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Privacy Policy

Dakila Institute

Dakila Association, Zagrebška cesta 20, 2000 Maribor; The Personal Data Protection Policy of Dakila Association is a document by which the controller fulfils its obligations under Articles 13 and 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as the "General Data Protection Regulation"). The content of the Personal Data Protection Policy is as follows:

1. About the Personal Data Protection Policy 

The purpose of the Personal Data Protection Policy (hereinafter referred to as the "Policy") is to inform users and other persons (hereinafter referred to as "Individuals") about the purposes and basis for the processing of personal data by the Dakila Association, Zagrebška cesta 20, 2000 Maribor (hereinafter referred to as the "Dakila Association") and the rights of Individuals in this area. At the same time, this Policy further clarifies the consent to data processing. Definitions written with a capital letter shall have the meanings given in the General Terms and Conditions for the Provision of Services to Users and the General Terms and Conditions for the Provision of Services to Legal Entities and Entrepreneurs (hereinafter: General Terms and Conditions), unless otherwise specified in the Policy. In accordance with the General Data Protection Regulation, the following information is included in the Policy: contact information of the Dakila Association and the contact details of the Data Protection Officer, the purposes, grounds and types of processing of various types of personal data of Individuals, including the creation of a profile of the personal data of Individuals, the transfer of data to third parties and to other countries, the storage period for individual types of personal data, the rights of Individuals in relation to the processing of personal data, the right to lodge a complaint in relation to the processing of personal data. Where applicable, the provisions relating to Individuals shall also apply to issues of secrecy and confidentiality of communications of users who are legal persons.

2. Controller and Data Protection Officer 

The controller of the personal data of Individuals processed in accordance with the Personal Data Protection Policy is the Dakila Association, Zagrebška cesta 20, 2000 Maribor. The Dakila Association has appointed a Data Protection Officer who can be contacted at the following e-mail address info@dakila.si

3. Purposes of processing and grounds for processing 

3.1. Processing on the basis of a contract

Dakila processes the personal data of Individuals for the performance of its obligations under a contractual relationship for services, including value-added services, or the sale of goods. In the context of exercising rights and fulfilling contractual obligations, Dakila Society processes the personal data of Individuals for the following purposes: Identification of the Individual, conclusion of the contract, supply of services or goods, home delivery of goods and/or documentation, notification of changes in legislation in a specific area or changes to the terms and conditions of sale, implementation of changes to membership fees, implementation of changes to the contractual relationship, billing for services, resolution of any technical problems, complaints or claims of Individuals, sending notices to Individuals in connection with the performance of memberships or other contractual relationship, carrying out any collection procedures, selling receivables, and for other purposes necessary for the performance or conclusion of the contractual relationship between Dakila Association and the Individual.

For the purposes of the provision of the services and related services ordered by the Individual, Dakila Society shall, for as long as it is necessary for the provision of these services, process all the data necessary for this purpose. This includes, in particular, the individual's login and data communications, including SMS/MMS communications; internet data and data and notifications, by SMS, e-mail or, where applicable, voice alert upon connection; data relating to the activation or expiry of the membership fee and the options available; the activation or change of membership and accessibility; the activation of the opt-in and the (foreseen) deactivation of the membership fee; and the status, in accordance with the General Terms and Conditions, of the Individual's linked account. For the purposes of monitoring and verifying the quality of the provision of the Services and correcting any technical faults, the Dakila Association provides for the recording of technical parameters that may be related to the Individual. The processing of the Personal Data of the Individual may also be part of additional services ordered by the Individual, which are not part of the relationship between the Member and Dakila Association for the provision of services by Dakila Association. A contract for such services may also be concluded by making the appropriate choice on the Website. The Individual is informed of the possibility that, when registering for certain services or in connection with the exercise of certain contractual rights and obligations, the Individual's identity may be verified by means of authentication. Dakila Association shall not be liable for any disclosure of personal data or misuse of the identity of the Individual resulting from inadequate protection by the Individual. 

3.2. Processing under the law

Dakila processes the personal data of Individuals for the purposes of activating or terminating membership or other services, such as access to the Library or activation of contracts offered by the Association. Data on the status of membership and other services are any data also processed over an electronic communications network. This includes, for example, the IP address of a user's computer or telephone. The Dakila Society may store and process data about Individuals if it is needed for the billing of services and for payments.

3.3 Dakila also processes data on the basis of legitimate interestpursued by the Dakila Society or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data, in particular where the data relate to a child. Where further use of the data collected about the Data Subject is concerned, the Dakila Association shall carry out an assessment in accordance with the General Data Protection Regulation. For example, such further use of data in aggregate form constitutes a legitimate use of the data for other business or technical analyses of the Dakila Society, the creation of predictive models of behaviour, and the like. As an additional measure, some forms of further use of data also involve the deletion of certain data. In accordance with the General Data Protection Regulation, direct marketing is also a legitimate interest. For the purposes of direct marketing, the Dakila Association may create profiles of Individuals based on relationship information on the grounds of legitimate interest. The Data Subject has the right to object to that processing in accordance with point 6.4 of the Policy.

In accordance with its legitimate interest, Dakila processes personal data to the extent strictly necessary and proportionate to ensure business continuity, security and information, i.e. the ability of the information system to prevent, at a certain level of confidence, accidental events or unlawful or malicious acts that compromise the availability, authenticity, integrity and confidentiality of the personal data stored or transmitted, as well as the security of the related services offered by or accessible through the networks and systems. This includes, for example, the prevention, dissemination of malicious codes, denial of service attacks and damage to computer and electronic communication systems. This may include the processing of network diagnostic data (technical data or equipment readings) and historical data in diagnostic tools that could allow re-identification of the Individual. Dakila has a legitimate interest in aggregating and further using the data for analysis and purposes until the expiry of the legal retention period. Other legitimate interests include the prevention of abuse, the assertion of claims or the defence of claims in administrative and judicial proceedings.

In the event of suspected abuse, Dakila shall process data about Individuals to the extent appropriate and proportionate for the purpose of identifying and preventing possible fraud or abuse and may, if appropriate, also share such data with other business partners, the police, public prosecutors or other competent authorities. For the purpose of preventing future abuse or fraud, information about the history of identified abuse or fraud in relation to the Individual, which includes information about the relationship between the Individual and Dakila Association and, for example, the IP address, will be retained for five years after the termination of the business relationship.

In order to prevent the same information from being provided to members of the same household several times and to avoid unnecessary invasions of privacy, Dakila may link the data of persons living in the same household on the basis of contractual information (e.g. name, surname, address, purchase or membership fee). Individuals have the possibility to correct the presumption that they are in the same household with Dakila. Dakila reserves the right to process data on the fulfilment of contractual obligations of Individuals (bill payment data) in order to ensure a higher quality of its services and to ensure a subsequent disconnection of services to Individuals who pay their contractual obligations on time. Dakila wishes to inform Users and process personal data according to their preferences, and therefore uses contact details, telephone number, username and consent data to solicit consent from Users in the legitimate interest. The processing of data may be based on the consent given by the individual to the Dakila Association. Such consent will always be informed, free and specific. Consent relates to the provision of information about news and services of the Dakila Association or other partners, the provision of information tailored to the individual's habits or the provision of value-added services. The communication is carried out through the channels chosen by the Individual in the consent. Consent given for a particular channel may also include consent for a similar channel of communication. Notification via digital channels (e.g. Facebook, Instagram, etc.) shall be made using an e-mail address. The data subject may withdraw or modify his or her consent at any time in the same way as consent was given or in another way as specified by Dakila Association, where Dakila Association reserves the right to identify the customer beforehand. Changes to the consent may be arranged, inter alia, by e-mail, on the website, by telephone or in person at the headquarters of the Association, Zagrebška cesta 20, 2000 Maribor. Withdrawal or modification of consent relates only to the data processed on the basis of the consent. The last consent given by the Individual and received by the Dakila Association is valid. The possibility to withdraw consent to the processing of personal data for a specific purpose does not constitute a right of withdrawal in the Individual's relationship with Dakila Association. Consent may be given by a parent, foster parent or guardian in respect of a minor child who, in accordance with applicable law, is unable to give consent himself or herself. Such consent shall remain valid until revoked or modified by the parent, foster parent or guardian or by the child himself/herself once he/she has acquired this right in accordance with applicable law. In the absence of revocation, the data for which consent is given shall continue to be processed to a limited extent after the termination of the business relationship with Dakila Association.

4. Transfers of data to third parties and transfers of data to third countries (countries that are not members of the European Union or the European Economic Area)

Dakila Association may, insofar as it is compatible with the purpose for which the personal data is processed under EU law and Slovenian regulations, transfer personal data about Individuals: (I) to persons performing specific processing tasks for Dakila Society, such as, for example, the preparation and transmission of invoices or data analytics, maintenance and development of the network and services, including software, where these tasks involve the processing of Personal Data to the extent necessary; (II) to other operators of Electronic Communications Services and networks to the extent necessary for the provision and billing for these services. Account data may only be processed within Dakila by authorised persons who, under Dakila's supervision, are responsible for billing or managing traffic, answering questions from Individuals, detecting fraud, providing value-added services, or performing other tasks that require the processing of personal data, such processing to be limited to the extent necessary for the purposes of such activities.

5. Period of retention of personal data

For the purpose of fulfilling contractual obligations, billing data and related contact data of Individuals shall be stored until full payment for the service or until the expiry of the limitation periods for each claim, which by law range from one to five years. Invoices shall be kept for 10 years after the end of the year to which the invoice relates in accordance with the law governing value added tax. The turnover data shall be kept for the current and the three preceding accounting periods or until the invoice has been paid in full. If the turnover data is processed on the basis of the consent of the Individual for the purpose of marketing goods or providing value-added services, such data may be processed to the extent necessary for as long as it is necessary for such marketing or services.

6. Individuals' rights in relation to the processing of personal data

Dakila shall ensure that Individuals exercise their rights without undue delay and in any event within one month of receipt of the request. Dakila may extend the time limit for the exercise of the rights of the Individual by up to two additional months, taking into account the complexity and number of requests. If Dakila Society extends the time limit, it shall notify the Individual of any such extension within one month of receipt of the request, together with the reasons for the delay. Dakila Society shall accept requests regarding the rights of an Individual by email to the following address info@dakila.si or by post to the Dakila Society, Zagrebška cesta 20, 2000 Maribor. The individual may also submit the request in person at the address of Društvo Dakila, Zagrebška cesta 20, 2000 Maribor. Where the Data Subject submits the request by electronic means, the information shall, where possible, be provided by electronic means, unless otherwise requested by the Data Subject. Where there is reasonable doubt as to the identity of the Data Subject making a request in relation to any of his or her rights, the Dakila Society shall request the provision of additional information necessary to confirm the identity of the Data Subject. The Dakila Society provides the following rights to individuals in relation to the processing of personal data:

  • the right of access to data, 

  • the right to rectification, 

  • the right to erasure ("right to be forgotten"), 

  • the right to restrict processing,

  • the right to data portability,

  • the right to object. 

 6.1. Right of access to data

The data subject shall have the right to obtain confirmation from Dakila as to whether or not personal data concerning him or her are being processed and, where this is the case, to have access to the personal data and to additional information relating to the processing of the personal data, which shall include:

  • types of personal data;

  • the purposes of the processing; 

  • the users or categories of user to whom personal data have been or will be disclosed, in particular users in third countries or international organisations;

  • the existence of a right to obtain from the controller the rectification or erasure of personal data or the restriction of the processing of personal data concerning the data subject, or the existence of a right to object to such processing;

  • where possible, the envisaged period of retention of the personal data or, if this is not possible, the criteria to be used to determine that period; 

  • the right to lodge a complaint with the supervisory authority; 

  • where the personal data is not collected from the Data Subject, any available information regarding its source; 

  • the existence of automated decision-making, including profiling, and meaningful information about the reasons for it, as well as the meaning and intended consequences of such processing for the Data Subject.

Upon the request of the Data Subject, Dakila shall provide a copy of his or her personal data being processed. For additional copies of the data requested by the Data Subject, Dakila Society may charge a reasonable fee, taking into account administrative costs. 

6.2. Right to rectification

The data subject shall have the right to obtain from the Dakila Society the rectification of inaccurate personal data concerning him or her without undue delay. The data subject shall have the right, having regard to the purposes of the processing, to have incomplete personal data completed, including by submitting a supplementary declaration. 

6.3. Right to erasure ("right to be forgotten")

The data subject shall have the right to have personal data concerning him or her erased by Dakila without undue delay and Dakila shall have the obligation to erase the personal data without undue delay:

  • where the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;

  • where the Data Subject withdraws the consent on which the processing is based and there is no other legal basis for the processing; 

  • where the Data Subject objects to processing on the basis of a legitimate interest of Dakila Association, but there are no overriding legitimate grounds for processing;

  • where the personal data must be erased in order to comply with a legal obligation under EU or Slovenian law; where the data is incorrectly collected from a child who is not able to provide such data under the applicable law.

Where directory or other published data are involved, the Dakila Society shall take reasonable steps, including technical measures, to inform the controllers processing the personal data that the Data Subject has requested them to erase any links to, or copies of, such personal data.

6.4. Right to restriction of processing

The data subject shall have the right to obtain from the Dakila Society the restriction of processing where:

  • The data subject shall contest the accuracy of the data for a period which allows the controller to verify the accuracy of the personal data; 

  • the processing is unlawful and the Data Subject objects to the erasure of the personal data and requests instead the restriction of their use; - the Dakila Society no longer needs the personal data for the purposes of the processing, but the Data Subject needs them for the establishment, exercise or defence of legal claims; 

  • the Data Subject has lodged an objection to processing, pending verification that the legitimate grounds of the controller override those of the Data Subject. 

6.5. Right to data portability

The data subject shall have the right to receive personal data concerning him or her which are in the possession of Dakila Association in a structured, commonly used and machine-readable format, and the right to communicate such data to another controller, without being prevented from doing so by Dakila Association to which the personal data have been provided, where:

  • the processing is based on the consent of the Data Subject or on a contract; and

  • processing is carried out by automated means.

 6.6. Right to object

The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her, provided that the processing is based on legitimate interests pursued by the Dakila Society or by a third party. The Dakila Society shall no longer process the personal data unless it demonstrates compelling reasons for the processing which override the interests, rights and freedoms of the Data Subject or for the establishment, exercise or defence of legal claims.

7. Right to lodge a complaint concerning the processing of personal data

The individual may send any complaint concerning the processing of personal data to the following e-mail address info@dakila.si or by post to the Dakila Society, Zagrebška cesta 20, 2000 Maribor. The individual may also submit a complaint at the point of sale of the Dakila Association. Any Data Subject also has the right to lodge a direct complaint with the Information Commissioner if he/she considers that the processing of personal data concerning him/her violates Slovenian or EU legislation on the protection of personal data. If the Individual has exercised the right of access to data with Dakila Association and, following the decision received, Dakila Association considers that the personal data received is not the personal data requested or that he/she has not received all the personal data requested, he/she may, before lodging a complaint with the Information Commissioner, lodge a reasoned complaint with Dakila Association within 15 days. Dakila must decide on the complaint as a new request within five working days. 

8. Validity of the Privacy Policy

This Policy is published on dakila.si and will enter into force on 23.8.2023.

#DAKILA2023

Dear members and sympathisers of Dakila.

We would like to inform you that due to an emergency situation and the inability of Urandir and other guests from Brazil to arrive in Slovenia, the Rogla 2023 event will be postponed to the spring of 2024.

Those of you who have already purchased tickets for the Rogla 2023 event will be able to use them at that time. The deposits you have paid to book your accommodation will also apply then. We will inform you about the postponed event when we have more information from Brazil. We sincerely apologise for the situation and ask for your understanding and patience. Ultimately and in the actual direction, things will always fall into place and unfold in the best way for all involved.

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