In certain cases, processing personal data is vital for the execution of the controller’s contractual obligations. If the user does not provide the necessary personal data, the controller is unable to finalize a contract with the user or perform services.

The controller will process your personal data to perform contractual obligations for the following purposes:

• business Cooperation Agreement,
• carrying out activities stated in the cooperation agreement (consulting, preparing marketing and sales strategies, implementing marketing and sales campaigns, process informatization),
• communicating with contracting parties and other contact persons for the purposes of executing an activity stated in the cooperation agreement,
• to sign up a user to an event organized by FrodX, including for awarding certificates, receipts and licences to event attendees.

Based on your written consent, Frodx will process your personal data for the following purposes:

• sending e-mails for the purpose of informing about training courses, new features (in standards and in publications), services as well as events at the controller or third person,
• for contacting on the phone for the purposes of presenting professional system solutions to the user or employer (by prior appointment also at their location),
• for publishing in technical media and on websites with the basic purpose of promoting the user and their employer (licenced designer, licenced contractor …),
• for monitoring the user’s reading of sent e-mails, including which e-mail you opened or did not open, which links you clicked (which contents you read), how long you were reading them or surveyed certain contents,
• for segmenting users based on the factors from the previous paragraph and for further sending adapted (individualized) e-mails, which means different users can receive e-mails with different contents for the purpose of a better (more relevant) informing and achieving a higher level of response to the received e-mails,
• for the purposes of analysing the user’s pattern-of-life on the website: from where the user came to the website (source of the traffic), for monitoring their activities on the website, which websites they visited, which contents they downloaded or viewed,
• for segmenting users based on the facts from the previous paragraph and further sending adapted (individualized) messages through multichannel communication, which means different users can receive messages with different contents for the purpose of a better (more relevant) informing of individuals and reaching a higher level of user enthusiasm,
• for all other purposes for which you expressly agree in cooperating with the controller.

Any time you give consent for the processing of your personal data, the consent can be withdrawn at dpo@frodx.com. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Your personal data is also processed when required of us by the law. One example of such processing is processing your personal data for the purposes of judicial or administrative processes.

The controller can also process data based on legitimate interest, except when this interest is overruled by interests or basic rights and freedoms of the user to whom the personal data requiring data protection applies. In the case of using legitimate interest, the controller’s judgement always complies with the General Data Protection Regulation.

In certain cases, Frodx can, for further processing of your personal data based on legitimate interest that was collected based on one of the aforementioned legal basis (consent, contract), implement certain safeguards for the protection of your personal data, such as pseudonymisation, encryption, processing in an aggregated form and/or deleting certain categories of personal data.

Frodx will process your personal data based on a legitimate interest for the following purposes:

• Marketing, business and other technical analyses, such as analysing and determining which organizations the event attendees are coming from and what functions they perform in these organizations, for keeping records of how many and which events a user attended, for keeping records of awarded receipts, certificates and licences of event attendees.
• Preventing fraud, ensuring safety, submitting claims or defence of legal claims in court proceeding or administrative procedures. This allows the controller to process your personal data in cases of suspicion of fraud in an appropriate and proportional scope for the purpose of identifying and stopping potential fraud and deceit and can, if appropriate, forward the data to the police, the Prosecutor’s Office or other competent authority.
• Direct marketing, including creating user profiles, based on legally acquired personal data. The stated processing can be objected to in accordance with the chapter Right to Object in this Policy.

Your personal data can be accessed solely by Frodx employees and authorized processers of personal data.

Frodx will never forward your personal data to unauthorized third persons.

Frodx may entrust individual personal data processing tasks to a contracted processor based on a data processing agreement. Contracted processors may process entrusted data exclusively on behalf of the controller, within the limits of the authorization specified in a written contract or other legal act, and in accordance with the purposes defined in this Policy.

• The contracted processors that the company collaborates with primarily include:
• Accounting services and other providers of legal and business consulting.
• Infrastructure maintenance (video surveillance, security services).
• Information system maintenance.
• Providers of email services and software, cloud services (e.g., Microsoft, Google, HubSpot, SAP, Amazon, ZOOM, OpenAI).
• Social media and online advertising providers (Google, Facebook, Instagram, etc.).

For the purposes of better oversight and control over contracted processors and to maintain organized contractual relationships, the company keeps a list of all specific contracted processors it collaborates with.

Frodx will not, under any circumstances, disclose an individual's personal data to unauthorized third parties. Contracted processors are permitted to process personal data exclusively within the scope of the company instructions and may not use the personal data for any other purposes.

The company, as the data controller, and its employees do not transfer personal data to third countries (outside the member states of the European Economic Area – EU member states, Iceland, Norway, and Liechtenstein) or to international organizations, except to the United States. For transfers to the US, relationships with processors are governed by standard contractual clauses (model contracts adopted by the European Commission) and/or binding corporate rules (adopted by the company and approved by EU supervisory authorities).

The controller will not process personal data longer than necessary to achieve the purposes for which the personal data was collected and further processed.

The personal data processed by Frodx is processed in compliance with the agreement and is stored by Frodx for the period that is necessary to complete the contract and for 5 years after its completion, except in cases when a disagreement arises about the contract between you and the controller. In that case, Frodx keeps that data for 5 years after the finalized court judgements or arbitration decisions or settlement, or in the case of no litigation, for 5 years after the dispute has been resolved peacefully.

The personal data processed by Frodx based on the law is stored by Frodx for the legally determined duration of time.

The personal data processed by the controller based on your personal consent or legitimate interest are kept by Frodx permanently until you withdraw your consent or submit a request that the processing be terminated. Frodx will delete such data before they are withdrawn only if the purpose of the processing of the personal data has been achieved or if it is determined by the law.

After the storage duration period has elapsed, Frodx will effectively and permanently delete or anonymize your personal data so that it can no longer be traced back to you.

Frodx is dedicated to protecting your personal data. They prevent any unauthorized access to it, their use and their revelation with the following measures:

• The data is protected with the workspace, equipment and system software, including input-output units.
• The data is protected by application software that is used for processing personal data.
• Frodx prevents unauthorized access to personal data during their transfer, including forwarding using telecommunication means and networks.
• Frodx enables an effective way of blocking, destroying, deleting or anonimizing personal data after the purpose, for which they were collected, ceases.
• Frodx enables later detection of when individual data that had been entered into the personal data database were used, forwarded or otherwise processed and by whom.

Unauthorized access to personal data, their use and revelation is prevented by Frodx with the following safety technologies and procedures:

• controlling physical access,
• locking rooms, closets, computers,
• storing carriers of personal data in secured rooms,
• preventing office maintenance workers, clients and other visitors of the controller’s offices from having any consultation with the personal data,
• preventing password use to persons who have not been directly assigned to the stated purpose,
• limiting data transfer by the employees,
• controlling the number of copies and data transfer,
• limiting, documenting and securing the transfer of the data through telecommunication networks,
• preventing insight into the data to persons whose employment contract has been terminated,
• strictly separating their data from the data of any other possible controllers.

In accordance with the General Data Protection Regulation, Frodx guarantees you the following rights relating to personal data protection, which are further elaborated in the following chapters of the Policy:

• right of access to the data,
• right to rectification,
• right to erasure (“right to be forgotten”),
• right to restriction of processing,
• right to data portability,
• right to object.

You have the right to obtain confirmation from Frodx as to whether or not they are processing your personal data, and, where that is the case, you have the right to access your personal data and the following information about personal data processing:

• the purposes of the processing,
• the categories of personal data,
• the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations,
• where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period,
• the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the user or to object to such processing,
• the right to lodge a complaint with a supervisory authority,
• where the personal data are not collected from the user, any available information as to their source,
• the existence of automated decision-making, including profiling, and meaningful information about the reasons for it, as well as the significance and the envisaged consequences of such processing for the user.

Based on your request, Frodx will provide you with a free copy of your personal data undergoing processing. For any further copies you request, Frodx will charge a reasonable fee based on administrative costs.

You have the right to obtain from Frodx without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to erasure (“right to be forgotten”)

You have the right to obtain from Frodx the erasure of personal data concerning you without undue delay and Frodx shall have the obligation to erase your personal data without undue delay where one of the following grounds applies:

• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed,
• you withdraw consent on which the processing is based, and where there is no other legal ground for the processing,
• you object to the processing pursuant the controller’s legitimate interest and there are no overriding legitimate grounds for the processing,
• you object to the processing for the purposes of direct marketing,
• the personal data have to be erased for compliance with a legal obligation in accordance with EU or Slovenian State law.

Where Frodx has acted in accordance with the Policy and has made your personal data public, Frodx shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the user has requested the erasure of any links to, or copy or replication of those personal data.

Right to restriction of processing

You have the right to obtain from Frodx the restriction of processing of your personal data where one of the following applies:

• You contest the accuracy of the personal data, for a period enabling the controller to verify the accuracy of your personal data.
• The processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead.
• When Frodx no longer needs the personal data for the purposes of the processing, but you required them for the establishment, exercise or defense of legal claims.
• You have objected to processing, pending the verification whether the legitimate grounds of the controller override yours.

Right to data portability

You have the right to receive personal data concerning you, provided by Frodx, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from Frodx to which the personal data have been provided, when:

• the processing is based on consent or agreement, and
• the processing is carried out by automated means.

Right to object

On grounds relating to your particular situation, you have the right to object, at any time to processing of your personal data, if your objection is based on legitimate interests pursued by Frodx or a third party. Frodx shall no longer process the personal data unless they demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing. If the direct marketing is based on consent, the right to object can also be achieved by withdrawing the personal consent.

All the aforementioned claims on exercising rights regarding your personal data can be addressed in written form to the controller at the e-mail address dpo@frodx.com or by post to the address Frodx d.o.o., Celovška cesta 280, 1000 Ljubljana, Slovenia.

If you submit your claim, in accordance with the previous paragraph, using electronic means, the information, where possible, will be provided to you in electronic means, unless you request otherwise.

The controller can, for the purposes of reliable identification in cases of claiming rights on personal data, request additional information from you that is necessary to confirm your identity, and may decline acting in accordance with this chapter only in the event that they cannot reliably identify you.

The controller will respond to your request exercising your rights regarding your personal data without undue delay in no more than a month after receiving the claim. Frodx can extend the deadline to comply with the rights for no more than two additional months, taking into account the complexity and number of claims. If Frodx extends the deadline, they will inform you about the extension within one month of receiving the claim, including the reasons for the delay.

If your claims regarding this chapter are obviously unfounded or excessive, especially when repetitive, Frodx can:

• charge a reasonable fee based on administrative costs of forwarding the information or the claim or of processing the claim,
• decline to act on the claim.

You can send any potential complaint regarding the processing of your personal data to the e-mail address dpo@frodx.com or by post to the address Frodx d.o.o., Celovška cesta 280, 1000 Ljubljana, Slovenia.

You have the right to lodge your complaint directly to the Information Commissioner, if you believe processing your personal data is infringing on Slovenian State or EU rules on personal data protection.

This Policy enters into force on 20th June 2024 and can be changed or amended at any time.