DATA PROTECTION STATEMENT
Bank Assets Management Company (hereinafter: “BAMC” or “us”) respects your right to privacy and aims to ensure the highest degree of protection of your personal data. In providing our services through this website or in conducting business through telecommunication means we are therefore bound to operate in accordance with laws and regulations which stipulate protection of personal data, especially in accordance with the General Data Protection Regulation, in accordance with applicable Slovene Personal Data Protection Act and the Electronic Communications Act.
The purpose of this Data Protection Statement (hereinafter: “Statement”) is to acquaint you with the purposes for which your personal data will be obtained and how they will be used and with your rights regarding the data we keep about you and how to enforce them.
BAMC undertakes that the collected personal data you will provide through our website or through telecommunication means (e.g. as part of electronic correspondence) shall be used in accordance with this Statement, that your personal data shall not be sold, loaned or in any other way transmitted to third parties, except in cases stipulated by the law.
2. Data Controller
The controller of your personal data is Družba za upravljanje terjatev bank, d.d., address: Davčna ulica 1, SI-1000 Ljubljana, e-mail: firstname.lastname@example.org, telephone number: +386 (0)1 429 38 77.
Since we value your privacy we appointed a data protection officer to whom you can turn in case of questions regarding processing of your personal data. Our data protection officer can be reached via e-mail address email@example.com.
Strict confidentiality shall apply for all topics and content considered by the data protection officer.
3. Purpose of data processing and types of personal data
All personal data you provide us shall be treated strictly confidentially and shall be used solely for purposes for which they were provided. If the need for further processing of your data for another purpose arises, we shall contact you beforehand and ask for your consent.
At each visit of our website the log file of the on-line server is automatically saved on the on-line server (e.g. IP number – number which identifies an individual computer or another on-line device, browser version, time of the visit, location information or internet access entry point and the like). We process these data for the purpose of analysis which enables us to improve content and user experience on our website and keeping statistics of website visits. We collect the stated data with the help of cookies, we will ask your permission prior to installing more invasive cookies, while we collect certain other data based on our legitimate interests.
BAMC shall process data collected in such manner and shall not link it with other personal data of its website users. By only using these data and considering the state of the technology the visitor cannot be uniquely identified.
Sending inquiries and other communication with us:
You can fill out the contact form on our website with which you can submit your inquiry regarding our services and activities. You can also send us an inquiry or contact us by using any of the contact information published on our website.
For this purpose, BAMC collects the following data you provide in a voluntary manner:
- name and surname,
- title and company,
- e-mail address,
- data on the content of your inquiry or message.
All data collected through this website or which were in any other way communicated to us with the help of telecommunication means are collected for the purpose of carrying out our basic activity, namely for asset management and sale of assets for the best possible price. We shall process the data for the purpose of responding to your inquiry, to inform you of the asset sales procedure, for possible preparation and conclusion of the contract and for implementation of the concluded contract. We shall use the data you provide by filling out the contact form solely in order to provide contractually agreed services and for the purpose of our internal administration and management of our business.
We may also process the provided contact data pursuant to our legitimate interest for basic adjusted communication with you through e-mail and we try to present appropriate services and activities which could be interesting for you based on your former interactions with us. In this we do not use any (automatic) profiling, but only collect appropriate sets of recipients for individual messages.
You can unsubscribe from such communication at any time free of charge by sending us an e-mail message to the e-mail address: firstname.lastname@example.org. Additional information on your rights regarding direct marketing are available in items 7 and 8 of this statement titled “Your rights”.
Subscription to electronic news:
You can also subscribe to receiving our news and information on our services and activities at our website or by replying to our e-mail message.
For the purpose of direct marketing determined in such manner we may inform you of our new services and activities which are directly connected to our asset management activity and sale of assets for the best possible price via e-mail and/or mail. We will inform you of the news as necessary.
These data are processed pursuant to your express consent and you may withdraw your consent to receiving marketing messages at any time free of charge by sending us an e-mail message at the e-mail address: email@example.com. Additional information on your rights regarding direct marketing are available in items 7 and 8 of this statement titled “Your rights”.
All data collected pursuant to the above mentioned legal ground shall be used in accordance with purposes for which they were collected. In cases when the collected data would be used for a purpose different from the initial purpose for which they were obtained or stored, we shall acquire your prior written consent.
4. Data recipients
We undertake to not transmit your personal data to unauthorised third parties without your consent.
We hereby inform you that we may delegate individual tasks regarding your data to other persons (e.g. data processors). Processors may process such data solely on our behalf and within the limits of our authorisation (provided in a written contract or another legal act) and in accordance with purposes contained in this Statement.
Within these statutory powers your personal data may be disclosed to the following data recipients:
- to accounting service providers, law firms and other legal and business consulting services providers;
- to postal service providers, dispatch service providers, providers of file and data carrier destruction services;
- to information technology service providers as part of software repair and maintenance services;
- to the website administrator;
- to cloud computing service providers and e-mail service providers (e.g. Mailchimp and others);
- to customer relations management service providers.
We undertake that neither us nor any other recipient of your personal data shall provide or transmit such data outside of the European union or the European Economic Area or to an international organisation which does not ensure the appropriate degree of protection. Your personal data may be transmitted to the U.S. in which all our contractual processors in the USA are included in the EU-U.S. Privacy Shield program.
5. Period of storage of personal data
We ensure you that we only store your data as long as it is necessary in order to fulfil the purpose for which particular data were collected and further used. After the end of the period of storage we shall efficiently and permanently delete and anonymize your personal data so that your identification will be no longer possible.
We store data we process pursuant to the law in accordance with the period prescribed by the law. We store data we process in order to carry out the contractual relationship with you for the period required for implementation of the contract and for the entire statutory period of limitation applicable for contracts concluded in such manner, except in case of a dispute regarding the contractual relationship.
We permanently store personal data we process based on your consent or a legitimate interest, e.g. in case of sending electronic news, until withdrawal of consent by you or until the request to stop processing in which we undertake that we will check the existence of the purpose of personal data processing in regular time intervals. We shall delete the data prior to withdrawal only if the purpose of the personal data processing has been achieved (e.g. if we stopped sending e-mail news) or in case it is stipulated by the law.
If a different statutory storage period applies for certain data processed for the purpose of performance of contracts (e.g. accounting and tax data), the storage period shall be up to 10 years. During this time the processing of data is limited.
6. Modality of protection of your data
BAMC undertakes to protect personal data you provide us with the use of our website, through telecommunication channels or in any other manner. We undertake to do everything to protect the personal data from any violations and misuse.
After the need to keep the data ceases to exist, namely the purpose for which they have been collected is fulfilled, the data shall be immediately, irreversibly and permanently deleted.
In case that links to other websites are published on the BAMC website which are in no way connected with BAMC, we assume no responsibility for protection of your data on such websites.
7. Freedom of choice
You control the information you provide. If you decide to not provide certain data, you will not be able to access some parts or functions in this website and in such cases we will not be able to reply to your inquiry or conclude a contractual relationship with you.
If you no longer wish to receive news via e-mail, you can unsubscribe from news free of charge by sending us an e-mail with the content “Unsubscription from e-mail news” at the e-mail address: firstname.lastname@example.org. If your personal data (postal number, e-mail address, address, telephone number etc.) change, we ask you to inform us of the change at the e-mail address: email@example.com.
8. Your rights
BAMC ensures exercising of all the rights to which you are entitled with regard to the processing of your personal data.
A data subject may at any time demand that:
- we confirm whether or not we process data concerning him/her and enable access to personal data (namely, to review, transcribe or copy such data),
- we provide information regarding processing of these data (e.g. regarding the purpose of processing, categories of personal data, recipients to which the personal data were or will be disclosed, the expected retention period, technical and organisational measures for data protection etc.),
- we enable rectification of incorrect personal data associated with the data subject and enable the data subject to complete incomplete personal data,
- we enable the right to erasure of personal data (e.g. the right to be forgotten),
- we enable the right to restriction of processing,
- we enable the right to object to processing if data processing is based on our legitimate interest in which case we will continue with processing of your personal data only in case if we will demonstrate compelling legitimate grounds for processing which shall prevail over your interests, rights and freedoms. You may object to processing of personal data for purposes of direct marketing without stating any reasons,
- we enable the right to portability of data and provide the data in commonly used and machine-readable format or directly transmit them to another controller in which this shall apply only in case of processing your personal data pursuant to your consent or to a contractual relationship and
- we shall enable the right to withdraw consent when personal data are processed pursuant to consent in which the withdrawal of consent shall not affect the legality of data processing which carried out until consent withdrawal.
If you suspect that legislation has been violated with the processing of your data, you shall have the right to file a complaint with the Information Commissioner of the Republic of Slovenia, at the address Zaloška 59, 1000 Ljubljana, Slovenia, telephone number: 00 386 (0)1 230 97 30, e-mail address: firstname.lastname@example.org.
At your request and in accordance with the applicable law we shall also provide you other information regarding your personal data we process.
We undertake to reply to your request without undue delay and no later than within the statutory deadlines.
Questions regarding confidentiality of your data, manner of collecting and processing of data and your requests to exercise rights regarding your data shall be answered by the data protection officer at BAMC on the telephone number: +386 (0)1 429 38 77or at the e-mail address: email@example.com.
We reserve the right to amend this Statement as needed in order to align it with actual circumstances and the personal data protection legislation. We therefore ask you that you check the applicable version each time you provide your personal data in order to be acquainted with possible changes and amendments. We shall also inform you of possible changes which significantly impact the processing of your personal data in advance and in an appropriate manner (e.g. by posting a notice on our website, via e-mail).
In Ljubljana, on 25 May 2018