Privacy Protection Policy
Privacy Policy for Website Visitors and Delta Agile Service Users
The website www.deltaagile.com is managed by Delta Agile, education and consulting, Denis Curk s.p., Seliškarjeva cesta 14, 1290 Grosuplje (hereinafter: DA; also derivatives “we”)
This privacy policy explains in detail how we use the personal data you provide when using the website and when ordering services offered by DA. Protection
1. What is Personal Data?
Personal data is information that directly or indirectly identifies you as an individual, where “indirectly” means in combination with other information, such as your name, postal address, email address, telephone number, identification number, location data, or other identifiers.
2. What Personal Data Do We Collect?
If you are just a visitor to DA’s websites, we don’t collect any data about you. If you are a user of DA services (e.g., you have registered for a course organized by DA), we also collect other personal data needed to provide the services you ordered. This personal data includes:
- first and last name;
- contact email address;
- username;
- contact phone number;
- company name;
- billing information (name and surname, address and postal code, and tax number for legal entities).
3. How Do We Use (Process) your Personal Data?
All provided personal data is treated confidentially and is used solely for the purpose for which it was provided. DA takes data security very seriously. We use an appropriate level of protection and have established reasonable physical, electronic, and administrative measures to protect collected data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of personal data, or unauthorized access to personal data that has been transmitted, stored, or otherwise processed. Our information protection policies and procedures are closely aligned with widely accepted international standards and are regularly reviewed and updated as necessary to meet our business needs, changes in technology, and regulatory requirements. Access to your personal data is only permitted to personnel and service providers who need this data to perform their work.
In case of a personal data security breach, DA will follow all relevant data breach regulations.
If you have ordered a DA service, personal data is collected and processed for the conclusion and execution of the contract, i.e., to provide the ordered services and inform about additional details of these services, possible changes, additional details, instructions for using services, or to provide working materials for DA services that are educational in nature.
In case of ordering a paid service, based on tax regulations for proper invoice issuance, we obtain and process your address and tax number for legal entities and sole proprietors.
In case of subscribing to DA e-news (i.e., newsletter), we process your provided email address and name based on consent for the purpose of general information about all DA services and summaries of news, articles, and training published on the DA website.
You can unsubscribe from e-news or notifications about ordered DA services at any time by clicking the link in received messages or by writing to us at sales@deltaagile.com.
DA commits not to sell, lend, or otherwise transfer the data you provide through websites or in any other way to third parties, except in the cases stated below and unless regulations require otherwise.
DA will only disclose your personal data to the listed third parties under the conditions written below, whereby DA will ensure that your personal data is processed, protected, and transferred in accordance with applicable regulations:
External Service Providers
When necessary, we will authorize other companies and individuals to perform certain work that contributes to our services. For example, we may share personal data with providers hosting our database and applications, for data processing services, for sending information you requested, for conducting required training, for providing support services, etc. We will only share or make such data accessible to external service providers to the extent required for a specific purpose. They will not be allowed to use this data for any other purposes. DA’s external service providers are contractually bound to respect the confidentiality of your personal data.
Business Transfers
In connection with any reorganization, restructuring, sale, or any other transfer of assets (collectively “business transfers”) we will transfer data to a reasonable extent and as necessary for the business transfer, provided that the receiving party commits to respecting your personal data in accordance with applicable data protection regulations. We will continue to ensure the confidentiality of all personal data and notify affected users before personal data becomes subject to another privacy policy.
Public Authorities
We will only disclose your personal data to public authorities when required by national legislation or European Union law. DA will, for example, respond to requests from courts, law enforcement agencies, and other state authorities, which may include state authorities of another EU member state.
4. Legitimate Interest
Based on legitimate interest, we use your personal data to detect and prevent fraudulent use and abuse of services or subscriptions to them, furthermore as part of ensuring stable operation of our system and services, as well as for implementing information security measures, fulfilling requirements regarding service quality, and detecting technical system and service failures.
Based on legitimate interest, we also use your personal data for potential enforcement, judicial and out-of-court collection purposes.
5. Your Rights Regarding your Personal Data
Individuals can request from DA access to personal data, correction, deletion, or restriction of processing of your personal data, you have the right to object to processing and portability of your personal data.
Right to Information: you always have the right to know whether personal data concerning you is being processed and if so, access to personal data and the following information: (a) purposes of processing; (b) types of personal data concerned; (c) recipients or categories of recipients to whom personal data has been or will be disclosed; (d) planned period of storage of personal data or, if not possible, criteria used to determine that period; (e) where personal data is not collected from you, all available information regarding their source.
Right to Correction: you have the right to have inaccurate personal data concerning you corrected and, taking into account the purposes of processing, the right to complete incomplete personal data.
Right to Erasure: you have the right to obtain erasure of your personal data when one of the following reasons applies:
(a) personal data is no longer necessary for the purposes for which it was collected or otherwise processed; (b) when you withdraw consent on which the processing is based and where there is no other legal basis for processing; (c) when you object to processing and there are no overriding legitimate grounds for processing; (d) personal data has been processed unlawfully.
Right to Restriction of Processing: you have the right to obtain restriction of processing of your personal data when one of the following cases applies:
(a) when you contest the accuracy of data, for a period enabling us to verify the accuracy of personal data; (b) processing is unlawful and you oppose erasure of personal data and request restriction of their use instead; (c) we no longer need your personal data for processing purposes, but you need it for establishment, exercise, or defense of legal claims; (d) if you have filed an objection regarding processing based on DA’s legitimate interests, until verification whether our legitimate grounds override your grounds.
When processing of your personal data has been restricted in accordance with the previous paragraph, such personal data shall, with the exception of storage, only be processed with your consent or for establishment, exercise, or defense of legal claims or for protection of rights of another natural or legal person.
Before lifting the restriction of processing your personal data, we are obliged to inform you.
Right to Data Portability: you have the right to receive your personal data that you have provided to us in a structured, commonly used, and machine-readable format, and the right to transmit this data to another controller when processing is based on your consent or processing is carried out by automated means. At your request, where technically feasible, personal data may be transmitted directly to another controller.
Right to Object: when we process your data based on legitimate interest for marketing purposes, you can object to such processing at any time.
Right to File a Complaint with the Information Commissioner: if we do not decide on your request within the legal deadline or reject your request, you have the option to file a complaint with the Information Commissioner.
6. Access and Correction of your Personal Data and Exercise of other Rights
As a user of DA’s website or subscriber to DA services, you have the right to verify whether DA processes personal data about you and to access personal data we store or process about you (in this case, we will provide it to you in a machine-readable PDF document). You can always request correction of inaccurate personal data about you. If you believe there is no longer a justified reason for continued use or processing of your personal data, please let us know, however, we cannot delete certain personal data collected based on the Value Added Tax Act. You also have the right to restrict the use of your personal data in cases where you contest the accuracy of personal data, when you assess that processing is unlawful but do not want deletion, and when personal data is no longer needed for processing purposes but you need it for establishing legal claims. In case of newsletter subscription, you have the right to object to the processing of your personal data.
To exercise your described rights, please send your request in writing via email to info@deltaagile.com (Denis Curk). The responsible person will respond to your request within the prescribed period of 1 month. In case of complexity and a larger number of requests, we may extend the deadline by up to two additional months, about which you will be notified.
7. Storage
DA stores personal data received from you until unsubscription from e-news (withdrawal of consent). DA performs an annual review of existing newsletter subscribers and if you haven’t opened or read any of your e-news for a long time, we will send you an email to renew your consent (newsletter subscription) with a 14-day deadline, otherwise we will delete your personal data and stop sending you e-news.
DA keeps data related to performed services for 10 years after service completion. After this time, we delete them. Based on tax regulations provisions, DA is obliged to keep invoices containing personal data of DA service subscribers for 10 years after the service is performed.
DA will also not delete data needed to provide proof that person’s data was deleted (i.e., audit trail), and keeps records of persons who do not wish to be contacted by DA in the future. This data includes email address and name and surname.
8. Cookies
The DA website uses “cookies”. These are small files that are stored on your disk when visiting the site. They contain information about your computer, but not your personal data. Cookies can make your future visits to the site easier. Through your browser settings, you can decide whether to accept or reject “cookies”.
If you don’t accept “cookies”, some website options may not display correctly or you may not have access to all information or website functionality.
9. Privacy Policy Changes
DA reserves the right to change its privacy policy at its discretion at any time and update and modify this privacy policy. Therefore, we recommend that you regularly review this privacy policy. DA will notify you of changes to these Privacy Rules by email only in case of substantial changes that affect personal data processing.
10. Contact
If you have any questions about the privacy policy or the data we hold about you, please write to us at email address info@deltaagile.com
Grosuplje, November 2, 2023
