Policy purpose

We want to inform you about what personal data we collect and why we do it, how we collect, use and disclose this personal data, the legal basis for processing and your rights related to the processing of your personal data when using the website www.as-digitalservices.com.

We process collected personal data in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679; the “GDPR”), the applicable law governing personal data protection and sectoral legislation.

Controller

The controller of your personal data is the company AS Digitalne Storitve d.o.o. with English company name AS Digital Services Ltd. (angleščina), Stegne 21C, 1000 Ljubljana, Slovenia, with registration no. 9087303000.

We are also available via e-mail address info@as-digitalservices.com.

Our data protection officer’s contact is dpo@as-digitalservices.com.

Personal data categories

We collect the following categories of your personal data:

  • “Online Interaction Data” are data related to the web use (including online identifiers of your computer or other device, IP address, cookies, browser and operating system data, time (date and hour) of (sub)page visit). We obtain them when you visit our website. The IP address and browser data originate from your browsing service provider and cookie, device and operating system data from your equipment;
  • Communication Data” are data that you entrust us with by and/or in an e-message (including name and surname, e-mail address and possible personal data you provide in the e-message itself).

Purpose and legal basis

Consent

Direct marketing

Based on your consent, we use your Communication Data (name, surname, and e-mail) for the purpose of direct marketing (e-news, e-posts and e-offers).

If you consent to direct marketing (e-news, e-posts and e-offers), we will inform you twice per month via your e-mail address about offers, benefits and news with respect to our services.

You can withdraw your consent at any time by clicking the “unsubscribe” button in our e-mail or by writing to us on our e-mail address.

Google Analytics

We use your Online Interaction Data (online identifier of your computer or other device, IP address, cookies, browser and operating system data, date and hour of (sub)page visit) to measure the traffic of website visitors. To do this, we use the analytics tool Google Analytics. We provide the aforementioned data to Google that in turn provides us with insight into analytical reports on visitors and visits of the website and its subpages. Among other things, we see the approximate location of the visitor, demographics (age and gender) of visitors, device (computer, mobile phone, tablet) and source of arrival (social network, browser or through search engine), visited (sub)pages, what was done on the website and duration of the visit. Through Google Analytics we cannot identify a specific individual nor is this our intention. We measure the traffic of the visit in order to display the content of the website in accordance with the general interests in a way that puts in the foreground the content that meet the greatest demand and to adjust the display according to the relevance of a particular topic. We provide your information to Google only if you consent to analytical cookies on the website (further specified in our cookie policy). We’ve also installed Google’s IP anonymization (masking) feature for which Google assures that it anonymizes your IP address as soon as technically feasible. However, Google receives your full IP address and may associate your Online Interaction Data with other personal information. You can withdraw your consent at any time – in which case we will stop sending data to Google, which does not, however, affect the lawfulness of the processing until the withdrawal, i.e., the fact that Google has received your data.

In this part, we are responsible for the processing of your personal data, for which we actually determine the purposes and means. Information how the said provider processes your personal data can be accessed by clicking on the Google link.

The legal basis is Article 6(1)(a) of GDPR. We store this data until your withdrawal.

The provision of this data is not a contractual nor statutory requirement. Failure to sign-up to our marketing messages or Google Analytics will not have any consequences for you.

Legitimate interest

We need your Communication Data (name, surname, your e-mail address and potential other personal data that you provide in your e-message) that you send through our online contact form on the website or directly to our e-mail address to be able to reply to your message and/or inquiry.

The provision of this data is our legitimate interest, since we wouldn’t be able to reply to you without it.

Web server’s log files that include Online Interaction Data (including IP address and identity of your device, time of visit of our website and address of the website from which you came to our website) are automatically stored on the web server each time you visit our website. When accessing the website, your device’s IP address is communicated to the server on which the website is stored. This is necessary so that the data accessed may be transferred to the correct recipient and to ensure stability and security (functioning of the website). The purpose is to provide access to the website, as well as to detect and prevent activities that would jeopardize the operation of our website.

The legal basis is Article 6(1)(f) of GDPR. We keep the pseudonymized IP address for 26 months following your visit of the website. After that, data is deleted. We keep the rest of the data as long as there is purpose.

On this legal basis, we also process strictly necessary cookies, which are further specified in the cookie policy.

Personal data recipients

To achieve the above purposes, we disclose your personal data to the following categories of recipients:

  • IT service providers (server, maintenance and hosting);
  • provider of e-mail marketing messages;
  • Google.

The recipients are processors in the EU with whom we have concluded contracts and who have undertaken to provide appropriate protective measures.

Data subject’s rights

You can send your request to the e-mail address info@as-digitalservices.com or exercise it directly in the online contact form.

You can exercise the following rights:

  • access to personal data in accordance with Article 15 of GDPR;
  • rectification of personal data in accordance with Article 16 of GDPR;
  • erasure of personal data in accordance with Article 17 of GDPR;
  • restriction of processing in accordance with Article 18 of GDPR;
  • data portability in accordance with Article 20 of GDPR;
  • to object in accordance with Article 21 of GDPR;
  • to lodge a complaint with a supervisory authority in accordance with Article 77 of GDPR.

We will process your request in accordance with the provisions of GDPR. In order to guarantee your rights, we will primarily use the e-mail address you have communicated for this purpose.

Last updated: 13 May 2022