Chatbot Ljubo: Privacy Protection Policy

1. General

These Rules on Protection of Privacy apply to anyone who is in accordance with the General Terms and Conditions of Business and Use of the Turizem Ljubljana chatbot called »Ljubo« in its entirety, including its subpages, accessed via the Facebook Messenger platform.

A user is any legal entity or natural person using or the Turizem Ljubljana chatbot called »Ljubo«. (Hereinafter: user).

By using the chatbot the user agrees with these Rules on Protection of Privacy.

The chatbot can be accessed only via the Facebook Messenger platform, therefore the Terms and Conditions and Cookie Use of Facebook also apply for the use of this chatbot.

2. Protection of personal data

Turizem Ljubljana respects your privacy and undertakes to use your personal data exclusively for the stated purposes. Your personal data shall be carefully protected in accordance with the legislation governing the protection of personal data (Regulation (EU) 2016/679, the Personal Data Protection Act in force, Rules on Protection of Privacy and Cookie Use and internal rules of Turizem Ljubljana.

3. Controller of personal data

The controller of personal data processed in accordance with these Rules is Turizem Ljubljana, Krekov trg 10, 1000 Ljubljana.

4. Personal data protection officer

Katja Hrvatin Rakar, the person authorized for personal data protection at Turizem Ljubljana is available at the e-mail address [email protected].

5. Personal data processor

The contract processor of personal data collected within the scope of the chatbot use is the company Klepetalni robot d.o.o., Ulica Pavle Jeromnove 5A, 1000 Ljubljana. The controller and processor of personal data have defined and regulated their mutual relations and obligations, including personal data protection, with a written contract.

6. Transmission of personal data to third parties or third countries

Turizem Ljubljana does not transmit personal data collected on the website to third parties or third countries.

An exception is the partners that provide and enable the development and operation of the chatbot service.

The information collected by the Turizem Ljubljana chatbot is stored on the servers of ChatFuel 200 Labs Inc., 25 Taylor Street STE 619, San Francisco, CA, 94102-3916, USA, and data transfer to third countries is based on the Privacy Shield, jointly designed by the US Department of Commerce and the European Commission, which serves as a support mechanism for meeting data protection requirements for the transfer of personal data from the European Union to the US or transatlantic businesses. Data is also processed using the Google Sheets tool provided by Google LLC, Mountain View, California, USA.

7. Types of personal data and purposes of their processing

Turizem Ljubljana collects and processes personal data based on the legislation or consent (agreement) of individuals.

Processing based on the legislation

Turizem Ljubljana performs its tasks and activities based on the legislation of the Republic of Slovenia, and therefore, in line with the legal basis, collects and processes personal data of individuals necessary for the fulfilment of legal obligations imposed on it as a controller of personal data. In accordance with the provisions of the act, governing data protection and the General Data Protection Regulation Turizem Ljubljana keeps processing records where the legal basis for personal data collection and processing is specifically determined.

Processing based on consent (agreement) of an individual

Based on prior voluntary, explicit, informed and unequivocal statement of will or consent (agreement) of individuals, and their simultaneous notification that they can revoke their consent at any time, Turizem Ljubljana collects and processes personal data, namely:

• for the purpose of sending notifications with information about the city of Ljubljana and the country of Slovenia: name, surname, chatbot subscription status and Facebook Messenger ID;
• for the purpose of sending notifications with information regarding various giveaways hosted by Turizem Ljubljana: name, surname, chatbot subscription status, home address, e-mail and Facebook Messenger ID.
• For the purpose of sending notifications with information regarding new features and news subscriptions on www.visitljubljana.si: name, surname, chatbot subscription status and Facebook Messenger ID;

The personal settings of an individual can be changed at any time by selecting the "Settings" option in the chatbot menu and afterwards clicking the “Your Data” option. The individual can then control the saved data by deleting parts or all of it or unsubscribing from the chatbot.

8. Personal data collection

To ensure personal data protection Turizem Ljubljana implements all necessary legal, organisational and appropriate logistical and technical procedures and measures, either on its own on, based on the legislation, regulations and internal rules or via its contract partners. For the purpose of the latter Turizem Ljubljana binds the providers or operators to necessary and consistent compliance with the legal basis, the General Data Protection Regulation and internal rules of Turizem Ljubljana.

9. The personal data retention period

Personal data of individuals, obtained on the basis of consent, can be processed and stored until the fulfilment of the purpose for collecting and processing data or until the revocation of the consent given by an individual. Individuals can change or revoke their consent at any time.

Personal data, collected based on regulations, are stored in accordance with the legislation regulating their collection. After the expiry of the legal retention period, the data is erased.

10. Rights of an individual

In accordance with the personal data protection regulations, individuals have the right to revoke their consent at any time and edit their personal data via the chatbot personal settings.

Individuals can also submit a complaint with regard to the processing of their personal data directly to the competent supervisory authority, that is, to the Information Commissioner of the Republic of Slovenia.

11. Procedure in case of violation

In case of violation of the personal data protection, Turizem Ljubljana shall immediately take all appropriate measures for the protection of rights and interests of the individual in accordance with the applicable legislation and the General Data Protection Regulation.

12. Validity

In case of any additions or changes to these Rules on Protection of Privacy, the users will be notified accordingly.

These Rules on Protection of Privacy are published on www.visitljubljana.com and are effective from October 14, 2019.