Protection of personal data

1. Data Controller

The personal data controller is Tourne Mobil, proizvodnja, storitve in trgovina, d.o.o. (hereinafter: Tourne Mobil), Ljubljanska cesta 16, 1360 Vrhnika, Slovenia. E-mail: info@tourne-mobil.com. Telephone: +386 (0)1 750 7638.

For any questions regarding the processing of your personal data, or to exercise your rights, you may contact us at info@tourne-mobil.com.

2. Legal Basis and Purpose of Processing

2.1. Tourne Mobil collects and processes personal data on the following legal bases:

• Your explicit consent (Article 6(1)(a) GDPR) — for the use of non-essential cookies and similar technologies (analytics and marketing), for sending you information you have requested, and for any other purpose for which we specifically ask for your consent;
• Performance of a contract or pre-contractual steps taken at your request (Article 6(1)(b) GDPR) — e.g. responding to enquiries, providing information, establishing contact between seller and buyer, processing orders;
• Our legitimate interests (Article 6(1)(f) GDPR) — e.g. operation, administration and security of the website and improvement of our services, where these are not overridden by your rights and freedoms;
• Compliance with legal obligations (Article 6(1)(c) GDPR) — e.g. tax and accounting law, prevention of undeclared work, and requests from competent authorities.

2.2. Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal. You can withdraw or change your cookie consent at any time via the “Manage cookie preferences” link in the website footer.

3. Direct Marketing

We send electronic communications and direct marketing only on the basis of your consent or, in cases where the law permits, to inform existing customers about similar products or services. You can unsubscribe from receiving them at any time, free of charge.

4. Contact Forms

We will use your data to respond to your enquiry, in accordance with this privacy policy.

5. Categories of Personal Data being Processed

5.1. Depending on how you use the website, we may process:

• Identity and contact data: name and surname, e-mail address, country, telephone number;
• Data you voluntarily submit through forms on the website, including reviews and ratings;
• Order and purchase data;
• Online identifiers and technical data: IP address, device and browser information, operating system, referring URL, pages visited and interactions on the website, and identifiers stored in or read from cookies (including Google Analytics and Meta/Facebook identifiers such as _ga, _fbp and _fbc).

5.2. The data in the last category are collected automatically through cookies and similar technologies, and the analytics and marketing data are collected only where you have given the relevant consent (see the Cookies section below).

6. Recipients and Processors of Personal Data

6.1. Tourne Mobil discloses personal data only to recipients who process it on our behalf under a data processing agreement, or who act as independent or joint controllers as described below. Our recipients include:

• Marko Damiš s.p. — website development and maintenance (processor);
• Avant.Si d.o.o. (Neoserv.si) — website hosting (processor; Slovenia/EU);
• Google Ireland Limited — website analytics (Google Analytics 4), tag management (Google Tag Manager) and form spam protection (Google reCAPTCHA);
• Meta Platforms Ireland Limited — measurement and advertising tools (Meta Pixel);
• Fathom Analytics (Conva Ventures Inc., Canada) — cookieless website analytics; sets no cookies and stores no personal-data identifiers on your device;
• ActiveCampaign, LLC (Postmark) — delivery of transactional/website e-mails (processor);
• Mailgun Technologies, Inc. (a Sinch company) — delivery of form-notification e-mails (processor; EU data region).

6.2. Joint controllership (Meta Pixel). Where you have consented to marketing cookies, the website uses the Meta Pixel. For the collection of your data through the Pixel and its transmission to Meta, Tourne Mobil and Meta Platforms Ireland Limited act as joint controllers within the meaning of Article 26 GDPR. The essence of the arrangement is set out in Meta’s Controller Addendum (https://www.facebook.com/legal...). Meta’s processing of the data after transmission is governed by Meta’s Privacy Policy (https://www.facebook.com/priva...).

Advanced Matching is not used. The Meta Pixel is operated without Advanced Matching, so no hashed contact data (e.g. e-mail or telephone) from form submissions is shared with Meta.

6.3. Transfers outside the EU/EEA. As a rule, Tourne Mobil keeps personal data within the EU/EEA (the website is hosted in Slovenia and the Mailgun e-mail region is set to the EU). Where the use of the tools above involves a transfer to the United States (e.g. to Meta Platforms, Inc., Google LLC, ActiveCampaign/Postmark or Mailgun), such transfer takes place on the basis of the EU–U.S. Data Privacy Framework adequacy decision and/or the European Commission’s standard contractual clauses, which provide appropriate safeguards. Fathom Analytics processes only aggregate, cookieless data in Canada, which is covered by a European Commission adequacy decision.

7. Period for which the Personal Data are Kept

7.1. Personal data submitted through forms or a user account is kept for 5 years from your last interaction with us, or for the period required by applicable law (e.g. accounting records).

7.2. Data collected through cookies is kept for the lifetime of the relevant cookie (see the table below) or, where stored by the third-party tool, for the retention period configured in that tool [confirm GA4 data-retention setting]. You can delete cookies from your browser at any time.

8. Rights of the Users

8.1. Under the General Data Protection Regulation and the applicable Personal Data Protection Act, you have the right to: request access to your personal data; request rectification or erasure; request restriction of processing; object to processing; withdraw consent at any time; and request data portability in a machine-readable format.

8.2. You also have the right to lodge a complaint with the Information Commissioner of the Republic of Slovenia (Informacijski pooblaščenec, Dunajska 22, 1000 Ljubljana, gp.ip@ip-rs.si, +386 1 230 97 30, www.ip-rs.si) if you believe your data protection rights have been infringed.

8.3. You can exercise your rights by writing to info@tourne-mobil.com.

9. Limitation of Liability of the Controller

9.1. Tourne Mobil does not access and is not responsible for personal data exchanged directly between users of the website (e.g. between a seller and a buyer).

9.2. Tourne Mobil undertakes to protect personal data with due care and in accordance with the applicable Personal Data Protection Act and the General Data Protection Regulation.

Tourne Mobil d.o.o. David Svetličič, director

Cookies

Cookies are small text files placed on your device by the websites you visit. They allow a website to function, to function more efficiently, and to provide information to the website operator. On tourne-mobil.com we use cookies that are strictly necessary for the website to work, as well as — only with your consent — analytics and marketing cookies.

Separately, we use Fathom Analytics, a privacy-focused, cookieless analytics tool. It stores and reads no cookies on your device and collects only aggregate, non-identifying usage statistics, so it runs without consent and is not listed in the cookie table below.

Some of these cookies are set by third parties (Google and Meta), which may use the data for their own analytics and advertising purposes and may transfer it outside the EU/EEA as described in Section 6. Analytics and marketing cookies are not anonymous and may allow you to be recognised across websites and devices.

Your choices. When you first visit the website, a consent notice appears that you resolve before continuing. You can accept all, reject all, or open “Manage preferences” to opt in per category — analytics and marketing are off by default, and refusing is as easy as accepting. Strictly necessary cookies are always active because the website cannot function without them. Analytics and marketing cookies are set only after you give the relevant consent and are not set beforehand. You can change or withdraw your consent at any time via the “Manage cookie preferences” link in the website footer.

The cookies we use:

Category	Service / Provider	Cookie name(s)	Duration	Purpose
Strictly necessary	Tourne Mobil (self-hosted vanilla-cookieconsent)	cc_cookie	182 days (~6 months)	Stores your cookie consent choices.
Strictly necessary	Craft CMS	CraftSessionId	Session	Maintains your session, e.g. when using forms.
Strictly necessary	Craft CMS	CRAFT_CSRF_TOKEN	Session	Security token protecting forms against cross-site request forgery.
Strictly necessary (security)	Google reCAPTCHA — Google Ireland Ltd	_GRECAPTCHA	~6 months	Spam/bot protection on the contact form; loaded by Google only on pages that contain a protected form.
Analytics (consent)	Google Analytics 4 — Google Ireland Ltd	_ga, _ga_	2 years	Distinguishes users and retains session state to measure website use.
Marketing (consent)	Meta Pixel — Meta Platforms Ireland Ltd	_fbp	~3 months (90 days)	Identifies your browser to measure conversions and deliver advertising.
Marketing (consent)	Meta Pixel	_fbc	~3 months (90 days)	Stores a click identifier when you arrive from a Meta advertisement.

Meta and Google may set additional cookies in their own domains when their tools are loaded. For details, see Meta’s Privacy Policy and Google’s Privacy Policy. You can also manage or delete cookies through your browser settings; disabling strictly necessary cookies may cause parts of the website to stop working.