PRIVACY POLICY for Skvin d.o.o.
Last Updated: October 23rd, 2025
1. Introduction
Skvin d.o.o. (“we,” “us,” or “our”), with its registered office in Metlika, Slovenia, is committed to protecting the privacy and security of your personal data. We are a diversified Slovenian company operating in three distinct areas: providing customer ski recommendations, producing and selling boutique wine, and offering educational consulting services.
We act as a Controller of your personal data. This Privacy Policy outlines how we collect, use, store, and protect your personal data in compliance with the General Data Protection Regulation (GDPR) and the Slovenian Personal Data Protection Act (ZVOP-2).
2. Identity and Contact Details of the Controller
Controller: Skvin d.o.o.
Registered Address: Vidošiči 16, 8330 Metlika
Registration Number: 8794529000
VAT Identification Number: SI49214748
Contact Email: skvinslovenia@gmail.com
Phone: +386 31 000 947
3. Personal Data We Process and Why
We process personal data that is specific to the nature of our interaction with you.
| Business Activity | Category of Data Subject | Examples of Personal Data Collected |
| Ski Recommendations | Service Recipients | Name, email, phone number, height, weight, skill level, skiing style, boot size, purchase history related to gear. |
| Vineyard & Wine Sales | Wine Buyers / Event Attendees | Name, delivery address, billing information, email, phone number, date of birth (for age verification related to alcohol sales). |
| Educational Consulting | Students / Parents / Clients | Name, contact details, academic history, educational needs, professional experience (for adult education), payment information. |
| General Operations | Website Users, Suppliers, Applicants | IP address, browser data, cookie data, supplier contact information, CVs, and application details. |
4. Purposes and Legal Basis for Processing
We process your personal data only when we have a valid legal basis as defined by GDPR.
| Purpose of Processing | Legal Basis (GDPR Article 6) | Key Data Processed | Retention Period |
| Provide Ski Recommendations | Performance of a contract or pre-contractual steps (Art. 6(1)(b)) | Height, weight, skill level, contact info. | For the duration of the relationship/service, plus statutory limitation periods (e.g., 5 years) for liability. |
| Process Wine Orders & Delivery | Performance of a contract (Art. 6(1)(b)) and Compliance with a legal obligation (Art. 6(1)(c)) | Billing/shipping address, payment details, Date of Birth (to verify legal drinking age in Slovenia – currently 18). | 10 years for accounting records as required by Slovenian law. |
| Deliver Educational Services | Performance of a contract or pre-contractual steps (Art. 6(1)(b)) | Academic history, contact information. | For the duration of the service, plus statutory retention periods for educational certificates/records. |
| Direct Marketing(for wine, consulting, or skiing offers) | Your specific Consent (Art. 6(1)(a)) OR Legitimate interest (Art. 6(1)(f)) – only for existing customers regarding similar products/services with an easy opt-out. | Email address, name. | Until withdrawal of consent or objection to processing. |
| Comply with Legal Obligations (Tax, accounting, age verification records) | Necessary for compliance with a legal obligation (Art. 6(1)(c)) | Tax/financial data, records related to age verification. | As required by Slovenian and EU law (typically 10 years). |
| Website Operation (e.g., essential cookies) | Legitimate interest (Art. 6(1)(f)) | IP address, technical usage data. | Detailed in our Cookie Policy. |
5. Recipients of Personal Data
Your personal data may be shared with the following recipients:
Processors who act on our behalf (e.g., IT service providers, cloud hosting, email service providers). These entities are subject to specific GDPR contractual requirements (Data Processing Agreements).
Third Parties where required by law, such as the Financial Administration of the Republic of Slovenia (FURS), judicial, or administrative bodies.
Logistics Providers (e.g., courier services like Pošta Slovenije or others) for the delivery of wine and consulting materials.
Payment Providers (e.g., banks, credit card processors, PayPal) for processing sales transactions.
External Consultants (e.g., certified accountants or legal advisors) when necessary for business operations and legal compliance.
6. International Transfers of Data
If we transfer your personal data outside of the European Economic Area (EEA), we will ensure an adequate level of protection is afforded to it, typically by relying on one of the following safeguards:
Adequacy Decision by the European Commission.
Standard Contractual Clauses (SCCs) approved by the European Commission, along with supplementary measures to ensure security.
Your explicit consent to the proposed transfer (Art. 49(1)(a) GDPR).
7. Data Subject Rights (Your Rights)
Under GDPR and ZVOP-2, you have the following rights regarding your personal data:
Right of Access: To know what data we hold about you and receive a copy of it.
Right to Rectification: To have inaccurate or incomplete data corrected.
Right to Erasure (‘Right to be Forgotten’): To request the deletion of your personal data under certain conditions (e.g., when the data is no longer necessary for the purposes for which it was collected).
Right to Restriction of Processing: To limit how we use your data.
Right to Data Portability: To receive your personal data in a structured, commonly used, and machine-readable format.
Right to Object: To object to processing based on legitimate interest or for direct marketing purposes.
Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw it at any time.
You can exercise these rights by contacting us using the email address in Section 2. We will respond to your request without undue delay and in any event within one month of receipt of the request.
8. Right to Lodge a Complaint with a Supervisory Authority
If you believe that the processing of your personal data infringes data protection law, you have the right to lodge a complaint with the supervisory authority in Slovenia:
Informacijski pooblaščenec (Information Commissioner)
Address: Dunajska cesta 22, 1000 Ljubljana, Slovenia
Email: gp.ip@ip-rs.si
Website: https://www.ip-rs.si/en/
9. Security of Personal Data
We implement appropriate technical and organizational measures (such as encryption, access controls, pseudonymization, and regular security audits) to ensure a level of security appropriate to the risk. These measures protect personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
10. Cookies and Tracking Technologies
Our website uses cookies and similar tracking technologies to function, analyze usage, and personalize content. You will find more detailed information about the cookies we use, the purposes for which we use them, and your ability to manage your preferences in our separate Cookie Policy.