The purpose of the Privacy Policy is to present to you in a simple way the personal data we collect about you, on what basis and for what purposes we process it, the options for managing your privacy settings and to present your rights regarding personal data.

The privacy policy of Colby d.o.o. and the igabiba.si website is in line with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter the General Data Protection Regulation) and the legislation of the Republic of Slovenia and covers the following information:

  • contact information of the company Colby, d.o.o. and contact of the authorised person for data protection,
  • the legal basis and purposes of the processing of personal data,
  • the types of personal data we collect,
  • use of cookies and related technologies,
  • managing privacy settings,
  • transmission of personal data,
  • deadlines for the retention of personal data,
  • protection of personal data,
  • the rights of individuals with regard to personal data, including the right to appeal,
  • changes to the Privacy policy.
  1. CONTROLLER AND CONTACT

The personal data controller is Colby d.o.o., Ob Dravi, 6 2000 Maribor (hereinafter also "igabiba").

Your questions regarding this Privacy policy, the confidentiality of your personal data, the method of processing or your requests regarding the exercise of personal data rights will be answered by the responsible person and/or the data protection officer at igabiba. You can contact the data protection officer via the above address or via e-mail info@igabiba.si.

  1. LEGAL BASIS AND PURPOSES OF PROCESSING

Igabiba collects, records, edits, stores, transmits and otherwise processes the personal information we hold about you on the basis of various legal bases and for the purposes defined below in the document.

2.1. Contract-based processing - purposes

Igabiba processes personal data for the exercise of rights and obligations under concluded contracts, namely:

contracts for the sale/purchase of products - personal data of customers in the online store at www.igabiba.si (regardless of the registration);

contracts on the use of services - personal data of service subscribers (e.g. opening a user profile in the online store, subscribing to receive e-mail newsletters or sms newsletters);

IGABOOSTER loyalty program membership contracts - personal data of program members provided on the access statement at www.igabiba.si.

As part of exercising rights and fulfilling contractual obligations, igabiba processes personal data of individuals for the purpose of identifying the individual, concluding a contract (although the contract for the sale of products between igabiba and the customer in the online store is concluded at the moment igabiba sends the customer an e-mail order confirmation, it is considered that the provided personal data in this case is processed on the basis of the contractual legal basis also for the purpose of concluding the contract), for communication with you (notification of changed general terms, new version of the website, changed membership conditions in the club, etc.), to provide benefits brought by membership in the IGABOOSTER program (special benefits for members, prices, congratulation cards, etc.), to provide support to users (e.g. elimination of technical problems), and in the case of purchase for the purpose of order execution (shipment, delivery of products, issuing invoices, resolving any customer claims (complaints, warranties)), sending notifications to individuals regarding order execution and possible other purposes necessary for the execution of the order, for the storage of the history of purchases (only registered users), for the implementation of possible recovery procedures and for own accounting and tax needs.

2.2. Processing on the basis of legal obligations - purposes

Igabiba processes personal data on the basis of legal obligations applicable to Igabiba (e.g. in particular tax regulations, storage of invoices, storage of data of prize game winners, etc.).

2.3. Processing on the basis of legitimate interests - purposes

Igabiba may process personal data on the basis of the legitimate interests pursued by igabiba, except where such interests are outweighed by the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data. When it comes to the further processing of data collected about an individual, Igabiba conducts an assessment in accordance with the General Data Protection Regulation. Such further use of data in a pseudonymous or aggregated (combined) form, for example, constitutes a lawful use of data for marketing and other business or technical analyses of igabiba. Deletion of certain data may also be used as an additional measure in some forms of further processing of traffic data.

 Based on a legitimate interest, igabiba may process personal data to the extent necessary and proportionate to ensure the operation of online services, in particular to prevent unauthorized access to your user account, the spread of malicious codes, the prevention of fraud or other misuse of websites or mobile applications, as well as to protect its intellectual property rights in connection with online services.

Based on legitimate interests, igabiba may also process your personal data for the purposes of direct marketing (in the case of customers), prevention of abuse, assertion of claims or defense against claims in administrative and judicial proceedings.

2.4. Processing on the basis of consent - purposes

Igabiba processes personal data on the basis of consent for the processing of personal data provided by the individual to the company for the following purposes:

for the purpose of direct marketing - receiving notifications. Notifications include current offers, benefits and/or invitations to events of the manager and its business partners, invitations to participate in prize games and contests, and useful tips, news and reminders from the world of gaming;

to perform marketing analyses and customer segmentation and to provide customized product and service offerings;

for the purpose of participating in prize games.

Depending on the provided personal data, you can receive notifications and customized offers via SMS, MMS to the provided mobile phone number, by e-mail to the provided e-mail address.

You can revoke your consent at any time or change it in the same way as consent was given; by clicking on the 'unsubscribe' button located at the bottom of the e-mail; in user profile settings, by returning a text message (STOP) to any text message you have received from igabiba, or by forwarding a request to revoke consent for a specific purpose to the address info@igabiba.si.

Where consent includes direct marketing on the basis of an individual's profile, igabiba may classify individuals into segments on the basis of the use of the igabiba.si website for the purposes of customized offers of services and products.

  1. PERSONAL DATA WE COLLECT

Igabiba collects various data about you, including personal data that can be used to identify you directly or indirectly if you or others choose to share this personal data with igabiba. We receive data in several ways, including shopping in the online store, by subscribing to newsletters (direct marketing), registering a user profile in the online store, visiting igabiba websites. Igabiba collects data about your use of the services we offer.

Personal data we collect:

  1. basic personal data such as: name and surname, date of birth, e-mail address, address of residence (street, street number, postal code, place, country), delivery address (street, street number, postal code, place, country), telephone number and password to ensure the security and use of our services;
  2. online store user account data, when you decide to provide your data via the online profile, in addition to the basic personal data you provide us at registration, we also collect personal data such as content and data (information) that you upload to the user account or post, send, forward or otherwise share using the online store (e.g. comments, etc.);
  3. data on the purchase and method of payment;
  4. we collect technical information from your web browser, computer or mobile device when you access igabiba services.
  5. COOKIES

When you use our online services, cookies are loaded on your computer. In general, cookies and related technologies work by assigning a unique number to a web browser or device that has no meaning outside of igabiba.

Igabiba uses these technologies to customize the experience and to help provide content that is specific to your use.

A list of cookies used by the website can be found at this link.

You can use the settings in your browser or mobile device to manage the collection of information via cookies or related technologies. Igabiba is committed to allowing you to manage your privacy and sharing but assumes no responsibility for missed "Do Not Track" signals via a web browser. Rejection of cookies may result in some features of the services offered not being available to you.

  1. MANAGING SETTINGS IN THE USER PROFILE

5.1. User profile updates

The individual is obliged to provide accurate and complete data. Your possible changes to personal data in the user profile of the online store can be updated, adjusted or changed by the registered user in user profile settings.

Changes to personal data can also be reported in an e-mail to info@igabiba.si

5.2 Closing the user account

If you want to close your user profile of the online store, you can do so at any time by sending a request to close the user account to the contact address, a written request must provide proof of identity and address. The profile will be closed within 10 working days after obtaining the written request of the individual and proof of his identity.

Closing the user profile of the online store does not mean revoking the consent (unsubscribe) from receiving direct marketing notifications.

Closing a user profile also does not mean deleting your personal data from the igabiba database.

Please note that some personal data about you that we process under a purchase agreement may not be deleted. In accordance with the regulations in the field of tax law, we keep the data for 10 years from the execution of the order or the resolution of the complaint or return of the product.

At the same time, you should be aware that your posts from the time of the active user profile may remain visible even after closing the user profile (e.g. comments on products in the online store).

  1. TRANSMISSION OF PERSONAL DATA

6.1 Contractual processors

Igabiba may transmit your personal data to third parties with whom we have personal data processing contracts (hereinafter: contractual processors) for the purposes of supporting, analyzing and continuously improving our services, processing payments or delivering orders. Contractual processors have access only to those personal data that they urgently need to provide the services they provide for us, the data and only for the purposes of performing these tasks on our behalf and may not use them for any other purpose. Contractual processors are obliged to protect your personal data.

Igabiba may cooperate with contractual processors who process statistics for us on how you use our services for the purpose of advertising services or to display information that may be of interest to you. Such processors only have anonymized data.

6.2 Publicly available information

Some information about you may be publicly available, such as information that you provide or share through a comment in the online store or social networks, etc.

6.3 Third party websites and applications

We may share your personal data with third-party applications with your consent if you choose to access our services through such application (e.g. Facebook, Google account). Igabiba is not responsible for what third parties do with your data, so you need to make sure that you trust the application and that it has adopted appropriate personal data protection guidelines.

There are links on igabiba websites to websites that are not under the control of igabiba. By visiting these pages, you can pass on your information to third parties with whom igabiba does not have a contract for the processing of personal data. These websites have their own privacy policy in accordance with which they process your personal data. Please read their privacy policy to find out how your personal data is processed on the third-party websites you visit.

6.4 Joint controllers

We may share your personal information with contractual partners with whom we act as a joint controller who process your personal data in accordance with this privacy policy (e.g. an example of a prize game in cooperation with suppliers).

6.5 Universal legal succession

In the event of a merger, or if igabiba becomes involved in a business combination, division, or transfer of activities to a third party, we may transfer your data to a third party related to the acquisition of igabiba.

6.6 Public authorities

Notwithstanding the provisions regarding the retention period of personal data under the Privacy policy, we may store your personal data for a longer period and pass it on to third parties such as the police, prosecutor's office, court and other competent state authorities inside or outside the Republic of Slovenia, if such intervention is necessary and required by law, including for the purposes of the prevention, investigation, detection or prosecution of criminal offenses. We may also provide your personal data to public authorities when necessary to assert, enforce or defend legal claims in court proceedings or in administrative or extrajudicial proceedings.

6.7 Transmission of data to non-EU or non-EEA countries

In the case of using online services outside the EU Member States, due to the provision of online services, the transmitted data may be transferred, stored or processed in third countries, where legislation in the field of personal data protection prescribes different standards than in EU or EEA Member states. By using the services in countries outside the EU, you agree that personal data may be transferred or forwarded to entities located in third countries. Pikapoka will not otherwise export your personal data to countries outside the EU or the EEA.

  1. TIME LIMITS FOR THE RETENTION OF PERSONAL DATA

We keep personal data for as long as necessary to provide our services or longer, if there are legal obligations.

Personal data associated with your user account is stored until the request for deletion, while the data related to the purchase made by the user in the online store is retained. You can close the user account yourself in the user account settings or ask us to delete it. Closing your user account and deleting your personal data can take up to 10 business days from a complete request. Please note that we may retain certain data from closed accounts in accordance with the law, to prevent fraud, to recover debts, to resolve disputes, to resolve problems, to assist in investigating competent authorities, to enforce terms of service and to take other measures permitted by law. The data we retain will be treated in accordance with this privacy policy.

Data related to the payment of the purchase in the online store and related contact data on individuals may be stored for the purpose of fulfilling contractual obligations until the full payment of services or until the possible expiration of the limitation period in respect of an individual claim, which may by law amount to up to five years. In accordance with tax regulations, issued invoices are kept for 10 years after the end of the year in which the invoice is issued.

Personal data obtained on the basis of consent are kept until the revocation of consent, but for a maximum of 8 years.

Data about you that are no longer necessary for the purposes for which they were collected or otherwise processed may be anonymized and combined with other data that do not allow the identification of an individual to gain insight into statistical information that is commercially useful for igabiba, such as an example of statistics on the use of the services we offer. This personal data is anonymized and does not offer a link to an identifiable individual.

  1. PERSONAL DATA PROTECTION

We implement several technical and organizational measures to ensure the security of personal data during collection, transmission and storage. Igabiba strives to adequately protect your personal data, but we do not guarantee the complete security of the personal data you provide to us, and we are not responsible for the theft, destruction, loss, intentional or unintentional disclosure of your personal data or information about you. Igabiba adheres to generally accepted standards for the protection of received information both during and after transmission, but no method of electronic transmission or storage is 100% secure, so we cannot guarantee complete security. Igabiba uses Secure Sockets Layer (SSL) technology, which provides encryption of personal and credit card information. Igabiba works with a company to ensure the security of our services and your personal data. Igabibe servers are additionally protected by the use of firewalls and other technologies to ensure data security.

The user is also responsible for data protection by adequately ensuring the security of their mobile device or computer, as well as by protecting the username, password and appropriate software (anti-virus) protection of their electronic device. To ensure that these measures are effective in preventing unauthorized access to your personal data, you should be aware of the security features available to you through your web browser. Use a web browser that allows you to set security features before sharing your personal or credit card information over the Internet. Please note that if you use a web browser that does not support the use of SSL technology, such transfer of personal data may be risky.

Most web browsers allow you to be notified if you are on a website that does not provide a secure connection, or if you are sending data over an unsecured connection. Igabiba recommends that you enable these features of your web browser to help secure your personal data. You can also track your address (URL). Secure web addresses start with https:// instead of http://, along with the secure connection symbol used by your web browser (usually such a symbol is a lock at the beginning of the web address). Such a symbol indicates the use of secure communication with the server. At the same time, please check the details (validity) of the security certificate of the website where you are located.

Limitation of liability Igabiba is committed to protecting your personal data and information about you, but no connection over the Internet can be 100% secure and can guarantee the complete security of the data you provide to us. You provide us with your personal data at your own risk.

  1. RIGHTS OF INDIVIDUALS

Igabiba ensures the exercise of the rights of data subjects. The individual's requests regarding the exercise of rights are sent to the e-mail address info@igabiba.si or by post to Colby d.o.o., Ob Dravi 6, 2000 Maribor. An individual is obliged to submit proof of identity and/or address to a request that is not sent from the registered user's e-mail address. Igabiba will respond to your request in accordance with applicable regulations.

An individual has the following rights in relation to personal data:

9.1 Right to access data

An individual may at any time request igabiba to confirm that data relating to them is being processed and, if so, to provide access to personal data and to provide information relating to the processing of their personal data (e.g., to whom personal data have been or will be provided, the envisaged data retention period, technical and organizational measures for data protection, etc.).

9.2 Right to rectification

An individual may at any time request from igabiba to allow them to correct inaccurate personal data concerning them and to supplement incomplete personal data.

Registered users can do this through their user profile settings in the online store.

9.3 Right to deletion

Subject to the conditions set out in more detail by the applicable regulations, an individual may at any time request from igabiba to grant them the right to have personal data deleted (the so-called right to be forgotten).

9.4 Right to restriction of processing

Subject to the conditions set out in more detail by the applicable regulations, an individual may at any time request that igabiba grant him the right to restrict the processing of personal data. Registered web service users can do this in their user profile settings.

Please note that if we restrict the processing of certain personal data, we may not be able to provide a full service.

9.5 Right to data portability

An individual may at any time request from igabiba to allow them to provide personal data in a structured, commonly used and machine-readable form, to the individual or to the controller of the individual's choice (if technically feasible), under conditions further specified by applicable regulations.

9.6 Right to object

In the event that igabiba processes personal data on the basis of legitimate interests, as presented above, the individual may in certain cases object to such processing. Igabiba will stop processing this personal data unless it deems that it has reasonable and legitimate reasons to continue processing or if the processing is necessary for legal reasons.

An objection to the processing of personal data for the purposes of direct marketing can also be made by revoking the consent to receive notifications by clicking on the 'unsubscribe' button, which is located at the bottom of the e-mail or to follow the instructions in each notification sent.

9.7 Withdrawal of consent

The individual may revoke the consent at any time, in cases where they have given consent for a specific purpose of processing your personal data.

Registered users can revoke their consent in the user profile settings.

Revocation of consent does not affect the lawfulness of the processing of personal data carried out until its revocation.

9.8 Right to appeal to the supervisory authority

An individual has the right to lodge a complaint with the Information Commissioner of the Republic of Slovenia if they consider that their personal data are processed contrary to the applicable regulations governing the protection of personal data. The appeal procedure with the supervisory authority is published on the website of the supervisory authority.

  1. CHANGES TO THE PRIVACY POLICY

Igabiba reserves the right to change the privacy policy according to the situation and legislation in the field of personal data protection. Please review it periodically.

We will notify you in advance of any changes regarding the processing of your personal data and/or changes (updates) to the privacy policy. Changes to the privacy policy will also be posted on our websites in a timely manner.

If you do not agree with the privacy policy, please stop using our online services and close your user profile or revoke the given consents.

Colby, d. o. o. Maribor, April 2020