Legal notice and cookies

This Privacy Policy (hereinafter: “Policy”) applies to any individual whose personal data is processed by LANAI d.o.o.

In order to implement the principle of fair and transparent processing, LANAI d.o.o. – as the controller of your personal data – have prepared this Policy, which enables an individual to obtain all relevant information related to their personal data from a single point.

At LANAI d.o.o., we respect your privacy and will use your personal data solely for the purposes set out in this Policy. We will take great care to protect your personal data in accordance with the legislation governing the personal data protection, especially EU Regulation 2016/679 (hereinafter: “GDPR”), the Personal Data Protection Act (ZVOP-1) and other internal acts of LANAI d.o.o. governing the area of personal data protection.

Personal data controller

The controller of personal data is LANAI d.o.o., Pot za Brdom 22, 1000 Ljubljana. If you require more information or have additional questions regarding the protection of your personal data, you can contact us at info@vilapodvin.com.

Personal data categories and purposes of their processing

PLANAI d.o.o. collects and processes personal data based on the consent of the data subjects and / or for the purpose of implementing contracts and pre-contractual measures.

Consent-based processing

Personal data processing may be based on the specific consent of the individual who permits LANAI d.o.o. to use their personal data for the purposes specified in the consent, namely the implementation of marketing activities, such as information about the offer, news and benefits, to provide magazines, brochures and other promotional material about the offer of LANAI d.o.o., its affiliates and its business partners.

Based on the consent, LANAI d.o.o. collects and processes the following personal data:

from data subjects who are consumers: name, surname, e-mail address, telephone number, country of residence. We require the information about the country of residence in order to send you notifications in the most appropriate language;
from non-consumer data subjects (representatives of companies): name, surname, e-mail address and telephone number.

We will send you notifications using the contact details we obtain from you.
Consent is given for the purposes specified in the consent form and is valid until revoked. When a data subject revokes their consent partially or completely, we shall no longer use their data for the purposes, because of which they revoked the consent. If a data subject wishes to revoke their consent, they can write to us at info@vilapodvin.com. An individual can always “unsubscribe” from receiving individual messages via the communication channel through which they received a particular message. The link to the unsubscribe option or to the information on how to unsubscribe can be found in the message. We will record the data subject’s request for revocation in our system and start enforcing it immediately or no later than 15 days after receipt.

If the data subject does not give their consent for the implementation of the above purposes of personal data processing, gives it in part or revokes it (in part), LANAI d.o.o. shall send notifications to such data subject only in the cases and in the scope of the given consent or in the ways permitted by the applicable legislation.
The conclusion of a contract for the purchase of products and accommodation packages and / or for the booking of apartments of LANAI d.o.o. shall not be conditional on the giving of consent to carry out marketing activities. Giving consent is voluntary and if a data subject decides that they do not wish to give it or decide to revoke it later, this shall in no way reduce their rights arising from the contract and shall not represent additional costs or aggravating circumstances.
LANAI d.o.o. shall process personal data based on the consent of the data subject in accordance with the last received consent of the data subject regardless of the communication channel, through which the data subject gave their consent.

Contract-based processing

LANAI d.o.o. collects and processes personal data of data subjects on the basis of a concluded contract for the (i) purchase of products and accommodation packages as defined in the General Terms and Conditions and (ii) booking of apartments of LANAI d.o.o. (iii) LANAI d.o.o. further collects and processes personal data of data subjects on the basis of contracts concluded with its business partners. Under these contracts, LANAI d.o.o. collects personal data of said data subjects that are in any way necessary for the performance of the contract.

Personal data collected on this basis are necessary for the performance of concluded contracts (for the purpose of performing the above services and / or products) and measures prior to the conclusion of the contract. If the stated personal data are not provided or the data subject does not agree with their processing, the conclusion of the said contracts is not possible, and we shall withdraw from the already concluded contracts.
(i) For the purposes of the performance of the contract for the purchase of products and accommodation packages, LANAI d.o.o. collects and processes the following personal data: name, surname, e-mail address, telephone number, country of residence, language settings.
(ii) For the purposes of the performance of the contract for the booking of apartments at Vila Podvin, LANAI d.o.o. collects and processes the following personal data from the data subject: name, surname, e-mail address, telephone number, address, country of residence, language settings.
(iii) For the purpose of the performance of the contract with its business partners, LANAI d.o.o., as a rule, collects the following personal data: name, surname, e-mail address and telephone number. Under these contracts, LANAI d.o.o. also collects other personal data specified in the individual contract and necessary for the performance of said contract.

LANAI d.o.o. does not collect numbers and other data that are related to payment cards and provided by the customer via the website www.vilapodvin.com. This data is collected exclusively by payment card providers.

Users of personal data

Users of personal data are employees of LANAI d.o.o. from the sales, marketing and IT departments as well as contractual processors that are bound by labour law, personal data processing contracts, contracts on the protection of confidential data and similar obligations to protect the personal data of data subjects in accordance with the law.
More detailed information on user categories and contractual processors can be obtained on request at info@vilapodvin.com.

Contractual processing of personal data

Individual tasks related to data subjects’ personal data may be entrusted to third parties (contractual processors). Contractual processors may process entrusted data exclusively on behalf of the provider, within the limits of the provider’s authorisation (in a written contract or other legal act) and in accordance with the purposes defined in this Policy.

Personal data protection

In order to ensure the protection of personal data, LANAI d.o.o. shall implement all necessary legal, organizational and relevant logistical and technical procedures and measures, either itself based on internal acts or through its contractual partners, so as to:

protect premises, equipment and system software, including input-output units;
protect application software used to process personal data,
prevent unauthorised access to personal data during their transmission, including transmission using telecommunications means and networks;
ensure an effective method of blocking, destruction, deletion or anonymization of personal data;
enable subsequent determination of when the individual pieces of data were used and entered in the filing system as well as who did that, namely for the period, for which the individual pieces of data are stored.

Personal data retention period

The personal data retention period depends on the basis and purpose of processing of each category of personal data. Personal data shall be retained only as long as necessary for the achievement of the purpose, for which they were collected or further processed. Personal data shall be erased, destroyed, blocked or anonymized after the purpose of the processing has been fulfilled, unless there is no other legal basis or if this is necessary to assert, implement or defend legal claims.
Personal data processed on the basis of the contract are retained for the period necessary for the performance of the contract and for an additional 5 years after its termination, except in cases of a contract-related dispute between us and the data subject, in which case we retain the data for an additional 5 years after the finality of the court decision, or arbitration award, or settlement or, if there was no court dispute, 5 years from the date of the peaceful resolution of the dispute. Invoices shall be kept for 10 years after the end of the year, to which the relevant invoice relates in accordance with the act governing the value added tax.
Personal data obtained on the basis of consent to carry out marketing activities shall be retained until the consent is revoked.

Data subject’s rights

If a data subject wishes to obtain information on all the purposes, for which LANAI d.o.o. uses their personal data, they may request this by exercising their right of access. LANAI d.o.o. shall provide them with a detailed list of all processing activities performed on their personal data and the legal basis for such activities.

LANAI d.o.o. provides data subjects whose personal data are processed with the option of exercising their rights, in particular the right of access to personal data and the rectification or erasure of personal data, and the exercise of the right to object to processing. A data subject may submit a request in a manner that enables their identification (e.g. a verbal request made on the record at the registered office of LANAI d.o.o.) or a written request sent to the address of LANAI d.o.o., Pot za Brdom 22, 1000 Ljubljana. We are obligated to provide a copy of the personal data that is processed or the requested information to the data subject free of charge. For any further copies requested by the data subject, we may charge a reasonable fee based on administrative costs. Where the data subject’s requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may (1) charge a reasonable fee based on the administrative costs associated with communicating the information or message or the performance of the required measure, or (2) refuse to act on the request.

A data subject shall have the right of access to their personal data, which have been collected concerning him or her, and to exercise that right easily and at reasonable intervals in order to be aware of the processing and its lawfulness of the processing (the right to know).
The data subject shall have the right to obtain from LANAI d.o.o. confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information: purpose of processing, types of personal data concerned, users or categories of users to whom personal data have been or will be disclosed, the retention period of personal data, the existence of the right to require the controller to correct or erase personal data or restrict the processing of personal data concerning the data subject, or the existence of the right to object to such processing, the right to lodge a complaint with the supervisory authority where the personal data are not collected from the data subject, all available information regarding their source and the existence of automated decision-making.
The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her (right to rectification). Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format (right of portability) The data subject shall have the right to obtain from us without undue delay the erasure of personal data concerning him or her in the following cases:
(1) personal data are no longer required for the purposes, for which they were collected or otherwise processed;(2) the individual revokes the consent, on the basis of which the processing is being performed, and there is no other legal basis for the processing;(3) the individual objects to the processing and there are no overriding legitimate reasons for the processing;(4) personal data have been processed unlawfully;(5) when so provided by law (right of erasure).

The data subject shall have the right to limit the processing of his or her personal data when one of the following cases applies:(1) the data subject disputes the accuracy of the data, i.e. for a period that allows us to verify their accuracy;(2) the processing is unlawful and the individual opposes the erasure of personal data, and instead requests that their use be restricted;(3) we no longer need personal data for the purposes of processing, but the data subject needs them to assert, enforce or defend legal claims;(4) the data subject has lodged an objection concerning the processing of the data until it has been verified that the legitimate reasons of the controller outweigh the reasons of the data subject (right to restrict processing).

Where the processing of personal data has been restricted in accordance with the above, such personal data, with the exception of their retention, shall be processed only with the consent of the data subject or for asserting, enforcing or defending legal claims or for the protection of the rights of another natural person or legal entity. We shall notify the data subject before revoking the processing restriction.

Without prejudice to any other legal remedy, the data subject shall have the right(i) to lodge a complaint with LANAI d.o.o. via the e-mail info@vilapodvin.com regarding the processing of their personal data and(ii) to lodge a complaint with the supervisory authority (in Slovenia, this is the Information Commissioner) if they believe that the processing of personal data related to them violates personal data protection regulations (right to lodge a complaint with the supervisory authority).

Additional information when data is not obtained from the data subject

Personal data not obtained directly from the data subject are available from LANAI d.o.o. at the request of the data subject. The data subject shall have the right to obtain all available information regarding their source.

Cookies

The cookies we install in your browser anonymously collect certain information about your visit to the website. They enable us to ensure the operation of all functions of the website, adapt certain content specifically to you and constantly improve the website by analysing visits.

Essential cookies

The required cookies provide basic functions such as site navigation and access to specific parts of the website. Without these cookies, the website does not guarantee full functionality to the user. Essential cookies also include those designed to adjust the behaviour or appearance of the website on subsequent visits, for example to display in the selected language.

Statistics tracking cookies

Statistics cookies anonymously collect and report information to website owners. This helps them understand how visitors use the website and improve the user experience based on this information.

Advertising and user profiling cookies

Marketing cookies anonymously collect information about your website visits. They are used by advertisers to show you ads that are more relevant and interesting to you. They are also used to prevent ads, which the user has already seen, from reappearing.

The exact description of each cookie and their lifespan in your browser is shown in the tables below:

Required cookies

Required cookies make the website useful as they provide basic functions such as page navigation and access to secure areas of the website. The website will not work properly without these cookies.

Cookie name	Service	Lifespan	Description
cookie_consent	vilapodvin.com	1 year	A system cookie that records information on whether the user allows analytics and / or advertising cookies to be loaded in their browser.

Statistics tracking cookies

Statistics cookies help website owners understand how visitors use the website by collecting and reporting information anonymously.

Cookie name	Service	Lifespan	Description
_ga	Google Analytics	2 hours	Performs unique identity registration (ID), which is used to generate statistics on how a visitor uses the website.
_gat	Google Analytics	Session	Google Analytics uses the cookie to manage the number of requests.
_gat_t1	Google Analytics	Session	Google Analytics uses the cookie to manage the number of requests.
_gib	Google Analytics	Session	Performs unique identity registration (ID), which is used to generate statistics on how a visitor uses the website.

III – Validity

This Privacy Policy and the use of cookies by LANAI d.o.o. will be updated as appropriate, of which you will be informed accordingly.
This Policy is published on the Vila Podvin website and applies as of 18 March 2022 onwards.