The purpose of this Privacy Policy and Cookie Usage ("Policy") is to inform subscribers, users, customers, and other individuals (hereinafter also referred to as "individual") about the purposes and legal basis for processing personal data by the company Lumada d.o.o., Tacenska cesta 123a, 1000 Ljubljana ("controller"), as well as the rights of individuals in this area.
This Policy applies to the following websites: www.religi.eu, app.religi.eu, and the Religi mobile application, all managed by LUMADA d.o.o., Tacenska cesta 123a, 1000 Ljubljana.
In accordance with Regulation (EU) 2016/679 of the European Parliament and of the 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 the General Data Protection Regulation or GDPR) and the Personal Data Protection Act (Official Gazette of the Republic of Slovenia, No. 163/22, ZVOP-2), this Policy includes the following information:
Contact information of the company and the contact of the data protection officer,
Purposes, legal bases, and types of processing of different types of personal data of individuals, including profiling,
Transfer of data to third parties and to third countries,
Retention periods for different types of personal data,
Rights of individuals regarding the processing of personal data,
The right to lodge a complaint regarding the processing of personal data.
Where applicable, provisions relating to individuals also apply to issues of confidentiality and privacy of communications of users who are legal entities.
This Policy applies to the user from their first visit to the website and for all subsequent visits. By using the website, the user confirms that they have read, accept, and agree to all provisions of this Policy. The Policy may be changed or supplemented at any time without warning or notice. By using the website after a change to this Policy, the user confirms agreement to the changes.
The controller (and provider) of the websites is:
LUMADA d.o.o.
Tacenska cesta 123a, 1000 Ljubljana, Slovenia
Registration number: 6220312000
Tax number: SI 27132064
Telephone number: + 386 70 704 581
Email: info@religi.eu
The controller has not appointed a data protection officer, as it does not process personal data to the extent requiring this obligation. Since your privacy is extremely important to us, you can always contact us with questions regarding the processing of your personal data via the telephone number or email provided above.
The company undertakes to protect the confidentiality of personal data and the privacy of participants or users of the website and will take all necessary steps to protect them from any violations or misuse, as the protection of users' privacy is very important to us.
At LUMADA d.o.o., we process personal data in accordance with the applicable ZVOP-2, the General Data Protection Regulation, and the Personal Data Protection Policy of LUMADA d.o.o., which regulate the processing of personal data, procedures, and security measures, including responsibility and supervision in the process of their processing.
The provider processes personal data based on the individual's personal consent, based on a concluded contract, or based on the law.
Every user of the websites who enters personal data on one of our websites also gives active personal consent for the processing of personal data by submitting a specific form before sending an inquiry/order/subscription to e-newsletters/registration on the portal.
The provider collects the following data about users of our websites:
Subscription to e-newsletters: name and email address;
Registration in the application/portal: name, surname, telephone (landline/mobile), email, company name (address, tax and registration number, region, country), purchase history; password in encrypted form, date and time of registration;
Forms for questions/inquiries: name, surname, telephone, email;
Any other data that the user voluntarily provides to the company.
The customer or user of the website, by clicking on the "I agree with the terms of business" button and the "I agree with the privacy policy" button, confirms that they have been properly informed in writing about the scope and purpose of processing personal data from the previous paragraph (the scope and purpose of processing personal data are also indicated on each web form on our websites) and also those that the controller obtains during the time the customer uses the controller's web or mobile application based on these general terms and privacy policy, which relate mainly to the following circumstances:
Device settings;
Language used by the customer,
Customer's location,
Whether the customer uses a smartphone, personal computer, tablet, and the operating system used by the customer,
Data on the user's use of the controller's website (dates and times of visits to the website, pages or URLs visited, time spent on each page, number of pages visited, total time spent on the website, settings made on the website),
Type and version of the browser through which the customer accesses the website.
The provider processes the IP addresses of the devices through which users access the website.
The provider uses "cookies" on the web portal to recognize users, but in such a way that it is not possible to identify users, meaning that based solely on the data collected in this way, it is not possible to determine the user's name, surname, and other identification data.
The collected data will be used by LUMADA d.o.o. exclusively for the provision of the services it offers and for the purposes and scope for which the customer or user has been clearly informed or instructed in advance.
In the case of using the collected personal data for marketing or advertising purposes by directly contacting the customer, the controller will clearly mark advertising messages as such and inform the customer of the possibility and method of unsubscribing from receiving such messages.
LUMADA d.o.o. undertakes not to disclose personal or other data to third parties without explicit permission or to allow third parties to access personal or other data of the participant or user, except if required by state authorities, if such an obligation is prescribed by law, or for the needs of proceedings before courts or other state bodies.
The provider will use the collected data about users exclusively for the following purposes:
To send an offer based on a received inquiry, telephone contact upon ordering goods/services or concluding a sales contract, sending invoices, and executing the sales contract;
Maintaining customer records;
Informing about news or offers from LUMADA d.o.o.;
Occasionally sending emails (if the individual subscribes to receive our emails) with content related to the website and special offers, notices, articles, current events, and benefits offered by LUMADA d.o.o.;
To deliver the ordered products/information you requested;
Statistical, marketing, and other analyses and research related to website users, with the aim of improving the provider's offer and services.
Sharing data with third parties and sharing data with third countries (countries that are not members of the European Union or the European Economic Area).
The company may, if this is in accordance with the purpose for which personal data are processed under EU law and Slovenian regulations, disclose personal data about individuals to:
Persons who perform individual processing tasks for the company, such as: preparation and sending of invoices or data analytics, maintenance and development of services, when these tasks include the processing of personal data to the necessary extent;
Persons who provide sales and marketing services for the company, including sales and marketing in the field, or cooperate with the company in the field of marketing and selling their own services or services of third parties, to the extent necessary for such tasks within the purposes and bases defined in this Policy;
In the case of ordering products offered by the provider and consequently delivery – the transfer of your certain data will be carried out based on your consent with the carrier's requirements and will relate to data necessary for the delivery of goods (order number, name and surname, contact number, and delivery address).
The collected personal data are not disclosed to other third parties or to third countries without an adequate level of protection. Your personal data may be transferred to the USA (within the provider of web analytics and email notification services), whereby we conclude appropriate contracts with all contractual processors in the USA.
If the company is merged with or acquired by another company, personal data are transferred to the acquirer in accordance with the law. By using our services, you consent to the further processing of your personal data by the acquirer.
The provider uses appropriate technological and organizational means to protect the transmission and storage of personal data.
Billing data and related contact data about individuals may be retained for the purpose of fulfilling contractual obligations until the full payment of the service or at the latest until the expiry of the limitation periods in relation to the individual claim, which may, by law, range from one to five years. Invoices are kept for an additional 10 years after the end of the year to which the invoice relates, in accordance with the law governing value-added tax.
If traffic data are processed based on the individual's consent for the purpose of marketing services, selling goods, or providing value-added services, these data may be processed to the necessary extent as long as it is necessary for such marketing or services. All other data obtained for the purposes of notification and direct marketing are retained until revoked.
The provider ensures the protection of personal data in accordance with this policy and with the requirements for the protection of personal data as set out in the legislation of the Republic of Slovenia (the applicable ZVOP-2) and the General Data Protection Regulation.
The user is aware and agrees that the provider stores their data provided during registration for as long as the user has the status of a registered user in the provider's applications or is a subscriber to e-newsletters, and for one year after the termination of this status or unsubscribe from e-newsletters. Other data may be retained as long as it is strictly necessary to achieve the purpose for which the data were collected, and then permanently deleted or effectively anonymized so that a particular piece of data can no longer be linked to a specific user.
Personal data collected based on the explicit consent of the individual are processed for the purposes defined by the consent and retained until the consent is revoked.
The user is also responsible for protecting personal data by ensuring the security of their username and password and appropriate software (antivirus) protection of their computer.
Regarding your personal data that we process, you have the right to:
Withdraw consent for the processing of personal data at any time (withdrawal of consent does not affect the lawfulness of data processing carried out based on consent before its withdrawal). If you only want to update personal data, you can do so, for example, in your account on the website,
Be informed: obtain confirmation as to whether we are processing your personal data,
Access your personal data relating to you and a copy of this information, obtain information about the purposes of processing, types of personal data, whether personal data are transferred to a third country or international organization, etc.,
Have inaccurate personal data relating to you corrected without undue delay and the right to have incomplete personal data completed,
Erasure (right to be forgotten): you can request that we delete personal data relating to you without undue delay in certain cases, such as when processing is no longer necessary for the purposes for which the personal data were collected or otherwise processed, or when we have collected personal data based on consent and you revoke consent for the processing of personal data, etc.,
Restriction of processing in certain cases, such as when you dispute the accuracy of the data, etc.,
Data portability: you have the right to receive personal data in a structured, commonly used, and machine-readable format and the right to transmit personal data to another controller in certain cases,
Object at any time to the processing of personal data concerning you based on our legitimate interest, the right to object to direct marketing and profiling if it is related to direct marketing,
State that a decision based solely on automated processing of personal data, including profiling, which produces legal effects concerning you or similarly significantly affects you, does not apply to you. If the decision is (1) necessary for entering into or performing a contract between you and us or (2) based on your explicit consent, we will implement suitable measures to safeguard your rights, freedoms, and legitimate interests and ensure at least the right to human intervention by the controller, to express your point of view, and to contest the decision,
The right to lodge a complaint with a supervisory authority, independent of the aforementioned rights, if you believe that the processing of your personal data constitutes a breach of the GDPR. You can lodge a complaint with the Information Commissioner, Dunajska 22, 1000 Ljubljana, email: ip@ip-rs.si, telephone: 00386 1 230 97 30, website: www.ip-rs.si.
Regarding all the aforementioned rights, you can contact us at any time:
By email: info@religi.eu
We will ensure that the request is fulfilled immediately, but no later than one (1) month. You will receive the requested personal data in a structured, machine-readable, and commonly used format. The first copy of your personal data in electronic or physical form is free of charge; any additional copies may be charged to cover the costs of preparing the copy.
The user can exercise their rights at any time by email to info@religi.eu or in writing to LUMADA d.o.o., Tacenska cesta 123a, 1000 Ljubljana, Slovenia.
These rights do not release you from the obligations you have under the General Terms and Conditions or those that the concluded contract with LUMADA d.o.o. has towards you.
Our websites may contain links to third-party websites. These websites have their own privacy policies, which you should familiarize yourself with, as we do not assume any responsibility for them.
Our website contains links to social networks (social network plugins); we have integrated links to Facebook and Instagram, which, when clicked on their icon, redirect to the mentioned social networks. The processing of personal data that social networks obtain when you click on the social network plugin and are redirected to the social network is carried out by the mentioned social networks and in accordance with their privacy policies, which are available at:
Facebook: Processing of personal data is carried out by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA; the privacy statement is available at https://www.facebook.com/policy.php.
Instagram: Processing of personal data is carried out by Instagram LLC, 1601 Willow Rd, Menlo Park, CA 94025, USA; the privacy statement is available at https://help.instagram.com/155833707900388.
Twitter: Processing of personal data is carried out by Twitter International Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07 IRELAND; the privacy statement is available at https://twitter.com/en/privacy.
LinkedIn: Processing of personal data is carried out by LinkedIn Corporation, 1000 West Maude Avenue Sunnyvale, CA 94085, USA; the privacy statement is available at https://www.linkedin.com/legal/privacy-policy.
The provider is not responsible for any damage that may occur to the user because they provided incorrect, incomplete, or outdated data to the provider when making an inquiry/subscribing to e-newsletters or later.
The controller of the website www.religi.eu kindly asks users who do not agree with this Policy or its changes or additions to leave the website and not use it in the future.
Our website www.religi.eu uses cookies, based on the Electronic Communications Act (ZEKom-2, Official Gazette of the Republic of Slovenia, No. 130/22 and 18/23 – ZDU-1O).
The controller of "cookies" and the website is the company LUMADA d.o.o., Tacenska cesta 123a, 1000 Ljubljana, Slovenia.
Our website uses cookies. Cookies are small text files that a website stores on individuals' devices with which they access the internet. Their storage is under the complete control of the individual, as they can limit or disable the storage of cookies in the browser they use. Cookies perform numerous functions – they enable tracking of website visits, enable various campaigns and discounts, enable system logins, provide support for social network plugins, and other functions.
Cookies provide a convenient way to keep content fresh and relevant, in line with the interests and preferences of the website visitor. Based on statistical data on website traffic, which cookies also enable, we can assess the effectiveness of our website design.
Consent to the installation of cookies is not required for necessary cookies. These enable the normal functioning of the website. Through these cookies, basic use of the website is enabled. Without these cookies, the website does not function normally or at all, so they are installed even if the individual refuses the installation of cookies.
Temporary or session cookies (session cookies) "live" from the moment you open the browser until you end the session and close the browser. They are removed from the computer when you close your browser.
Persistent or stored cookies (persistent cookies) remain stored even after the session ends, and they stay on the computer for approximately 6 months. The website uses them, for example, to analyze visits to our website so that we can further improve our offer.
Targeting or advertising cookies of third parties (Targeting Cookies): These cookies are used to offer content that is interesting to you based on your interests. Targeting cookies are often linked to the functionality of the website provided by another organization (hence the name third-party cookies) and are installed on the website with the permission of the website controller. They are used to limit the number of times an individual ad is shown and to help measure the effectiveness of an advertising campaign (e.g., they remember your visit to the website and pass the information to other organizations, usually advertising organizations or social networks through your actions such as clicking the "Like" button or "Share on Facebook" (AddThis to Facebook) and similar). Targeting cookies enable tracking of your actions on the web.
We use the following cookies:
LUMADA d.o.o.
| Cookie name | Duration | Purpose |
|---|---|---|
| PHPSESSID | When the browser is closed | Ensures the proper functioning of the website |
| Cookie name | Duration | Purpose |
|---|---|---|
| __utma | 2 years | Used to distinguish users; Google Inc. |
| __utmb | 30 minutes | Used to determine the session; Google Inc. |
| __utmc | When the browser is closed | Used to determine the session; Google Inc. |
| __utmz | 6 months | Used to determine the source of visitors; Google Inc. |
| _mauuid | 10 years | Used to distinguish users; Net-Results |
| __atuvc | 3 years | Used to distinguish users; AddThis |
GOOGLE ANALYTICS
On our website, we use Google Analytics. Google Analytics is a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). The entity responsible for users in the EU/EEA and Switzerland is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, Ireland, 1600. Google Analytics uses so-called "cookies" to analyze your use of the website. More information about this is available at: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Google uses all this data on behalf of the controller to evaluate your use of the website, compile reports on website activities, and provide additional services related to your use of the website and the internet. The IP address that your browser sends as part of Google Analytics is not merged with other Google data.
The processing of data by Google Analytics is carried out based on Article 6(1)(a) of the GDPR if you consent to the use of Google Analytics.
The company LUMADA d.o.o., Tacenska cesta 123a, 1000 Ljubljana, will handle all data collected on the website in accordance with the Personal Data Protection Act and the Electronic Communications Act (ZEKom-2), and will not sell or rent your personal data to third parties.
You can decide whether to use cookies. You can always fully/partially accept or refuse cookies, delete them, or disable them. You can view and manage cookies here (link: chrome://settings/content/cookies), and you can also disable Google Analytics tracking at the following link (https://tools.google.com/dlpage/gaoptout). For help with managing cookies, you can also refer to "user help" in your browser.
This Policy is published on our websites and enters into force on 28.02.2025.
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