Protection of personal data

This document applies to the website tourne-mobil.com and to the website my.tourne-mobil.com (MY TOURNE), which hosts the vehicle configurator, the model (edition) pages, the stock-vehicle pages and their forms. Wherever “the website” is mentioned below, both websites are meant unless stated otherwise.

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, preparing an offer for a vehicle you built or chose on my.tourne-mobil.com, 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 “Cookie settings” link in the footer of both websites.

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

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

4.2. Forms on my.tourne-mobil.com. On my.tourne-mobil.com you can request an offer for a vehicle you built in the configurator or on a model page, a PDF of your configuration, or an offer for a stock vehicle. Only your e-mail address is required; your name, telephone number and a message are optional. You can also tick what you are interested in: a test drive, your configuration with current incentives, contact with a dealer or a factory visit. The configuration you built (or the details of the stock vehicle you are interested in) is stored together with your request. After you submit the form, we send you a confirmation e-mail through Postmark.

4.3. Legal basis. We process the data from these forms to prepare an offer at your request and to take steps prior to a possible contract (Article 6(1)(b) GDPR). Submitting a form does not subscribe you to a newsletter; we do not send you newsletters on this basis.

4.4. Passing your request to an authorised dealer. Requests are kept in our internal customer relationship management system (CRM) on my.tourne-mobil.com. Tourne Mobil passes your request to the authorised Tourne dealer in your country and may assign it to a specific dealer, so that the dealer can prepare your offer and contact you about it.

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;
• Vehicle configuration data: the vehicle you built or chose (model, base vehicle, colour, wheels, equipment and price), the market or country you selected, and the interests you ticked in the form;
• 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).

5.3. Dealer and staff accounts. Authorised Tourne dealers and Tourne Mobil staff sign in to the CRM on my.tourne-mobil.com; to run their user accounts we process their name, e-mail address and sign-in data (e.g. the time of the last sign-in). Signed-in users are not measured with Google Analytics or the Meta Pixel.

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. — development, maintenance and hosting of the websites tourne-mobil.com and my.tourne-mobil.com (processor; Slovenia);
• 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, including confirmations of requests submitted on my.tourne-mobil.com (processor);
• Mailgun Technologies, Inc. (a Sinch company) — delivery of form-notification e-mails (processor; EU data region);
• The authorised Tourne dealer in your country — receives your request submitted on my.tourne-mobil.com in order to prepare your offer and contact you about it (see point 4.4).

6.2. Joint controllership (Meta Pixel). Where you have consented to marketing cookies, the websites tourne-mobil.com and my.tourne-mobil.com use 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. On both websites, 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 (both websites are 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, including requests and configurations stored in the CRM on my.tourne-mobil.com, 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. 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 and my.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.

On both websites, we separately 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.

Measurement with Google Analytics 4 and the Meta Pixel. On both websites, Google Analytics 4 and the Meta Pixel are loaded through Google Tag Manager (on my.tourne-mobil.com: measurement ID G-DNV90L0ZKB and Meta Pixel ID 1328360798867957). Until you give your consent in the cookie notice, no Google or Meta tool is loaded on either website, not even Google Tag Manager; the only exception is the Google reCAPTCHA form protection on tourne-mobil.com, which is strictly necessary (see the table below). Consent to analytics cookies switches on Google Analytics 4; consent to marketing cookies switches on the Meta Pixel.

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 “Cookie settings” link in the footer of both websites.

One consent for both websites. The choice you make in the cookie notice applies to both websites, tourne-mobil.com and my.tourne-mobil.com. It is stored in the cc_cookie cookie on the .tourne-mobil.com domain for 182 days; when that period ends, we ask for your consent again.

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. It is set on the .tourne-mobil.com domain and applies to both websites (tourne-mobil.com and my.tourne-mobil.com).
Strictly necessary	Craft CMS (both websites)	CraftSessionId	Session	Maintains your session, e.g. when using forms.
Strictly necessary	Craft CMS (both websites)	CRAFT_CSRF_TOKEN	Session	Security token protecting forms against cross-site request forgery.
Strictly necessary (functional)	Tourne Mobil (my.tourne-mobil.com)	tourne_region	1 year	Stores the market or country you selected, so that prices and the offer are shown for your market.
Strictly necessary (functional)	Tourne Mobil (my.tourne-mobil.com) — browser local storage, not a cookie	ds-theme, ds-theme-v	No expiry (until deleted)	Stores the light or dark display theme you chose. It is kept in your browser’s local storage, not in a cookie, and is not sent to our server.
Strictly necessary	Craft CMS (my.tourne-mobil.com; signed-in dealers and staff only)	sign-in cookies (Craft CMS)	Session; set at sign-in	Keep you signed in to the CRM. Set only for Tourne dealers and staff who sign in.
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. Used only on tourne-mobil.com.
Analytics (consent)	Google Analytics 4 — Google Ireland Ltd	_ga, _ga_ (on my.tourne-mobil.com: _ga_DNV90L0ZKB)	up to 2 years	Distinguishes users and retains session state to measure website use. Used on both websites.
Marketing (consent)	Meta Pixel — Meta Platforms Ireland Ltd	_fbp	~3 months (90 days)	Identifies your browser to measure conversions and deliver advertising. Used on both websites.
Marketing (consent)	Meta Pixel	_fbc	~3 months (90 days)	Stores a click identifier when you arrive from a Meta advertisement. Used on both websites.

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.