I. INITIAL PROVISIONS

1. Introduction

1.1 We are committed to protecting the privacy of visitors and users of 2mobile.si website and our customers. This Notice explains how we handle your personal data.

1.2 This Notice applies in all cases where we act as a data controller, which means the instances where we determine the purposes and means of processing of personal data.

1.3 Our website may use certain cookies. In cases where the use of cookies is not strictly necessary for provisioning the website, we will ask for your consent to the use of cookies. You can find more information about cookies in Section III of this Privacy and Cookie Notice and by clicking on the shield icon found in the bottom left corner of the website: 

1.4 "We", including "us" and "our", shall refer to 2Mobile d.o.o., Dunajska cesta 106, 1000 Ljubljana, Slovenia, registration number: 6125123000, VAT ID: SI 82898286. For more information about 2Mobile d.o.o., please visit About us (2mobile.si) section of our website.

1.5 "You", including "your", shall refer to the visitor or user of the 2mobile.si website or the user of our services.

II. PRIVACY NOTICE

2. How do we use your personal data?

2.1 This section contains information about:

2.2 Chatbot: We process information that you provide to us (e.g. first name, last name, phone number, email address) or that is collected automatically using essential cookies - LivePerson tag (your IP address, IP location, browser type and version, operating system, referring URL, length of chat, time data, frequency and pattern of chatbot use). We process data for the purpose of communicating with you, providing you with relevant information regarding your enquiry and improving your user experience. The legal basis for this processing is our legitimate interest.

2.3 Messages: We process the information you provide in the messages you send to us through (i) the contact form on our website or (ii) emails sent to info@2mobile.si or (iii) telephone. We obtain the data directly from you and process it for the purpose of providing information related to your message or enquiry. The legal basis for this processing is our legitimate interest. 

2.4 Customer relationships: We process information about our customer relationships, including contact information. The information may include your first name, last name and contact details, your job title, customer details (your employer) and details of communication between us. We obtain the data directly from you or our customer (your employer) and process it for the purposes of managing our customer relationships, communicating with the customer, recording data about communications and marketing our services. The legal basis for this processing is our legitimate interest.

2.5 Newsletter sign-up: On our website, you can sign up to receive our newsletter by submitting your email address and indicating that you agree to receive the newsletter by email. You then confirm your consent to receive the newsletter by clicking on a confirmation link sent to your email address. In this case, we process your email address. We obtain the data directly from you and process it for the purpose of informing you about our offers and services. The legal basis for this processing is your consent. You can unsubscribe from the newsletter using the unsubscribe link included at the end of each newsletter. 

2.6 We may also process the personal data specified in this Notice to establish, exercise or defend legal claims, whether in judicial, administrative or extrajudicial proceedings. The legal basis for this processing is our legitimate interest, namely the protection and defence of our rights, your rights and the rights of third parties.

2.7 We may also process the personal data specified in this Notice for the purpose of risk management or obtaining an expert opinion. The legal basis for this processing is our legitimate interest, namely the protection of our business against risks.

2.8 In addition to the purposes of processing explicitly set out in this section, we may also process your personal data, where necessary, to fulfil our legal obligations.

3. Disclosure of personal data to third parties

3.1 We may disclose your personal data to our professional advisors where reasonably necessary to obtain their professional opinion or for risk management purposes.

3.2 We may also disclose your personal data to our contractors or contractual partners who carry out specific data processing tasks for us, such as the development and maintenance of software and IT systems, hosting services, accounting and other administrative services, website hosting, and the provision of mass email and newsletter infrastructure, when these tasks involve the processing of personal data to the necessary extent.

3.3 We may also disclose your personal data to third parties when this is necessary to perform our legal obligations or to establish, exercise or defend our legal claims, whether in judicial, administrative or extrajudicial proceedings.

4. Transfer of personal data to third countries

4.1 When processing personal data in third countries, i.e. countries outside the European Economic Area (EEA), we will ensure that the transfer of personal data is subject to the legal bases defined in the applicable regulations, namely

• an implementing act of the European Commission on the adequacy of protection in a third country;
• binding corporate rules, in accordance with the General Data Protection Regulation, if duly approved;
• standard data protection provisions;
• other mechanisms permitted by the GDPR.

5. Retention and deletion of personal data

5.1 In this chapter, we inform you about our policy on the retention and deletion of personal data, which ensures that the retention of personal data complies with the applicable regulations.

5.2 We keep personal data for no longer than is necessary to fulfil the purpose of their processing.

5.3 Personal data retention periods:

(a) Chatbot data: 13 months since the chat.

(b) Data from messages: a maximum of 5 years after the end of the year in which the message was sent.

(c) Customer relationship data: throughout the duration of the relationship and for 5 years after the end of the year in which the relationship ended.

(d) Newsletter subscription data: for the duration of the newsletter subscription and for another 3 months after we stop sending the newsletter or immediately if you withdraw your consent. 

After the period set out above expires, your personal data will be deleted.

5.4 Notwithstanding the above provisions on the retention term, we may store personal data longer when this is necessary to comply with our legal obligation.

6. Your rights

6.1 In this chapter, we inform you of your rights under the applicable data protection regulations.

6.2 Your rights consist of:

(a) the right of access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object;

(f) the right to data portability;

(g) the right to lodge a complaint with the Information Commissioner;

(h) the right to withdraw consent.

6.3 As part of the right of access, you may ask us to confirm whether we are processing personal data about you and, if so, to provide you with access to your personal data and certain additional information about the processing of your personal data, such as information about the purposes of the processing; the categories of personal data we are processing; and the recipients of the personal data. Provided that this does not interfere with the rights and freedoms of others, we will provide you with a copy of your personal data. We will provide you with the first copy free of charge, and a reasonable fee will be charged for any additional copies.

6.4 Under the right of rectification, you may request the rectification of incorrect or inaccurate personal data relating to you or the completion of incomplete data, where the completion is compatible with the purpose of processing.

6.5 In certain circumstances, you may request us to delete your personal data without undue delay. These circumstances are, for example: the personal data are no longer necessary for the purposes for which they were collected or processed; you have withdrawn your consent to the processing where consent was the legal basis for the processing; you object to the processing and there are no overriding legitimate grounds for the processing; the processing is carried out for direct marketing purposes; your personal data have been processed unlawfully. However, there are certain exceptions to the right to erasure. Erasure shall not be possible, inter alia, where the processing of personal data is necessary for: the exercise of the right to freedom of expression and information; the performance of a legal obligation; the establishment, exercise or defence of legal claims.

6.6 In certain circumstances, you have the right to request the restriction of the processing of your personal data. These circumstances are, for example: you contest the accuracy of the data for the period of time that allows us to verify the accuracy of your personal data; the processing is illegal and you object to the erasure of the personal data and instead request only the restriction of its use; we no longer need your personal data for the purposes of the processing and you need it to assert, exercise or defend legal claims; you have lodged an objection regarding the processing and we are verifying whether our legitimate reasons outweigh yours. In case of a restriction of processing, we may continue to store your personal data. We may process them in other ways only in the following instances: with your consent; where necessary to establish, exercise or defend legal claims; where necessary for the protection of the rights of another natural or legal person; for imperative reasons of overriding public interest.

6.7 You have the right to object to the processing of your personal data on grounds relating to your particular situation, where the processing is based on our legitimate interests or the legitimate interests of a third party. In this case, the right is not absolute. We are obliged to stop the processing, unless we can demonstrate necessary legitimate reasons for processing which override your interests, rights and freedoms or where processing is necessary to establish, exercise or defend legal claims.

6.8 In any case, you can object to data processing (including profiling) for direct marketing purposes. If we receive an objection, we are obliged to immediately cease processing data for direct marketing purposes.

6.9 Where the legal basis for processing your personal data is:

(a) your consent; or

(b) the implementation of an agreement between you and us or activities that you have requested we take before the agreement is concluded,

and the processing is carried out by automated means and we have received the data directly from you, you have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format. Nevertheless, you cannot exercise this right if doing so could have negative consequences for the rights and freedoms of others.

6.10 If you believe that our processing of your personal data violates data protection regulations, you have the right to lodge a complaint with the Information Commissioner. You may lodge a complaint in the EU member state where you live or work, or where the infringement took place.

6.11 Where the legal basis for processing your personal data is your consent, you have the right to withdraw your consent at any time. Withdrawal of your consent will not affect the lawfulness of the processing of personal data carried out before the consent was withdrawn.

6.12 You may notify us in writing if you wish to exercise any of your rights. We always have the right to verify your identity and we will take reasonable steps to do so.

6.13 We will respond to your requests to exercise your rights as soon as possible, and no later than within the time limits set by data protection regulations.

7. Third party websites and applications

7.1 Our website may contain links to or information about websites or applications managed by third parties. Access to and use of third-party websites or applications is subject to the terms and conditions set out by the provider of the relevant website or application.

7.2 We are not familiar with and have no influence over the personal data protection policies and practices of such third parties. We suggest that before you visit such a website or use such an application, you read and understand the privacy policies and practices that apply to it.

8. Personal data of minors

8.1 Our website and our services are intended for persons over the age of 18 and we do not knowingly process personal data of persons under the age of 18.

8.2 If you have reason to believe that we are processing data about a person under the age of 18, please inform us.

9. Updating personal data

9.1 Please let us know if there is any change in your personal data. Upon receipt of your notification, we will correct the personal data in our records accordingly.

III. COOKIES

10. About cookies

10.1 A cookie is a file containing an identifier (a sequence of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is sent back to the server whenever the browser requests access to a site hosted on the server.

10.2 Cookies can be either "persistent" or "session": a persistent cookie is stored by the web browser and remains valid until the set expiry date, unless the user deletes it before then; a session cookie remains valid only until the end of the user's individual session, until the user closes the browser.

10.3 Cookies do not include personally identifiable information; however, the personal data we store about you may be linked to data obtained from cookies.

11. Cookie types

11.1 Strictly necessary cookies

These cookies do not store personal data but are necessary for the operation of the website and cannot be turned off on our systems. They are usually set up only in response to user actions and used to store information, such as the user's privacy settings.

11.2 Functional cookies



Cookies that we use for the purpose of improving the user experience. The information we obtain from cookies helps us understand how visitors use the website, based on which we can make decisions about making functional and content adjustments.

11.3    Analytical cookies

Site visit analysis cookies collect anonymised information about your visit to the website. The information we obtain from these cookies helps us understand how visitors use the website. Based on these statistics, we decide on general improvements to the website's functionality and content.

11.4 Cookies for marketing and usage analysis

These cookies are set by our advertising partners and partners who enable us to analyse browsing on selected subpages of the website (heat-mapping). With the help of these cookies, advertising partner companies can detect what you are interested in and can then show you relevant content on other websites. If you do not accept these cookies, the ads you see online will not be tailored to your interests.

11.5 Cookies for social networks

These cookies are set by the social network providers we have added to this website. The cookies allow you to share content with your friends and networks. They track your browser as you browse websites and build a profile of your interests. This influences the content and messages you see on the websites you visit. If you refuse the use of cookies, content sharing tools may not be available to you.

12. Changing your cookie settings

12.1 You consent to the use of cookies when you first visit the website. By clicking "Accept all" you agree to the setting of essential cookies, functional cookies, analytical cookies, cookies for marketing and usage analysis and social media cookies.

12.2 If you wish to manage your cookie settings, you can do so on your first or any subsequent visit to the website by clicking on the shield icon in the bottom left corner of the website: 

12.3 If you do not accept some cookies, some parts of the website or some services may not work properly.

13. About us

13.1 The owner and operator of www.2mobile.si is 2Mobile, svetovanje in posredovanje, d.o.o.

13.2 2Mobile d.o.o. is a company registered in Slovenia, with registration number 6125123000 and registered office at Dunajska cesta 106, 1000 Ljubljana.

13.3 You can contact us:

(a) by post to the address given in the previous section;

(b) by email to info@2mobile.si;

(c) using the chat functionality of our website;

(d) using the online form on our website.

14. Language

14.1 These Terms and Conditions are drafted in Slovenian and English. In the event of any inconsistency between the two versions, the Slovenian version shall prevail and be considered the original.

15. Amendments

15.1 We may change this Privacy and Cookie Notice by posting a new or amended notice on the 2mobile.si website.

15.2 We suggest that you check the content of the notice from time to time to keep up to date with any changes.

15.3 This Privacy and Cookie Notice is effective as of 30 September 2022 and fully replaces the Personal Data Protection Policy of 18 December 2020. This Privacy and Cookie Notice has been updated on 15 February 2023.

2Mobile d.o.o.