Personal data protection policy (GDPR)
Right to privacy is one of the most important human rights. In LEP d.o.o. (hereinafter referred to as the Company), we are very well aware of this and we, therefore, respect the privacy of our customers and treat their personal data responsibly, carefully and according to the applicable legislation. The access to personal data is permitted only to authorised Company personnel and contracted processors, to the extent and with the purpose strictly necessary for the smooth implementation, assurance and fulfilment of rights and obligations arising from concluded contractual relations.
By taking proper measures, we ensure that unauthorised persons do not access personal data, protect its confidentiality and integrity, and prevent its loss or unintentional destruction throughout the entire time of being processed. We will not be held responsible for any “hacking” into a computer system!
Company and its processors fully respect the general principles regarding the processing of personal data, which are:
For questions related to the processing and use of personal data, information, corrections, blocking, deletion of personal data or cancellation of notification consent, cancellation of consent, please contact info@
wine-tours-slovenia.comwinetastingbled.com (hereinafter referred to as email address under point 1).
We can treat personal data in accordance with valid legislation from the field of protection of personal data:
The company processes personal data of individuals to fulfil its obligations under a contractual relationship for the organisation of events, workshops or other services agreed between the contractual parties. In the context of the exercise of rights and the fulfilment of contractual obligations, Company processes personal data of individuals for the following purposes:
To the extent strictly necessary for authentication and identification of transactions, Company processes data for the purpose of preparing reports and planning further activities.
For the purposes of organising events and related services or other services ordered by an individual, Company processes all information needed. This includes in particular, but not exclusively: name, first name, surname, birth date, address, place, country, telephone number, email, etc.
We do not need explicit consent for contractual processing of personal data.
At events or workshops that are strictly connected with photographing and publication of pictures (on Facebook, Twitter, YouTube in Instagram), it is numbered that photographing and publication of pictures are part of an event or workshop. In spite, that photographing and publishing of pictures is a contractual relationship, Company will still gain explicit consent of an individual. In a case where explicit consent for photographing and publication of pictures will not be given and Company will not be able to assure that an individual will not be on photograph, Company is justified to rejects application on such event or workshop.
If the individual does not provide all personal data that the Company needs to fulfil the contractual relationship, the Company cannot execute the individual’s order. Hereby, Company always acquires and further processes only the personal data that is needed to fulfil the contractual relationship.
The legal basis means that the Company processes personal data of an individual to fulfil the applicable legal obligations imposed by the legislation. In the Republic of Slovenia, legal obligations to process certain personal data are determined in particular by:
Value Added Tax Act ZDDV-1;
Tax Procedure Act;
Rules on the implementation of the Value Added Tax Act;
Slovenian Accounting Standards.
If Company processes personal data of an individual who has made an online purchase or service order, it keeps the invoice for 10 years (as well as individual’s/buyer’s data on the account).
Company may process data on the basis of a legitimate interest which Company or a third party pursues, except when such interests are prevailed by the interests or fundamental rights and freedoms of an individual, to whom the data that requires the protection of personal data is related, in particular when the data relates to a child. In the case of further use of collected data on an individual, the Company implements the assessment according to the General Data Protection Regulation. Such further use of data in a pseudonymised or aggregated form, for example, represents the lawful use of data for marketing and other business or technical analyses of Company.
According to the General Data Protection Regulation, direct marketing also belongs to legitimate interests. For the purposes of direct marketing, Company may create individual profiles without any consent on the basis of basic information on selected services, such as e.g. the type or specific characteristics of the selected service, time of selection or past marketing contacts with the individual, in particular with respect to the expressed interest or lack of interest in certain services. Such basic profiling shall never include sensitive data. An individual may object to the processing according to the right to the restriction (item 7.4).
Based on legitimate interest, the Company may contact the individual to improve the service or determine his satisfaction with the services, even when this is not strictly necessary for the implementation of the contract. Due to the individuals’ interest, the Company does not contact those individuals who have objected to this.
The company has a legitimate interest to keep and further use data for analyses and research for marketing, business planning and similar until the expiration of the legally prescribed retention period.
Explicit consent is the basis for personal data processing for which Company does not have a legal or contractual legal basis. For example, consent may relate to:
The individual gives the consent for himself, in the case of a child, consent is given by one of the parents or a legal representative.
In these cases, the processing of personal data is implemented to the extent and for purposes allowed by the individual’s statement and through agreed communication channels, until cancellation.
If the individual does not consent to the personal data collection and processing for one or more purposes specified in an individual consent, this does not have any consequences for the data the processing of which is implemented based on other legal bases.
Personal data collected on the basis of consent will be processed only within the framework and for the purpose of the given consent and will not be transmitted to third parties unless this is explicitly stated in the consent and the individual agrees that personal data may be transmitted to the processor specified in the consent.
The individual can cancel the consent to process personal data at any time by contacting our data protection point (point 8). The consent can be cancelled by an email sent to the email address under point 1.
Personal data shall be stored in accordance with the applicable regulations governing the protection of personal data. It shall be stored only as long as necessary for the purposes for which it is processed or according to the law. We store personal data, which we process based on the personal consent of the individual, permanently, until cancellation. Personal data, which we process based on the law or contractual relationship, is kept for as long as the law determines.
If the data is processed based on an individual’s consent due to the marketing of Company, the data may be processed to the necessary extent for as long as necessary for such marketing or services.
After the expiry of the retention period, the personal data is effectively and permanently deleted or anonymised so that it can no longer be linked to an individual.
We use technical and organisational security measures to protect personal data against unlawful or unauthorised access or use and also against unintentional loss or impairment of their integrity. We have designed these measures with regard to our IT infrastructure, possible impact on an individual’s privacy and costs and according to current industry standards and practices. Our contractual processors shall process your personal data only if they comply with these technical and organisational security measures.
Maintaining data security means protecting the confidentiality, integrity and availability of personal data:
Our security procedures include access security, backup copies, monitoring, revision and maintenance, security incident management, etc.
Depending on the purposes for which we process individuals’ personal data, we can disclose this data to the following categories of processors:
Our business partners listed above under item b), may only process individuals’ personal data in the framework of our instructions and may not use personal data to pursue any of their own interests. Each individual must bear in mind that the processors listed in items b) and c) above, in particular, service providers that offer services within the framework of applications and/or through their own channels may separately collect your personal data. In this case, they are solely responsible for its control and their cooperation with individuals must take place according to their terms.
The Company ensures that individuals exercise their rights without undue delay, but in any case, no later than one month after receiving the request. The Company may extend the deadline for exercising the rights of the individual for a maximum of two months, considering the complexity and number of requests. If extending the deadline, Company shall notify the individual about the extension within one month of receipt of the request, stating the reasons for the delay.
When the individual, to whom the personal data is related, sends the request by e-mail, the information shall, when possible, be provided by electronic means, unless the individual requests otherwise.
Each individual can contact us to the email address E-mail address under point 1. to find out which personal data we process. Each individual has the right to access personal data and additional information concerning the processing of personal data, including:
If an individual finds any error in his personal data or if he finds it incomplete or wrong, he may request Company to correct or supplement inaccurate or incomplete personal data without undue delay.
An individual may request to delete his personal data without undue delay. The Company is obliged to delete personal data without undue delay:
(except in some cases, for example, to prove the transaction or if required by law).
Each individual may request a restriction of the processing of his personal data when:
Each individual shall have the right to receive the personal data concerning him or her, which he or she has provided to Company, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the Company, where the processing is based on consent pursuant or on a contract pursuant and the processing is carried out by automated means.
On the basis of reasons related to their special circumstances, each individual has the right to object at any time to the processing of their personal data based on the legal interests pursued by Company or a third person. In this case, Company ceases to process personal data, unless it proves necessary processing reasons that prevail over the individual’s interests, rights and freedoms, or for the enforcement or defence of legal claims. When personal data is processed for the purpose of direct marketing, each individual has the right to object at any time to the processing of personal data related to him for the purposes of such marketing, including profiling, if it relates to such direct marketing. If direct marketing is based on consent, the right to object can be exercised by cancelling the given consent.
We have organised a contact point that will address your questions or requirements regarding your personal data (and their processing) and the exercise of your rights. You can send us an email address under point 1.
For the purposes of reliable identification when exercising the rights connected to personal data, we may require additional data from you and we can deny action only if we can prove that we cannot identify you reliably.
Everyone has the right to file the complaint related to processing of personal data Complaints should be sent to the e-mail address under point 1. You also have the right to file a complaint directly to the Information Commissioner if you believe that the processing of personal data related to you violates Slovenian or EU regulations on the protection of personal data. If you have exercised the right to access the data and, after receiving the decision, you believe that the personal data that you have received is not the personal data you requested or that you did not receive all the personal data required, you can lodge a reasoned complaint to Company within 15 days, before submitting a complaint to the Information Commissioner. The Company will decide on the complaint as on a new request, within five working days of receipt.
GDPR shall take effect on the date of 10.04.2019.