commonly used and machine-readable format and have the right to transmit such data to another controller without hindrance from AVC Group, where:

  • the processing is based on consent or on a contract, and
  • the processing is carried out by automated means.

In exercising the right to data portability, Users have the right to have their personal data transmitted directly from AVC to another controller of their choice, where technically feasible.

The Right to Object to Data Processing

Where personal data is processed for direct marketing purposes, Users have the right to object at any time to processing of their personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing; where Users object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

The Right to Lodge a Complaint with the Supervisory Authority

Users have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged infringement. In Slovenia, they may contact Informacijski pooblaščenec, Dunajska cesta 22, 1000 Ljubljana, Slovenia, gp.ip@ip-rs.si.

 

This Privacy Policy shall be effective as of December 22, 2020.