Privacy Policy is an integral part of the WOTRA Focus portal's general terms and conditions.

The term "WOTRA", "WOTRA Focus", "provider" or "us" or "we" refers to the owner of this online portal and the personal data controller whose official name is "WOTRA d.o.o." with its registered office at Donova 2, SI-1215 Medvode, Slovenia. The registration number of the company is 1689339 and the place of registration is in Ljubljana.

The term "you", "user", "buyer", "subscriber" refers to the visitor of this portal as well as the (potential) subscriber or the customer or buyer of one or more products and services from the offer of this portal.

The purpose of our Privacy Policy is to inform visitors of this online portal, users, customers, potential customers or subscribers of products and services from the offer of this WOTRA Focus portal with the purposes and basis of the processing of personal data by WOTRA.

Privacy Policy addresses the handling of information that we receive from you when you visit and use this online portal or provide us with information in any other way (e.g. at the time of purchase, order, enquiry, etc.).

By continuing to browse and use this online portal, you agree with our general terms and conditions, including with our privacy and cookie policy governing our relationship with you in connection with this portal.

 

data controller | personal data collected | legal basis | purpose of processing | retention period | transferring personal data | freedom of choice | individual rights | exercising rights

 

The personal data controller and contact details

The personal data controller in the sense, as defined by the current legislation regulating the protection of personal data, is a company:

WOTRA d.o.o.
Donova 2
SI-1215 Medvode
Slovenia
T: +386 40 790 000
W: www.wotra.com 

If you have any questions about the use of this Policy or about the rights you can exercise arising from this Policy, contact us in written in any of the following ways:

WOTRA d.o.o., Donova 2, SI-1215 Medvode, Slovenia, with the addendum ‘Personal data protection’"
E: privacy /@/ wotra.com

 

Types of personal data collected

WOTRA may collect the following personal data in accordance with the purposes set out below in this Privacy Policy:

  • basic contact information (name, surname, phone number, e-mail, country);
  • analytical cumulative or anonymous information about the use of the online portal and the response to our emails;
  • the information we need to complete the contract and/or delivery of purchased products and services (customer information, purchase item, price, delivery address, delivery time, payment method, date of payment, information on complaints, invoice information, etc.);
  • information about the authors of professional contents with their profile, which are given to us by the author for the purpose of presenting the author;
  • information about consultants, lecturers and other experts with their CVs, references and other information that they provide either via e-mail or through online forms for the purpose of their involvement in WOTRA projects and/or for the purpose of participating in the provision of joint services offered to WOTRA clients;
  • other data entered by users of this online portal into online forms, which are designed according to the specific purpose of each form.

 

Legal basis for the collection and processing of personal data

In accordance with personal data protection legislation, we may process your personal data on the following legal basis:

  • where this is necessary to fulfill our legal obligations (e.g. issuing invoices for a purchased service or product, saving data for tax-related obligations);
  • where the processing of your personal data is necessary to perform a contract you’ve entered into or because you wanted us to bid;
  • where you’ve given your consent to the processing of your personal data for a particular processing purpose, however you always have the right to withdraw your consent;
  • where we have a legitimate interest to process your personal data.

Providing personal data that we require to perform a contract is voluntary. We would like to remind you that in case you do not provide your personal data that we require to provide our services (e.g. entering into a contract, registering for a webinar), we will not be able to provide that service.

Giving consent is always voluntary and without any adverse consequences. However, we would like to remind you that certain services cannot be provided without your consent or after you withdraw your consent.

 

The purpose of the processing of personal data

We may use your personal information for one or more of the following purposes:

  • communicating with you regarding the performance of our services and responding to your enquiries;
  • entering into a contract and performing obligations from that contract; Specifically, the provision of services such as registrations and orders made through our portal (thereby ensuring that you can successfully register to our events, webinars, and that you can order services or products through the online shop). All personal data processed in relation to orders in our online shop is processed with the purpose of entering into and performing contracts that you entered into with us. If you do not provide all data required to complete an order, we reserve the right to delay or cancel the order;
  • for marketing communications (such as sending e-mails via our WOTRA Focus - eNews, regular mails and SMS messages, all with the purpose of notifying you about new services or upgrades of existing services, events organised by WOTRA and/or by business partners, business opportunities and other information, services and tools);
  • for marketing communications, based on targeted or individualized offers. The use of some personal data helps us to personalized communication with you so that it’s as interesting and useful to you as possible. Based on certain personal data, we can divide individuals into groups, enabling us to tailor the content of messages to each group. Marketing communication with targeted or individual offers will be conducted only with your explicit consent.
  • to enforce any legal claims and to settle disputes; During the course of protecting our business and exercising and/or protecting our rights, personal data may be disclosed. Your personal data will be disclosed only in the manner and under circumstances defined by the law.
  • for statistical analysis of the sale of our services and products and the use of our websites, which is our legitimate interest of maintaining and/or improving our business performance.

You have the right to withdraw your consent for any processing of your personal data at any time. You can communicate the withdrawal of your consent in written in any way listed in chapter "The personal data controller and contact details" of this Policy.

 

Retention period of personal data

We will only keep your personal information for as long as it takes for the purpose for which the personal data were collected and processed (e.g. to ensure that you access and use your online account and the online store on WOTRA Focus portal, for completing your orders, checking your payments and meeting other obligations on our or your side, to ensure that you can access the specific information available to you on the portal, to ensure that you can use the benefits of the CollaboVentures platform, to send you eNews, etc.).

We keep those personal data that we process on the basis of the law for the period prescribed by law.

The personal data we process for the execution of the contractual relationship with you shall be kept for the period necessary for the execution of the contract and for a further 5 years after the conclusion of the contractual relationship, except in the event of a dispute over the contract between you and WOTRA; in such a case, we store data for another 5 years after the final decision of the court or arbitration or settlement has been made, or, if no dispute has been made, for 5 years from the date of the peaceful settlement of the dispute.

Those personal data acquired based on your consent or our legal interest are permanently stored or until you withdraw your consent. The data collected on your consent will be deleted even before you withdraw your consent if the purpose for which the data were collected has already been achieved.

Personal data for which the storage period has expired (e.g. because the purpose for which they were collected has been achieved, or because the legal deadline has been reached) will be erased, destroyed, or rendered anonymous to prevent the personal data from being reconstructed.

 

Transferring personal data

Your personal data – for the expressed purpose for which the were collected – can be transferred, consulted or access to certain third parties (so-called data processors), who carry out certain tasks for us in terms of data processing. They are required to follow applicable legislation and the provisions of the personal data protection policy. Each data processor with whom we share the personal data may process the data only for the purposes for which they were collected.

Your personal data can be transferred to:

  • contractors who provide business services for us (e.g. accounting, legal, lawyer and other similar services);
  • providers of online services that enable us to distribute e-mails and eNews (such as Mailchimp or Sendinblue), advertising (e.g., Google AdWords, LinkedIn Ads and Fasebook Ads), and web analytics (Google Analytics and Matomo Analytics);
  • data center service providers where our websites and portals are hosted;
  • where we are required to do so by law (e.g. tax authorities, courts).

Your personal data may be transferred to third parties outside of the European Economic Area (EEA), where these data can be processed by us or third parties. For each transfer outside of the EEA, we’ll take additional steps to ensure the security of your personal data.

 

Freedom of choice

Providing personal data that we require is voluntary. However, if you do not provide them, you can not receive certain services, access all functionalities of our online solutions, or conclude contracts with us.

Giving consent is always voluntary and without any adverse consequences. We would like to remind you that certain services (e.g. e-notifications or customised dissemination of e-mails and eNews) cannot be provided without your consent or after you withdraw your consent.

 

Rights of data subjects

In accordance with the applicable legislation governing the field of personal data protection, you have the following rights:

  • access to personal data: You can request information from us about whether we process your personal data. If we do, you can request access to your personal data and information about the processing (which data is being processed and where the data come from).
  • rectification of personal data: You can request that we rectify or amend imperfect or inaccurate data about you which is being processed.
  • restriction of processing of personal data: You can request that we limit the processing of your personal data.
  • erasure of personal data: You can request from us that we erase your personal data (we cannot erase those personal data that we control due to legal obligations or based on a contractual relationship).
  • copy of personal data: You can request from us that we provide a copy of the personal data that you sent in a structured, commonly used, and machine readable format. One (free) copy of your personal data is delivered to you in a format you specify (if the request is provided by electronic means of communication and you do not request otherwise, the copy shall be provided in electronic form). For additional copies you request, we can charge a reasonable fee, taking into account the costs.
  • withdrawing consent: You have the right to withdraw your consent about the use of personal data that we collect and process with your consent at any time. You can withdraw consent in any way listed in chapter "The personal data controller and contact details" of this Policy. Withdrawing consent has no drawbacks, but it is possible that we will not be able to provide certain services to you after you withdraw consent.
  • objecting to processing of personal data: You have the right to object the processing of your personal data when the purpose of the processing is direct marketing or transferring your personal data to third parties with the purpose of direct marketing. Additionally, you can object the processing when your data is being used with the purpose of indirect marketing with the use of personalized or individual offers (profiling). You can communicate your objection in any way listed in chapter "The personal data controller and contact details" of this Policy.

 

Procedure for exercising individual rights

You may address your written requests regarding the exercise of rights in connection with personal data in any way listed in chapter "The personal data controller and contact details" of this Policy.

For the purposes of reliable identification in the case of the exercise of your rights in connection with personal data, we may request additional information from you. We can only reject the procedure if we prove that you can not be reliably identified.

Upon your request, with which you exercise your rights in relation to personal data, we will respond within one month of receiving your request.

 

This Privacy Policy is effective as of May 25, 2018 and may be updated from time to time.

We reserve the right to modify or replace this Policy at any time by posting the revised Policy on this WOTRA Focus portal. You are responsible for reviewing and becoming familiar with any such change each time you access any part of this WOTRA Focus portal.