Privacy Policy

The purpose of the privacy policy is to acquaint customers, potential buyers or visitors to the websites owned by SWY Brand d.o.o., with the purposes and basis of the processing of personal data by SWY Brand, spletna prodaja d.o.o. Verdijeva Ulica 1, 6000 Koper, Slovenia (hereinafter: SWY Brand / company).

At SWY Brand company, we value your privacy, so we always protect your information carefully.

This privacy policy is subject to change or amendment at any time without prior notice. By using the company’s website after the change or amendment, the individual confirms that he agrees with the changes and additions.

By using the website, the user confirms that he accepts and agrees with the entire content of this privacy policy, unless additional forms of consent are required for individual cases.

Our activities are in accordance with European legislation (Uredba (EU) 2016/697 o varstvu posameznikov pri obdelavi osebnih podatkov in o pretoku takih podatkov) (Splošna uredba o varstvu podatkov or GDPR) and Council of Europe conventions (ETS No. 108, ETS no. 181, ETS No. 185, ETS No. 189)) and national legislation of the Republic of Slovenia (Zakono o varstvu osebnih podatkov (ZVOP-1, Ur. l. RS, št. 94/07), Zakono o elektronskem poslovanju na trgu (ZEPT, Ur. l. RS, št. 96/09 in 19/15) etc.).

As we are aware that your privacy and familiarity with the processes of processing your personal data means a lot to you, we also invite you to read more about individual segments of personal data protection in the guidelines of the Informacijski pooblaščenec, who acts as a competent state body personal data protection framework.


Personal data is information that identifies you as an individual: your name, surname, e-mail or ordinary address, etc.

For business purposes, SWY Brand collects the following user data:

name and surname,

address and place of residence,

e-mail address,

contact telephone number,

and other information you enter on the relevant forms on the website.


By registering and / or placing an order on the website, you expressly agree that SWY Brand may use the obtained personal data (name and surname, address of residence, e-mail address and any other data provided to the company for the purpose of fulfilling the contract), for the purposes of direct marketing through all advertising channels used by the company (notification by phone and SMS, print media, unaddressed and addressed direct mail, e-mail, etc.), and for the purposes of direct marketing-related statistical and market analysis, marketing profiling and segmentation. The data cannot be used for the purposes of negotiating a contract or fulfilling a contract – an order (as defined in Article 10 of the current Zakon o varstvu osebnih podatkov). In this way, we will make sure that you are properly informed about our current offers at all times, and at the same time you will only be informed about the product offers that best suit your wishes.

As a customer, you must explicitly give your consent to direct marketing to SWY Brand company by e-mail when registering and / or placing an order on the website marked “Subscribe to e-news”. Otherwise, the customer will not receive direct marketing via e-mail, nor will he be duly informed about the company’s online campaigns.

How to revoke the consent for direct marketing via e-mail:

  • by sending a return e-mail in response to a specific e-mail received by the provider each time direct marketing is carried out, or
  • by filling in the online form, the link to which is stated in each e-mail received by the company when conducting direct marketing. You will be notified of the possibility to revoke your consent to carry out direct marketing by e-mail every time you receive direct marketing e-mail. The company will take into account your wish to cancel and consistently within 15 days arrange for the withdrawal of consent for the purpose of direct marketing through the respective or all advertising channels and notify you in writing or in another agreed manner within five (5) days. You do not suffer any costs in doing so. The company also guarantees you all other rights in accordance with the applicable legislation, which is defined below. The company does not collect or process your personal data, except when you allow it or. agree to it, i.e. when ordering products or services, when you subscribe to receive e-news, participate in a prize draw, etc., or when there is a legal basis for the collection of personal data or the company has a legitimate interest in processing.

The provider collects and processes your personal data on the following legal bases:

law and contractual relations,

the consent of the individual,

legitimate interest.


In the event that the provision of personal data is a contractual obligation, an obligation necessary for the conclusion and performance of a contract with a company, or a legal obligation, you must provide personal data; in case you do not provide personal data, you cannot conclude a contract with the company, nor can the company perform services or supply products under the contract, as it does not have the necessary data to perform the contract.

Purpose of processing – more detailed explanation

Conclusion and implementation of the contract

Conclusion and implementation of the contract concluded with the company, including the company’s fulfillment of your orders (supply of products and provision of services), communication with you, verification of your payments and fulfillment of other obligations of the company and / or your obligations. point (f) of Article 6 (1) GDPR). Direct notification to customers about special offers, discounts and other content via e-mail or SMS to SWY Brand d.o.o. in accordance to the ZEKom-1 Act (Zakon o elektronskih komunikacijah Republike Slovenije, which is implemented on the basis of Directive 2002/58 / EC of the European Parliament and of the Council of 12 July 2002). We inform our customers about our products, services and contents. The customer may at any time request the termination of such communication and processing of personal data. The customer can terminate such communication at any time via the unsubscribe link in the received e-mails, or by a written request to the e-mail address [email protected].


The company may also process data on the basis of a legitimate interest pursued by the company, except when such interests are outweighed by the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data. In the case of a legitimate interest, the company always makes an assessment in accordance with the Splošna uredba o varstvu podatkov.


More detailed explanation

General statistical processing of data on customers and their orders and potential customers (contacts) for the purposes of internal analysis of sales, repurchases, aggregate customer behavior, advertising optimization and business optimization.

In the company SWY Brand d.o.o. we perform general statistical processing of data on customers and their orders and potential customers (contacts), based on which we perform internal analyzes of sales, repurchases and aggregate customer behavior and monitor and optimize our business efficiency and optimize our advertising, e.g.:

we monitor sales through our sales channels (internet),

we monitor how many customers make repeat purchases, how quickly and in what value,

we monitor general sales statistics, such as the average value of the cart, the number of products on order and the like,

we monitor responses to e-mails, SMS messages, telephone calls and various advertising messages (online ads) and on this basis we optimize our advertising (we decide what, where, to whom and how to advertise).

This type of statistical monitoring enables us to optimize business and advertising in general, and on this basis also to offer users affordable products and services. We offer access to your past orders and other information to SWY Brand employees in order to provide better service and better deals. Upon your call to the SWY Brand (or our outbound call to you) or in the event of your visit (if and when you identify yourself), our sales and support consultants have access to your recorded personal information and purchase history, based on which they will offer better service and more personalized offers. If you do not wish to do so, you may terminate this type of data processing at any time by making a written request to the email address [email protected]

Processing of data on uncollected distance orders in order to prevent fraud

At SWY Brand d.o.o., based on our legitimate interest, we process data on sent and uncollected payment upon receipt orders, in order to determine whether and which customers disproportionately order products with payment upon receipt and then do not accept these products, thus causing business damage that we want to prevent.

Once we identify such customers, we prevent them from ordering products in the online store with payment upon receipt, but they are still allowed to order products with other payment in advance methods.

Automatic email communication with the user based on his or hers start of the online buying process

At SWY Brand, based on its legitimate interest, we occasionally send emails to potential customers who have added selected products to the shopping cart but have not completed their purchase, with the aim of attempting to complete the purchase or providing assistance and information in this regard.

If you do not wish to do so, you may terminate this type of data processing at any time or by making a written request to the email address [email protected]

Basic personalized communication (via email, SMS, phone calls, mail, notifications via browser, information on the website, social networks) with customized discounts, offers and content

As part of basic personalized communication (via email, SMS, phone calls, mail, browser notifications, website information, social networks), we try to present you with relevant offers, discounts and other content that may be of interest to you based on your past interactions. with us.

We use the following information for this:

demographic data (gender, age, address),

history of your purchases (purchased products, time of purchase, number of purchases),

addressing your behavior on SWY Brand websites (viewing individual products or content that may trigger the sending of customized messages), without using this information to create user profiles,

your responses (opening a message, clicking on a link, purchasing) to the various messages we send you.

We do not use any semi-automatic or automatic profiling, but only select the appropriate sets of recipients for individual messages. In doing so, we never focus on individual data, but perform aggregate processing of larger groups.

Based on this information, it may then depend on which messages you receive from us:

which products and contents we will present to you so that they will be of maximum interest to you,

what offers you will receive (customers with a larger number or frequency of purchases at SWY Brand get better offers),

how often we will send you messages and through which communication channels. The customer may terminate such communication at any time via the unsubscribe link in received messages, or by a written request to the email address [email protected] SWY Brand, based on its legitimate interest in online advertising, also uses the Facebook Custom Audiences service, either as part of the implementation of basic personalized communication based on its legitimate interest or as part of the consent obtained for communicating with customized offers and content based on the user’s profile.

This service works as follows:

we upload your email address, which we obtained from you during your purchase or your voluntary entry, to Facebook,

Facebook compares your email address with your user base and finds out if you are a Facebook user

if you are not a Facebook user, then nothing happens to your email address and Facebook does not perform any activities with it,

however, if you are a Facebook user, Facebook will add you to the newly created list of customized audiences, which will only and explicitly allow us to display customized ads to this group of users on Facebook,

based on this, we can show you more targeted and customized ads on Facebook and, above all, additional discounts. You can cancel this at any time or by writing a request to the email address [email protected]


The company collects and processes (uses) your personal data also for the following purposes, when you give your consent:

  • ensuring that you access and use your online account with the company and the company’s online store and for technical reasons of administration on the company’s website,
  • ensuring that you can access specific information available to you on the company’s website and on your online account / profile provided by the company,
  • prepare and send personalized e-newsletters, if you have subscribed to it,
  • sending commercial offers and other content via e-mail, SMS messages, regular mail or telephone calls and social networks (Facebook, Instagram) when there is no other basis for this and you have agreed to it,
  • any other purposes for which you specifically agree to cooperate with the company.


As an individual, you are aware of and agree that the company may entrust individual tasks related to your data to other persons (contractual processors). Contractual processors may process confidential data exclusively on behalf of the company, within the limits of the company’s authorization (in a written contract or other legal act) and in accordance with the purposes defined in this privacy policy.

Accounting Service; law firms and other providers of legal advice,

data processing and analytics providers,

IT system maintainers,

e-mail providers,

payment system providers,

providers of customer relationship management systems,

online advertising solution providers.

The company will not pass on your personal data to unauthorized third parties. Contractual processors may only process personal data within the framework of the controller’s instructions and may not use personal data to pursue any personal interests. The controller and users do not export personal data to third countries.


The company will keep your personal data only as long as it is necessary to achieve the purpose for which the personal data was collected and further processed. Those personal data that the company processes on the basis of the law, the tenderer shall keep for the period prescribed by law. The personal data processed by the company for the purpose of concluding a contractual relationship with an individual shall be kept by the company for the period necessary for the performance of the contract and for 5 years after its termination, except in cases where there is a dispute between you and the company. In such a case, the company shall keep the data for 5 years after the court or arbitration decision or settlement has become final or, if there has been no litigation, for 5 years from the date of the amicable settlement of the dispute.

Those personal data that the company processes on the basis of the personal consent of the individual or a legitimate interest, the company keeps permanently, until the revocation of this consent by the individual or. interruption requests. The company shall delete such data before cancellation only when the purpose of personal data processing has already been achieved or if so provided by law.

After the retention period, the controller deletes personal data efficiently and permanently, so that it can no longer be linked to a specific individual.


The information you provide about yourself is controlled by you. If you choose not to provide your information to the company, then you will not be able to access certain sites or functions on the website. Individuals wishing to unsubscribe from the e-newsletter should notify us at [email protected] If your personal information changes (postal code, e-mail address, physical address, telephone number), please notify us of the changes at [email protected]


Cookies are inconspicuous files that are temporarily stored on your hard drive and allow the company to recognize your computer the next time you visit the website. The company uses cookies only to collect information concerning the use of the website and to optimize its Internet advertising activities.

Advertising cookies monitor an individual’s use of the company’s website, unless the individual disagrees to the use of cookies on the site.


All information provided is protected from intrusion by third parties, which ensures you a carefree and uninterrupted business with the company. The protection of the personal data of our users is an important concern of our company. The privacy policy addresses the handling of information provided by the company about you when you visit and use our website or when you carry out other activities on the website (registration and / or purchase of a product). The company makes great efforts to ensure the security of personal data. Your data is protected at all times from loss, destruction, falsification, manipulation and unauthorized access or unauthorized discovery. The protection company provides various measures and information mechanisms that ensure the smooth operation of the website and the security of data transmission on it.


The company strongly recommends that all parents and guardians teach their children and caregivers how to handle personal data safely and responsibly online. Minors should not transfer any personal information to the websites without the permission of their parents or guardians. The company will never knowingly collect personal data from persons who would be aware that they are minors.


You have a number of rights in connection with your personal information. These include the right of access, review, deletion and restrictions on processing, transfer, objection and appeal.

Right of information: the right to know what information we collect about you, for what purposes and for how long, where we obtain your personal information, to whom we pass it, who processes it besides us and what your other rights are in connection with the processing of your personal data. You can read all this in the chapter “Privacy Policy”, in case you have any questions, you can contact us at [email protected]

Right to revoke consent: If, as an individual, you have consented to the processing of your personal data (for one or more specific purposes), you have the right to revoke that consent at any time, without prejudice to the lawfulness of the processing of consent. carried out until its revocation. Consent may be revoked by a written statement sent to [email protected] Withdrawal of consent to the processing of personal data does not have any negative consequences or sanctions for the individual. However, after revoking the consent to the processing of personal data, the controller may no longer be able to provide an individual with one or more of its services in the case of services that cannot be provided without personal data.

Right of access to personal data: as an individual you have the right to obtain confirmation from the company (controller of personal data) whether personal data are processed in relation to you and, where applicable, access to personal data and certain information (on the purposes of processing, types of personal data, on users, on retention periods or criteria for determining periods, on the existence of the right to rectify or delete data, the right to restrict and object to processing and the right to appeal to the supervisory authority, the source of data if the existence of automated decision-making, including profiling, the reasons for it and the importance and consequences of such processing for you, and other information in accordance with Article 15 of the GDPR).

Right to correct personal data: As an individual, you have the right to have the company correct inaccurate personal data about you without undue delay. As an individual, you have the right to supplement incomplete data, including the submission of a supplementary statement, taking into account the purposes of the processing.

Right to delete personal data: as an individual you have the right to have the company delete personal data concerning you without undue delay, and the company must delete data without undue delay when there is one of the following reasons: the data is no longer needed for the purposes for which were collected or. otherwise processed; if you revoke the consent and there is no other legal basis for the processing; if you object to the processing and there are no overriding legitimate reasons for the processing; the data were processed illegally; the data must be deleted in order to fulfill legal obligations under EU law or the law of the Member State applicable to the provider; data were collected in relation to information society service offers.

However, as an individual, in certain cases described in Article 17 (3) of the GDPR, you do not have the right to have the data deleted.

Right to limit processing: as an individual, you have the right to have the company restrict processing when there is one of the following cases: if you dispute the accuracy of the data for a period that allows the company to verify the accuracy of the data; the processing is illegal and you oppose the deletion of the data and instead request a restriction on their use; the data company no longer needs it for processing purposes, but you need it to enforce, enforce and defend legal claims; you have lodged an objection to the processing until it is verified that the legitimate reasons of the company outweigh your reasons.

Right to data portability: as an individual, you have the right to receive personal data concerning you that you have provided to the company in a structured, commonly used and machine-readable form, and you have the right to pass this data on to another controller without you the company to whom the personal data have been provided has been hindered in doing so, namely when: the processing is based on consent or on a contract and the processing is carried out by automated means.

As an individual, in exercising this right of transferability, you have the right to transfer personal data directly from one controller (company) to another, where technically feasible.

Right to object to processing: As an individual, you have the right, on grounds relating to your specific situation, to object at any time to the processing of personal data necessary for the performance of tasks in the public interest or in the exercise of public authority conferred on the company (point (e) of Article 6 (1) of the GDPR) or is necessary for legitimate interests pursued by the tenderer or a third party (point (f) of Article 6 (1) GDPR), including profiling based on those treatments; the company ceases to process personal data unless it proves compelling legitimate reasons for the processing that outweigh your interests, rights and freedoms, or for asserting, enforcing or defending legal claims. Where personal data are processed for marketing purposes, the individual has the right to object at any time to the processing of data relating to him for the purposes of such marketing, including the creation of profiles in so far as it relates to such direct marketing; where an individual object to the processing for the purposes of direct marketing, the data shall no longer be processed for those purposes. Where data are processed for scientific, historical or statistical purposes, the individual has the right to object to the processing of data relating to him or her for reasons related to his or her particular situation, unless the processing is necessary for the performance of the task carried out. for reasons of public interest.

Right to lodge a complaint with the supervisory authority: without prejudice to any other (administrative or other) remedy, you as an individual have the right to lodge a complaint with the supervisory authority, in particular in your country of residence, place of work or residence. which is alleged to have been breached (in Slovenia it is the Information Commissioner), if you believe that the processing of personal data in relation to you violates the regulations on personal data protection.

Without prejudice to any other (administrative or extrajudicial) remedy, you as an individual have the right to an effective remedy, against a legally binding decision of the supervisory authority in relation to it, as well as in the event that the supervisory authority does not consider your complaint or does not inform the situation or the decision on the appeal within three months. Proceedings against the supervisory authority shall be subject to the jurisdiction of the courts of the Member State in which the supervisory authority is established.

The individual may address all requests concerning the exercise of rights in relation to personal data to the controller, in writing, at [email protected]

For the purposes of reliable identification in the case of exercising rights in relation to personal data, the controller may request additional data from the individual, and may refuse to act only if he proves that he cannot reliably identify the individual. The controller must respond to a request from an individual exercising his or her rights in relation to personal data without undue delay and at the latest within one month of receiving the request.

In the event of a breach of personal data protection, the company is obliged to inform the competent supervisory authority, except when it is probable that the breach did not endanger the rights and freedoms of individuals. Where there is a suspicion that a criminal offense has been committed, the tenderer is obliged to inform the police and / or the competent prosecutor’s office about the violation. In the event of a violation that may cause a great risk to the rights and freedoms of individuals, the company is obliged to immediately or where this is not possible, without undue delay, inform the data subject. The notice to the individual must be made in understandable and clear language.


Any changes to our privacy policy will be posted on this website.

By using the website, the individual confirms that he / she accepts and agrees with the entire content of this privacy policy.

Updated: September 2020