Privacy policy
Data Controller
Open Line Vitaly BV, a company registered in Netherlands with VAT number NL814450842B01 with registered offices at Amerikalaan 90, 6199 AE Maastricht Airport, Netherlands, VAT: NL814450842B01.
Branch: Open Line Vitaly d.o.o., Cesta v Gorice 34C, 1000 Ljubljana, Slovenia, Registration No.: 1328689000
Email: privacy@openline-vitaly.com
We are committed to protecting your personal data in accordance with Regulation (EU) 2016/679 (GDPR), Slovenian Personal Data Protection Act (ZVOP-2, Official Gazette RS, No. 163/22), Slovenian Electronic Communications Act (ZEKom-2, Official Gazette RS, No. 130/22), and Slovenian Consumer Protection Act (ZVPot). This privacy policy explains how we collect, process, store, and protect your personal data, your rights as a data subject, and how you can exercise those rights. Our goal is to ensure transparency, compliance with applicable laws, and to strengthen your trust in our data handling practices.
1. Purpose and Scope of Personal Data Processing
We process personal data to ensure the functionality of the website www.openline-vitaly.com, conduct recruitment processes, perform marketing activities, and fulfill legal obligations. Personal data includes information that identifies you, such as your name, surname, email address, phone number, residential address, CV details, or other information you provide through web forms or job applications.
Processing is based on the following legal bases:
Contract (Article 6(1)(b) GDPR): To respond to inquiries submitted via web forms or to fulfill other requests requiring the conclusion or performance of a contract. Example: processing your name, email, and inquiry content to prepare an offer or response.
Consent (Article 6(1)(a) GDPR): For recruitment processes (e.g., job applications, inclusion in the candidate database) and marketing activities (e.g., sending newsletters or service notifications). You may withdraw consent at any time without affecting the lawfulness of prior processing.
Legitimate Interest (Article 6(1)(f) GDPR): To improve the website, analyze website traffic (using anonymized data), or prevent misuse. We conduct a balancing test to ensure your interests do not override ours.
Legal Obligation (Article 6(1)(c) GDPR): To provide data to competent authorities (e.g., courts, Slovenian Financial Administration) or comply with other legal requirements.
2. Types of Processed Data
We collect the following categories of data:
Website Usage: Name, surname, email, phone number, inquiry content, IP address (anonymized via analytical cookies).
Recruitment Processes: Name, surname, address, contact details (email, phone), CV details (e.g., education, work experience, skills, languages), information about previous applications, current employment status, or availability.
Marketing: Name, email, phone number for sending newsletters or service notifications.
Legal Records: Data required to fulfill legal obligations (e.g., accounting data, if applicable).
Data is collected directly from you (e.g., through forms, applications) or indirectly (e.g., via cookies for traffic analysis). We collect only the data necessary to achieve the stated purposes, in line with the data minimization principle (Article 5 GDPR).
3. Cookies
We use cookies on www.openline-vitaly.com, small text files stored in your browser, to ensure website functionality, enhance user experience, and analyze traffic:
Essential Cookies: Necessary for website operation, do not require consent.
_JSESSIONID (session): Tracks activity during browsing, deleted when the browser is closed.
en.parsek.web.cookies (1 year): Stores your cookie preferences.
Analytical Cookies: Enable anonymous traffic analysis to improve the website.
__ga (Google Analytics, 2 years): Records visit statistics (e.g., number of visits, time on site). IP addresses are anonymized using the anonymizeIP function. Data may be transferred to the USA under standard contractual clauses, in compliance with GDPR (Article 46).
We obtain your consent for analytical cookies via a banner displayed upon your first visit to the website. You can modify or withdraw consent at any time through cookie settings on the website or by emailing privacy@openline-vitaly.com. Withdrawal does not affect essential cookies required for website operation. For more details, including browser management instructions, see our Cookie Notice.
4. Sharing of Personal Data
We share your data only to the extent necessary to achieve the processing purpose:
External Processors: Carefully selected partners, such as IT service providers (e.g., website maintenance), accounting services, or the parent company Open Line Vitaly BV (within the EU). External processors are contractually bound to protect data and comply with GDPR. Data transfers to the parent company occur for recruitment or service management purposes.
Competent Authorities: We provide data to courts, law enforcement, or other public authorities (including those in other EU Member States) based on legal requests.
Third Countries: Data processed via Google Analytics may be transferred to the USA. Such transfers are safeguarded by standard contractual clauses or other measures ensuring GDPR compliance. For further information on data transfers, contact privacy@openline-vitaly.com.
External processors may use data solely for agreed purposes and are bound by confidentiality. We ensure that data is not sold or shared with unrelated third parties for marketing purposes.
5. Personal Data Security
We implement advanced technical and organizational measures to protect your data:
Technical Measures: Data encryption during transmission (e.g., SSL/TLS), restricted database access, regular system security updates.
Organizational Measures: Internal data protection policies, employee training, confidentiality agreements with external processors.
Physical Measures: Restricted access to premises where data is stored and physical server protection.
Data is stored in secure data centers within the European Union, except for potential transfers to third countries as described above. In case of a data breach likely to affect your rights, we will notify you promptly, in line with GDPR (Article 34).
6. Data Retention Periods
We retain personal data only as long as necessary to achieve the processing purpose or comply with legal obligations:
Web Forms: Until the purpose is fulfilled (e.g., responding to an inquiry) or consent is withdrawn.
Recruitment Data: 2 years from consent or until withdrawal, for inclusion in the candidate database for future opportunities.
Marketing Data: Until consent for newsletters or notifications is withdrawn.
Legal Data: In accordance with legal retention periods, e.g., 10 years for accounting records under the Slovenian Value Added Tax Act (ZDDV-1).
After the retention period expires, data is deleted, destroyed, blocked, or anonymized, unless otherwise required by law.
7. Data Subject Rights
Under GDPR, you have the following rights:
Right of Access: Verify which data we process and obtain a copy. Additional copies may incur a reasonable fee.
Right to Rectification: Request correction of inaccurate or completion of incomplete data.
Right to Erasure (“Right to be Forgotten”): Request deletion of data if no longer needed, you withdraw consent, or processing is unlawful.
Right to Restriction of Processing: Restrict processing, e.g., during verification of data accuracy or if you need data for legal claims.
Right to Data Portability: Receive data in a structured, machine-readable format or request transfer to another controller, if processing is based on consent or contract.
Right to Object: Object to processing based on legitimate interest due to your specific situation. We will cease processing unless we demonstrate overriding legitimate grounds.
Right to Withdraw Consent: Withdraw consent for marketing or recruitment data at any time via privacy@openline-vitaly.com, without affecting contractual relationships or prior processing lawfulness.
Submit requests to exercise your rights to:
Email: privacy@openline-vitaly.com
Post: Open Line Vitaly d.o.o., Cesta v Gorice 34C, 1000 Ljubljana, Slovenia
We process requests without undue delay, within 1 month of receipt, with a possible extension of 2 months for complex requests. If we doubt your identity, we may request additional information. If requests are manifestly unfounded or excessive, we may charge a reasonable fee or refuse to act.
8. Right to Lodge a Complaint
If you believe our data processing violates GDPR, ZVOP-2, or other legislation, you may lodge a complaint:
With the Controller: Submit a complaint to privacy@openline-vitaly.com or by post to Open Line Vitaly d.o.o., Cesta v Gorice 34C, 1000 Ljubljana.
With the Supervisory Authority: Information Commissioner, Dunajska cesta 22, 1000 Ljubljana, Slovenia, email: gp.ip@ip-rs.si, phone: +386 1 230 97 30, website: www.ip-rs.si.
If you exercise your right of access and believe the provided data is incorrect or incomplete, you may file a complaint with us within 15 days. We will decide on the complaint within 5 working days.
9. Policy Updates
We reserve the right to update this privacy policy. Changes will be published on www.openline-vitaly.com at least 30 days before taking effect. We may also notify you of changes via email if you are subscribed to our newsletters or have provided data in recruitment processes.
10. Effective Date
This privacy policy is effective from July 1, 2025.
For additional questions or clarifications, contact us at privacy@openline-vitaly.com.