Published on 31 July 2019

At Foreach Labs d.o.o., one of the most important goals is to improve of our services so we can adapt them to your requirements as much as possible. In order to achieve this, we need to collect and process certain personal data. The purpose of this Privacy Policy is to make you acquainted with what kind of personal information we collect and for what purposes, what we do with them, how we ensure their security, and what rights do you have in connection with the processing of your personal data. We treat the protection of your personal data with the utmost seriousness and responsibility. We fully comply with our obligations regarding lawful, fair and transparent personal data processing and we strive for ethical conduct. We advise you to get yourself fully acquainted with the contents of this Privacy Policy. In order to ensure the compliance of this Privacy Policy with the regulations governing personal data protection, Foreach Labs reserves the right to modify or amend the Privacy Policy accordingly. For that reason, we highly suggest you occasionally check our Privacy Policy to see what may have changed. You will be notify by email about any important change regarding your personal data you provided us with.

CONTROLLING OF YOUR PERSONAL DATA The controller of the personal data processed in accordance with this Privacy Policy is Foreach Labs d.o.o, company registration number 8449635000, with business address at Štihova ulica 3, 1000 Ljubljana, Slovenia. If you have any questions or requirements regarding the processing of your personal data, please send them to the following e-mail address: [email protected].

PROCESSING YOUR PERSONAL DATA We only collect your personal data when this is absolutely necessary or when you have given your consent. We will not process your personal data if the purpose or basis for their processing is not supported by the applicable regulations in the field of personal data protection (the Personal Data Protection Act, the Official Gazette of the Republic of Slovenia No. 94/07 – official consolidated version (ZVOP-1) and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR)) and our internal policies.

Foreach Labs’s processing of your personal data will be based on the following legal basis: by visiting our website, you accept and agree with the General Terms of this website and enter an agreement with Foreach Labs, that sets basis for processing your personal data. The data is coded and transferred to the server in a protected format. Such system prevents your personal data to be intercepted. The controller is subject to the following legislation: the national legislation, i.a. the Prevention of Money Laundering and Terrorist Financing Act (the Official Gazette of the Republic of Slovenia, No. 68/16; ZPPDFT-1), the Personal Data Protection Act (the Official Gazette of the Republic of Slovenia No. 94/07 – official consolidated version (ZVOP-1), the Copyright and Related Rights Act (the Official Gazette of the Republic of Slovenia No. 16/07 – official consolidated version, 68/08, 110/13, 56/15 in 63/16 – ZKUASP; ZASP), etc., other international agreements and EU regulations that oblige Foreach Labs to provide personal data of individuals to state authorities and other controllers when legally binded. Foreach Labs can process personal data for the purposes of the legitimate interests pursued by the controller: for statistical purposes and for collecting the demographic data and interests of the visitors; for identifying server problems and for website editing; for business analyses; for offer development; for information system safety; for improving or adapting the services to the individual; for measuring the efficiency of its promotional activities and advertising; on the basis of other legitimate interests.

In certain cases, Foreach Labs can process your personal data on the basis of your personal consent to perform other activities, such as for example: marketing activities (like sending newsletters and general notifications, which Foreach Labs at the moment does not provide) and for notifications on the service offer personalised on the basis of the profiling used by Foreach Labs for these purposes. The personal consent is completely voluntary. When you as a User visit Foreach Labs website, the company also collects your personal data through cookies for the purpose of improving the functionalities, user experience, safety, website functioning and for counting its website visitors. You can find all further information on the use of cookies under the Cookie Policy section.

PURPOSE OF COLLECTING PERSONAL DATA The purpose of collecting personal data on the website www.foreach-labs.si is of business and/or educational nature, mostly for a faster and better way of contacting you when required from your part, namely: in case you fill out the contact form for the purpose of business cooperation, you agree that in order to further communicate with you, we will keep your personal information in our database, based on the legitimate interest of the company. In this case, Foreach Labs processes and stores your data for the purpose of further cooperation and direct marketing. The communication in this case is individual, which means that you are not automatically placed on any e-mail list (unless you subscribe to it separately). In the event that you subscribe to our newsletter, you allow us to periodically send you emails (e-news). We acquire personal data from various sources. In most cases, they are supplied by you directly through visiting our website, filling out online forms and/or subscribing to our newsletter.

TYPE OF PERSONAL DATA WE PROCESS Foreach Labs processes the following types of personal data: – contact information This includes all the personal data you provide when filling in online forms or communicating with us by phone, e-mail or in any other way. It also includes all the data you provide when registering on the website, subscribe to our newsletter or report any kind of problem that arises during your visits to our website. In such cases, we collect and save data which can include your full name, e-mail address, company address and other provided data. – server data When you use this website, we collect various data in the server log: the dates and times of the visits; the visited subpages; your IP address; time zone settings; the time you have spent on our website; screenshots of clicks on this website; the information you viewed; webpage response time; downloading errors; the lengths of the visits to individual webpages and data on webpage interactions. – device data We collect data on the computer or mobile device which you use to access this website, including its model, the operating system and version of your software, the internet browser used and other identifiers of your device. – data on the use of our services To target our services, we use data on which of our services you already use, for how long, under what conditions and whether you have kept or cancelled them. We know how frequently and for what purposes you use our individual services. – data on contacts with us We keep records of your contacts with us, especially of the dates (sometimes also times) of the contacts and the reasons for them. This holds for all kinds of contacts (mostly regular mail, e-mail, live). – data from social networks In our marketing campaigns, we also use social media (e.g. Facebook) and, although we do not keep the data published on your profile, we use it for targeted marketing activities, but only if you consent to this during your use of the aforementioned media. In the scope of third-party cookies, we also offer user service improvements, content dissemination through various social media and personalisation of our offer according to your wishes and requirements which are evident from your previous web browsing. Despite all of our efforts, we can not guarantee for the security of the content of the connected external websites or check such content. You therefore click external links at your own risk. We are not liable for any damages or implications resulting from visiting any aforementioned external link. If you follow a link to another website, you thereby leave our website and this Privacy Policy does not apply to your use of other websites or your activities on them. – geolocation data Geolocation data or GPS coordinates (longitude, latitude) is acquired at your visit to our website in order to be able to help you find the most suitable end product and / or service. Foreach Labs processes location data in a form that can not be connected to a specific or identifiable person.

PROTECTION OF YOUR PERSONAL DATA In order to protect personal data, Foreach Labs will use all the technical and other suitable measures necessary to prevent unauthorised data destruction, modification, loss or any unauthorised processing. Among others, these measures can include internal rules, additional employee training, internal controls, etc. Other possible measures can include transparency, enabling individuals to monitor the processing, as well as continuous safety measure upgrades. We never ask for credit card numbers or other information that could be misused by online criminals. The website www.foreach-labs.si is hosted on a secure web server and is subject to regular malware scanning. We use your personal information exclusively for the purposes described above and for the purposes you explicitly give your permission for, and are not marketed or distributed to third parties other than partners who help us maintain the website and who are obligated to protect personal information under the same conditions as Foreach Labs d.o.o.

DEADLINE FOR STORING YOUR PERSONAL DATA The period of keeping your personal data depends on the basis and purposes of processing an individual personal data category. Personal data is only kept for as long as this is legally required or allowed and absolutely necessary to achieve the purpose for which the data has been collected or processed. After achieving the purpose, we will only keep the personal data we are legally obliged to keep or we might need for evidence or defence purposes in case of a possibility of legal claims. The rest of the data is erased, blocked or anonymised unless otherwise legally required for certain types of data. The personal data that we process to send offers and notifications on novelties is kept until your consent withdrawal or, in any case, for a maximum period of five years from your consent. After that period, we will again ask you for your consent.

USER’S RIGHTS REGARDING THE PROCESSING OF PERSONAL DATA You can always request to view or access your personal data, or request its correction or erasure. We will notify you if your request affects the possibility of further operation of the website. In certain cases, you also have the right to port your personal data to a different controller. This depends on the internal policies of individual controllers. Your consent to the processing of personal data for the purpose of sending offers and novelty notifications may be withdrawn at any time; however, the withdrawal of your consent does not affect the lawfulness of the processing of your personal data on the basis of your consent for the period prior to the withdrawal. Foreach Labs does not take responsibility for the credibility, accuracy and currency of the personal data you provide. The user themselves is obliged to ensure the accuracy and currency of all the data they provide. In the event of a violation of protection of your personal data, we will notify you in accordance with the conditions laid down by the applicable legislation. Your requests will be fulfilled as soon as possible, but in any case within one month of the receipt of your request unless otherwise provided by the applicable legislation. In the event of complexity and a large number of requests, this time limit may be extended by up to two months. We will notify you of any such extension within one month of receiving your request, together with the reasons for the delay.

COOKIES When you visit our website for the first time, we ask you to authorize the installation of cookies that enable the normal operation of www.foreach-labs.si. You can also decline the authorization or turn off all cookies in your web browser. In this case, your experience on the website www.foreach-labs.si may be affected. We use cookies for analysis of the website www.foreach-labs.si visits, based on statistical data and behavioral analysis (web analytics). This information is anonymized and does not contain your personal information. We process those using third party external tools (Google Analytics, Hotjar). We respect the desire to turn off tracking (Do Not Track) and do not follow ads if this feature is turned on.

LINKS TO THIRD PARTY WEBSITES As already described before, we never forward any personal data to any third parties, except when is so legally required by the State and its relevant authorities. Online content at www.foreach-labs.si can include links to third-party websites that have their own security policies. Foreach Labs d.o.o. does not have any influence on these policies and does not guarantee the operation, security and activities on the websites of such related providers.

CONTACT If you would like additional explanations regarding the privacy policy of Foreach Labs d.o.o., you can contact us at [email protected].