The purpose of the Personal Data Protection Policy is to inform users, parents, co-workers, employees, and others (referred to below as “individuals”) that cooperate with the Najdihojca Kindergarten (referred to below as the “Kindergarten”) about intentions and legal bases, data protection measures and the rights of individuals regarding the processing of personal data by our Kindergarten.<\/p>\n
Personal data is processed in accordance with Regulation (EU) 2016\/697 concerning the protection of natural persons with regard to the processing of personal data and concerning the free movement of such data (referred to below as the “General Regulation”), applicable Slovenian legislation in the field of personal data protection and privacy in electronic communication and other regulations that regulate personal data protection. The way we process personal data is based on the legal bases for the legality of processing it, taken from article 6(1) of the General Regulation: (a) consent, (b) implementation of a contract, (c) fulfilling legal obligations, (e) performing tasks in the public interest and (f) lawful interest.<\/p>\n
This policy describes the purposes for which we process any personal data that we receive from you on a legal basis, described below, and how we do so.<\/p>\n
any personal data that we receive from you on a legal basis, described below, and how we do so.<\/p>\n
According to this policy, the personal data controller is:<\/p>\n
Najdihojca Kindergarten, Gorazdova 6, 1000 Ljubljana, Slovenia, email: vrtec@najdihojca.si<\/a><\/p>\n In accordance with the provision of article 37 of the General Regulation, we have nominated the company Info hiša d.o.o. as an authorized person to protect personal data. Email: dpo@info-hisa.si<\/a>, tel. +386 1 2355 036.<\/p>\n We process personal data for enrollment and the performance of our activities within the framework of a public service, on the basis of a legal contract. We process the personal data for parents and children, which we are required to collect according to the Slovenian Kindergartens Act and Rules on the Collection and Protection of Personal Data in the Field of Preschool Education.<\/p>\n We must therefore collect the name, surname, personal identification number, address and contact information of the parents or guardians, the name, surname, personal identification number, gender and address of the child, and other data that is required by article 44 of the Slovenian Kindergartens Act.<\/p>\n To finalize the enrollment process, we will also need other information which will enable us to determine whether the criteria for enrolling your child, set by the City Municipality of Ljubljana each year, have been met. When your child is enrolled in the Kindergarten, we will store attendance data and observe the child’s development through his or her personal file (portfolio).<\/p>\n The contact address, email address and telephone number of at least one parent or guardian will be kept by us so that we can keep in contact after enrollment and inform you if your child has any urgent special medical needs, tell you about the work of your child’s department, and keep you up to date about any fees that you owe to the Kindergarten.<\/p>\n If you do not permit us to process your data, we will not be able to guarantee enrollment in the Kindergarten and provision of the program for your child.<\/p>\n The collected information will be kept for five years after the end of the calendar year after enrollment or after your child has left the Kindergarten.<\/p>\n To monitor monthly payments, the Kindergarten processes data that records the single and monthly payments made by parents. This data is collected on the basis of a legal contract and we are obliged to collect it according to the Slovenian Kindergartens Act and Value Added Tax Act.<\/p>\n The collected data will be kept for ten years after the end of the calendar year in which the last payment was made.<\/p>\n If your child needs counseling or help, or has a special educational needs guidance decision, we will process the following data, within the process for offering professional help, once we have received parental or guardian’s consent:<\/p>\n The collected data will only be used to provide professional counseling or help and will be forwarded to other users in accordance with the law. The data will be kept for one year after the child has left the Kindergarten.<\/p>\n With your consent, we will use your contact data to send you notifications and announcements about events and campaigns in the Kindergarten or ask for your opinion about the performance of our Kindergarten within the framework of our self-evaluation processes.<\/p>\n Within the framework of Kindergarten activities, we collect and process the following photographic and audio material:<\/p>\n We will ask for your consent, in advance, for each of the different reasons for processing the materials listed above, collected in such a way. We will also ask for your consent again, every year, in accordance with article 16 of the Slovenian Rules on the Collection and Protection of Personal Data in the Field of Preschool Education.<\/p>\n The materials we collect in such a way will also be made available to you, the parents and guardians in each department, and we will ask you to sign a declaration that you will respect the personal data of other parents, guardians, children in the department and any other potential third parties whose personal data might be included in the processing (e.g. due to their participation in a Kindergarten event).<\/p>\n As we are required to fulfill our legal obligations, we will process your personal data in accordance with tax regulations, which means we will, along with financial transactions, store your data, such as payer data (transactional account, name, surname), for ten years after the end of the calendar year in which we issued you an invoice. The legal basis for the purpose of processing is the fulfillment of legal obligations.<\/p>\n We want to improve your user experience, so we try to understand your use of our websites, services, or tools. To do so, we use internal or external tools to analyze the use of applications and user experiences.<\/p>\n We use internal tools on the legal basis of our legal interest. In the case of third party analytical tools, we will ask for your consent to forward data with them before you use them.<\/p>\n To perform analytical processing, we will store your data for no more than two years after the end of the calendar year in which that data was created or until you revoke your consent.<\/p>\n In the legal sense, cookies are any data that is stored in your terminal equipment. As a provider of web services, we need them to guarantee that our services work properly. We mostly use cookies to check and maintain your login and save your settings or preferences, or to guarantee internal analytical functionality and security. Such cookies are essential and necessary for our services to work properly. For this reason, their use is a contractual requirement.<\/p>\n With your consent, we can also use cookies for analyzing website use, connecting with social media, or to guarantee additional functionality. With the help of these cookies, we determine the efficacy of the design of our solutions and give you the best possible user experience.<\/p>\n We provide more information about specific cookies, for you to read, on each of our websites that uses cookies, where we will also ask you for your consent.<\/p>\n Your personal data will only be processed for as long as necessary to fulfill the purpose for which the data was collected and processed. If the data has been collected on a legal basis, we will store the data for as long as is specified by law.<\/p>\n The personal data that we need to meet our contractual obligations will be kept as long as necessary to fulfill the contract and then for another five years after the end of the calendar year in which the contract ended, except when storage for a longer period would be necessary due to disputes concerning the contract. In such cases, we will store your personal data for another ten years after the end of the calendar year in which the final court decision, arbitration, or court settlement occurred or, if there was no legal dispute, five years after the end of the calendar year in which the dispute was amicably resolved.<\/p>\n Personal data that we process on the basis of consent or our legal interest will be kept for no more than five years after the end of the calendar year in which the child left the Kindergarten, except for materials collected for the purpose of documenting the Kindergarten’s history, which will be kept indefinitely or until consent to do so is revoked. If you revoke your consent, we will delete your personal data by the beginning of the next school year at the latest. We can delete this data before you revoke your consent if the purpose of processing the personal data has been fulfilled or when specified by the law. If you revoke your consent, this does not affect our legal right to process your data on the basis of your consent prior to you revoking it.<\/p>\n In exceptional cases, we can deny your request to delete your data due to reasons specified in the General Regulation (EU): the exercising of rights to free expression and notification, the fulfilling of legal obligations to process personal data, reasons relating to the public interest in the field of public health, for the purpose of public archiving in the public interest, scientific or historical research purposes or statistical purposes and the application or defense of legal claims.<\/p>\n After the data storage period has ended, we will effectively and permanently delete or anonymize personal data so it cannot be connected with a specific individual.<\/p>\n When processing your personal data, we are entitled to task subcontracted data-processing organizations with processing individual sets or subsets of data. These data-processing organizations are exclusively permitted to process the data we communicate to them on our behalf, within the bounds of their authorization, which is defined in a written contract or other legal act in accordance with the purposes that are determined in this Privacy Policy.<\/p>\n In our work, we collaborate with subcontractors in the following fields:<\/p>\n To enable us to manage and control individual subcontracted data-processors more effectively, and ensure that our contractual relations with them are kept in order, we also have a list of such organizations, with which we collaborate.<\/p>\n For some services, we might also provide your personal data to potential project partners, supervisory authorities, or on the basis of judicial claims. We will never give your personal data to unauthorized third-parties.<\/p>\n In the case of Facebook posts, we also give your personal data to a third country (outside of the European Economic Area), the USA. We regulate relationships with subcontracted data-processors, co-controllers, or controllers in these countries with standard contracts that have been approved by the European Commission.<\/p>\n As the controller, we take care of information and infrastructure security (spaces and applicable system software).<\/p>\n We have implemented appropriate technical organizational security measures intended to protect personal data from random or unlawful destruction, loss, manipulation, unauthorized publication or access, and from other unlawful and unauthorized forms of processing.<\/p>\n As an individual, you are personally responsible for providing us with your personal data in a secure way and to guarantee the accuracy and authenticity of that data. As the controller, we will also ensure that the personal data that we process is accurate and, if needed, up-to-date. Occasionally, we might contact you to confirm the accuracy of processed personal data.<\/p>\n In accordance with the General Regulation (EU), you, as an individual, have the following rights relating to the protection of your personal data:<\/p>\n If you wish to exercise any of the previously listed rights, you can email a request to vrtec@najdihojca.si<\/a> or post a letter to our address. We will answer any request that relates to the rights of an individual without delay, and in any case within one month after receiving the request. You will be informed if there is a risk that this time period might be extended (to two months, at most), due to complexities and the number of requests we receive. An individual can access their individual personal data and exercise their rights free of charge, but we can charge you a reasonable fee if your request is excessive or obviously unjustified, and especially if it is repeated. In such a case, your request can also be rejected. When exercising rights from this address, we might have to ask you to provide specific information that will help confirm your identity. This is a security precaution that ensures that your personal data is not revealed to unauthorized individuals.<\/p>\n You can contact our authorized personal data protection officer at any time, especially if you consider that the way we manage your personal data protection rights is inadequate, at this email address: dpo@info-hisa.si<\/a>.<\/p>\n When exercising rights from this address, or if you believe that your rights have been violated, you can turn to the Slovenian supervisory authority for protection or help. This is the Information Commissioner, Dunajska 22, 1000 Ljubljana, Slovenia, https:\/\/www.ip-rs.si\/.<\/p>\n2. Information on the naming of an authorized person for the protection of personal data<\/h2>\n
3. Purposes and legal bases for processing personal data<\/h2>\n
3.1. Enrollment into the Kindergarten and implementing the Kindergarten program<\/h3>\n
3.2. Accepting payment<\/h3>\n
3.3. If your child needs help<\/h3>\n
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3.4. Informing you about events at the Kindergarten<\/h3>\n
3.5. The use of photo or audio materials and your or your child’s works<\/h3>\n
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3.6. Fulfilling tax obligations<\/h3>\n
3.7. Websites<\/h3>\n
3.7.1. Analytical monitoring of our websites<\/h4>\n
3.7.2. Cookies<\/h4>\n
4. Storing and deleting personal data<\/h2>\n
5. Contractual processing and personal data output<\/h2>\n
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6. Concern for data security and accuracy<\/h2>\n
7. Your rights in connection to personal data<\/h2>\n
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