Privacy Policy

Last updated: November 2021 

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Opti.Space Privacy Policy 

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1. Information about our organization and the websites we own 

This Privacy Policy describes the way in which Opti.Space collects, processes and shares the information and data you provide to us by using www.weareculturate.com (hereinafter: Opti.Space) and when you use Opti.Space services as subscribers.

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We refer to these two types of users collectively as “users” for purposes of these Privacy Policy. A user is any legal or natural person who uses or visits the said website (hereinafter: the user). The controller of personal data within the meaning of the General Data Protection Regulation Protection (GDPR) and the applicable Slovenian legislation on personal data protection is Opti.Space d.o.o., Mesarska cesta 22, 1000 Ljubljana, registration number: 8425795000, VAT ID: SI88192458 (hereinafter: controller).

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In addition to the Privacy Policy, we ask you to also familiarize yourself with the General Terms and Conditions governing the business relationship between the user (you as website visitors and as customers of services) and the collector and the Cookie Policy, which reveals which cookies we collect and for what purposes.

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We will only use the personal information collected on the website as set out in this Privacy Policy. Below you will find information on how we use your personal information, for what purposes your personal information is used, with whom we share it and what control and information rights you have.

 

By using the Website, you consent to the collection, use and disclosure of your information (including personal information) in accordance with this Privacy Policy. We receive and/or may ask you to provide your information (including personal information) whenever you are in contact with us or use the website. As detailed below, we share your information (including personal information) with third parties (as detailed below) and use it in ways consistent with this Privacy Policy. We may use your information (including personal information) in conjunction with other information to provide and improve products, services and content.

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With this document, Opti.Space, the author of this Privacy Policy, informs you of our Privacy Policy, practices and your choices about how we collect your information online and how we use that information. Please read this Privacy Policy carefully and revisit this page from time to time to review any possible changes.

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Opti.Space may change this Privacy Policy at any time by posting the changed terms on this page. All amended terms will automatically take effect on the date specified in the Privacy Policy, unless otherwise specified.

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2. Summary of our processing activities

The following summary gives you a quick overview of the processing activities carried out on our website. For more information see the sections below.

• When you visit our website for informational purposes only and without purchasing our services, limited personal information.

• In the event that you make a purchase of the service (i.e. to buy a subscription plan) or subscribe to our newsletter, further personal data will be processed as part of such services.

• Furthermore, your personal information will be used to provide advertising for our services and products and for statistical analysis to help us improve our website; in addition, we improve your experience of our website with third-party content.

• Your personal data may be disclosed to third parties located outside your country of residence, potentially applying different data protection standards.

• We have put in place appropriate safeguards to protect your personal information, which we only keep for as long as necessary.

• In accordance with the law applicable to you, you may be entitled to exercise certain rights in relation to the processing of your personal data.

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3. Websites covered by the Privacy Policy

This Privacy Policy applies to all websites and domains owned by Opti.Space, including  www.weareculturate.com. Opti.Space websites may have links to third party websites for easier reading and more information. By accessing these links, you will leave the Opti.Space websites. We do not control these sites, and their privacy policies may differ from ours. This Privacy Policy does not cover any personal information you choose to give to unrelated third parties. We do not monitor or control the information collected by such sites or are a practice of third-party privacy policies, and we are not responsible for their conduct or the content of their websites.

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4. Definitions

For the purposes of this regulation, “personal data” or “personal information” means any information relating to an identified or identifiable individual that can be identified, directly or indirectly, in particular by an identifier such as name, identification number, location data, online identifier, or by indicating one or more factors specific to that individual's physical, physiological, genetic, mental, economic, cultural or social identity. In some countries, "personal data" or "personal information" does not include business contact information.

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"Processing" means any act or series of actions carried out in relation to personal data or sets of personal data, with or without automated means, such as collecting, recording, editing, structuring, storing, adapting or modifying, retrieving, viewing, using , disclosure by brokering, expanding or otherwise making available, adapting or combining, restricting, deleting or destroying.

 

5. Use of the website – general 

Through the Opti.Space website, you can buy subscription plans as set out in the General Terms and Conditions, view information about the Service, or request support information. Every time you make a purchase, we will ask you for certain information.

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To understand the provisions of this Privacy Policy, we distinguish between two types of use which are depending on how you use the website:

• informative use of the website and

• use of the website as subscribers.

 

6. Informative use of the website

If you visit our website for informational reasons, i.e. without providing personal data in any form, we may automatically collect information about you, that will contain personal information only in limited cases as it is automatically recognized by our server. This information for example is: 

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• the site from which you were directed to our website;

• the date and time of your claims;

• device type, screen resolution, and browser version;

• your internet service provider;

• information about your operating system, including language settings;

• information about the offers you have visited on our website.

 

We use this information only to assist us in providing efficient services (e.g. to tailor our website to the needs of your device) and to collect broad demographic data for anonymous sharing.

The personal information we collect automatically, is necessary to secure the website and for our legitimate interest in ensuring the stability and security of the website.

 

Personal data that is collected automatically is immediately anonymized and all personally identifiable data is deleted accordingly.

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7. Use of the website as subscribers

If you use our website as a subscriber, we process, in connection with such use of the website, the following information:

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• information about the user's identity: surname, first names, telephone number, profile picture, address, IP address;

• information about the user's professional activity: days worked, days off, place of work, job position;

• information about the user's behaviour on the application;

• registration information allowing the person to use the Services: email, password, IP address.

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7.1. What we collect and why

When an Administer adds Culturate to your chat platform (e.g. Slack, Microsoft Teams), we collect information necessary for our Services to function. We also collect information if you give it to us.

Any of the information we collect from you may be used in one of the following ways: (a) Personalize your experience. (b) Better respond to your individual needs. (c) Operate and improve our Services. (d) Improve customer service. (e) Contact you.

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Here is what we collect and why:

• Your name and/or display name

  • To identify you in the product so we and people in your group can find you.

• Email address

  • Your account admin uses this to relate your information to other systems of record.

  • If you are an Administer, we may use your email to contact you regarding your product usage. This includes things like billing, troubleshooting, cancellation reasons, and welcoming you to the product. We strive to send the least email possible.

  • If you are a Member, we won't use your email unless you give us explicit permission to do so. Your email is used only that we can create your account on our platform. 

• Messages

  • In order to operate, maintain, and provide to you the features and functionality of our Service we only collect needed information, including; timestamp, giver, receiver, and where the message was located (e.g. channel name, chat platform).

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8. Collection of financial data

When buying a subscription plan, we need your financial information (such as credit card number, billing address and expiration date). The entire payment will be made through an external payment service provider Stripe, service outside the Opti.Space site. We do not store the financial data obtained from you and use them only to process the payment and issue a payment confirmation for the service via Stripe service. The mentioned Stripe services are regulated by the legal documentation of the provider, which is available at https://stripe.com/en-si/privacy.

 

We will only use your credit card information to process payments. Opti.Space does not store credit card data and other similarly sensitive personal data as it uses an external payment service provider.

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9. Collection of other information 

In most cases you agree to the use of your personal information in accordance with this policy by providing this information to us. In some cases, we specifically ask for your explicit consent if we believe the information is sensitive, or that our use of the information includes other uses not covered by this Privacy Policy or other privacy notices we have made available to you.

 

10. Newsletter 

With your e-mail address, you can subscribe to our newsletter and agree to regularly receive it. The newsletter provides you with the latest information about our services and may also contain advertisements related to our services. The legal basis for processing is your consent. Your email address will be kept as long as you subscribe to our newsletter. You can unsubscribe from this service at any time by clicking "unsubscribe" at the foot of each newsletter received.

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11. Online advertising

Our website uses online advertising services to present you with ads that match your interests. Such advertising is marked with the name of the provider (e.g. Google Ads). This service helps us to improve our website and make your visit more interesting. To this end, we collect statistics about you that are processed by the provider of such advertising. Such processing represents our legitimate interest in improving the experience with our website and in promoting our products and services.

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12. Cookies

On our website we use cookies for internal analysis of the use of our website, in order to provide you with the most attractive website possible. For more information on cookies and related technologies, visit our Cookie Policy, available at https://www.weareculturate.com/cookie-policy.

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13. Web analytics

For statistical analysis, we use web analytics services to collect information about the use of this site.

 

General tracking information

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Web analytics tools collect information such as:

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• device and browser information (operating system information, mobile device identifier, mobile operating system, etc.);

• IP address;

• access to the website; URL click flow (the chronological order of our websites you've visited);

• geographical location;

• time of visit;

• the reference site, application or service from which you were directed to our site.

 

We use the information we obtain from web analytics tool providers only to determine which information you are looking for and is therefore most useful to you and in order to improve and optimize the website. We do not combine data collected with such tools with your personal data.

 

Depending on the web analytics tool provider, data obtained about your use of the website may be downloaded and processed in third countries, e.g. in the United States. For more information on the potential risks of cross-border data transfer, see the "Cross-border Data Transfer" section of this Privacy Policy. These tools only collect the IP address assigned to you on the date of your visit to our website, not your name or other identifying information. Providers of such tools will use this information to evaluate your use of the Website, to compile reports on website activity and to provide other services related to the use of the Website.

 

The legal basis for this type of data processing is our legitimate interest in analysing the traffic on our website, improving the user experience and optimizing the website in general.

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14. Google Analytics

We use Google Analytics, a web analytics service provided by Google Ireland Ltd., Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). On our behalf, Google will use the information generated by the cookie to evaluate your use of the website, to compile reports on website activity and to provide other services relating to website activity and internet activity in connection with website usage.

 

Within Google Analytics, we have activated IP anonymization and your IP address will be truncated within the territory of the Member States of the European Union or other parties to the Agreement on the European Economic Area. Only exceptionally, the entire IP address will first be transferred to a Google server in the United States and truncated there. The IP address displayed by your browser as part of Google Analytics will not be associated with other data held by Google.

 

You can use cookies by selecting the appropriate settings in your browser; however, keep in mind that if you do, you may not be able to use the full functionality of the website. In addition, you can prevent the collection of information generated by the cookie about your use of the website (including your IP address) and the processing of this information by Google by downloading and installing a browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout.

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15. Unsubscribe from web analytics 

You may unsubscribe from any future collection of your personal information from us and Google Analytics in accordance with this Analytics Privacy Policy by following the instructions at this link: https://tools.google.com/dlpage/gaoptout.

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16. Opti.Space messages

When you sign up, we'll send you an e-mail to verify your email address. We answer your questions, provide custom services, and manage your account. We will communicate with you by e-mail or telephone and strive to respect your wishes.

 

We will also send you information about new products, services, special savings, promotions and general information. If you do not wish to receive this information, you can unsubscribe from future emails (see the Unsubscribe section below).

 

If you want to subscribe to our e-news, we will use your name and e-mail address to send e-news. You can subscribe to our e-news on our subscription page. You can unsubscribe at any time (see the Unsubscribe section below).

If necessary, Opti.Space will send you notifications related to non-promotional services. If you do not wish to receive them, you can deactivate your account on the Opti.Space website.

 

Please note that we do not provide your email address to our business partners. However, we may send you offers on behalf of our business partners. You can unsubscribe from receiving Opti.Space e-mail as described below.

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17. Exchange of information

Opti.Space does business with other service providers and suppliers in order to provide the comprehensive range of services and solutions as described above. These service providers may change their offer or sign a contract with additional service providers to better meet the needs of our customers.

 

Your personal data will be disclosed to third parties only to the extent necessary to fulfil our contractual relationship. The legal basis for the transfer of your personal data are points (b) and (f) of Article 6 (1) of the EU General Data Protection Regulation as they also represent our legitimate interest in enforcing our general terms and conditions or other contracts concluded with you. We may transfer your personal information across national borders. We may transfer your personal information to other countries for the purposes of data consolidation, storage, simplified customer information management, reporting, and other internal uses.

 

We may disclose anonymous aggregate statistics about our website users to potential partners, advertisers and other reputable third parties for the purpose of describing our services and other legitimate purposes. However, such information will not contain any personal information.

 

We may disclose your personal information to our contractors who assist us in providing the services we offer through the website. Such transfer will always be based on a personal data processing agreement, which means that our contractors will only use your personal data to the extent necessary to perform their functions and will be contractually obliged to process your personal data only on our behalf and in accordance with our requirements.

 

Opti.Space does not disclose personal information to third parties for its own use without your permission. However, Opti.Space must share information in some cases as a result of applicable law. For example, Opti.Space must disclose information due to a court order, testimony, or judicial investigation. In addition, we may voluntarily provide information in accordance with applicable law to assist in the investigation of law enforcement, or if disclosure is necessary to protect our systems, our business, or the rights of others.

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18. Cross-border data transmission 

As part of the above data exchange activities, your personal data may be transferred to other countries (including countries outside the European Economic Area (EEA)), which may have different data protection standards from the country in which you reside. Please note that data processed in a foreign country may be subject to foreign laws and be accessible to foreign governments, courts, law enforcement agencies and regulatory agencies. Notwithstanding the foregoing, we will endeavour to take reasonable steps to maintain an appropriate level of data protection in the exchange of your personal data with such countries.

 

In the case of a non-EEA transfer, this transfer is protected by either a privacy shield or EU model contractual clauses. For further information on the mentioned protective measures, you can contact us at info@opti-space.com.

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19. Cookies and other digital markers

Opti.Space automatically collects data using cookies and other digital markers. Cookies and digital markers are small computer files that can be stored on your computer's hard drive or embedded in our websites, and allow us to recognize and track your visit to the Opti.Space website. Opti.Space may use the services of third parties to collect and process personal data using cookies and other digital markers on our behalf. To disable cookies on your computer, change the settings in the settings menu or options of your browser. If you choose to disable cookies, you may not be able to access certain areas of the Opti.Space website.

 

20. Your decisions and checkout

Opti.Space allows you to receive various information that complements our services. You can only subscribe to receive certain information about services and marketing messages at the Opti.Space level. Opti.Space level messages may include information about new services, special offers, or invitations to participate in market research.

 

If you no longer wish to receive our e-newsletters and/or promotional messages, you may unsubscribe from them by following the instructions included in each e-newsletter or message or by sending us an email at info@opti.space. In case of the latter, please enter "unsubscribe" in the address bar.

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21. Access to and accuracy of your information 

We provide you with access to your information, including online access and the opportunity to change your information if possible. To protect your privacy and security, we will verify your identity with appropriate measures, such as your password and username, before you are given permission to access your information. In accordance with applicable law and our General Terms and Conditions, we reserve the right to refuse visitors the access of our websites. In such cases, we will give the concerned visitor the reason why he/she was refused access. 

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22. Security of your data

To protect against the loss, misuse and alteration of personal data, we have introduced reasonable state-of-the-art security measures that are under our control. For example, our security and private policies are regularly reviewed and improved as needed, and only authorized personnel have access to personal information. While we cannot guarantee that information will never be lost, misused or altered, we use all reasonable efforts to prevent it.

 

Opti.Space does not guarantee the security of our servers, nor can we guarantee that the information you send to the Opti.Space websites will not be intercepted while being transmitted over the Internet. We use generally accepted technical standards to protect the personal information you provide to us, both during transfer and after receipt. When you enter sensitive information (such as credit card information) when making a payment, we use the Stripe service to encrypt that information.

 

You need to keep in mind that sending information over the internet is never completely secure. We cannot guarantee the security of the information you send through our website, even if they are in transit over the internet and any transmission is at your own risk.

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23. Data storage

We strive to keep our processing of your personal data as limited as possible. If there are no retention periods specified in this Privacy Policy, your personal information will only be stored for as long as we need it to fulfil the purpose for which we collected it and, if necessary, for as long as the statutory retention period requires it.

 

24. What rights you have regarding your personal data

If you have any questions regarding our Privacy Policy or the processing of your personal information, you may contact us without hesitation. Write to us at info@opti.space. Upon your request, we will inform you - in writing and in accordance with the applicable law.

 

In accordance with the provisions of the EU General Data Protection Regulation, you have the following rights as an individual.

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24.1 Right to withdraw consent: If you, as an individual, have consented to the processing of your personal data (for one or more specific purposes), you have the right to revoke your consent at any time, without prejudice to the lawfulness of the data processing carried out up to your revocation. Consent may be revoked by a written statement sent to the controller at one of the contacts listed on the website https://opti.space or on other websites owned by Opti.Space  https://www.opti-space.de, https://www.opti-space.com, https://www.weareculturate.com . Withdrawal of consent to our processing of personal data does not have any negative consequences or sanctions for the individual. However, after revoking the consent to our processing of personal data, the controller may no longer be able to provide one or more of its services to the concerned individual if the services cannot be provided without personal data.

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24.2 Right of access: As an individual, you have the right to obtain a confirmation from the provider (personal data controller) whether personal data is processed in relation to you and, where applicable, access to personal data and certain information (on the purposes of processing, on the types of personal data, about the users, on retention periods or criteria for determining periods, on the existence of the right to rectify or delete data, the right to limit and object to processing and the right to appeal to the supervisory authority, the source of data if the data have not been collected from you, the existence of automated decision making, including the creation of profiles, the reasons for it and the meaning and consequences of such processing for you, and other information in accordance with Article 15 of the EU General Data Protection Regulation).

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24.3 Right to correct personal information: As an individual, you have the right to have the controller correct inaccurate personal data about you without undue delay. As an individual, you have the right to supplement incomplete data, including the submission of a supplementary statement, taking into account the purposes of the processing.

 

24.4 Data deletion (“the right to forget”): As an individual, you have the right to request deletion of the personal information that the controller holds about you. The controller must delete the data without undue delay when there is one of the following reasons:

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• data are no longer needed for the purposes for which they were collected or. otherwise processed

• if you revoke the consent and there is no other legal basis for the processing;

• if you object to the processing and there are no overriding legitimate reasons for the processing;

• the data were processed illegally;

• the data must be deleted in order to fulfil legal obligations under EU law or the law of the Member State applicable to the controller;

• data were collected in connection with the provision of information society services.

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However, as an individual, in certain cases described in Article 17 (3) of the EU General Data Protection Regulation, you do not have the right to have the data deleted.

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24.5. Restriction of processing: You have the right to request the controller to restrict the processing of your personal data where:

• you contest the accuracy of the personal data until the controller has taken sufficient steps to correct or verify its accuracy;

• the processing is unlawful but you do not want the controller to erase the data;

• the controller no longer needs your personal data for the purposes of the processing, but you require such data for the establishment, exercise or defence of legal claims; or

• you have objected to processing justified on legitimate interest grounds (see above) pending verification as to whether the controller has overriding compelling legitimate grounds to continue processing.

 

24.6 Data portability: You, as an individual, have the right to receive personal data about you that you have provided to the controller in a structured, commonly used and machine-readable format, and also to require the controller to transmit it to another controller where this is technically feasible. Namely when:

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• processing is based on consent or a contract, and

• processing is carried out by automated means.

 

24.7 Right to object: On grounds relating to your specific situation, you have the right to object at any time to the processing of personal data that is necessary to perform tasks in the public interest or exercise public authority conferred on the controller (point (e) of Article 6 (1) of the EU General Data Protection Regulation) or is necessary for legitimate interests pursued by the controller or a third party (point (f) of Article 6 (1) of the EU General Data Protection Regulation), including profiling on the basis of those treatments. The controller ceases to process personal data unless it proves urgent legitimate reasons for the processing that outweigh your interests, rights and freedoms, or for asserting, enforcing or defending legal claims.

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Where personal data are processed for marketing purposes, the individual has the right to object at any time to the processing of data relating to him/her for the purposes of such marketing, including the creation of profiles, in so far as it relates to such direct marketing. Where an individual objects to processing for direct marketing purposes, the data shall no longer be processed for those purposes.

 

Where data are processed for scientific or historical-research purposes or for statistical purposes, the individual has the right to object to the processing of data relating to him/her for reasons related to his/hers particular situation, unless the processing is necessary for the performance of a task carried out by reasons of public interest.

 

24.8 Right to lodge a complaint with a supervisory authority: Without prejudice to any other (administrative or other) remedy, you, as an individual, have the right to lodge a complaint with the supervisory authority, in particular in the country where you have your habitual residence, where you work or where the infringement allegedly took place (in Slovenia this is an Information Commissioner), if you believe that the processing of your personal data violates the regulations on the protection of personal data.

 

Without prejudice to any other (administrative or extrajudicial) remedy, you as an individual have the right to an effective remedy against a legally binding decision of the supervisory authority, as well as in the event that the supervisory authority does not consider your complaint or does not inform you about the situation or the decision on the appeal within three months. Proceedings against the supervisory authority shall be subject to the jurisdiction of the courts of the Member State in which the supervisory authority is established.

 

The individual may address all requests concerning the exercise of rights in relation to personal data in writing to the controller, via one of the contacts listed on the website https://opti.space, https: //www.opti- space.de, https://www.opti-space.com, https://www.weareculturate.com.

 

The controller may, for the purposes of identification of the individual in case of exercising his/her rights in relation to personal data, request additional data from the individual and may refuse to act, if the individual cannot be reliably identified. 

 

The controller must respond to the request of the individual by which he/she exercises his/her rights in relation to personal data without undue delay and no later than one month from the receipt of the request.

 

Without prejudice to any other administrative or legal remedy, you as the concerned individual have the right to lodge a complaint with the supervisory authority in particular in the Member State in which you have your habitual residence,  in which your place of work is located or in which an infringement has allegedly taken place, if you believe that the processing of your personal data infringes the EU General Regulation on the Protection of Personal Data. The supervisory authority with which the appeal is lodged, will inform the appellant about the status of the case and the decision on the appeal, including the possibility of a legal remedy under Article 78 of the EU General Data Protection Regulation. As a data subject, you have the right to lodge a complaint at the following address: Republic of Slovenia, Information Commissioner, Dunajska cesta 22, 1000 Ljubljana, telephone: 01 230 97 30, e-mail: gp.ip@ip-rs.si.

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25. Change of Privacy Policy

Occasionally the controller may, in its discretion, make changes to the Privacy Policy and if necessary, adjust it to the actual situation and legislation in the field of personal data protection. For this reason, we ask you to check the current version before each transfer of personal data to be informed of any changes and additions. We will also inform you in advance and in an appropriate manner (e.g. by a notification on our website, by e-mail) of any changes that significantly affect the processing of your personal data. The date of the last Privacy Policy is recorded in the document.

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26. Change of business 

In the event that Opti.Space undergoes a business change, such as a merger, takeover by another company or sale of all or part of its assets, your personal data will probably be among the transferred assets.

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27. Terms and conditions

If you choose to visit the Opti.Space websites, your visit and any privacy dispute is subject to this Privacy Policy and our Terms and Conditions, including, but not limited to, the limitations of warranty and limitations of liability.

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28. Contact us

We appreciate your feedback. If you have any comments or questions regarding this Privacy Policy or would like to express your concerns about the processing of your personal information, please email us at info@opti-space.com. If you are concerned about privacy, please type “Privacy” in the address bar of your email.

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Opti.Space d.o.o.