Privacy Policy | 2Mobile

I. INTRODUCTORY PROVISIONS

1. Introduction

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

1.2 This notice applies in all cases where we act as a controller of personal data - that is, in cases where we determine the purposes and means of processing personal data.

1.3 We may use certain cookies on our website. In cases where the use of cookies is not strictly necessary for the provision of the website, we will ask you for your consent to the use of cookies. You can read more about cookies in Chapter III of this Privacy and Cookies Notice and by clicking on the fingerprint icon located in the lower left corner of the website:

White fingerprint icon inside a blue circle.

1.4 "We", including "us", "to us", "at us", "with us" are the company 2Mobile doo, Dunajska cesta 106, 1000 Ljubljana, Slovenia, registration number: 6125123000, tax number: SI 82898286. More information about the company 2Mobile doo is available at About us (2mobile.si).

1.5 "You" including "you", "to you", "at you", "with you" are a visitor or user of the 2mobile.si website or a user of our services.

II. PRIVACY NOTICE

2. How do we use your personal data?

2.1 In this chapter we will introduce you to:

Table with icons and text about personal data processing: categories, source, purpose, and legal basis.

2.2 Chat via chatbot: We process the data that you provide to us in your message sent via (i) the contact form published on our website or (ii) email to support@2mobile.si or (iii) by phone. We obtain the data directly from you and process it for the purpose of providing information related to your message or inquiry. The lawful basis for this processing is our legitimate interests.

Table with four rows: data, sender, information, and legal interests, each with text and an icon.

2.3 Customer relationships: We may process data about our customer relationships, including contact details. The data may include your name, surname and contact details, your job title, details about the customer (your employer) and data about mutual communication. We obtain the data directly from you or the customer (your employer) and process it for the purpose of managing our customer relationship, communicating with the customer, recording communication data and presenting our services. The lawful basis for this processing is our legitimate interests.

Table with icons and text: contact details, employer, communication, marketing.

2.4 Newsletter subscription: On our website, you can subscribe to receive the newsletter via the online form by providing us with your email address and indicating that you agree to receive the newsletter by email. You also confirm your agreement to receive the newsletter via the confirmation link that we send 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 offer and services. The legal basis for this processing is your consent. You can unsubscribe from receiving the newsletter via the unsubscribe link available at the end of each newsletter.

2.5 We may also process the personal data specified in this notice for the establishment, exercise or defence of legal claims, whether in judicial, administrative or extrajudicial proceedings. The lawful basis for this processing is our legitimate interests, namely the protection and safeguarding of our rights, your rights and the rights of third parties.

2.6 We may also process the personal data specified in this notice for the purpose of risk management or obtaining professional advice. The lawful basis for this processing is our legitimate interests, namely protecting our business from risks.

2.7 In addition to the processing purposes explicitly set out in this section, we may also process your personal data where this is necessary to comply with our legal obligation.

3. Transfer of personal data to third parties

3.1 We may disclose your personal information 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 perform individual 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 providing infrastructure for mass sending of emails and newsletters, 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 where this is necessary to comply with our legal obligation or where this is necessary to assert, exercise or defend legal claims, in judicial, administrative or extrajudicial proceedings.

4. Export of personal data to third countries

4.1 In the event of processing personal data in third countries, i.e. countries outside the European Economic Area (EEA), we will ensure that the legal basis for the transfer of personal data is provided as specified in applicable regulations, namely:

European Commission implementing act on the adequacy of protection in a third country;
Binding Corporate Rules, in accordance with the General Data Protection Regulation, if they are duly approved;
standard data protection clauses;
another mechanism permitted by the General Data Protection Regulation.

5. Storage and deletion of personal data

5.1 In this section, we inform you of our personal data retention and deletion policy, which ensures that the retention of personal data is in accordance with applicable regulations.

5.2 We store personal data for no longer than necessary to fulfill the purpose of their processing.

5.3 Personal data retention periods:

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

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

(c) Data from newsletter subscriptions: for the entire duration of your newsletter subscription and for 3 months after we stop sending you the newsletter or immediately if you withdraw your consent.

After the period specified above, your personal data will be deleted.

5.4 Notwithstanding the above provisions on retention periods, we may retain personal data for a longer period of time where this is necessary to comply with our legal obligation.

6. Your right hand

6.1 In this section, we inform you of the rights you have under applicable personal data protection regulations.

6.2 Your rights are:

(a) right of access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restriction of processing;

(e) the right to object;

(f) the right to portability;

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

(h) the right to withdraw consent.

6.3 Within the framework of the right of access, you may request from us confirmation as to whether we are processing personal data concerning you and, if so, to provide you with access to your personal data and certain additional information about the processing of personal data, such as information on the purposes of the processing; the categories of personal data that we process and the recipients of the personal data. Provided that this does not prejudice the rights and freedoms of other persons, we will provide you with a copy of your personal data. We will provide you with the first copy free of charge, and for any additional copies we will charge you a reasonable fee.

6.4 Within the framework of the right to rectification, you can request the correction of incorrect or inaccurate personal data relating to you or the completion of incomplete data, where the completion is consistent with the purpose of their processing.

6.5 In certain circumstances, you may request that we erase your personal data without undue delay. These circumstances include, 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 lawful basis for the processing; you object to the processing and there are no overriding legitimate grounds for the processing; where the processing is carried out for the purpose of direct marketing; your personal data have been processed unlawfully. There are certain exceptions to the right to erasure. Erasure is not possible, among other things, where the processing of personal data is necessary: to exercise the right to freedom of expression and information; to comply with a legal obligation; to assert, exercise or defend legal claims.

6.6 In certain circumstances, you have the right to request the restriction of the processing of your personal data. These circumstances include, for example: you contest the accuracy of the data, for a period enabling us to verify the accuracy of your personal data; the processing is unlawful and you oppose the erasure of the personal data and instead request the restriction of their use; we no longer need your personal data for the purposes of the processing, but you need them for the establishment, exercise or defence of legal claims; you have objected to the processing and we are verifying whether our legitimate grounds override your grounds. In the event of restriction of processing, we may continue to store your personal data. We may otherwise process them only: with your consent; where this is necessary for the establishment, exercise or defence of legal claims; where this is necessary to protect the rights of another natural or legal person; for reasons of important 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 demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or where the processing is necessary for the establishment, exercise or defence of legal claims.

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

6.9 In cases where the lawful basis for processing your personal data is:

(a) your consent; or

(b) the performance of a contract between you and us or the taking of steps, at your request, prior to entering into a contract,

and the processing is carried out by automated means and we have received the data directly from you, you have the right to request that we provide you with your personal data in a structured, commonly used and machine-readable format. However, you cannot exercise this right if this could have negative consequences for the rights and freedoms of other persons.

6.10 If you believe that our processing of your personal data infringes data protection regulations, you have the right to lodge a complaint with the Information Commissioner. You can lodge a complaint in the EU Member State in which you reside or work or in which the infringement occurred.

6.11 Where the lawful basis for processing your personal data is your consent, you have the right to withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of the processing of your personal data carried out by us prior to its withdrawal.

6.12 You may exercise any of your rights by notifying us in writing. In all cases, we have the right to verify your identity and will use reasonable measures to do so.

6.13 We will respond to your requests regarding the exercise of your rights as soon as possible, and at the latest within the deadlines set by regulations in the field of personal data protection.

7. Third-party websites and applications

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

7.2 We are not aware of, and have no control over, the privacy policies and practices of such third parties. We encourage you to review the privacy policies and practices of such third parties before visiting such websites or using their applications.

8. Personal data of minors

8.1 Our website and our services are intended for persons over the age of 18, and under no circumstances do we 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 notify us if any of your personal information changes. Upon receipt of your notification, we will amend the personal information 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 a web server sends to a web browser and the browser stores it. The identifier is sent back to the server whenever the browser requests access to a page 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 validity period expires, unless the user deletes it beforehand; a session cookie remains valid only until the end of the individual user session, until the user closes the browser.

10.3 Cookies do not include information that would allow the identification of individuals; however, the personal information we hold about you may be linked to information obtained from cookies.

11. Types of cookies

11.1 Strictly Necessary Cookies

The cookies we use are essential cookies when they are strictly necessary to enable the core functionality of our service. The description, purpose, retention period and other information about essential cookies can be accessed by clicking on the fingerprint icon located in the lower left corner of the website:

11.2 Functional cookies

Cookies that allow us to analyze user behavior for the purpose of measuring and improving performance are functional cookies. The description, purpose, retention period and other information about functional cookies are accessible by clicking on the fingerprint icon located in the lower left corner of the website:

11.3 Marketing cookies

Marketing cookies are used by advertisers to display ads that are relevant to your interests. The description, purpose, retention period and other information about marketing cookies can be accessed by clicking on the fingerprint icon located in the lower left corner of the website:

12. Changing cookie settings

12.1 You consent to the use of cookies upon your first visit to the website. By clicking "Accept all", you agree to the setting of strictly necessary cookies, functional cookies, analytical cookies, marketing and browsing analysis cookies, and social media cookies.

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

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

13. Our data

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

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

13.3 You can contact us:

(a) by post to the address specified in the previous point;

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

(c) via chat on our website;

(d) via an online form on our website.

14. Language

14.1 These terms and conditions are drawn up in Slovenian and English. In the event of any inconsistency between the versions, the Slovenian version shall prevail and shall be deemed to be the original.