Owner and Data Controller
EMA d.o.o., Teharje 7B, 3000 Celje, Slovenia - EU
Owner contact email: firstname.lastname@example.org
Policy key definitions
"I", "our", "us" or "we" refer to the business, (EMA Group, BlueTraker & other trading names), "you", "the user" refer to the person(s) using this website. GDPR means General Data Protection Act. Cookies mean small files stored on a users computer or device.
The legal basis of processing
Under GDPR EMA Group may process Personal Data relating to Users if one of the following applies:
- Users have given their free, specific, informed, and unambiguous consent for marketing content subscription (e.g. periodical newsletter)
- Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof
- Processing is necessary for compliance with a legal obligation to which the Owner is subject
- Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner
- Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party
EMA Group will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Types of data collected
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website. Among the types of Personal Data that this website collects, by itself or through third parties, there are:
- Email Address, First Name and Last Name (freely provided by the user via subscription forms on this Website)
- Usage Data and Cookies (collected automatically when using this Website).
Processing of your personal data
EMA Group takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the user Data. The Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the EMA Group, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the EMA Group. An updated list of these parties may be requested from the EMA Group at any time.
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located. Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data below.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:
Personal Data collected for purposes related to the performance of a contract between the Owner, and the User shall be retained until such contract has been fully performed.
Personal Data collected for the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn.
Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow EMA Group to provide its Services, as well as for the following purposes: Direct marketing, Analytics, Backup saving and management and Contacting the User. Users can find further detailed information about such purposes of processing and the specific Personal Data used for each purpose in the respective sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Mailing list, marketing messages or newsletter (this Website)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Website. Although EMA Group websites do not require users to sign up for a login, in the future your email address might also be added to this list as a result of signing up to this Website or after making a purchase.
Under the GDPR EMA Group uses the lawful consent basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the "Types of data" section above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third party service provider of software/applications that allows us to send out email marketing campaigns to a list of users/subscribers.
Our EMS provider is MailChimp. Please check their respective »Privacy for contacts« policy.
Email marketing messages that we send may contain tracking beacons/tracked clickable links or similar server technologies to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as times, dates, IP addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations, will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with the GDPR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any marketing messages (for example a footer of a Newsletter) for instructions on how to unsubscribe or manage your preferences; you can also unsubscribe here, otherwise, contact the EMS provider.
Personal Data collected: First name, Last name, Email Address, country, IP Address, Date and Time of subscription
- Contact form (this Website)
By filling in the contact form with their Data, the User authorizes this Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: First name, Last name, Email address, Country, Industry, Job Title and Position.
- Google Analytics (Google Inc.)
The services contained in this section enable EMA Group to monitor and analyze web traffic and can be used to keep track of User behaviour. Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data.
- Backup saving and management
This type of service allows EMA Group to save and manage backups of this Website on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to this Website. The Data is saved and backed up at the Owner's operating offices and in any other places where the parties involved in the processing are located. EMA Group might use third party services such as Google Drive and DropBox.
The rights of Users
Users may exercise certain rights regarding their Data processed by the EMA Group. Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with EMA Group to find out which rights apply to them. In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to the processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, EMA Group will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the EMA Group.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to the processing
Where Personal Data is processed for the public interest, in the exercise of an official authority vested in the Owner or for the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to EMA Group through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by EMA Group as early as possible and always within one month.
Applicability of broader protection standards
While most provisions of this document concern all Users, some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards. Such broader protection standards apply when the processing:
- is performed by an Owner based within the EU
- concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users
- concerns the Personal Data of Users who are in the EU and allows the Owner to monitor such Users’ behaviour taking place in the EU
- Additional information about Data collection and processing
The User's Personal Data may be used for legal purposes by EMA Group in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services. The User declares to be aware that EMA Group may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from EMA Group at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
This Website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed by the User’s consent, EMA Group shall collect new consent from the User, where required.
What are cookies?
Some cookies ensure that certain parts of the website work properly and that your user settings remain known. By installing urgent cookies, we make it easier for you to visit our website. This way, you do not have to enter the same information more than once while visiting our website. We may set these cookies without your consent.
Tracking cookies are cookies or any other form of local storage used to create user profiles to display advertising or to track a user on this website or on multiple websites for similar marketing purposes.
Consent to cookies
Types of cookies we use:
|Cookie name||Purpose||Duration||Used by|
|_ga||For monitoring and tracking web analytics||2 years||Google Analytics|
|_gat||For monitoring and tracking web analytics||1 minute||Google Analytics|
|_gid||For monitoring and tracking web analytics||1 day||Google Analytics|
|moove_gdpr_popup||Current GDPR Cookie Compliance session to monitor cookie settings and notifications||Current session||GDPR Cookie Compliance|
Web Analytics - Google Analytics
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Celje, May 25th, 2018