PRIVACY POLICY Your privacy is very important to us, which is why we at CIRCULAR SHIELD d.o.o., Vodovodna cesta 101, 1000 Ljubljana, Republic of Slovenia, protect your personal data that you provide to us by visiting our websites (“Online Services”).   Below, you can read about how CIRCULAR SHIELD d.o.o., Vodovodna cesta 101, 1000 Ljubljana, Republic of Slovenia (“CS”) handles personal data.   The purpose of this Privacy Policy is to inform you what personal data we collect, how we collect it, the bases for its collection, and the purposes for which we collect it, as well as your rights in relation to personal data.   This CS Privacy Policy is compliant 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 (“General Data Protection Regulation”), and encompasses the following:

1. CS contact information,
2. legal bases and purposes of the personal data processing,
3. categories of the personal data we collect,
4. cookie use,
5. transmission of personal data,
6. personal data retention periods,
7. personal data protection,
8. rights of individuals,
9. changes to the Privacy Policy.

  1. CS CONTACT INFORMATION CS (CIRCULAR SHIELD d.o.o., Vodovodna cesta 101, 1000 Ljubljana, Republic of Slovenia) is the personal data controller. Any questions you might have regarding this Privacy Policy will be answered by the CS responsible person and/or data protection officer. You can contact the data protection officer at the indicated CS address, at the email address info@circularshield.org, or by phone on 08/200 6002.   2. LEGAL BASES AND PURPOSES OF THE PROCESSING CS collects, edits, stores, transmits, and otherwise processes the obtained personal data on the legal bases and for the purposes defined below.   Processing on the basis of legitimate interests CS may process personal data on the basis of pursued legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject. In the case of further processing of data collected about the individual, CS makes an assessment pursuant to the General Data Protection Regulation. Such further use of data in a pseudonymised or aggregated form represents the lawful use of data for marketing and other business analyses of CS. Erasure of certain data may also be used as an additional measure in some forms of further processing of traffic data. On the basis of legitimate interests, we may also process your personal data for the purposes of preventing fraud and asserting claims, or defending against them in administrative and judicial proceedings. On the basis of a legitimate interest, CS may process personal data to the extent strictly necessary and proportionate to ensure the functioning of its website and its Online Services, in particular to prevent any unauthorised access to your user account, the spread of malicious code, fraud, or other misuse of CS websites or intellectual property.   Processing on the basis of consent CS processes personal data on the basis of the consent to process personal data which the individual gives to the company for the following purposes:

• for direct marketing purposes – receipt of notifications. Notifications include current offers, benefits and/or invitations to events of the controller and their business partners, invitations to participate in prize competitions and contests, useful tips, news and reminders regarding Municipal Material Flow Cycles;
• to analyse our website traffic and to provide tailored service offers.

  Depending on the personal data provided, you may receive notices and tailored offers to your email address, or via SMS or MMS to the provided mobile phone number, or in printed form to the provided address.   You can withdraw or modify your consent at any time by clicking “Unsubscribe”, which is located at the bottom of the email, or by emailing a request for withdrawing consent for a specified purpose to info@circularshield.org, or by post to CIRCULAR SHIELD d.o.o., Vodovodna cesta 101, 1000 Ljubljana, Republic of Slovenia.   Where the consent includes direct marketing, CS may classify individuals into segments based on their use of CS websites for the purposes of tailored service and product offers.   3. CATEGORIES OF THE PERSONAL DATA WE COLLECT CS collects different data, including personal data, with which you can be identified directly or indirectly, if you entrust your personal data to us. We receive data when you sign up for notifications and when you visit our websites.   We collect the following personal data:

• basic personal data such as name and surname, email address, phone number, address (street name and number, postal code, town, country);
• technical information about your browser, computer, or mobile device when you access our Online Services.

  4. USE OF COOKIES  Cookies are loaded on your computer when you use our Online Services. You can read our Cookie Policy here.   5. TRANSMISSION OF PERSONAL DATA CS may transmit your personal data to third parties with whom it has signed contracts on the processing of personal data (“Contractual Processors”) for support, analysis, or service improvement purposes. Contractual Processors shall have access only to the personal data they require to be able to provide the services they perform for CS, and may not use it for any other purpose.   Notwithstanding the provisions regarding the duration of personal data retention in this Privacy Policy, we may store certain personal data for a longer period and transmit it to the state authorities in the Republic of Slovenia or the European Union if we find that such transmission is necessary and required by law or other regulations, e.g. for crime prevention and investigation purposes, to enable administrative or court proceedings and the like.   When using the Online Services outside the EU Member States, the transmitted data may be, in order to be able to provide the Online Services, transferred, stored, or processed in third countries where legislation governing personal data protection prescribes different standards than in the countries of the European Union or the European Economic Area. By using the services in these countries, you agree that your personal data may be transferred or transmitted to entities located in third countries. Please note that CS will otherwise not transmit your personal data to countries outside the European Union or the European Economic Area.   6. PERSONAL DATA RETENTION PERIODS Personal data shall be stored for as long as necessary to provide our services, or longer in the event of legal obligations.   Personal data obtained on the basis of consent is stored until the withdrawal of consent, but not more than 5 years.   Data concerning you that is no longer necessary for the purposes for which it was collected or otherwise processed may, at our discretion, be anonymised and aggregated with other non-identifiable data, to obtain insights into statistical information that we consider necessary or useful, such as service usage statistics and the like. All of this data is anonymised and cannot be linked to an identifiable individual.   7. PERSONAL DATA PROTECTION CS strives to adequately protect your personal data, but we cannot guarantee the complete security of the personal data you provide to us, and we are thus not responsible for any theft, destruction, loss, or unintentional disclosure of your personal data or information about you. We assure you that we will observe generally accepted standards to protect the received information, both during transmission and after receipt, but unfortunately, no method of electronic transmission or storage is completely secure and therefore we cannot guarantee complete security. CS uses SSL (Secure Sockets Layer) technology, which provides encryption of personal data. CS works with a company that ensures the security of our services and the personal data we receive. Moreover, CS servers feature additional protection in the form of firewalls and other data security technologies. However, you as users are also responsible for data protection by making sure your computers and mobile devices are secure. For transmitting your personal data over the internet, we recommend that you use a browser that supports SSL technology, and allows you to configure security features. Otherwise, the transfer of personal data may be risky and we cannot protect you in this case. We therefore recommend enabling your browser’s features to secure your data or notify you of any unsecured connections, thereby enhancing the security of your personal data. Please keep in mind that secure web addresses begin with https://, not with http://, and pay attention to the secure connection icon used by your browser to indicate secure communication with the server.   Since no connection over the internet can be completely secure, as already mentioned, we are issuing a limitation of our liability, because we cannot guarantee the complete security of the data you provide to us, which means that you are providing your personal data to us at your own risk.   8. RIGHTS OF INDIVIDUALS CS shall ensure the exercise of your rights in regard to personal data.  You can submit your requests by email to info@circularshield.org, or by post to CIRCULAR SHIELD d.o.o., Vodovodna cesta 101, 1000 Ljubljana, Republic of Slovenia, and we will reply in accordance with regulations.   Right to access data  You may at any time request that we confirm whether we are processing your data and provide information regarding the processing of your personal data (e.g. the category of personal data, the purpose of the processing, to whom it was or will be transmitted, the data retention period and the like).   Right to rectification You may at any time request that we allow you to rectify inaccurate personal data relating to you, and to complete any incomplete personal data we might have in our possession.   Right to erasure Pursuant to regulations, you may at any time request that we erase your personal data (right to be forgotten).   Right to restriction of processing Pursuant to regulations, you may at any time request that we restrict the processing of your personal data.   Right to data portability Pursuant to regulations, you may at any time request that we transmit your personal data in a structured, commonly used, and machine-readable format to an individual or controller of your choosing, provided this is technically feasible.   Right to object Pursuant to regulations, you may at any time object to our processing of your personal data. On the basis of your objection, we will then stop processing your personal data, unless we decide that we have legitimate reasons for further lawful processing of your data despite your objection.   Withdrawal of consent You can withdraw your consent submitted for the processing of your personal data at any time by either clicking “Unsubscribe”, which is located at the bottom of the email, or by emailing a request for withdrawing consent for a specified purpose to info@circularshield.org, or by post to CIRCULAR SHIELD d.o.o., Vodovodna cesta 101, 1000 Ljubljana, Republic of Slovenia.   Right of appeal to the supervisory authority As an individual, you have the right of appeal to the Information Commissioner of the Republic of Slovenia if you think your personal data is being processed contrary to applicable regulations. The appeal procedure of the supervisory authority is published on their website, which is accessible here.   9. CHANGES TO THE PRIVACY POLICY CS has the right to change this Privacy Policy according to the situation and legislation governing personal data protection, and we therefore suggest that you check for changes from time to time. We will also notify you in advance of any changes to the processing of your personal data or this Privacy Policy, and publish the changes to the Privacy Policy on our websites. If you do not agree with our Privacy Policy, please stop using our Online Services and withdraw your consent for the use of your personal data.