This Policy describes the measures implemented by KIG d.d., Zagorica 18, 1292 Ig, Slovenia, registration number 5034418000, to ensure the protection of personal data in the context of the KALUU services.
This Policy applies to the processing of personal data carried-out in the context of the use of the KALUU services (the “Services”) and the mobile application (the “Media”).
If you use the KALUU Services on a subscription basis, the content of this Policy forms an integral part of the General Conditions of Access and Use applicable to the Services (“GTC”).
- PERSONAL DATA PROCESSED
We only process personal data that is relevant, adequate, not excessive and strictly necessary in relation to the purposes previously determined.
We process personal data concerning you that you may provide to us or that we may collect from you, when you use the Media and/or the Services, in particular when:
– You use the Media,
– You create an account,
– You subscribe to the Services,
– You use the Services,
– You contact our Customer Service Center or our other services to ask a question, exercise a right or make a complaint.
In such cases, we will collect and process all or part of the following personal data concerning you:
– Your identity: civility, surname, name, date of birth,
– Your contact details: postal address,email, phone number,
– Your account details: subscriber number, secret code/PIN code,
– Your transactions: transaction number and details. Your banking data are directly collected and kept by our payment service provider; we only keep non identifiable data (4 last numbers of your credit card and expiry date),
– Your location information: date and time of your location when you search for a suitable parking location,
– Any other data you may directly and voluntarily provide when using the Media and the Services.
Where information is requested from you, the mandatory nature of such information is typically marked by an asterisk in the corresponding forms. Failure to complete such mandatory fields or any response to such mandatory fields we would consider abnormal may result in us refusing to process your request.
You agree that the personal data you provide to us about yourself must be current, accurate, complete and unequivocal.
- PROCESSING PURPOSES
The processing we carry-out pursue specified, explicit and legitimate purposes.
In a general way, the personal data we process in the context of use of the Media and of the Services are intended to ensure the supply and the management of the Services and of their users.
More specifically, your personal data may be processed for the purposes and on the legal basis described in the table below:
|Managing your account, your subscriptions and your use of the Services :
– Setting up and management of your account
– Management of your subscriptions
– Management of the Services
– Reply to questions raised
– Management of complaints
– Sending messages concerning the use of the Services (these service messages are necessary for the proper use and management of the Services; their receipt does not depend on any choices made by you to receive marketing messages or not)
|Performance of the contract between you and KALUU|
|Processing your transactions and your payments||Performance of the contract between you and KALUU|
|Sending you information about the Services (newsletter) or messages from us for direct marketing purposes||Your consent to receiving such communications. Such consent may be withdrawn at any time.|
|Receiving messages from our partners for direct marketing purposes||Your consent to receiving such communications. Such consent may be withdrawn at any time.|
|Asking you to respond to market research or satisfaction studies||Our legitimate interest to better understand the needs and expectations of our customers. You may object to receiving that kind of messages.|
|Organising events and competitions in connection with the Services||Your consent to taking part in such event or competitions. Such consent may be withdrawn at any time.|
|Enabling you to exercise your rights under personal data protection legislation||Compliance with a legal obligation.|
- DATA RECIPIENTS
Your personal data are collected and processed by our teams in charge of the commercial and technical management of the Media and of the Services. We may provide access to your data to specific authorised third parties, for specific purposes.
These recipients are the following :
– Our affiliated companies involved in the provision of the Media or of the Services,
– Third-party service providers providing services in connection with the Media or the Services, in particular hosting, analytical, maintenance, customer relationship management, communication, as well as payment services. These third-party service providers act as processors, only on our instructions and under a written contract setting out their obligations and responsibilities. They will only have access to your personal data to achieve the purposes described above and are under the same security and confidentiality obligations as we are.
In addition, your personal data may be disclosed on the following grounds:
– In response to legal or administrative inquiries or proceedings of any kind or to enforcement measures requested by the competent authorities,
– To comply with legal obligations, protect the rights and/or safety of an individual, to protect our rights and property, including the need to ensure that this Policy is respected and to prevent any technical, security or fraud-related issues,
-In case of a merger or acquisition of all or part of our company by a third party.
- DATA RETENTION
We will keep your personal data for no longer than is necessary to achieve the purposes for which they are processed, as described above.
In order to determine an appropriate data retention period, we rely on the following criteria:
– Data relating to your account is kept as long as your account is active; this data will be deleted at the end of a reasonable period of time from the last activity recorded on your account.
– Data relating to your subscriptions is kept during the entire period of your subscriptions; this data will be deleted at the end of a reasonable period of time from the expiry of your subscription, including as necessary to deal with your complaints,in accordance with applicable contractual and legal terms.
– Location data is kept only as necessary to deal with the invoicing and possible related complaints, in accordance with applicable contractual and legal terms.
– Your payment information will be kept by our payment service provider as long as necessary to deal with your payments and possible complaints, in accordance with applicable contractual and legal terms.
We may keep your personal data for a longer period solely to comply with legal or regulatory requirements, or in accordance with the applicable statute of limitation periods in case of a complaint or a lawsuit.
- DATA TRANSFERS OUTSIDE THE EU
Some of the service providers, partners, affiliated companies or other recipients listed above, to whom we may disclose your personal data for the purposes listed above, may be located outside the European Union.
In such case, when such recipients are located in a country that has not been the subject of an adequacy decision by the European Commission, we require them to take all organisational and technical measures that permit ensuring an adequatelevel of protection of your personal data and put appropriate safeguards in place in accordance with applicable legislation, including by signing a data transfer agreement incorporating the standard contractual clauses of the European Commission.
- YOUR RIGHTS
In accordance with applicable data protection legislation, you have certain rights regarding the collection and processing of your personal data, namely:
– Information: you have the right to be informed in a concise, transparent, intelligible and easily accessible form about the way in which your personal data are processed.
– Access: you have the right to obtain (i) confirmation as to whether personal data concerning you are processed or not and, if processed, to obtain (ii) access to such data and a copy thereof.
– Rectification: you have the right to obtain the rectification of any inaccurate personal data concerning you. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
– Erasure: in some cases, you have the right to obtain the erasure of personal data concerning you without undue delay. The exercise of this right is subject to certain conditions and we will inform you if we have legal or legitimate grounds for keeping such data.
– Restriction of processing: in some cases, you have the right to obtain restriction of the processing of your personal data.
– Data portability: you have the right to receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from us. This right only applies when the processing of your personal data is based on your consent or on a contract and such processing is carried out by automated means.
– Objection: you have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you when such processing is based on our legitimate interest. We may, however, invoke compelling legitimate grounds for continued processing. When your personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of such data. You may, in particular, exercise that rightby clicking on the “unsubscribe” link provided at the bottom of any messages received.
– Withdrawal of consent: when the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time.
– Complaint with a supervisory authority: you have the right to contact the competent supervisory authority to complain about our personal data protection practices (Republika Slovenija, Informacijski pooblaščenec, Dunajska cesta 22, 1000 Ljubljana, phone no. 01 230 97 30, e-mail address: email@example.com).
To exercise these rights, you can send a request by postal mail or email to KIG d.d. at the address below:
– By email: firstname.lastname@example.org
– By post: KIG d.d., Zagorica 18, 1292 Ig, Slovenia,
– By phone: +386 1 280 62 01 840 (available on workdays 08.00 – 15.00 CET).
Your request must specify your surname and name, the email address used to set up your account and your subscription number.
In some cases, we may ask you to include a copy of your identity document together with your request for identity verification purposes.