This privacy policy (“Policy”) describes how Anteja ECG (“Anteja”, “we”, “us” or “our”) collects, protects and uses the personally identifiable information (“Personal Information”) you (“User”, “you” or “your”) may provide on the www.anteja-ecg.com website and any of its products or services (collectively, “Website” or “Services”).

    It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

    It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage. Anteja processes the data transmitted to it in accordance with the legislation in force, and, in particular, Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data, applicable from 25 May 2018, so-called General Data Protection Regulation (“GDPR”).

    Table of Contents:

    1.      Privacy Policy

    1. Data controller
      1. Sources of Data
      1. What information do we collect?
        1. Sensitive data
      1. How do we collect information?
      1. How do we use your information?
        1. Automatic collection of information
        1. Legal basis for processing your Personal Information
        1. Distribution of your Personal Information to third parties
      1. How do we store your information?
        1. Retention period
        1. Information security
        1. Data breach
      1. What are your data protection rights?
        1. Data protection rights
        1. How to exercise these rights
        1. Contacting your Data Protection Officer
        1. California privacy rights
        1. Newsletters
      1. Privacy of children
      1. What tracking technologies do we use?
        1. Cookies
        1. Do Not Track signals
        1. Links to other websites
        1. Website analytics
      1. . Legal implications

    1.10.1 Legal disclosure

    1. Indemnification

          1.11. Changes and amendments to this Policy

          1.12. Acceptance of this Policy

          1.13. Contacting us

    1.1 Data Controller:

    Regarding the data collected from the Website, the data controller is:

    Anteja ECG d.o.o.

    Lambergarjeva ulica 8

    1000 Ljubljana

    1.2 Sources of Data:

    This Policy applies to data that we collect from or about you, through the methods described in Section 2, from the following sources:

    • Our Website, www.anteja-ecg.com

    1.3 What information do we collect?

    You can visit the Website without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use our Services, you will be asked to provide certain Personal Information (for example, your name and e-mail address). We receive and store any information you knowingly provide to us when you create an account, publish content, or fill any online forms on the Website. When required, this information may include the following:

    • Personal details such as name, country of residence, etc.
    • Contact information such as email address, address, etc.
    • Account details such as username, unique user ID, password, etc.
    • Browser information such as your IP address, browser type and version, operating system type and version, language preferences or the webpage you were visiting before you came to our Website, pages of our Website that you visit, the time spent on those pages, information you search for on our Website, access times and dates, and other statistics.
    • Information about other individuals such as your family members, friends, etc.
    • Any other materials you willingly submit to us such as articles, images, feedback, etc.

    You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the Website’s features. Users who are uncertain about what information is necessary to use our Services are welcome to contact us.

    1.3.1 Sensitive data

    We do not collect any sensitive data as defined by Art. 9 GDPR, namely racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

    1.4 How do we collect information?

    You directly provide us with most of the Personal Information we collect when you:

    • Register on our Website or place an order to any of our Services
    • Complete surveys or provide feedback on our message boards or via email
    • Automatic collection of information when you use or view our Website via your browser’s cookies
    • Sign up for newsletters
    • Register for competitions
    • Contact us via email or other social media

    1.5 How do we use your information?

    The Personal Information we collect will be used in order to make our Website and Services available to you or to meet a certain legal obligation. If you do not provide the information that we request, we may not be able to provide you with the requested Services.

    Any of the information we collect from you may be used for the following purposes:

    • Create and manage user accounts
    • Send administrative information
    • Respond to inquiries and offer support
    • Request user feedback
    • Improve user experience
    • Administer prize draws and competitions
    • Enforce terms and conditions and policies
    • Protect from abuse and malicious users
    • Respond to legal requests and prevent harm
    • Run and operate our Website and Services

    1.5.1 Automatic collection of information

    Information collected automatically, such a browser information, is only used to identify potential cases of abuse and establish statistical information regarding Website usage. This statistical information is not otherwise aggregated in such a way that would identify any particular User of the system.

    1.5.2 Legal basis for processing your Personal Information:

    Processing of your Personal Information is done according to Art. 6(1) GDPR if one of the following applies:

    • You have given consent for the processing of your data
    • Provision of information is necessary for the performance of contract or in order to take steps at the request of the data subject prior to entering into a contract.
    • Processing is necessary for compliance with a legal obligation to which we are subject
    • Processing is necessary to protect the vital interests of the data subject or of another natural person
    • Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us
    • Processing is necessary for the purposes of the legitimate interests pursued by us or a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular, where the data subject is a child.

    Note that under some legislations we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

    1.5.3 Distribution of your Personal Information to third parties

    Should any of your Personal Information be distributed to third parties, you will be notified prior to approve such action. Should you decline, your information will not be shared with third parties. Keep in mind, rejection of such request may impact which features on our Website can be used and some Services may be unavailable.

    1.6 How do we store your information?

    1.6.1 Retention period

    Your Personal Information will be retained for the period necessary to achieve the objectives pursued (see section on how we use your Personal Information), comply with our legal obligations, resolve disputes, and enforce our agreements. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted or anonymized. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.

    1.6.2 Information security

    We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our Website cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite best efforts.

    1.6.3 Data breach

    In the event we become aware that the security of the Website has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website, send you an email, get in touch with you over the phone.

    1.7 What are your data protection rights?

    1.7.1 Data protection rights

    You may exercise certain rights regarding your Personal Information processed by us.

    According to applicable law and the GDPR, you have the right to the following:

    • The right to be informed about your Personal Information being processed by us including minimum info on existence of processing, its legal basis, and purposes.
    • The right to access, review, and request a physical or electronic copy of information held about you. You also have the right to request information on the source of your data.
      • The first exercise of the right access will be free of charge. For any additional request, a reasonable fee may be charged.
    • The right to object to the processing of your information if the processing is carried out on a legal basis necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, or when processing is necessary for the purposes of the legitimate interests. You must know that, however, should your Personal Information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn, whether we are processing Personal Information for direct marketing purposes, you may refer to the relevant sections of this document.
    • The right to rectification that Anteja correct any information you believe is inaccurate or to request Anteja to complete information you believe is incomplete.
    • The right to erasure of your personal data, under certain circumstances listed in Art. 17(3) GDPR.
      • We may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our obligations to our affiliates and partners. If you would like to delete your Personal Information or permanently delete your account, you can do so on the settings page of your account on the Website.
    • The right to restrict the processing of your Personal Information, under certain circumstances, namely when the User has objected to the processing, disputes the accuracy of the data, or considers the processing to be illegal.
    • The right to portability where you can request that Anteja transfers the data that we collected to another organization, or directly to you, under certain conditions. You have the right to receive your information in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.
    • The right to contact your data protection authority.

    1.7.2 How to exercise these rights

    Any requests to exercise User rights can be directed to Anteja through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by us as early as possible unless the request is unreasonable or excessive upon which a reasonable fee will be charged.

    1.7.3 Contacting your Data Protection Officer

    We hope that Anteja can satisfy queries you may have about the way we process your data or the exercise of your rights. However, if you have unresolved concerns you also have the right to complain to your competent data protection authorities, more specifically your designated Data Protection Officer.

    1.7.4 California privacy rights

    In addition to the rights as explained in this Policy, California residents who provide Personal Information to obtain products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the Personal Information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared such personal information for the immediately prior calendar year (e.g., requests made in the current year will receive information about the prior year). To obtain this information please contact us.

    1.7.5 Newsletters

    We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a third-party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.
    In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. You will, however, continue to receive essential transactional emails.

    1.8 Privacy of children

    Our services are not directed to children. We do not knowingly collect any Personal Information from children under the age of 16. If you are under the age of 16, please do not submit any Personal Information through our Website. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through our Website without their permission. You must also be at least 16 years of age to consent to the processing of your Personal Information in your country (in some countries we may allow your parent or guardian to do so on your behalf).

    If you have reason to believe that a child under the age of 16 has provided Personal Information to us through our Website, please contact us at information provided at the bottom of this Notice.

    1.9 What tracking technologies do we use?

    1.9.1 Cookies

    The Website uses “cookies” to help personalize your online experience. Please see our Cookie Policy below on how we use cookies and what your options are regarding cookies.

    1.9.2 Do Not Track signals

    Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. Our Website does not track its visitors over time and across third party websites. However, some third-party sites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.

    1.9.3 Links to other websites

    Our Website contains links to other websites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other websites or third parties. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every website that may collect Personal Information.

    2.9.4 Website analytics

    We may partner with selected third-party vendors, such as Google Analytics to allow tracking technologies and remarketing services on the Website using first-party and third-party cookies, to, among other things, analyze and track users’ use of the Website, determine the popularity of certain content and better understand online activity. By accessing the Website, you consent to the collection and use of your information by these third-party vendors.

    1.10 Legal implications:

    1.10.1 Legal disclosure

    We will disclose any information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

    1.10.2 Indemnification

    You agree to indemnify and hold harmless the Operator, its contractors, and its licensors, and their respective directors, officers, employees and agents from and against any and all claims and expenses, including attorneys’ fees, arising out of your use of the Site, including but not limited to your violation of this Agreement.

    1.11 Changes and amendments to this Policy

    We may update this Privacy Policy from time to time in our discretion and will notify you of any material changes to the way in which we treat Personal Information. When changes are made, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any updated version of this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified. Your continued use of the Website or Services after the effective date of the revised Privacy Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Data in a manner materially different than what was stated at the time your Personal Data was collected.

    1.12 Acceptance of this Policy

    You acknowledge that you have read this Policy and agree to all its terms and conditions. By using the Website or its Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to use or access the Website and its Services.

    1.13 Contacting us

    If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may send an email to info@phy2app.com or info@anteja-ecg.com.

    This document was last updated on 2nd October 2021.