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Privacy policy

The website www.testiramo.xyz/apartma/ is managed by the company FIRMA (hereinafter: FIRMA; also referred to as “we”).

This privacy policy explains in detail how we use the personal data you provide when using the website provided by FIRMA.

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, phone number, identification number, location data, or other identifiers.

2. What personal data do we collect?

If you are merely a visitor to FIRMA’s websites, we only collect data through the use of cookies. If you are a user of FIRMA’s services (e.g., you have registered for an event organized by FIRMA), we also collect other personal data needed to perform the services you have requested. This personal data includes:
· full name;

· contact email address;

· username;

· contact phone number;

· IP address;

· billing information (full name, address, postal code, and tax identification number for legal entities).

3. How do we use (process) your personal data?

All personal data provided is treated confidentially and is used solely for the purpose for which it was provided. FIRMA takes data security very seriously. We use an appropriate level of protection and have implemented reasonable physical, electronic, and administrative measures to protect collected data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to personal data that has been transmitted, stored, or otherwise processed. Our policies and procedures for information protection are closely tied to widely accepted international standards and are regularly reviewed and updated as necessary to align with our business needs, changes in technology, and regulatory requirements. Access to your personal data is permitted only to staff, service providers who need the data for business reasons (business “need-to-know”), or those who require it to perform their work.
In the event of a personal data security breach, FIRMA will comply with all relevant data breach regulations.

If you have ordered a service from FIRMA, personal data is collected and processed for the conclusion and execution of the contract, i.e., to provide the ordered services and to inform you of additional details of these services, possible changes, additional details, instructions for using the services, or to provide materials related to FIRMA’s services that are educational in nature.

If you have subscribed to FIRMA’s newsletter, your provided email address and name are processed based on consent for the purpose of general notifications about all FIRMA services and summaries of news, articles, and educational content published on FIRMA’s website.

You can unsubscribe from receiving newsletters or notifications about subscribed services from FIRMA at any time by clicking on the link in received messages or writing to us at [email protected].

FIRMA undertakes not to sell, lend, or otherwise disclose the data you provide via websites or in any other way to third parties, except in the cases listed below and when required by regulations.

FIRMA will disclose your personal data only to the specified third parties under the following conditions, ensuring that your personal data is processed, protected, and transferred in accordance with applicable regulations:

External service providers

If necessary, we will authorize other companies and individuals to perform certain tasks that contribute to our services. For example, we may provide personal data to contractors for hosting our database and applications, for data processing services, or for sending requested information, providing support services, etc. External service providers will only be given or have access to this data to the extent required for the specific purpose. They will not be allowed to use this data for any other purpose. FIRMA’s external service providers are contractually bound to maintain the confidentiality of your personal data.

Business transfers

In connection with any reorganization, restructuring, sale, or any other transfer of assets (collectively referred to as “business transfers”), data will be transferred to a reasonable extent and as necessary for the business transfer, provided that the receiving party agrees to protect 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 their personal data becomes subject to a different privacy policy.

Public authorities

We will disclose your personal data to public authorities only when required by national legislation or European Union law. FIRMA will, for example, respond to requests from courts, law enforcement agencies, and other state bodies, which may include state bodies of another EU member state.

4. Legitimate interest

We use your personal data on the basis of legitimate interest for detecting and preventing fraudulent use and abuse of services or subscriptions, ensuring the stable operation of our system and services, as well as for implementing information security measures, fulfilling service quality requirements, and detecting technical faults in systems and services.
We also use your personal data on the basis of legitimate interest for possible enforcement, legal, and out-of-court recovery.

5. Your rights regarding your personal data

As an individual, you can request access to personal data from FIRMA, request correction, deletion, or restriction of processing of your personal data, and have the rights to object to processing and data portability.
Right to information: You always have the right to be informed whether personal data concerning you is being processed, and if so, to access personal data and the following information: (a) the purposes of processing; (b) the types of personal data involved; (c) users or categories of users to whom personal data has been or will be disclosed; (d) the anticipated period for storing personal data, or if not possible, the criteria used to determine this period; (e) all available information regarding the source of personal data, if not collected from you.

Right to correction: You have the right to have inaccurate personal data concerning you corrected and, considering the purposes of processing, the right to complete incomplete personal data.

Right to deletion: You have the right to have your personal data deleted when one of the following reasons applies:

(a) the personal data is no longer needed for the purposes for which it was collected or otherwise processed; (b) when you withdraw consent on which processing is based and there is no other legal basis for processing; (c) when you object to processing and there are no overriding legitimate reasons for processing; (d) the personal data has been processed unlawfully.

Right to restrict processing: You have the right to have the processing of your personal data restricted in the following cases:

(a) when you contest the accuracy of the data, for a period enabling us to verify the accuracy of the personal data; (b) if processing is unlawful, but you oppose deletion and request restriction instead; (c) when the personal data is no longer needed for the purposes of processing but you need it to establish, exercise, or defend legal claims; (d) if you have objected to processing based on legitimate interests, pending verification of whether our legitimate grounds override yours.

When the processing of your personal data has been restricted as outlined above, such personal data will, with the exception of storage, only be processed with your consent or for establishing, exercising, or defending legal claims or for protecting the rights of another natural or legal person.

Before lifting the restriction on the processing of your personal data, we are required 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 transfer that data to another controller when processing is based on your consent or performed by automated means. Upon your request and where technically feasible, the 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 may object to such processing at any time.

Right to lodge 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 lodge a complaint with the Information Commissioner.

6. Access and correction of your personal data and exercising other rights

As a user of FIRMA’s website, you have the right to verify whether FIRMA processes personal data about you and to access personal data we hold or process about you (in which case we will provide it in a machine-readable PDF document). You can always request that inaccurate personal data about you be corrected. If you believe there is no longer a justified reason for further use or processing of your personal data, inform us; however, we cannot delete certain personal data collected under the Value Added Tax Act. You also have the right to restrict the use of your personal data when you contest the accuracy of personal data, when you believe processing is unlawful but do not want deletion, and when personal data is no longer needed for processing but you need it for legal claims. In the case of newsletter subscriptions, you have the right to object to the processing of your personal data.
To exercise any of your described rights, please send your request in writing by email to [email protected]. The responsible person will respond to your request within the prescribed period of 1 month. In cases of complexity and a larger number of requests, the period may be extended by up to two additional months, about which you will be informed.

7. Retention

FIRMA retains personal data you have provided until you unsubscribe from newsletters (withdraw consent). FIRMA conducts an annual review of existing newsletter subscribers, and if you have not opened or read any newsletters for a long time, we will send you an email asking you to renew your consent (newsletter subscription) with a 14-day deadline, after which your personal data will be deleted, and we will stop sending newsletters.
FIRMA retains data related to completed services for one month after the service is completed. After this time, the data is deleted unless otherwise provided by law. For example, under tax regulations, FIRMA is required to retain invoices containing personal data of service clients for 10 years after the service is provided.

FIRMA will also not delete data needed to ensure proof that data has been deleted (i.e., audit trail) and to keep records of individuals who do not wish to be contacted by FIRMA in the future. This data includes email address and full name.

8. Cookies

FIRMA uses “cookies” on the website – small files that are stored on your computer when you visit a site. Cookies can make future visits to the site easier for you. With your browser settings, you can choose whether to accept or decline cookies.
If you do not accept cookies, some web pages may not display correctly, or you may not have access to all the information or functionalities of the web pages; however, accepting cookies is not a requirement for using the FIRMA website.

Read more about cookies and their use in our Cookie Policy.

9. Changes to the Privacy Policy

FIRMA reserves the right to modify its privacy policy at any time at its own discretion and to update and amend this privacy policy. Therefore, we recommend that you review this privacy policy regularly. FIRMA will notify you of any significant changes affecting the processing of personal data by email only if there are major changes.

10. Contact

If you have any questions about the privacy policy or the data we hold about you, please write to us at [email protected].

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