Privacy Policy and Cookie Policy

 

LEGAL INFORMATION

In accordance with the provisions of Articles 6-III and 19 of Law No. 2004-575 of 21 June 2004 for the Confidence in the digital economy, known as LCEN, we bring to the attention of users and visitors of the site apprendrelangue.com following information:

Owner status: company

Prefix: LTD

Company Name: Sofimed d.o.o

Address: Letaliska cesta 16 Ljubljana 1000 Slovenia

Company number: 6732917000

Company director: Jaka Kovac

Email address: support@pregnancylifehacks.com

The Site Builder is: Sofimed d.o.o

The Publishing Manager is: Sofimed d.o.o

Contact the person responsible for the publication: support@apprendrelangue.com

 

The person responsible for the publication is a legal person:

The Webmaster is: Sofimed d.o.o

Contact the Webmaster: support@apprendrelangue.com

 

This Privacy Policy describes the privacy practices for the Website operated by apprendrelangue.com (hereinafter "Website" if singular, or, "Websites") and how the Website operated by Sofimed d.o.o collect and use the personal data you provide on Sofimed d.o.o Website, with the purpose to use Sofimed d.o.o Service. It also describes the choices available to you regarding our use of your personal information and how you can access, update and delete this information.

Based on Art 37/1 of the GDPR regulation, Sofimed d.o.o is not required to appoint a Data Protection Officer (DPO). There is however a person in charge of GDPR implementation at Sofimed d.o.o and which will address all questions, queries and requests on this topic. This person can be reached by email at support@apprendrelangue.com.

The  visit of the Website is possible without any indication of personal data; however, if a user wants to use Sofimed d.o.o Service via our Website, collecting and processing of personal data could become necessary. If the processing of personal data is necessary we generally obtain consent from the user as a data subject.

The processing of personal data, such as the name, address, e-mail address, telephone number or billing information of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to Sofimed d.o.o. By means of this Privacy Policy, we would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects (users) are informed, by means of this Privacy Policy, of the rights to which they are entitled.

As the controller, Sofimed d.o.o has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this Website.

In this Privacy Policy “Sofimed d.o.o”, “we”, “us” and “our” means Sofimed d.o.o.

 

DEFINITIONS

Personal data means any information relating to an identified or identifiable natural person (“data subject/user”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Data subject/user is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing; a user to the Sofimed d.o.o Service.

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject/user without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

Encryption is a security protection measure for personal data; as a form of cryptography, it is a process whereby personal data gets turned into an encoded and unintelligible version, using encryption algorithms and an encryption key, and whereby a decryption key or code enables users to decode it again.

Consent of the data subject/user is any freely given, specific, informed and unambiguous indication of the data subject/user`s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

 

CONTROLLERS AND PROCESSORS

The GDPR also introduces two parties when it comes to collecting and processing personal data: data controllers and data processors.

A data controller governs the purposes and ways that personal data is processed. Sofimed d.o.o customers, be they organizations or individuals, are data controllers.

Sofimed d.o.o is consequently considered in the new GDPR as data processor in the sense that it will process your personal data and is responsible to make sure that all processors with whom it deals will be GDPR compliant.

 

PERSONAL DATA COLLECTION AND USE

We strive to be compliant with GDPR and implemented data minimization principle. Personal data, as defined above, which we collect, consist of:

(i) full name (first and last), (ii) e-mail address, providing the data subject with the ability to register an account and become a user of our Service with the purpose to use the Sofimed d.o.o Service correspondingly, (iii) billing information, which includes full address, zip code, city, country, telephone number, (iv) payment method (not full credit card number and expiration date), (v) IP address – assigned by the Internet service provider (ISP) and used by the data subject/user, and (vi) location data – for statistics of user’s areas involvement.

The personal data entered by the data subject/user are collected and stored exclusively for internal use by the controller and for his own purposes. The personal data stores separately in Sofimed d.o.o data base to avoid data subject identification by using depersonalization features in compliance with GDPR storage limitation principle.

When you purchase Sofimed d.o.o Service you have to fill the User’s Information, which should contain your personal information as ID (first name, last name) and email, which is processed and stored by Sofimed d.o.o.

You also have to fill the Billing Information, which should contain your Personal data, which is partly stored by Sofimed d.o.o and processed by the payment providers.

We may use your Personal data to: (a) improve your browsing experience by personalizing the Website and to improve the Service; (b) send information to you by email regarding registration status, password verification, payment confirmation; (c) send you communications relating to your use of the Service and materials/content being Service, and (d) provide our partners with statistical information about our users by secured channels under data processing agreements (DPA).

 

AGGREGATE INFORMATION THAT IS AUTOMATICALLY COLLECTED. COOKIES. LOG FILES. PIXEL TAGS

We also collect and store information that is generated automatically as you navigate through our Website to enhance your experience on our Website by using tracking technologies as Cookies, Log Files and Pixel tags.

The data subject may, at any time, prevent the setting of cookies through our Website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of Cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other Service programs.

If you do not wish to receive Cookies you may be able to refuse them by adjusting your browser settings to reject Cookies.

Sofimed d.o.o also may use Pixel tags (single-pixel image files also known as transparent GIFs, clear GIFs or web beacons) to access Cookies and to count users who visit the Website or open our HTML-formatted e-mail messages.

 

LEGAL MATTERS

Sofimed d.o.o considers your use of its Service to be private. However, we may disclose your personal information stored in your account and/or on Sofimed d.o.o servers and databases, in order to:

(1) comply with the law or legal process served on us;

(2) enforce and investigate potential violations of this Privacy Policy; including use of this Service to participate in, or facilitate activities that violate the law;

(3) investigate potential fraudulent activities; or

(4) protect the rights, property, or safety of Sofimed d.o.o, its employees, its customers or the public.

In the event of a change of control of Sofimed d.o.o (such as asset transfers through a merger, sale, assignment or liquidation of the business entity, or any of its properties, assets or equity) or, in the event of a direct or indirect sale of any of its publishing properties and/or its Website(s), personal data of users of the affected Website(s) in our possession will be transferred to the new owner/successor. You will be notified of any such transaction and have an ability to exercise your legal rights under GDPR. You may always change or delete your personal data or opt out by contacting us as provided below, or if the acquirer posts a new Privacy Policy with new contact information, you may change or delete your personal data or opt out by following any new instructions that are posted.

We may share Aggregate Information with third parties, including strategic partners, for marketing and promotional purposes under concluded data processing agreements, which secure the transfer and processing of personal data according to GDPR.

The controller may also transfer to one or more processors (e.g. a payment provider under DPA) personal data of a data subject for payment processing purpose, which is attributable to the controller and without which a user would not be able to purchase the Service and use Sofimed d.o.o Service.

As we use third party technological services for the provision of Services, we may transfer your personal date internationally. Providers of such technological services may process personal data collected in the course of providing us their services as sub-processors only under DPA in accordance with GDPR.

In case there might be a risk of unauthorized disclosure of personal data the controller communicates the personal data breach to the data subject without undue delay. However, as the controller has implemented appropriate technical and organizational protection measures, as encryption, and it was applied to the personal data affected by the personal data breach, the controller is not required to communicate the data subject.

However, the encryption is useless if the access password or other credentials are weakly protected and stored by data subject. In this case the controller is not responsible for personal data breach.

In the case of a personal data breach, the controller shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the competent supervisory authority.

 

RIGHTS OF THE DATA SUBJECT

a) Right of confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed.

b) Right of access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

the purposes of the processing;

the categories of personal data concerned;

the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;

where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;

the existence of the right to lodge a complaint with a supervisory authority;

where the personal data are not collected from the data subject, any available information as to their source;

the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If one of the aforementioned reasons applies, data subject may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately.

c) Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

d) Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.

The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.

e) Right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.

The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.

The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.

The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned reasons applies, data subject may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately.

f) Right to data portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

g) Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

If one of the aforementioned reasons applies, data subject may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately.

 

CHILDREN’S PRIVACY

Provision of our Service generally not aimed at children. This Website is not intended for use by children under the age of 18.

 

PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period and when we no longer need personal data, we routinely and securely delete or destroy it, as long as it is no longer necessary for the Purpose.

 

ROUTINE ERASURE AND BLOCKING OF PERSONAL DATA

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of Service provision, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

 

HOW DO I OPT OUT OR CHANGE MY PERSONAL INFORMATION?

To opt out of further e-mail communications from us, just visit Unsubscribe Page and cancel your subscription, or contact us as instructed at the end of this Privacy Policy. We may need up to 10 (ten) business days to assure compliance with your request.

To change your personal data that you have provided to us, please contact us as instructed at the end of this Privacy Policy.

 

COOKIE POLICY

Data Types We Collect and the Ways We Use Them

The only data types we collect are marketing data vital for updates or promotional offers, and minimal personal information (name, address, telephone number & email address). The latter is provided on the check-out page, as we need it to create an account. No such data are disclosed to the third parties; they are treated as anonymous statistics.

Cookies and Log Files

We use cookie technology as part of our web site’s statistical reporting. Cookies are central to the customization of the internet and online behavioral advertising. We gather statistical data on which pages are visited, what is downloaded, the Internet provider’s domain name and country of the visitors, as well as the addresses of sites visited immediately before, and after, coming to Sofimed d.o.o.

Google Analytics helps us measure the effectiveness of our advertising, as well as simplicity and efficiency of our site’s usage.

 

COOKIES USAGE CONTROL

Some browsers will let you block cookies that do not meet your privacy preferences. If necessary, you can stop accepting new cookies, be notified when you receive a new cookie, and disable existing cookies. Disabling all cookies could significantly affect your web browsing, rendering it impossible to take full advantage of all of our web site features. Be informed that some parts of our websites require your accepting cookies for it to work in a proper mode. Cookies can be removed or declined by changing your web browser settings any time you wish. For more information, please visit www.allaboutcookies.org and/or www.youronlinechoices.com

 

CHANGES OR UPDATES TO THIS PRIVACY POLICY AND COOKIE POLICY

We may modify this Privacy Policy at any time and post any changes to the Privacy Policy on the Website, so please review it frequently.

Changes to this Privacy Policy may not affect your personal data we have previously collected from you or after such changes.

If you object to the changes, please contact us as provided below.

 

GOVERNING LAW

This Privacy Policy is governed by and construed with the laws including the Data Protection Directive (95/46/EC) and Regulation 2016/679 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 (“GDPR”), effective as of 25 May 2018.

Those who access the website from locations outside of the European Union are responsible for compliance with local laws if and to the extent that local laws are applicable.

 

CONTACT US

If you have any questions about this Privacy Policy or you wish to make changes to your personal information or remove yourself from our database, please contact us by E-mail: support@apprendrelangue.com and insert only the words "Re: Privacy Policy" in the subject line header of the e-mail.