InstantFeedback by FrodX

InstantFeedback service is provided by FrodX d.o.o. (www.frodx.com)

1. Introduction

Frodx d.o.o., Celovška cesta 280, 1000 Ljubljana (hereinafter: “Frodx” or “controller”), is dedicated to responsibly handling the personal data of our clients, potential clients, FrodX website visitors and any natural persons who reveal their personal information when contacting us (hereinafter: “users”), so we are implementing this Personal Data Protection Policy (hereinafter: “Policy”) to inform our users in a transparent, easy to understand way using plain language about the purpose, the legal ground for the processing of their personal data and their rights regarding the processing, as they are afforded to them under the Personal Data Protection Act (ZVOP-2) and the Regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016 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 (hereinafter: “General Data Protection Regulation”).

Terms, such as “controller”, “processing”, “restriction of processing”, “processor”, “profiling”, “pseudonymisation”, “third party” and “company”, used in this Policy have the meaning as stipulated in the General Data Protection Regulation. In accordance with the General Data Protection Regulation, the Policy covers the following areas:

Contact details of the controller and of the data protection officer,
purposes and legal basis for processing various types of users’ personal data, including profiling the users’ personal data,
recipients of the personal data, contractual data processing and the transfer of personal data to third countries,
storage period for different categories of personal data,
security of the personal data,
users’ rights regarding the processing of their personal data,
procedure to exercise users’ rights regarding personal data processing,
the right to submit a complaint about personal data processing.

2. Contact details of the controller and of the data protection officer

Controller:

Frodx d.o.o., Celovška cesta 280, 1000 Ljubljana

Data Protection Officer:

dpo@frodx.com

3. Personal data

Personal data constitutes any information that identifies you as an identified or identifiable natural person. The user is identifiable when they can be directly or indirectly determined, especially using an identifier, such as the name, identification number, location data, an online identifier or by stating one or more factors specific to the user’s physical, physiological, genetic, mental, economic, cultural or social identity.

In accordance with the purposes stated in the following chapters of the Policy, the controller collects the following personal data:

basic information on the user (full name, title, occupation and other information about the employer),
contact information and information about the user’s communication with the controller (e-mail, telephone number, date, time and contents of the postal or e-mail communication, date, time and duration of phone calls),
data about attendance at events organized by Frodx (information on the event you attended, date and place of the event),
channel and campaign – manner of gaining the user’s consent or the source through which the user came into contact with the controller (website and advertising campaign or promotion),
data on the user’s use of the controller’s website (dates and hours of visits to the site, visited pages or URLs, duration of time spent on a website, number of visited pages, total time spent on the website, performed settings on the webpage) and usage data on received messages (e-mail, SMS) from the controller,
data from voluntarily filled in forms on the controller’s website, e.g. for prize contests,
other data the user voluntarily submits to the controller when requesting certain services that demand such data.

The controller does not collect or process the user’s personal data without their expressed consent, i.e. when ordering products or services, subscribing to e-newsletters, participating in a prize contest etc., when there is a legal basis for the collection of the personal data, the processing is necessary to execute contractual obligations or when the processing is necessary for legitimate interested pursued by the controller (hereinafter: “legitimate interest”).

4. Basis for processing and purpose of processing

Frodx will process your personal data for one of the purposes listed below based on the following legal basis:

your agreement or consent,
for compliance with the legal obligations of the controller,
based on legitimate interest,
for compliance with their contractual obligation.

Processing to fulfil contractual obligations

In certain cases, processing personal data is vital for the execution of the controller’s contractual obligations. If the user does not provide the necessary personal data, the controller is unable to finalize a contract with the user or perform services.

The controller will process your personal data to perform contractual obligations for the following purposes:

business Cooperation Agreement,
carrying out activities stated in the cooperation agreement (consulting, preparing marketing and sales strategies, implementing marketing and sales campaigns, process informatization),
communicating with contracting parties and other contact persons for the purposes of executing an activity stated in the cooperation agreement,
to sign up a user to an event organized by FrodX, including for awarding certificates, receipts and licences to event attendees.

Based on your written consent, Frodx will process your personal data for the following purposes:

sending e-mails for the purpose of informing about training courses, new features (in standards and in publications), services as well as events at the controller or third person,
for contacting on the phone for the purposes of presenting professional system solutions to the user or employer (by prior appointment also at their location),
for publishing in technical media and on websites with the basic purpose of promoting the user and their employer (licenced designer, licenced contractor …),
for monitoring the user’s reading of sent e-mails, including which e-mail you opened or did not open, which links you clicked (which contents you read), how long you were reading them or surveyed certain contents,
for segmenting users based on the factors from the previous paragraph and for further sending adapted (individualized) e-mails, which means different users can receive e-mails with different contents for the purpose of a better (more relevant) informing and achieving a higher level of response to the received e-mails,
for the purposes of analysing the user’s pattern-of-life on the website: from where the user came to the website (source of the traffic), for monitoring their activities on the website, which websites they visited, which contents they downloaded or viewed,
for segmenting users based on the facts from the previous paragraph and further sending adapted (individualized) messages through multichannel communication, which means different users can receive messages with different contents for the purpose of a better (more relevant) informing of individuals and reaching a higher level of user enthusiasm,
for all other purposes for which you expressly agree in cooperating with the controller.

Any time you give consent for the processing of your personal data, the consent can be withdrawn at dpo@frodx.com. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Processing based on legitimate interest

Frodx will process your personal data based on a legitimate interest for the following purposes:

Marketing, business and other technical analyses, such as analysing and determining which organizations the event attendees are coming from and what functions they perform in these organizations, for keeping records of how many and which events a user attended, for keeping records of awarded receipts, certificates and licences of event attendees.
Preventing fraud, ensuring safety, submitting claims or defence of legal claims in court proceeding or administrative procedures.
Direct marketing, including creating user profiles, based on legally acquired personal data.

5. Recipients of personal data, contractual data processing and transfer of personal data to third countries

Your personal data can be accessed solely by Frodx employees and authorized processers of personal data. Frodx will never forward your personal data to unauthorized third persons.

The contracted processors that the company collaborates with primarily include:

Accounting services and other providers of legal and business consulting.
Infrastructure maintenance (video surveillance, security services).
Information system maintenance.
Providers of email services and software, cloud services (e.g., Microsoft, Google, HubSpot, SAP, Amazon, ZOOM, OpenAI).
Social media and online advertising providers (Google, Facebook, Instagram, etc.).

6. Personal data storage period

The controller will not process personal data longer than necessary to achieve the purposes for which the personal data was collected and further processed.

The personal data processed by Frodx is processed in compliance with the agreement and is stored by Frodx for the period that is necessary to complete the contract and for 5 years after its completion, except in cases when a disagreement arises about the contract between you and the controller.

After the storage duration period has elapsed, Frodx will effectively and permanently delete or anonymize your personal data so that it can no longer be traced back to you.

7. Personal data protection

Frodx is dedicated to protecting your personal data. They prevent any unauthorized access to it, their use and their revelation with comprehensive security measures including:

Workspace, equipment and system software protection, including input-output units.
Application software protection used for processing personal data.
Prevention of unauthorized access during data transfer, including telecommunication networks.
Effective blocking, destroying, deleting or anonymizing personal data after purpose fulfillment.
Audit trails for tracking data usage, forwarding or other processing activities.

8. Users’ rights in personal data protection

In accordance with the General Data Protection Regulation, Frodx guarantees you the following rights:

Right of access to the data

Obtain confirmation and access to your personal data being processed.

Right to rectification

Correct inaccurate or incomplete personal data.

Right to erasure

“Right to be forgotten” when data is no longer necessary.

Right to restriction

Limit processing under specific circumstances.

Right to data portability

Receive your data in a structured, machine-readable format.

Right to object

Object to processing based on legitimate interests or direct marketing.

9. Procedure to exercise rights

All claims regarding your personal data rights can be addressed in written form to:

Email: dpo@frodx.com

Post: Frodx d.o.o., Celovška cesta 280, 1000 Ljubljana, Slovenia

The controller will respond to your request without undue delay in no more than a month after receiving the claim. This deadline may be extended by up to two additional months in complex cases.

10. Right to lodge a complaint regarding personal data processing

You can send any potential complaint regarding the processing of your personal data to dpo@frodx.com or by post to Frodx d.o.o., Celovška cesta 280, 1000 Ljubljana, Slovenia.

You have the right to lodge your complaint directly to the Information Commissioner, if you believe processing your personal data is infringing on Slovenian State or EU rules on personal data protection.

11. Policy validity

This Policy enters into force on 20th June 2024 and can be changed or amended at any time.

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