version 2.0, dated 23.05.2018
- This policy covers how Naviter treats personal information that Naviter collects and receives, including information related to your past use of Naviter products and services. This document helps you understand what personal information we collect about you, how we collect it, what we use it for, and what rights you have regarding your personal data. Personal information is information about you that is personally identifiable like your name, address, email address, or phone number, and that is not otherwise publicly available.
- Naviter informacijske tehnologije d.o.o., is the entity responsible for processing your personal data.
This policy does not apply to the practices of companies that Naviter does not own or control, or to people that Naviter does not employ or manage.
Information Collection and Use – General
- Naviter collects personal information when you register with Naviter, when you use Naviter products or services, when you visit Naviter pages or the pages of certain Naviter partners. Naviter may combine information about you that we have with information we obtain from business partners or other companies.
- When you register and use our services we ask for information such as:
- your name,
- email address,
- birth date,
- ZIP code,
- personal interests
- flight records,
- planned routes,
- other files and information that you share with us,
- When you register at any of the Naviter websites and sign in to our services, you are not anonymous to us.
- Naviter collects information about your transactions with us and with some of our business partners,
- When you visit our websites, Naviter automatically receives and records information on our server logs from your browser, including your IP address, Naviter cookie information, and the page you request. When you visit the website, we register your computer’s IP address and browser settings. The IP address is the numerical address of the computer used to visit the website. Browser settings can include the type of browser you use, browser language, and time zone. We collect this information so that we can trace the computer used in cases of misuse or unlawful actions in connection with visits to or use of the website.
- Naviter uses information for the following general purposes:
- to enable you to use our products,
- to make your flying easier and safer,
- to customize the advertising and content you see,
- fulfill your requests for products and services,
- improve our services,
- contact you,
- conduct research, and
- anonymous statistics.
On what legal basis do we process your personal data?
We need to process your personal information in order to:
- Perform our contract with you or execute your order of our products or services (see Article 6.1.b of the GDPR)
- Comply with our legal obligations (see Article 6.1.c of the GDPR)
- Pursue legitimate business interests of our own related to operating the website and providing our services to you, or to pursue the legitimate interests of third parties as long as your interests and fundamental rights do not override those interests (see Article 6.1.f of the GDPR).
- For the establishment, exercise or defence of legal claims, where necessary (see Article 9.2.f of the GDPR)
Some of these grounds for processing your personal data overlap, so there may be several reasons which justify us processing your personal information.
In those limited circumstances where you have expressly given your consent to us to process your personal data (see Article 6.1.a of the GDPR), for example, when subscribing to our newsletters, you are free to revoke your consent at any time. However, please be aware that we may have the right to continue to process your information if it can be justified on one of the other legal bases mentioned above.
You have the right to object to how we process your personal information, or ask us to restrict the processing. Please see below for more details.
If you would like more information about our legal basis for processing your personal information, please contact us email@example.com.
Information Sharing and Disclosure
- Naviter does not rent, sell, or share personal information about you with other people or non-affiliated companies except to provide products or services you’ve requested, when we have your permission, or under the following circumstances:
- We provide the information to trusted partners who work on behalf of or with Naviter under confidentiality and data processing agreements. These companies may use your personal information to help Naviter communicate with you about offers from Naviter and our marketing partners. However, these companies do not have any independent right to share this information.
- We respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.
- Naviter does not provide any personal information to the advertiser when you interact with or view a targeted ad. However, by interacting with or viewing an ad you are consenting to the possibility that the advertiser will make the assumption that you meet the targeting criteria used to display the ad.
- Naviter advertisers include financial service providers (such as banks, insurance agents, stock brokers and mortgage lenders) and non-financial companies (such as stores, airlines, and software companies).
- Naviter works with vendors, partners, advertisers, and other service providers in different industries and categories of business. For more information regarding providers of products or services that you’ve requested please read our detailed reference links.
In addition to the above, we disclose your personal information to the following parties and in the following circumstances:
- To allow third party vendors, consultants and other service providers to perform services on our behalf
- To comply with laws or to respond to claims, legal process (including but not limited to subpoenas and court orders) and requests from public and government authorities
- To cooperate with regulatory bodies and government authorities
- To third parties in connection with enforcement of our Terms & Conditions and Guidelines
- To third parties in order for us to protect our operations or those of our affiliates
- To third parties in order for us to pursue available remedies, or limit damages that we may sustain
- To third parties in order for us to investigate, prevent or take action regarding suspected or actual prohibited activities, including but not limited to fraud and misuse of our websites
- To a third party in the event of any reorganization, merger, acquisition, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in connection with any bankruptcy or similar proceedings).
Information for which we are the data controller
- We are the data controller of the data you enter to create and maintain your profile, which includes but is not limited to your name, password and email address, as well as the registration of your IP address.
- We are also the data controller of the information which is disclosed to other services, that we use to provide our products and services to you and to ensure your best user experience. Slovenian data protection laws, together with GDPR govern our collection of your data.
Links to websites
Our websites contains links to other websites. Our inclusion of such links does not imply that we endorse those websites. We do not control the content of those third party websites, and assume no responsibility for the third party or their policies or practices.
We encourage you to review the privacy policies for these third party websites because their procedures for collecting, handling and processing personal data will be different from ours.
Data processors and transfer of personal information outside the EU
We use external companies to maintain the technical operation of the website and our services. These companies are in some cases data processors for the personal data for which we are the data controller and in some cases data controllers. By accepting this Policy, you agree that we may also allow your data to be processed by these data processors.
We have data processing agreements in place with the data processors and it follows from these agreements that they must act solely in accordance with our instructions. By accepting this Policy, you authorize us to instruct the data processors to process data in accordance with the Policy and for the purposes of using our websites and other related services.
The data processors have taken reasonable technical and organizational measures to protect against the information being accidentally or illegally destroyed, becoming lost or deteriorating, and to protect against the information being disclosed to unauthorized persons, being misused, or in other ways being processed in violation of data protection laws.
On your request the data processors must supply you with sufficient information to demonstrate that the above-mentioned technical and organizational safety measures have been taken.
Some of these data processors and third party services are located outside of the European Union, such as in the US. You consent to us using data processors in such third countries provided that there is a legal framework governing the transfer of your personal data and ensuring adequate protection of it, for example if the data processor is part of the EU-US Privacy Shield framework, EU Model Clauses for export of personal data in place, etc..
We keep all personal data you provide, for as long as you have an account or as needed to provide you with our services. If you choose to delete your account please note that all your data, related to this account will also be deleted. We will delete this information upon your request and we will only save a log with the following information: your name, email address and the date of the deletion of your account. We will keep the log for 5 years. All other information will be deleted.
If you only use our websites without registration or without logging in, we will retain your information and keep your account open until you decide to close your account. In some cases, even if you close your account, we then choose to retain certain information (e.g. visits to our Website) in an anonymized or aggregated form.
We use reasonable organizational, technical and administrative measures to protect your personal information within our organization and we regularly audit our system for vulnerabilities. However, since the internet is not a 100% secure environment, we cannot ensure or warrant the security of the information you transmit to us. Emails sent via our website may not be encrypted, and we therefore advise you not to include any confidential information in your emails to us.
We are always working to improve our security practices and we will update this information as these practices evolve over time.
What types of Cookies do we use?
Cookies are small pieces of information that the Website places on your computer’s hard disk, on your tablet or on your smartphone. Note that HTML5 introduced web storage that has a similar nature to Cookies, and that we therefore consider that as a Cookie in the following.
Cookies contain information that the websites use to make the communication between you and your web browser more efficient. Cookies identify your computer or device rather than you as an individual user.
We use session cookies, persistent cookies. Session cookies are temporary in nature and are deleted when you exit your web browser. Persistent cookies are permanent in nature and are stored and remain on your computer until they are deleted. Persistent cookies expire or auto delete after a certain period of time, which is set per cookie, but are renewed each time you visit the website.
- Generating statistics: Measuring websites traffic such as the number of visits to the website, which domains the visitors come from, which pages they visit on the website and in which overall geographical areas the visitors are located.
- Monitoring website performance and your use of our websites: Monitoring the performance of the website, our applications and how you use our websites and applications.
- Authentication and improving the functionality of our websites:Optimizing your experience with the websites, which includes remembering your username and password when you return to the website, and remembering information about your browser and preferences (e.g. which language you prefer).
- Connecting you to Social Networks: We give you the option of connecting with Social Networks, such as Facebook.
Third party Cookies
Third party Cookies are set by third party websites – not our website. When you visit our website, the following third party Cookies may be set:
- Facebook cookies, set when you log in to our website with Facebook
- Google cookies, set when you log in to our website with Google
- Google AdSense cookies, set when displaying relevant targeted advertisements on our website. Some cookies may be set as DoubleClick, which is part of Google
Deletion of cookies
You can delete the cookies already on your device. You can typically delete cookies from the Privacy or History area, available from the Settings or Options menu in the browser. In most browsers, the same menu can be reached through the Ctrl+Shift+Del keyboard shortcut or Command+Shift+Del if you’re on a Mac.
If you do not accept Cookies from our websites, you may experience inconvenience in your use of the website, and you may be prevented from accessing some of its features.
Your Ability to Edit and Deactivate Your Account Information and Preferences – General
You may at any time correct or delete any content and personal information on the websites for which you are the data controller. If your personal information changes, or if you no longer wish to appear on the website, you can update or delete the information by logging in to your account.
We reserve the right to send you certain communications relating to the Naviter service, such as service announcements, administrative messages and the Naviter Newsletter, that are considered part of your Naviter account, without offering you the opportunity to opt out of receiving them in case they are required for the safe use of our products and services.
You can deactivate your Naviter account by visiting your account page. If your account is deleted, all the data associated with your account will be deleted. Some information, related to the audit trails might possibly remain in our archived records after your account has been deactivated.
Confidentiality and Security
We limit access to personal information about you to employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs.
We have physical, electronic, and procedural safeguards that comply with regulations to protect personal information about you.
In addition to the rights set out above concerning your personal data, you also have the following rights:
- You also have the right to object to the processing of your personal data and have the processing of your personal data restricted.
- In particular, you have an unconditional right to object to the processing of your personal data for direct marketing purposes.
- If our processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of the processing of data carried out before you withdrew your consent. You may withdraw your consent by emailing us at firstname.lastname@example.org.
In some circumstances, these rights may be limited or conditional. For example, whether or not you have the right to data portability in a particular case depends on the specific circumstances of the processing activity.
We reserve the right to make changes to this Policy. The date shown at the start of this Policy indicates when it was last revised. If we make material changes to it, we will provide notice through our website, or by other means, to give you the opportunity to review the changes before they come into effect. If you object to our changes, you can close your account. Your continued use of our website after we publish or send a notice about the changes to the Policy will mean that you accept and agree to the updated Policy.
Contact information and where to send questions or complaints
If you have questions or concerns about our Policy, how we process your personal information, or would like us to correct your personal information, feel free to contact us at: email@example.com.
You can also reach us by post.
If contacting us does not resolve your complaint, you have further options, for example you may always lodge a complaint with a data protection supervisory authority, e.g. Slovenian Information Commissioner.
Our contact details are: