Legal notice and cookies

I. Personal Data Protection Policy

This Personal Data Protection Policy (hereinafter: Privacy Policy) applies to all individuals whose personal data is processed by Neuhaus upravljanje d.o.o.

With the purpose of ensuring fair and transparent processing of your personal data Neuhaus upravljanje d.o.o. as the data controller has drawn up this Privacy Policy that allows individuals to obtain all the relevant information pertaining to their personal data in one place.

Neuhaus upravljanje d.o.o. respects your privacy and will only use your personal data for the purposes specified in this Policy. We will carefully protect your personal data in accordance with the legislation regulating personal data protection (especially Regulation (EU) 2016/679 (General Data Protection Regulation; hereinafter GDPR) and the applicable Personal Data Protection Act) and the internal rules on personal data protection of Neuhaus upravljanje d.o.o.

Neuhaus upravljanje d.o.o. implements all the necessary legal, organizational, logistical and technical procedures and measures for protecting personal data, be it itself based on internal rules, or through contractual partners, with which it has concluded appropriate contracts.

 

1. Personal data controller

Neuhaus upravljanje d.o.o., Kolodvorska ulica 6a, SI-1000 Ljubljana (hereinafter also Controller) is the data controller. If you want more information or have questions about the protection of your personal data, you can contact us at neu@neu-residences.com.

 

2. Types of personal data and the purpose of their processing

Neuhaus upravljanje d.o.o. collects and processes personal data based on data subjects’ consent and/or for the purpose of performing a contract and implementing pre-contractual measures and for the legitimate interest of the Controller.

2.1. Processing based on consent

Personal data processing may be based on data subject’s consent, which allows Neuhaus upravljanje d.o.o. to use the personal data for purposes specified in the consent, in particular for marketing activities, such as sending of information on the range of services, new products and benefits, and sending magazines, brochures and other promotional materials on the products and services of Neuhaus upravljanje, d.o.o. and its partners.

Based on consent, Neuhaus upravljanje d.o.o. collects and processes the following personal data:

• from individuals who are consumers: full name, email address, phone number, country of residence. We need the information on your country of residence so that we can send you the information in the appropriate language;
• from individuals who are not consumers (primarily company representatives): full name, email address, and phone number.

We will inform you using the contact information obtained from you.

The consent is given for the purposes specified therein, and applies until its withdrawal. When the data subject partly or fully withdraws their consent, we will no longer use the data for the purposes for which the withdrawal was made. If you wish to withdraw your consent, write to neu@neu-residences.com. Data subjects can always unsubscribe from messages through the same communications channel through which they receive those messages. Link for unsubscribing or to the information on how to unsubscribe is in every received message. We will enter the unsubscribe request in our system and start applying it immediately or within 5 days of receiving it at the latest.

If an individual does not give their consent to the processing of their personal data for the above listed purposes, or only gives a partial consent or partially withdraws the consent, the Controller will only send messages to them within the scope of the given consent and in ways permitted by the applicable law.

Concluding contracts for packages and/or booking an apartment at NEU Residences does not require giving consent to processing for marketing activities. The consent must be given voluntarily, and if an individual decides not to give their consent or to withdraw it later, this will not under any circumstances reduce their rights arising from the contract or result in additional cost or aggravating circumstances for them.

Neuhaus upravljanje d.o.o. will process personal data based on consent in accordance with the latest consent received from the data subject, regardless of the communication channel through which the consent was given.

2.2. Processing based on a contract

Neuhaus upravljanje d.o.o. collects and processes individuals’ personal data based on a concluded purchase contract for products and packages, as specified in the General Terms and Conditions and the apartment booking at NEU Residences.

Neuhaus upravljanje d.o.o. further collects and processes individuals’ personal data based on contracts concluded with its partners. Based on these contracts, Neuhaus upravljanje d.o.o. collects personal data of those individuals who are in any way needed for the implementation of the contract.

Personal data collected on this basis is required for the purpose of implementing concluded contracts (for the purpose of providing the above listed services and/or products) and pre-contractual measures and procedures. If such personal data is not provided or the data subject does not agree to its processing, these contracts cannot be concluded and the Controller has the right to withdraw from already concluded contracts.

(i) For the purpose of implementing contracts on the purchase of products and packages, Neuhaus upravljanje d.o.o. collects and processes the following personal data: full name, email address, phone number, country of residence, language settings.

(ii) For the purpose of implementing contracts on the booking of apartments at NEU Residences, Neuhaus upravljanje d.o.o. collects and processes the following personal data from individuals: full name, email address, phone number, address, country of residence, language settings.

(iii) For the purpose of implementing contracts with its partners, Neuhaus upravljanje d.o.o. collects and processes the following personal data of partner’s contact person: full name, email address, phone number. Based on these contracts, Neuhaus upravljanje d.o.o. may also collect other personal data as specified in an individual contract and needed for the implementation of the contract.

Neuhaus upravljanje d.o.o. does not collect numbers or other data pertaining to payment cards that the buyer provides via www.neu-residences.com websites. This data is only collected by payment service providers.

2.3. Processing for legitimate interests pursued by the Controller 

Neuhaus upravljanje d.o.o. may process your personal data based on legitimate interests, the existence and grounds for which are based on a careful assessment that these interests are not overridden by your interests or rights and freedoms and that you may reasonably expect only processing for that purpose when the data is collected. The following processing activities are performed on this basis: direct marketing, service satisfaction surveys, analyses and research for marketing purposes, operational planning, etc., prevention and restriction of abuse and fraud, filing of claims in court proceedings and similar.

Based on legitimate interest, we process your personal data obtained during the implementation of the contract and based on other grounds specified in this Policy.

 

3. Personal data recipients

Personal data recipients are employees of Neuhaus upravljanje d.o.o., responsible for processing in specific areas (sales, marketing, IT, etc.), who process personal data within the scope of and in accordance with granted authorizations.

Your personal data may also be processed by contracted processors as defined in the following clause.

 

4. Contracted personal data processing

Your personal data may be processed by contractors that provide services agreed in contracts, such as IT support services, document printing and mailing services, private debt collection services, sales and marketing services, etc. Contractors are obliged to meet the same standards of personal data protection as the Controller, and may only process the personal data on behalf of the Controller, and within the authorization given in the written contract or another legal document and in compliance with the purposes specified in this Policy.

 

5. Transfer of personal data to third countries

Neuhaus upravljanje d.o.o. will not transfer the collected personal data to third countries, except when we send you emails over the MailChimp platform. The personal data stored on this online platform consists of data for sending messages to facilitate contract implementation (full name, email address, phone number, country), sending messages on special offers and new products for business users (full name, email address, phone number, company), and sending messages on special offers and new products for individuals (full name, email address, phone number, country).
MailChimp undertakes to comply with GDPR rules in its General Terms and Conditions and Privacy Policy and confirms that it has obtained the certificate of compliance with EU-U.S. Privacy Shield Framework. This can be verified on list of certificate holders kept by the U.S. Department of Commerce and available at https://www.privacyshield.gov/list.

 

6. Automated decision-making

All decisions regarding contractual relationships and other decisions with legal and similar effects at Neuhaus upravljanje d.o.o. are made by employees or partners with suitable information support, and decision-making is not automated.

 

7. Data storage period

The storage period for personal data depends on the basis for processing and the purpose of processing the specific personal data category. Personal data will only be stored for the period necessary to achieve the purpose for which it is collected or processed. After the purpose of processing is achieved and if there is no other legal basis for processing and the data is not required for establishing, exercising or defending legal claims, the personal data will be deleted, destroyed, blocked or anonymized.

Personal data processed based on a contract will be stored for the period necessary for performing the contract and 5 years after the contract expires, unless a dispute arises between the data subject and our company in relation to said contract; in such cases, data will be stored for a period of 5 years after the court or arbitration decision or settlement becomes final, or, if no legal proceedings took place, for 5 years after the amicable resolution of the dispute. Invoices are stored for 10 years after the end of the year for which the invoice was issued in line with the law regulating value added tax.

Personal data collected based on consent for marketing activities is stored until the consent is withdrawn.

 

8. Individual’s rights

In accordance with applicable European and Slovenian regulations, we guarantee you the following rights regarding privacy and personal data protection:

• right to information on the processing of your personal data;
• right to access personal data, which means that you have the right to obtain from us, the Controller, the confirmation whether personal data concerning you is being processed, and when this is the case, access to this personal data and additional information (purpose of processing, type of personal data, data recipients, the existence of the right and the possibility of lodging a complaint, sources of data, the existence of automated decision-making or profiling);
• right to obtain a copy of processed personal data from the Controller, if there is legitimate interest;
• right to rectification, which means that you have the right to obtain from the Controller without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you also have the right to have incomplete personal data completed, including by means of providing a supplementary statement;
• right to erasure, which means that you have the right to obtain from the Controller without undue delay the erasure of personal data concerning you, when the following conditions are met (processing is no longer necessary, the consent was withdrawn and there is no other legal ground for the processing, there is a reasoned objection, the processing is unlawful, the data is erased based on legal grounds, etc.);
• right to restriction of processing, which means you have the right to obtain from us, the Controller, restriction of processing if you contest the accuracy of the data, or have lodged a complaint, or the processing is unlawful, or processing is no longer necessary for us as the Controller, but is required by the data subject for the establishment, exercise or defense of legal claims;
• right to information concerning rectification or erasure of data or restriction of processing, if your personal data was sent to another recipient or processor, unless this proves to be impossible or would involve a disproportionate effort;
• right to data portability means the right to receive the personal data concerning you that you have provided to the Controller, in a structured, commonly used and machine-readable format, and the right to transmit that data to another controller without hindrance, when processing is based on consent or contract and the processing is carried out by automated means;
  right to object means you have the right to object at any time to certain types of processing of your personal data (public interest, Controller’s legitimate interest, marketing purposes), and the Controller must demonstrate compelling legitimate grounds for the processing or stop processing that data;
• right concerning automated processing and profiling means that you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similar effects concerning you, unless this is necessary, prescribed or based on your consent.

Data subjects may exercise the above listed rights by sending a written request by e-mail to neu@neu-residences.com or by regular mail to the Controller’s address, marked “personal data”.

The Controller shall provide information on actions concerning the processing of your personal data at your request under Articles 15 to 22 of GDPR, without undue delay and in any event within one month of receiving the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. The Controller shall inform you of any such extension within one month of receiving your request, together with the reasons for the delay. If you make the request in electronic form, we will provide in the same form where possible, unless you request otherwise.

In the case of a personal data breach that is likely to result in major risk to your rights and freedoms, we will inform you about the personal data breach without undue delay.

If you believe your rights or personal data protection regulations are being violated, you can lodge a complaint with the Information Commissioner of the Republic of Slovenia by mail to Dunajska cesta 22, SI-1000 Ljubljana or by email: gp.ip@ip-rs.si.

 

9. Additional information when the data is not obtained from the data subject

Personal data that was not obtained directly from the data subject is available from Neuhaus upravljanje d.o.o. at data subject’s request. The data subject has the right to obtain all the available information regarding its source.

 

II. Cookies

Cookies set on your browser anonymously collect certain information on your visit to the website. They allow us to ensure all website functionalities, personalize certain content and improve the website by analyzing visits.

• Required cookies – set always
  These cookies enable essential functionalities of the website, such as navigation and access to certain parts of the website. The website cannot function fully without these cookies. These cookies include cookies for modifying the performance and layout of the website upon future visits, e.g. display in the selected language.
• Statistics cookies – accept/reject
  Statistics cookies anonymously collect and send information to website owners. They help us understand how visitors use the website and improve user experience based on this information.
• Advertising and profiling cookies – accept/reject
  Advertising cookies anonymously collect data on your website visits. They are used by advertisers to show you ads that are relevant and interesting for you. They are also used to prevent the showing of ads that you already saw.

Required Cookies

The required cookies make the site useable, as they ensure basic features such as page navigation and access to secure areas of the website. Without these cookies, the website does not function properly.

Cookies for Monitoring Statistics

Statistics cookies help website owners to understand how visitors use the website by collecting and reporting information anonymously.

III. Validity

This Privacy and Cookie Policy of Neuhaus upravljanje d.o.o. will be amended as necessary, with all the amendments published on the website.

This Policy shall be published on www.neu-residences.com and comes into effect on 1 March 2022

Neuhaus upravljanje d.o.o.
Ljubljana, 1 March 2022

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