Privacy Policy

TORNADO PLUS d.o.o.
Grintovec 30,
1294 Višnja Gora
Slovenia


Tax number: SI 44556136


Registration number: 6652697000


Legal representative: LAKNER NINA


As of 20 September 2022


In the area of data protection, the unified standards of the EU General Data Protection
Regulation (the “GDPR”) have been applicable throughout Europe since 25 May 2018. In the
following data protection information, we will inform you about the processing of personal data by
TORNADO PLUS d.o.o., Grintovec 30, 1294 Višnja Gora (“TORNADO PLUS,” and/or “we,”
and/or the “Controller”) in accordance with the GDPR.
Please read through our data protection information carefully. Should you have any questions or
comments concerning our data protection information, please contact us at info@tornadoplus.eu.

1.Name and contact data of the processing Controller
This data protection information applies to data processing by:
TORNADO PLUS d.o.o.
Grintovec 30,
1294 Višnja Gora
Slovenia
Telephone: 051 216980
Email address: info@tornadoplus.eu
represented by the management board – Nina Lakner
Website: www.tornadoplus.eu/

2.Contact data of the data protection officer
You can reach the company data protection officer(s) of the Controller at:
Nina Lakner
TORNADO PLUS d.o.o.
Grintovec 30,
1294 Višnja Gora
Slovenia
Email: info@tornadoplus.eu

3.Purposes of the data processing, legal bases, and legitimate interests that are pursued
by the Controller or by a third party, as well as categories of recipients


3.1. Retrieval of our websites/applications


3.1.1. Log files
Each time access is made to websites/applications, information is sent by the respective internet
browser on your respective end device to the server of our website/application, and temporarily
stored in log data files, the so-called log files. The data sets stored in this way contain the
following data which are stored up until automatic erasure: date and time of the retrieval, name of
the site retrieved, IP address of the inquiring device, referral URL (source URL, from which you
arrived at our websites), the data quantity transferred, loading time, and the product and version
information of each browser used as well as the name of your access provider.
The legal basis for the processing of the IP address is Article 6(1)(f) GDPR. We have a legitimate
interest in:
– guaranteeing that connections are established smoothly,
– guaranteeing convenient use of our website/application, and
– evaluating system security and stability.
No immediate inference as to your identity is possible by means of the information; nor do we
draw any such inference. The data are stored and automatically erased after the aforementioned
purposes have been achieved. The periods established by the regulation for erasure are
determined by the criterion of necessity.


3.1.2. Cookies, tracking
For our website/application, we use so-called cookies, tracking tools, and targeting procedures.
The following will explain in detail precisely which procedures are involved and how your data are
used for them.


3.2. Online presence and website optimization


3.2.1 Cookies – general information
On our website, we use cookies in order to make the visit to our website attractive and to enable
the use of certain functions, as well as to record statistics about the use of our website. Cookies
are small text data files which your browser automatically creates and which are saved on your
end device (laptop, tablet, smartphone, and the like) whenever you visit our site. Cookies do not
damage your end device; nor do they contain any viruses, Trojan horses, or any other malware.
The cookie stores information that follows in each instance in connection with the end device
specifically used. However, this does not mean that we thereby receive any direct knowledge of
your identity.
Most of the cookies used by us are erased again after the end of the browser session (so-called
session cookies). Using these, we can offer you, for example, the cross-website shopping basket

display, from which you can see how many articles are already in your shopping basket and the
current amount of your purchases. Other cookies remain on your computer and enable us to
recognize your computer again during the next visit (so-called permanent or cross-session
cookies). These cookies, in particular, serve to make our offer user-friendly, more effective, and
more secure. Thanks to these data files, it is possible, for instance, for you to receive on the site
displays of information that are customised to your interests.
You can set up your browser in such a manner that it does not store our cookies in your end
device. The help function in the menu bar of most web browsers explains how to prevent your
browser from accepting new cookies, provided that you set up your browser to notify you
whenever you receive a new cookie, or how you can erase all of the cookies already received
and block any additional ones.
Please take the following steps:


In Internet Explorer:

  1. Select the “Tools” button in the menu, then select “Internet Options”.
  2. Select the “Privacy” tab.
  3. Now you can perform the security settings for the internet. Here, you can adjust whether and
    which cookies are supposed to be accepted or blocked.
  4. Confirm your setting with “OK.”

In Firefox:

  1. Click the menu button and choose “Options.”
  2. Select the Privacy & Security panel.
  3. In the drop-down menu, choose Use custom settings for history.
  4. Now you can set whether cookies ought to be accepted, how long you wish to keep these cookies and add exceptions, and which websites you always or never wish to allow to usecookies.
  5. Confirm your setting by clicking on “OK.”


In Google Chrome:

  1. Click on the Chrome menu on the browser symbol bar.
  2. Select “Settings”.
  3. Click “Advanced.”
  4. Under “Privacy & Security,” click “Content Settings”.
  5. Click “Cookies”. From here, you can make the following adjustments for cookies:

5.1. erase cookies;

5.2. block cookies by default;

5.3. erase cookies and site data automatically after closing the browser

5.4. allow exceptions for cookies from specific sites or domains

However, we would like to point out that in this event, it is possible that you will not be able to use

all of the features of this website in their fullest scope.

Insofar as personal data are involved with these cookies and/or the information contained
therein, the legal basis of the data processing is Slovenian GDPR. Our interest in optimising our
website is in the course of such to be regarded as legitimate within the meaning of the
aforementioned regulatory provision.


3.2.2. Google Analytics
For the purpose of the needs-based configuration and ongoing optimization of our websites, we
use – upon the basis of Slovenian GDPR – Google Analytics, a web analysis service of Google,
Inc. (“Google”). Google Analytics uses so-called “cookies,” text files that are stored on your
computer and facilitate an analysis of your use of the website. In this connection, pseudonymized
use profiles are created and cookies are used. The information generated by the cookie
TORNADO PLUS d.o.o. use of this website includes:
– browser type/version,
– operating system used,
– referral URL (the previously visited site),
– host name of the accessing computer (IP address),
– time of the server inquiry
On behalf of the operator of this website, Google will use this information to evaluate your use of
the website, to compile reports about website activities, and to render additional services
affiliated with the website use and the internet use vis-à-vis the website operator. The IP address
transferred by your browser within the framework of Google Analytics is not merged with other
data from Google. Using a corresponding setting on your browser software, you can prevent
cookies from being stored; however, we would like to point out that in this event, it is possible
that you will not be able to use all of the features of this website in their fullest scope. Moreover,
you can prevent Google from recording the data generated by the cookie and relating to your use
of the website (including your IP address) by downloading and installing the browser plug-in
available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
As an alternative to the browser add-on, particularly with browsers on mobile end devices, you
can also prevent the recording by Google Analytics by clicking on this Link. An opt-out cookie will
be engaged that prevents any future recording of your data during visits to this website. The opt-
out cookie is valid only in this browser and only for our website, and is stored on your device. If
you delete the cookies in this browser, then you will have to engage the opt-out cookie again.
You can find additional information about data protection in connection with Google Analytics on
the Google Analytics website.


3.2.3. Google Adwords
Our website uses the service Google Adwords. Google AdWords is an online advertising
program of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
(“Google”).
You can deactivate Google’s use of cookies by following the link below and downloading and
installing the plug-in provided there: www.google.com/settings/ads/plugin.
You can find more specific information in the Google data protection declaration

at: www.google.com/privacy/ads/.
3.2.4. Right to object/possibility of opting out
Besides the deactivation methods already described, you can also generally stop the
technologies described here by means of a corresponding cookie setting in your browser. In
addition, you have the possibility of deactivating preference-based advertising with the aid of the
preference manager, retrievable here.


3.3. Contact
You have the opportunity to contact us in several ways: via email, telephone, or surface mail. If
you contact us, then we will use the personal data that you provide us voluntarily, exclusively for
the purposes of getting in touch with you and being able to address your inquiry.
Slovenian GDPR established the legal basis for this data processing.

4.Recipients outside the EU

With the exception of the processing shown here, we do not share your data with recipients
having their seat outside the European Union or the European Economic Area. The processing
set forth includes a data transfer to the servers of the tracking technology providers retained by
us. These servers are located in the United States of America. The data transfer is effected upon
the basis of so-called standard contractual clauses of the EU Commission and in accordance
with the principles of the so-called Privacy Shield.

5.Your rights


5.1. Overview
Alongside the right to withdrawal of the consents you have given to us, if the respective statutory
prerequisites are present, then you are entitled to the following additional rights:
– the right of access to your personal data stored by us, in particular, you can obtain access
to purposes of the processing, the category of the personal data, the categories of recipients to
whom your data were or are being disclosed, the envisaged period of storage, and the source of
your data, insofar as these were not collected directly from you;
– the right to rectification of inaccurate data or to completion of incomplete data,
– the right to erasure of your data stored with us, to the extent that we do not have to comply
with any statutory or contractual retention periods or other duties or rights by operation of law
concerning further storage by us,
– the right to the restriction of processing of your data, to the extent that the accuracy of the
data is contested by you, that the processing is unlawful, but you oppose its erasure; the
Controller no longer needs the data, but that you, however, require the data for the

establishment, exercise, or defense of legal claims, or have filed an objection to the processing
as contemplated under Slovenian GDPR,
– the right to data portability in accordance with Slovenian GDPR, i.e., the right to obtain in a
commonly used, machine-readable format selected data TORNADO PLUS d.o.o. and stored with
us, or to demand the transfer of such to another controller,
– the right to lodge a complaint with a supervisory authority. As a rule, for this purpose you
can turn to the supervisory authority at your habitual residence or place of work, or where our
company seat is located.
You can avail yourself of the above rights to which you are entitled with regard to us at
info@tornadoplus.eu.


5.2. Right to object
It is possible under the prerequisites of Slovenian GDPR to object to the data processing on
grounds relating to the particular situation of the data subject.
The general right to objection above applies to all processing purposes described in this data
protection information, which purposes are processed on the basis of Article Slovenian GDPR. In
contrast to the special right of objection oriented to data processing for promotional purposes, we
are obligated under the GDPR to implement such a general right of objection only if you set forth
reasons of overarching significance (e.g., a potential risk to life or health).


5.3. Right to withdrawal
Insofar as we process data upon the basis of a consent that you have issued, you have the right
to withdraw the consent issued at any time. The withdrawal of the consent does not result in the
data processing becoming ineffective which has taken place upon the basis of the consent up to
the date of the withdrawal.

6. Payment

If you make a purchase on our site, we use a third party payment processor Stripe. Payments are encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction.

All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.

PCI-DSS requirements help ensure the secure handling of credit card information by our site and related courses and its service providers.