1 Who Are We
ABS Center d.o.o., incorporated and registered in Slovenia, registration address Kvedrova cesta 12, 6000 Koper, company ID number: 5352282000.
Your personal data is controlled by ABS Center d.o.o. who is the data controller in regard to its Services. Should you have any privacy related question, please contact us: email@example.com.
3 When and How Do We Collect Personal Information?
“Personal Information” means any information about an individual from which that person may be identified. Personal Information includes obvious things, like your name, telephone number, email address, street address, as well as less obvious things like your IP address, device ID and location information. Personal Information does not, however, include information from which the identity of an individual has been definitively removed (also known as anonymous or anonymized data).
We collect Personal Information directly from you when you provide it to us, such as when you take any action while visiting our Website or using our Services or otherwise communicate with us, verbally or in writing. We may also collect information indirectly through automated technologies, such as cookies, or from third parties.
4 Types of Personal Information We Collect
4.1 Personal Information You Provide
We collect Personal Information that you provide in the process of using our Services or otherwise. We receive and store any information you knowingly provide to us. The Personal Information you provide to us may include some or all of the following:
- Basic Information. We ask for basic information needed for acquiring our license, such as: name and surname, company information that may include personal data (for example: authorized person), email, address (street, house number, city, country), etc.
- Any other Personal Information that you voluntarily choose to provide to us.
We may communicate with you if you've provided us the means to do so. For example, if you've given us your email address, we may send you promotional email offers on behalf of other businesses or email you about your use of the Services. If you do not want to receive communications from us, please indicate your preference by opting out of receiving such emails.
4.2 Personal Information We Collect Automatically
We collect certain information automatically from your device. Our web servers log some technical information automatically. Accordingly, Personal Information that we collect automatically may include the following:
Log Information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information.
Usage Information: We collect information about your usage of our Services.
Location Information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions.
5 How we use Your Information
We use the information we collect about you/your device to deliver services and our App/Software to you and to operate our business. We use it also for improving our services, for enhancing security and for analytics and research purposes to make sure we provide you with the best experience. In addition, we use your information to promote our services. We use your information for the following purposes:
Delivering and improving our services: We use your information for developing, delivering and improving our Software and other products, services, and content, tailoring our products and services, providing updates, technical troubleshooting, understanding and analyzing trends in connection with usage of the Software and administering the Software.
Analytics and research: We use your information for understanding and analyzing trends in connection with the usage of the Software, data about where the Software was downloaded from.
Customer Support: We use your information for providing customer support to you and to respond to your inquiries.
Our legal obligations: We use your information when we are required to do so by law, for example we use your country or region for tax reporting purposes.
For Safety and Security. We store technical logs of your activities. In line with the best practice, only authorized staff members can access personal data and only when required for user safety or critical systems issues.
For Marketing or Communication Purposes. We use your data (email, full name - if provided, IP address or other identifier assigned by a third-party service provider). You can unsubscribe from receiving our marketing material at any time by clicking “unsubscribe” link which is present in any email or by emailing us to: firstname.lastname@example.org.
6 Legal Basis
For users located in the European Economic Area (EEA), we must have a valid legal basis in order to process your Personal Information. The main legal bases under the European Union’s General Data Protection Regulation (GDPR) that justify our collection and use of your Personal Information are:
Contract performance: This covers data that is processed by us in order to provide you with Services that you have requested.
Consent: Where you have consented to our use of your personal data.
Legitimate interests: This covers data processed by us for the purposes that can be reasonably expected within the context of your use of our Services to pursue our legitimate interests, in order to improve our Services and your experience, for general social benefits, for marketing our Services, exploring business opportunities, for scientific research and to enable us to offer a safe and secure service.
Legal Obligation. This covers information that is processed by us to comply with a legal obligation, for instance is to maintain records for tax purposes.
7 How We Share Your Information
We do not sell our users’ private personal information. We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:
Legal and Regulatory Requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request.
To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Spry.
Third Party Technology and Providers. Third party providers are data processors. This means they process your information on our behalf, in accordance with our instructions. We only allow your information to be used by them to offer services to us. How third-party providers' use of information is controlled by the terms of their contract with us and any settings enabled by us through the user interface of their product.
Service Providers. We may share your Personal Data with our Service Providers, such as auditors, lawyers, consultants, accountants, and insurers; service providers who assist us with recruiting, blog delivery and other services, translators, etc. We do not allow our third-party service providers to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.
We require all third-party service providers to respect the security of your Personal Information and to treat it in accordance with the law
8 How Long Do We Keep Your Personal Information?
Some exceptions from static retention periods may occur. For instance, we cannot delete Personal Information when there are legal obligations to retain it (e.g., payment documentation, obligations arising from tax or commercial law, or our obligations as legal advisors). This is particularly true of financial data and payment information, as well as any information provided in connection with our legal representation of you. Information regarding existing licenses are stored permanently. Additionally, we cannot delete Personal Information when it is needed for the establishment, exercise or defense of legal claims (“litigation hold”). In this case, the Personal Information can be retained as long as needed for exercising respective potential legal claims.
In some instances, we may choose to anonymize your Personal Information instead of deleting it, for statistical use, for instance. When we choose to anonymize, we implement measures so there is no way that the Personal Information can be linked back to you or any specific user.
Please contact us if you would like more information.
9 Protecting Your Personal information
We have put in place reasonably appropriate technical and organizational measures to protect the Personal Information that we collect and process about you. While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks. The measures that we use are designed to provide a level of security appropriate to the risk of processing your Personal Information.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. We also require those parties to whom we transfer your Personal Information to comply with the same. While we take all reasonable steps necessary to provide the most secure Website, you understand and assume the risks associated with your activities on the Internet.
11 Links to Other Websites
12 Your Rights
You have certain rights in connection with your personal information and how we handle it, i.e. you have a right to obtain information about whether we hold personal information about you, to access personal information we hold about you, to obtain the correction, update, amendment or deletion of your personal information and to turn to supervisory authority. Some of these rights may be subject to some exceptions or limitations. You can exercise these rights at any time by sending your requests regarding your personal information to: email@example.com. Your rights include:
Right to object. You have the right to object to the processing of your personal information that is processed on the grounds of legitimate interests (see Legal Bases below). You are always free to opt out from the future collection of your personal information by uninstalling our Software from each of your computing devices.
Right of access. You have a right to know what information we hold about you and, in some cases, to have the information communicated to you. If you wish to exercise this right, please contact us by letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will explain to you why. We will try to respond to any request for a right of access as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity.
Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please contact us via firstname.lastname@example.org and we will correct it as soon as we can.
Data deletion. You have a right to request deletion of the personal information that we hold about you. Should you wish to do that, please contact us via email@example.com. We reserve the right to ask to provide us additional information to verify your identity before we can start processing your request. Once we receive all information we need in order to be able to identify you, we will delete your personal information you requested us to delete as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity. Please note that we may still retain some or all of that information, for example for complying with our legal obligations and protecting or enforcing legal rights. We may also retain your information in an anonymous form.
Data portability. In some circumstances, you have the right to request that we provide you with the personal information which you have provided to us, so you can transfer this information to another data controller. Should you wish to do that, please contact us via firstname.lastname@example.org.
Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your personal information.
Right to file a complaint. You have the right to file a complaint against us. To do so, contact the supervisory authority in your country of residence.
14 Final Provisions
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