Privacy Policy

This privacy policy governs the types of personal data, the manner of use, and processing of user personal data collected during visits to the website or through the use of our services by the website operator. This privacy policy also governs the purposes and basis for processing personal data by the operator and the rights of individuals in this area.

The operator of the website and your personal data is:

Smart NARIS, an education and development company, d.o.o.

Beethovnova Ulica 2

1000 Ljubljana

URL: home.esmartarena.com

Phone: 01 600 45 37

Email: info@esmartarena.com

The operator pays great attention to the protection of personal data. The processing of personal data takes place exclusively within the framework of valid data protection regulations, especially the General Data Protection Regulation - Regulation (EU) 2016/679 (hereinafter: "GDPR"), the applicable Data Protection Act, and other valid Slovenian legislation in the field of data protection. Personal data are treated confidentially and used only for the purpose for which they are collected.

In connection with the use of the website, users are requested to also familiarize themselves with the General Terms of Use of the website and the Cookie Policy.

This privacy policy includes the following information:

• Contact details of the operator,
• The purpose, bases, and types of processing of various personal data of individuals,
• The retention period of individual types of personal data,
• The rights of individuals in relation to the processing of personal data,
• The right to file a complaint related to the processing of personal data,
• Validity of the Privacy Policy.

The terms used in this Privacy Policy have the following meanings:

"we", "us", "SMART ARENA" means the company Smart NARIS, an education and development company, d.o.o.

"personal data" means any information relating to an identified or identifiable individual.

"controller" generally means a natural or legal person, public authority, agency, or other body that alone or jointly with others determines the purposes and means of processing. The controller is Smart NARIS, an education and development company, d.o.o.

"Website" means home.esmartarena.com and all possible subpages of this website managed by the operator.

"Processing of personal data" means any operation or set of operations which is performed on 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.

 2. Purpose of processing and basis for processing personal data

SMART ARENA uses users' personal data only as necessary to achieve the purposes described in this Privacy Policy and only if we conclude that the processing does not harm you or infringe on your privacy in a way that would be contrary to our legitimate interest in achieving these purposes.

Processing of personal data based on a contract:

In accordance with the purpose of fulfilling a contract, the controller may process the following data of an individual for the following purposes: identification of the individual, management of registration on the website, notification of appointments and any changes, provision of services, transmission of additional details and/or instructions for using the services, resolving complaints related to services, billing for services, and for other purposes for executing contractual obligations.

Processing of personal data based on law:

Legitimate interest may be to assert or defend against legal claims or our legitimate interest in handling your claim or complaint or in responding to legal claims (Article 6(1)(f) GDPR or Article 9(2)(f) GDPR).

To a certain extent, in accordance with general regulations, the legal basis for processing by the controller is also due to the legal obligations of the controller and the need to respond to requests from official bodies or courts (Articles 6(1)(c) and (e) GDPR).

Processing of personal data based on the individual's consent:

A valid basis for processing personal data is also the individual's valid consent (Article 6(1)(a) GDPR). This applies particularly in the case of subscriptions to newsletters. You can revoke your consent to the processing of personal data at any time. In the event of revocation, the revocation has no effect on the processing of data based on your consent before the actual revocation.

3. Website Visit

• Automatic data storage

Every time the Website is visited, web server log files are automatically stored on the server. This includes, but is not limited to, the following data (hereinafter "log file data"):

• Information about the type and version of the browser
• Information about the user's operating system
• Information about the internet service provider
• User's IP address
• Date and time of access

SMART ARENA collects data about the user's use of the website, the time spent on each sub-page of the Website, the total time of the visit to the Website, and the manner of movement on the Website, relating both to the manner and purpose of use. This data is important for us because it allows us to ensure the expected and quality level of the website's operation and at the same time act in accordance with our legal obligations and in line with our desire for continuous improvement of the services we offer you.

Purpose of processing: Data from log files are anonymously evaluated to fulfill the following purposes:

• Continuous improvement and adaptation of the website to users,
• Quick and efficient error correction,
• Access to, operation, administration, and improvement of the Website and business premises and other aspects of our business,
• Analysis of usability and quality for improving our Website; 
• Fulfillment of our legal obligations and for asserting, exercising, and defending legal claims.

These data are stored using cookies, the use of which you confirm each time you visit the website. More about cookies on our Website can be read in the Cookie Policy.

Retention period: data is retained for 30 days from the day of the website visit. More provisions related to this are contained in the Cookie Policy Usage Policy.

4. Use of the contact form on the website

• Personal data submitted in the contact form

If a user actively submits personal data, for example, by filling out an individual online contact form, registering, or in any other way, these data will be collected by the controller.

By submitting personal data for the purpose of information about services, the person submitting the data guarantees that: (i) they are authorized to submit this information; (ii) that you have informed the person about the content of this notice; and (iii) that you will take care of updating and the accuracy of personal data after they have been provided to us.

SMART ARENA thus collects the following data: name, surname, email address, phone number, company name.

Purpose of collection: Personal data obtained through the use of the contact form on the Website will be processed by SMART ARENA for the purpose of: identifying the individual, communication, informing about services and any changes, ensuring services.

The basis for processing is your consent and legitimate interest, as well as for fulfilling the contractual interest with the user of services or our customers (subscribers).

Retention period: data is retained for 5 years from the completion of the contact form or for a longer period if allowed by applicable law.

6. Assessment of provided services

In the event that the user agrees at the end of the process of submitting the contact form or inquiry for a self-paid service or related process on the Website, the user may be invited to submit a rating or opinion on the service provided after the service is completed. The user of the website voluntarily decides whether to respond to the questions and give an opinion or not.

Purpose of processing: for the purpose of sending a questionnaire to the user by email, the operator processes the personal data of the individual, namely his email address, service appointment (if available) and information about the service used by the user. The purpose of collecting such personal data is also due to the analysis of satisfaction regarding the provided service.

The basis for such data processing is the individual's consent (Article 6(1)(a) GDPR).

Retention period: After the questionnaire is completed and returned by the user, this data is deleted, as the purpose of use has been achieved and they are no longer needed for further processing.

7. Data of users/customers - limitation of the controller's liability

All data that you provide to SMART ARENA, including information and materials provided in the context of your inquiries, responses, requests for information, and comments (hereinafter "User Content") is your exclusive responsibility and SMART ARENA is not liable for it. The user is solely responsible for the data they provide through the application or via it and consequently assumes all responsibility for the accuracy and timeliness of such submitted data.

By using the Website, you agree and confirm that you are fully responsible for all content that you provide to us. SMART ARENA does not control User Content and does not guarantee its accuracy, completeness, and quality. SMART ARENA is not responsible for any loss or damage that your reliance on the provided information and data may cause.

Please notify us of any alleged violations in connection with User Content at the email address: info@esmartarena.com. The content you provide to us will be read, and the data will be used and collected only by SMART ARENA or by persons authorized by SMART ARENA for the purpose of resolving the alleged violation in connection with User Content.

8. Retention of personal data

SMART ARENA stores your personal data in accordance with one of the retention periods listed below:

• In the case where your data is processed solely based on your explicit consent, until the revocation of consent to the processing of personal data on your part,
• In the case where the purpose for which the personal data was obtained has already been fulfilled, but before that, there was no revocation of consent to the processing of personal data, until the fulfillment of the purpose or
• If the retention of personal data is necessary to protect the interests of SMART ARENA in relation to the content of communication initiated through the contact form, until the expiry of the periods for asserting your rights and obligations or the rights and obligations of SMART ARENA.

After the retention period of personal data has expired, SMART ARENA will permanently delete, anonymize, or block access to them, thus making it no longer possible to associate personal data with you.

9. Controller and contractual processors of personal data

We may entrust your personal data to our carefully selected contractual partners who provide sufficient guarantees for an appropriate level of protection of personal data and their lawful processing based on a contract. We may also share your personal data with authorized auditors and external consultants.

Your personal data is not transferred to third countries. Before any possible transfer, we will explicitly inform you about it and ask for your consent.

10. User rights in relation to collected personal data

In accordance with the GDPR and the current law regulating data protection, you have the following rights in connection with your personal data:

a) The right of access to personal data,

b) The right to rectification if personal data is inaccurate,

c) The right to erasure ("right to be forgotten"),

d) The right to restriction of processing,

e) The right to withdraw consent,

f) The right to data portability,

g) The right to object and complain to the Information Commissioner.

All requests with which you wish to exercise any of the rights listed above can be sent to info@esmartarena.com. SMART ARENA reserves the right to verify your identity before proceeding with your request:

a) a) The right of access to personal data

Every user has the right to know whether personal data related to him is being processed, and if so, has the right to access personal data (insight or provision of a copy of personal data) and information about the following: the purpose of processing, the type of personal data that is processed, about the persons who process your personal data (users or categories of users to whom personal data have been or will be disclosed), about the retention periods or criteria for determining retention periods, about the existence of the right to rectification, the right to erasure and the right to restriction of processing of your personal data, about the right to object to the processing of personal data, about the right to file a complaint with the supervisory authority, about the source of the data if the personal data were not obtained directly from you, and about the possible existence of automated decision-making, including profiling.

b) b) The right to rectification if personal data is inaccurate

Everyone has the right to request that SMART ARENA rectify or complete personal data of an individual that is inaccurate or incomplete.

c) c) The right to erasure ("right to be forgotten")

An individual may request the erasure of all personal data related to the individual available for processing by SMART ARENA in the following cases:

• if the purpose of processing for which the individual's personal data were collected has ceased,
• if the individual has withdrawn consent to the processing of personal data and there is no other legal basis for processing,
• if the individual has objected to the processing of personal data and all legally defined conditions are met (cases where the controller does not have the right to reject the individual's objection)
• if SMART ARENA has processed personal data unlawfully (without a legal basis) or
• if the erasure of personal data is required as a legal obligation imposed on SMART ARENA by the law of the member state (applicable to SMART ARENA) or EU law.

d) The right to restriction of processing of personal data

An individual may at any time restrict the processing of their personal data if:

• the data being processed is not correct, and the incorrectness of the data relates to the period that SMART ARENA as a data processor can verify, and when asserting the right to objection or rectification, namely in the interim time of deciding on this right, or
• the data is processed unlawfully, but at the same time you do not want the controller to delete your data, or
• when the data controller no longer needs the data, but you need it to assert, exercise, or defend legal claims, SMART ARENA as a data processor no longer needs this data since the purpose of processing has ceased.

Restriction cannot be demanded if there is a legal basis for processing in the law or in consent.

e) The right to withdraw consent

Consent to the processing of personal data, which the individual gave for the processing of personal data, can be revoked at any time, without affecting the legality of the processing of data that was lawfully carried out based on consent until its revocation.

f) f) The right to data portability

An individual may at any time request their personal data processed by SMART ARENA in a structured, commonly used, and machine-readable format. Thus obtained personal data may be forwarded by the individual at any time to another controller or request that the data be forwarded directly to another processor (where technically feasible), without SMART ARENA hindering you in this.

This right particularly applies in cases where the controller processes personal data using automated means based on the individual's consent or due to a contract.

Transfer cannot be requested if it would negatively affect the rights and freedoms of others.

g) The right to object and complain to the Information Commissioner.

Objection to the processing of personal data is related to the processing of personal data on the legal basis of legitimate interests of the public or private sector (Article 6 (1f) or (1e) of the Regulation). You cannot assert an objection if it is not a processing that would take place on the basis of a legitimate interest, but takes place on another legal basis, e.g. on consent.

The right to object thus gives the individual the opportunity to object to processing carried out on the basis of legitimate interests, the controller must immediately cease processing unless it proves that there are compelling legitimate reasons for processing.

When SMART ARENA processes an individual's data for the purpose of direct marketing, the individual can object to such processing at any time, and SMART ARENA must immediately cease informing in the event of an objection.

SMART ARENA will stop processing your personal data in the event of an objection, unless it proves compelling legitimate reasons for processing that outweigh the interests of the individual, rights, and freedoms, or for asserting, exercising, or defending legal claims.

If you believe that SMART ARENA does not handle your collected personal data in a manner prescribed by the relevant legal provisions, you can file a complaint with the Information Commissioner (Dunajska cesta 22, 1000 Ljubljana, email address: gp.ip@ip-rs.si, phone: 012309730, website: www.ip-rs.si).

11. Changes to the Privacy Policy

We reserve the right to change or amend this privacy policy at any time, and therefore we advise constant and regular monitoring of this Privacy Policy.

©Smart NARIS d.o.o. (Ljubljana, June 2023)