General conditions of protection of personal data Unija d.o.o.

1 Introduction

We at Unija, pay special attention to the protection of personal data. With the help of this privacy policy, we want to inform the general public about the nature, scope and purpose of the personal data that we collect, use and process. In addition, individuals are informed about their rights.

Unija, as a processor and manager, has implemented a number of technical and organizational measures to ensure the best protection of personal data, that we gather. The collection and processing are regulated in accordance with the General Data Protection Regulation (GDPR) and in accordance with nationally determined and regulated data protection regulations. However, data transmissions over the Internet may contain security gaps, so absolute protection may not be guaranteed. In case of doubt, we invite you to inform us about any questions that may arrise.

2 Definitions

1. A) Personal data
   Personal data is all information about a specified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors characteristic of a physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
2. B) Data subject
   An individual to whom the data relates is in any form recognized or identifiable natural person whose personal data is collected and processed by the collector and processor.
3. C) Data processing
   Processing is any operation or set of operations carried out on personal data or on groups of personal data, regardless whether it is carried out automatically, meaning collection, recording, organization, structuring, storage, adaptation or modification, retrieval, disclosure by transmission, dissemination or otherwise making available, matching or combination, restriction, deletion or destruction.
4. D) Consent
   The consent of an individual to whom the personal data relates, is any freely given, concrete, informed and unambiguous indication of the desire of the individual who, by means of a statement or a clear affirmative measure, agrees to the processing of personal data relating to him/her.

3 Name and address of the processor and operator

Manager or the processor for the purposes of the General Data Protection Regulation (GDPR), other data protection legislation applicable in the member states of the European Union and other provisions related to data protection is:

Unija d.o.o.
Tržaška cesta 515
1351 Brezovica pri Ljubljana
Telephone: +386 1 360 20 00
E-mail:  info@unija.com
Website:  www.unija.com

We are available for all information and explanations at info@unija.com .

4 Cookies

Cookies are small text files on your computer, that store information about how often you visit our site and what interests you during those visits. Cookies do not contain any personal data or information that could identify you.

Why are cookies necessary?

With the help of cookies, we can provide you with a better user experience on the website. Thus, e.g. cookies record your preferences and settings, entries in online forms and information for registered users. Even basic e-business functions would not be possible without cookies. In online stores, the products in the shopping basket, popular products, other purchase data, etc., are recorded in cookies. With the help of cookies, we can record website statistics, so we can more easily detect and eliminate possible errors and offer you better content or more suitable offer. Some cookies are absolutely necessary for the website to function, while others can only be stored, if you agree. On our site, we consider only those cookies that relate to saving the selected language to be necessary.

Necessary cookies

These cookies are absolutely necessary to provide services available on our website and to use some of its functions (language selection).

You can always block or delete cookies by changing your browser settings and forcibly blocking all cookies on this website. However, the website will remind you to accept/reject cookies each time you visit it. If you block cookies, this will affect how our website works.

Analytics cookies (optional)

Target cookies (optional)

Functional (necessary) cookies

Change existing settings – you have a settings icon on the bottom left

Disabling cookies

Most web browsers accept cookies automatically. You can turn off cookies at any time in your browser settings. Information about cookie settings in individual browsers is available at the links below:

• Chrome
• Firefox
• Internet Explorer
• Opera
• Safari

If you turn off cookies, the website will not function optimally or some functionalities will be disabled. Even when all cookies are turned off, the browser will still obtain certain information that is necessary for the basic functioning of our website.

5 Collection of general data and information

Our website collects a range of general data and information when an individual visits the website. This general data and information is stored in server log files. The following can be collected:

• the type and version of the browser used,
• the operating system used by the access system,
• the website from which the access system reaches our website (so-called referrers),
• sub-national websites,
• date and time of access to the website,
• Internet Protocol address (IP address),
• access system internet service provider and
• any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, Unija does not obtain any specific data about the individual. Instead, this information is needed to:

• correct delivery of our website content,
• optimizing the content of our website, as well as its advertisements,
• ensuring the long-term viability of our information technology systems and website technology, and
• providing law enforcement authorities with information necessary for law enforcement in the event of a cyber attack.

6 Contact forms on the website

Unija’s website contains contact forms that enable quick electronic contact with the company. If an individual decides to contact us via the contact form, the personal data provided on the form is automatically saved. Such personal data is stored by the data controller for the purpose of processing or establishing contact with the person to whom the data relates to. This personal data is not passed on to third parties.

The recipient of e-notifications can cancel the application to which the data relates at any moment. The consent to the storage of personal data, which the individual has confirmed for sending e-notifications, can be revoked by the individual anytime. To withdraw consent, a corresponding link is available in each e-notification. Also, the individual can notify the data controller directly of the opt-out in another way (written, electronic or verbal).

6.1 Registration for e-news

On Unija’s website, users have the option to subscribe to our monthly e-newsletter, where they can obtain useful information and advice in the fields of accounting, finance, taxes and personnel.

With the help of e-notifications, Unija periodically informs its recipients, who have agreed to receive e-notifications/e-news, about new services and current events that it organizes.
Notifications are only received by the data subject, if:

• subject has a valid email address, and
• the individual to whom the data relates registers to receive e-notifications and e-news.

Unija will use the data obtained from users for the following purposes:

• informing and sending e-news, articles, event notifications via e-mail,
• direct marketing and sending offers via e-mail, regular mail, on the website or by making telephone calls,
• segmentation and automated processing with the aim of creating customized messages and offers that will be more relevant to the user,
• statistical and market analyses, tracking e – mail clicks and openings, website clicks to segment and customize e – mail content,
• displaying customized ads on advertising platforms (Google and Facebook).

6.2 Application for a vacant position

On Unija’s website, users have the option to apply for a job vacancy or to apply to the jobseeker database.

Unija will use the data obtained from users for the following purposes:

• notification regarding applying for a vacant position;
• notification of vacancies;
• displaying customized ads on advertising platforms (Google and Facebook).

By applying for a job vacancy and submitting supporting documentation (resume, cover letter, etc.), the individual agrees to the processing of the submitted data, until canceled by the candidate.

7 Participation in events

1. A) General provisions
   The general conditions govern the purpose and conditions under which the events organized by Unija will take place, method of registration for them, conditions of participation and procedure for possible withdrawal from an individual event before its conduction. The organizer of the event is Unija.
   The general terms and conditions are an integral part of the registration for each event. An individual who registers for any event fully, irrevocably and unconditionally accepts these general conditions published on the Unija’s website.
2. B) Registration for the event
   Registration for the event is done by filling out the registration form on the Unija’s website, where the individual must provide their information (name, surname, company and e-mail address). By entering these data, the individual guarantees that they are true, correct and complete. Pre-registration for the event is mandatory, as the number of places is limited.
   By registering, the individual also agrees and allows the organizer to record and/or photograph the event and to publish the footage publicly after the event.
3. C) Cancellation of the event by the organizer
   The organizer reserves the right to adjust the content of the event and, in case of insufficient number of interested parties, force majeure or other reasons, to adjust the time or location of the event or cancel it. The organizer will inform those registered for the event about a possible cancellation no later than the day before the event, namely via e-mail to the e-mail address that the individual provided in the registration for the event or by calling the indicated telephone number.
4. D) Use of personal data
   The operator of the collection of personal data collected in the context of registration for the event, or otherwise within the context of the event, is the organizer. Organizer undertakes to carefully store and use all received personal data specified in the application form in accordance with the Protection Act personal data (ZVOP-1) for the purpose for which they were obtained. Organizer will not forward them to third parties. Purposes are defined on the online application form.

8 Deletion and blocking of personal data

The data controller processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of storage, if authorized by the European legislator or other legislator in the laws or regulations that concern the controller. If the purpose of storage is not specified or is not suitable, or if the period for storage prescribed by the European legislator or other competent legislator expires, personal data is routinely blocked or deleted in accordance with legal requirements. Of course, deletion is also possible at the request of the individual to whom the personal data relates.

9 Individual rights

1. A) The right to confirmation
   Every individual has the right to obtain information from the controller on whether personal data relating to him or her is being processed or not. If an individual wants to use this right, he can contact the contact persons (employees) at the company at anytime.
2. B) Right of access
   Every individual has the right to obtain a copy of personal data that is stored at any given moment. In addition, European directives and regulations allow access to the following information for persons whose data is stored:

• purpose of processing,
• categories of personal data in question,
• recipients or categories of recipients for whom personal data has been or will be disclosed, in particular recipients in third countries or international organizations,
• where possible, the estimated period during which the personal data will be stored, or if this is not possible, the criteria used to determine this period,
• the existence of the right for the controller to request the correction or deletion of personal data or the restriction of the processing of personal data in relation to the persons to whom the personal data relate, or to object to such processing,
• the existence of the right to lodge a complaint with the supervisory authority,
• where personal data is not collected directly from the individual to whom it relates – access to all available information about its source.

1. C) Right to rectification
   Every individual has the right to obtain from the controller the correction of inaccurate personal data relating to him/her without undue delay. Taking into account the purpose of the processing, the individual has the right to complete missing data.
   If an individual wants to use this right, he/she can contact the contact persons (employees) at the company at anytime.
2. D) Right to deletion
   Every individual has the right to have the controller delete personal data relating to him/her without undue delay. In cases provided for by law, the controller must obligatorily delete personal data without undue delay.
3. E) The right to restriction of data processing
   Every individual has the right to obtain a restriction of data processing from the controller, if one of the following applies:

• The individual challenges the accuracy of personal data for the time that allows the controller to check the accuracy of personal data.
• The processing is unlawful and the individual objects to the erasure of personal data and instead restricts its use.
• The controller no longer needs the personal data for processing purposes, but the data subject requires the establishment, exercise or protection of legal claims.
• The data subject has objected to the processing in accordance with the GDPR, until it is verified whether the controller’s legitimate reasons prevail over the subject’s data.

If one of the above conditions is met, and the individual to whom the personal data relates requests the restriction of the processing of personal data stored by Unija, Unija must immediately ensure that the request for the restriction of processing is taken into account.

1. F) The right to data portability
   Every individual has the right to data portability, in connection with which the individual to whom the personal data relates can contact Unija anytime.
2. G) The right to object
   Every individual has the right to object at any time to the processing of personal data relating to him/her, based on reasons that concern his/her particular situation.
   Unija will no longer process personal data in the event of an objection, unless it has a legal basis for doing so or for the establishment, exercise or protection of legal claims.

If Unija processes personal data for the purposes of direct marketing, the individual to whom the personal data relates has the right to object at any time to the processing of personal data for such purposes. If an individual objects to the processing of data for direct marketing purposes, Unija will no longer process personal data for these purposes.
To exercise the right to object, the individual to whom the personal data relates, can directly contact Unija or its employees at any time.

1. H) Automated individual decision-making, including profiling
   Unija does not use profiling based on the obtained personal data.
2. I) The right to withdraw from data protection
   Every individual has the right to withdraw his/her consent to the processing of his/her personal data at any time. If an individual wishes to exercise the right to revoke consent, he or she may contact Unija or its employees directly at any time.

10 Protection of personal data

The administrator will protect the obtained data in accordance with the applicable legislation on the protection of personal data, and in accordance with its internal acts adopted on the basis of the law. It will provide adequate organizational and technical protection. In no case will the operator forward or disclose the obtained data to third parties. Unija implements appropriate technical and organizational measures for the protection of personal data.

11 Contract processors and storage area

The controller also forwards the collected personal data to its contractual processors. They can process the data exclusively within the framework of the controller’s instructions and authorizations and are bound by a written contract concluded with the controller to ensure an adequate level of personal data protection, namely: for CRM, HRM, e-mail marketing system and marketing automation system. The provider keeps collections of personal data in the EU and does not export them to third countries.

The controller can provide personal data to digital advertising platforms (Google, Facebook, LinkedIn, etc.) and use their cookies, which enable the controller to create more precise segments, display targeted ads and remarket. This allows the user to receive more relevant advertisements on these platforms from the operator. This may involve the export of data to a contractual processor outside the EU.

12 Personal data storage period

We keep the personal data of the individual until the consent for the storage and processing of the individual’s data is revoked, or in accordance with the statutory deadlines. After revoking an individual’s consent, we permanently delete their personal data.
If the purposes described above, for which we store and process personal data, cease in our company, we will permanently delete the data collections whose purpose has ceased.

Unija d.o.o.
Brezovica pri Ljubljani, September 2023