Privacy Policy

1. Data controller

The data controller is Implementor d.o.o., Tržaška cesta 2, 1000 Ljubljana, Slovenia, [PLACEHOLDER: company registration number], [PLACEHOLDER: tax number].

For questions regarding personal data protection: [email protected]

Given the nature, scope, context, and purposes of processing, Implementor d.o.o. is not required to appoint a Data Protection Officer (DPO) under Article 37 GDPR. For any questions regarding personal data protection, please contact the email address above.

2. Personal data we collect

We collect the following categories of personal data:

2.1 Contact form data

When you submit the consultation request form, we collect: full name, company name, email address, phone number (optional), company size, inquiry intent, and any message you provide. We also record the sender's IP address on submission.

2.2 Technical data on website visits

Our servers automatically record standard log data: IP address, browser type, operating system, referring URL, and access time. We retain log files for a maximum of 30 days, after which they are automatically deleted or anonymised. Processing is based on legitimate interest (Art. 6(1)(f) GDPR) for security, error diagnostics, and protection against abuse.

2.3 Cookies and tracking technologies

We use cookies and similar technologies to collect data on website usage, as described in section 8 (Cookies).

3. Purposes and legal basis for processing

3.1 Handling inquiries

We process contact form data to respond to your inquiry and for any follow-up communication related to our services. Legal basis: performance of a contract or pre-contractual measures (Art. 6(1)(b) GDPR) and legitimate interest (Art. 6(1)(f) GDPR).

3.2 Website analytics

We process website visit data to improve content and user experience. Legal basis: consent (Art. 6(1)(a) GDPR), given via the cookie banner.

3.3 Marketing communications

We currently do not send marketing emails. Should we begin sending such communications in the future (e.g. newsletters, event invitations, or offers), we will do so exclusively on the basis of your explicit consent (Art. 6(1)(a) GDPR), using a double opt-in mechanism, and with a simple unsubscribe option in every message.

4. Data retention

After the retention period, data is deleted or anonymised, unless legislation requires longer retention.

5. Recipients of personal data

We do not sell your data to third parties. We share data only with the following categories of processors:

• Hostinger International Ltd. (Lithuania, EU) — website hosting and delivery of inquiry email notifications via an SMTP server within the same hosting environment. Data is processed in data centres within the European Economic Area.
• Google LLC (Google Tag Manager, Google Analytics 4, Google Ads) — for web analytics, advertising, conversion measurement, and remarketing (re-engaging visitors who have already visited the website). Analytics and advertising cookies are activated only with your consent. Google is located in the United States; transfers are based on appropriate safeguards (standard contractual clauses).
• Meta Platforms Ireland Ltd. (Meta Pixel) — for advertising purposes, including conversion measurement and remarketing, only with your consent.

All processors are bound to process data solely on our instructions and in compliance with GDPR.

We also use Google Search Console to monitor the website's visibility in Google Search. The tool does not place cookies on your devices; the aggregated data on search queries, clicks, and impressions is obtained from Google's search index rather than from this website.

6. Transfers to third countries

Some recipients (Google LLC, Meta Platforms, Inc.) are located in the United States. Both recipients are certified under the EU–US Data Privacy Framework (DPF) on the basis of the European Commission's adequacy decision of 10 July 2023; transfers are additionally based on standard contractual clauses (SCCs) in accordance with Art. 46(2)(c) GDPR. Website hosting and inquiry processing take place within the European Economic Area.

7. Your rights

Under GDPR and the Slovenian Personal Data Protection Act (ZVOP-2), you have the following rights:

• Right of access — you may request confirmation of whether we process your data, and a copy of that data.
• Right to rectification — you may request correction of inaccurate data or completion of incomplete data.
• Right to erasure — you may request deletion of personal data when there is no legal basis for further retention.
• Right to restriction of processing — you may request restriction in certain cases (e.g. while data accuracy is being verified).
• Right to data portability — you may request your data in a machine-readable format.
• Right to object — you may object to processing based on legitimate interest.
• Right to withdraw consent — you may withdraw consent at any time for processing based on consent, without affecting lawfulness prior to withdrawal.

To exercise these rights, contact us at: [email protected]. We will respond to your request within one month.

If you believe your rights have not been respected, you have the right to lodge a complaint with the Slovenian Information Commissioner (www.ip-rs.si), Dunajska cesta 22, 1000 Ljubljana.

8. Cookies

The implementor.si website uses cookies. On your first visit, we ask for consent via the cookie banner in accordance with the Slovenian Electronic Communications Act (ZEKom-2).

Strictly necessary cookies

Ensure basic website operation (session, CSRF security token). No consent required.

Analytics cookies

Google Analytics 4 (via Google Tag Manager) — records anonymous visit data (pages, time, traffic source). Activated only with your consent.

Marketing cookies

Google Ads (conversion tracking and remarketing) and Meta Pixel — for measuring ad performance and showing relevant ads to visitors who have already visited the website. Activated only with your consent.

You can change your consent preferences at any time by clicking the Cookie settings link in the footer of the website.

9. Data security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, modification, or destruction, including encryption of data transmission (HTTPS) and restricted access to data.

10. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The last updated date appears at the top of this document. For material changes, we will notify you via the website.

11. Contact

For any questions regarding personal data protection, please contact us: