Privacy policy

Identity and Contact Details of the Data Controller

SNTT d.o.o. (“SNTT”, “we”, “us”, or “our”) is the Data Controller responsible for processing your personal data collected through our website, osntt.com. We are committed to protecting and respecting your privacy.

Contact Details:

• Legal Entity: SNTT d.o.o.
• Registered Address:  Spodnja Senica 20, Spodnja Senica, 1215 Medvode, Slovenia, 
• Email: info@osntt.com
• Telephone: 38640240836
• For inquiries specific to the General Data Protection Regulation (GDPR), please contact us at info@osntt.com.

We encourage you to reach out with any questions or concerns regarding the handling of your data. Our dedicated team is committed to addressing all inquiries and providing the necessary information regarding your rights and the processing of your data.

Types of Personal Information Collected

At SNTT d.o.o., we collect various types of personal information to provide and improve our services at osntt.com(https://osntt.com). Below are the categories and types of personal data we collect:

1. Contact Information: This includes data we receive directly from you when you interact with our website, register for an account, or contact us for support. Examples include:

   – Full name

   – Email address

   – Telephone number

   – Mailing address

   – Company data

2. Account Details: When you create an account with us, your account data is stored on lampyre.com, please refer to their privacy policy. 
3. Financial Information: For processing payments and maintaining subscriptions, we collect financial data, which may include:

   – Billing addresses

   – Transaction history

4. Technical and Usage Data: As you navigate through and interact with our website, we automatically collect information about your equipment and browsing actions. This data includes:

   – IP address

   – Browser type and version

   – Device information

   – Operating system

   – Log files

   – Access times

   – Pages viewed

5. Cookies and Tracking Technologies: We use cookies and similar tracking technologies to track activity on our service and hold certain information, enhancing your experience and understanding how our services are used. 
6. Interaction Records: Information related to communications with us, whether through emails, phone calls, or other forms of communication, may be collected and stored.

This list is not exhaustive and may be updated as our website evolves and technology changes. The information we collect depends on the context of your interactions with us, the choices you make (including your privacy settings), and the products and features you use.

Purposes of Processing

At SNTT d.o.o., we process personal information collected through our website osntt.com(https://osntt.com) for a variety of purposes, each with a legal basis under data protection laws, including the General Data Protection Regulation (GDPR). Below are the key purposes for which we process your personal data, along with the corresponding legal bases:

1. To Provide and Manage Services:

   – Legal Basis: Contract necessity

   – We process your Contact Information, Account Details, and Financial Information to fulfill our contractual obligations to you in providing and managing the services you request.

2. To Communicate with You:

   – Legal Basis: Consent

   – We use your Contact Information to communicate with you about your account or transactions with us, and to send you information about changes to our terms, conditions, and policies.

3. To Improve and Customize Our Services:

   – Legal Basis: Legitimate interests

   – We analyze Technical and Usage Data to understand how our services are used and to improve their functionality, which allows us to better serve you and meet your needs.

4. To Process Payments:

   – Legal Basis: Contract necessity

   – Financial Information is processed to complete transactions required to use our services.

5. For Marketing Purposes:

   – Legal Basis: Consent

   – We may use your Contact Information to send promotional messages and marketing offers, provided you have not opted out of receiving such communications.

6. To Ensure Network and Information Security:

   – Legal Basis: Legitimate interests

   – We process Technical and Usage Data to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks.

7. To Comply with Legal Obligations:

   – Legal Basis: Legal obligation

   – We may process your information when complying with legal requirements, such as court orders or other legal process requirements.

The information you provide helps us to operate, provide, improve, understand, customise, support, and market our services. We do not use the information we collect for materially different, unrelated, or incompatible purposes without notifying you.

Details of Data Recipients

SNTT d.o.o. takes your privacy seriously. This section outlines the recipients of the personal data collected through our website, osntt.com(https://osntt.com), and the circumstances under which your data may be shared.

1. Service Providers and Partners:

We share your information with selected third parties who perform services on our behalf, such as web hosting, data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, and auditing services. These third parties are given access to personal data needed to perform their functions but are restricted from using it for other purposes.

2. Affiliates:

Your personal data may be shared among our affiliates for internal administrative purposes, service optimization, and customer support.

3. Legal Requirements and Compliance:

We may disclose your personal data if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, in regard to any legal investigation, to protect and defend our rights or property, ensure the personal safety of users of the service or the public, or protect against legal liability, to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or Terms and Conditions of our website.

4. Business Transfers:

As we continue to develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, or similar event, personal data may be part of the transferred assets.

5. International Transfers:

Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. We ensure that adequate measures, such as standard contractual clauses, are in place to safeguard your data during such transfers.

6. Marketing and Advertising:

With your consent, we may share your Contact Information with third-party marketing partners or use it to send you promotional messages. 

We do not share your personal data with third parties for their own direct marketing purposes without your explicit consent. We also ensure that all data sharing and transfers comply with existing data protection legislation.

Information on Data Transfers

SNTT d.o.o. operates globally, which means your personal data may be transferred to and processed in countries other than the one in which you reside. Below we outline how we handle these international data transfers in compliance with the General Data Protection Regulation (GDPR). 

1. Transfers within the European Economic Area (EEA):

For residents of the EEA, your data is primarily processed within the EEA. However, if we transfer data outside the EEA, we ensure similar protection and take steps to provide appropriate safeguards.

2. International Transfers Outside the EEA:

When we transfer your personal data outside the EEA to countries not deemed by the European Commission to provide an adequate level of data protection, we implement one or more of the following safeguards:

• Standard Contractual Clauses: We use European Commission-approved Standard Contractual Clauses with our service providers and business partners to ensure that your personal data is treated by those third parties in a way that is consistent with and respects the EU and other applicable laws on data protection.
• Binding Corporate Rules: Where applicable, we may transfer data within our group of companies pursuant to our Binding Corporate Rules that have been approved by EU data protection authorities.
• Other Mechanisms: We may use other mechanisms under the GDPR, such as consent of the data subject, necessary for the performance of a contract, or other legally accepted bases.

Data Subject Rights

SNTT d.o.o. is committed to ensuring that you remain fully informed of your rights under data protection laws. This section describes your rights under the General Data Protection Regulation (GDPR) applicable to EEA residents.

 Rights under GDPR

If you are within the European Economic Area (EEA), you have the following data protection rights:

1. Right of Access: You have the right to request access to your personal data that we process.
2. Right to Rectification: You can request that we correct any inaccuracies in your personal data.
3. Right to Erasure: Also known as the ‘right to be forgotten,’ you can ask us to delete your personal data, provided there are no legal reasons for us to retain it.
4. Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data under certain circumstances.
5. Right to Data Portability: You can request a copy of your personal data in a machine-readable format and the right to transmit that data to another controller.
6. Right to Object: You have the right to object to the processing of your personal data, based on your particular situation, when the data processing is based on legitimate interests.
7. Rights in relation to Automated Decision Making and Profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

Exercising Your Rights

To exercise any of your rights, please contact us at info@osntt.com. We may request specific information from you to help us confirm your identity and process your request.

Methods for Exercising Rights

At SNTT d.o.o., we are committed to ensuring that exercising your rights related to your personal data is as easy as possible. Below are the steps you can follow to exercise your rights under the General Data Protection Regulation (GDPR) for residents of the European Economic Area (EEA).

 Contact Information

To exercise any of your rights, please contact us through one of the following methods:

• Email: Send an email to info@osntt.com
• Postal Mail: Write to us at the following address:
• Insert the postal address of the company

Please provide as much detail as possible regarding your request to help us identify the information you wish to access, correct, or delete.

 Identity Verification Process

To protect your privacy and security, we will take reasonable steps to verify your identity before granting access to your personal data or complying with your request. The verification steps may include:

• For General Requests: Asking you to provide identifiable information that matches the data we hold.
• For Sensitive Requests: Requiring you to provide a copy of a government-issued ID or respond to other security questions to confirm your identity.

 Assistance

If you need assistance or have any questions about how to exercise your rights, please do not hesitate to contact our privacy team at info@osntt.com. We are here to help you with any concerns or requests you may have regarding your personal data.

Consent Mechanisms

SNTT d.o.o. respects your right to privacy and ensures that all personal data is processed based on lawful grounds. This section outlines the mechanisms we have implemented to obtain and manage your consent under GDPR.

 GDPR Consent Mechanisms

1. Obtaining Consent:

• Clear and Informed: When you use our services at osntt.com(https://osntt.com), we provide clear, concise information about the data processing activities for which consent is required. Before collecting your data, we ensure that consent is freely given, specific, informed, and unambiguous.
• Active Engagement: Consent is obtained through a proactive click-through consent form, checkbox, or similar mechanism that requires an affirmative action to indicate your approval.

2. Withdrawing Consent:

You may withdraw your consent at any time, which will not affect the lawfulness of processing based on consent before its withdrawal. To withdraw your consent, please contact us at info@osntt.com. Alternatively, you can use the consent management tools available on your user account settings page on our website.

 Assistance and Queries

If you have any questions regarding our consent mechanisms or need assistance with managing your preferences, please contact our privacy support team via email at info@osntt.com. We are committed to addressing your inquiries promptly and effectively.

Use of Cookies and Tracking Technologies

SNTT d.o.o. uses cookies and similar tracking technologies to track the activity on our website osntt.com(https://osntt.com) and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyze our service.

 Types of Cookies Used

1. Essential Cookies: These cookies are essential to provide you with services available through our website and to enable you to use some of its features. For example, they allow you to log in to secure areas of our site and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
2. Functionality Cookies: These cookies allow our website to remember choices you make when you use our website, such as remembering your login details and remembering the changes you make to other parts of our website which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our website.
3. Analytical/Performance Cookies: These cookies are used to collect information about traffic to our website and how users use our website. The information gathered does not identify any individual visitor. It includes the number of visitors to our website, the websites that referred them to our website, the pages they visited on our website, what time of day they visited our website, whether they have visited our website before, and other similar information. We use this information to help operate our website more efficiently, to gather broad demographic information and to monitor the level of activity on our website.
4. Advertising Cookies: These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests.

Cookie table:

• Essential cookies:

• Non-essential Cookies

 Consent and Control

Under GDPR, non-essential cookies require your consent before being placed on your device. We provide detailed information about the storage of cookies on your device when you first visit our website, along with options to accept or reject non-essential cookies.

How to Control or Delete Cookies

You have the right to accept or refuse cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of our services.

To learn more about managing your cookie preferences, you can follow the instructions provided by your browser, which are typically found under the “Help,” “Tools,” or “Edit” menus.

 Further Information

If you have any questions about our use of cookies or other technologies, please email us at info@osntt.com.

Retention of Data

1. SNTT d.o.o. is committed to retaining your personal data only for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. The criteria we use to determine the appropriate retention periods for different categories of personal data include:
2. Nature of the Data: We consider the amount, nature, and sensitivity of the personal data. More sensitive data may require shorter retention periods or enhanced protective measures.
3. Purpose of Processing: The retention period depends on the specific purposes for which the data is processed. Data needed for the fulfillment of our contractual obligations to you is retained for the duration of the contractual relationship and an appropriate period thereafter to deal with contract-related matters such as claims or queries.
4. Legal Obligations: Where laws or regulations require us to retain certain information for a specific period, we comply with those requirements. For instance, financial records are typically retained for seven years to comply with tax and accounting laws.
5. Consent: If we have processed data based on your consent, such as for marketing purposes, we will retain the data until you withdraw your consent.
6. Statutory Limitation Periods: We retain data considering the time limits for potential legal claims. This ensures we have sufficient data to defend ourselves or to make claims.
7. Operational Requirements: Some data may be retained for longer periods due to operational necessities, such as customer service, maintaining business records, managing business operations effectively, and responding to legal or regulatory inquiries or requests from competent authorities.
8. Deletion Protocols: Once the retention period concludes and there is no lawful basis or legitimate business purpose for retaining personal data, the data is either securely deleted or anonymized.

 Review of Retention Periods

Our data retention policies and procedures are regularly reviewed to ensure compliance with legal obligations and to ascertain whether there is a need to update the retention period of the data we hold. Adjustments are made based on changes in legal requirements or operational needs.

 Further Information

If you have any questions about the specific retention periods for various types of personal data, please contact us at info@osntt.com.

Children’s Privacy

SNTT d.o.o. does not knowingly collect or solicit personal data from children under the age of 16. Our website and services are not designed to attract children, and we do not intentionally target minors for data collection.

 Compliance with Legal Requirements: GDPR (EEA Residents): For children under the age where they can consent to data processing under local laws, we do not process their data without parental consent. The age of consent varies by country but is never below 13 years. old.

 Parental Control

Parents or guardians who believe that their child has provided us with personal information without their consent should contact us at info@osntt.com to request the deletion of the data.

Security Measures

At SNTT d.o.o., we prioritize the security of your personal data. We implement a variety of security measures designed to protect your information from unauthorized access, alteration, disclosure, or destruction. Here are the key practices we follow to safeguard your data:

• Technical measures
• Encryption: We use HTTPS (SSL/TLS) to encrypt data during transmission, ensuring the protection of personal data and sensitive information.
• Access Control: Access to personal data is restricted to authorized personnel based on their roles and responsibilities.
• Secure Infrastructure: Our website is hosted on servers in Slovenia, secured with industry-standard firewalls and intrusion detection systems. We use security tools like firewalls and monitoring systems to enhance protection.
• Organizational Measures 
• Training: Our employees receive regular training on data protection and security to ensure they understand the importance of safeguarding personal data.
• Policies and Procedures: We maintain and regularly update comprehensive data protection and information security policies. 
• Incident Response
• Monitoring: We continuously monitor our systems for potential vulnerabilities and attacks.
• Response Plans: We have established incident response plans to quickly address any security breaches. These plans include notifying affected users and regulatory authorities, as required by law.
•  Continuous Improvement
• Evaluations: We regularly evaluate our security policies and practices to adapt to new threats and changes in technology.
• Updates and Patches: Our software and systems are regularly updated to incorporate the latest security features and patches.

 Commitment to Data Security

We are committed to maintaining the security of your personal data and have implemented stringent measures to prevent data loss, misuse, or unauthorized access. Should you have any questions about the security of your personal data, please contact us at info@osntt.com.

Changes to the Privacy Policy

SNTT d.o.o. reserves the right to update or modify this privacy policy at any time to reflect changes in our practices, service offerings, or legal or regulatory requirements. Here is how we will inform you of any changes:

 Notification of Changes

• Updates on Our Website: We will post any changes to our privacy policy on our website osntt.com(https://osntt.com). We encourage you to review our privacy policy periodically to stay informed of any updates.
• Direct Communication: For significant changes, we may also notify you directly via email or through a notification on our service platforms, particularly if the changes affect the way we process personal data or expand our rights to use personal data that we have already collected.

Effective Date

Posting Date: The date of the latest revision will be indicated at the top of the privacy policy page, so you are always aware of when the last update occurred.

 Your Acceptance of Changes

Continued Use: By continuing to use our services after these changes are posted, you agree to the revised policy. If you do not agree to the changes, you should discontinue your use of our services.

 Contact Information

If you have any questions or concerns about our privacy policy or its updates, please do not hesitate to contact us at info@osntt.com.

Right to Lodge a Complaint

SNTT d.o.o. takes your concerns about privacy very seriously. If you are located in the European Economic Area (EEA) and believe that we have not adhered to applicable privacy laws, you have the right to lodge a complaint with a supervisory authority, especially in the member state where you reside, work, or where the alleged infringement occurred.

 How to Lodge a Complaint

1. Identify the Authority: You can file a complaint with the national supervisory authority of your country. A list of these authorities can be found on the European Commission’s website or through local government resources.
2. Contact the Authority: Each authority typically has a procedure for lodging complaints, which can often be completed online or by submitting a form through the post.
3. Provide Details: When submitting a complaint, include all relevant details, such as what your complaint is about, any correspondence you’ve had with us related to your grievance, and why you believe your data has not been processed in compliance with GDPR.

Commitment to Resolve Issues

We encourage you to contact us at info@osntt.com before filing a complaint with a data protection authority. We are committed to resolving any complaints concerning our data protection practices and would appreciate the opportunity to address your concerns directly.

Third-Party Websites

This Privacy Policy applies only to your use of this website. 

Our website may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites, since we do not review and cannot be responsible for these third-parties websites or their content. Therefore we advise you to check and read the privacy policies of any such websites before providing any data to them.

Contact Us

If you have any questions about your personal data and your rights under CCPA, please contact us at info@osntt.com.