Privacy Statement


What does this Policy cover?


We at Inovacijski Center LUSI d.o.o. take your personal data very seriously. This policy:


  • Sets out the types of personal data that we collect about you;
  • Explains how and why we collect and use your personal data;
  • Explains how long we keep your personal data for;
  • Explains when, why and with who we will share your personal data;
  • Sets out the legal basis we have for using your personal data;
  • Explains the effect of refusing to provide the personal data requested;
  • Explains the different rights and choices you have when it comes to your personal data; and
  • Explains how we may contact you and how you can contact us.


What personal data do we collect about you?


We collect the information necessary to be able to find available opportunities and further information needed to assess the best fit to your needs of our training courses, consulting services and certification tracks. This information may include

  • Identity Data includes first name, maiden name, last name, username or similar identifier, job title and company.
  • Contact Data includes email address and telephone numbers.
  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
  • Profile Data includes CV’s, educational records, work and project history, employment experiences and goals.
  • Communications Data includes your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).


Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.



Where do we collect personal data about you from?


The following are the different sources we may collect personal data about you from:


  • Directly from you. This is information you provide while searching for training or consulting support, and/or during the different project stages [or coaching, where relevant].
  • Through publicly available sources. We use the following public sources:
    • LinkedIn
    • XING


How and why we use your personal data?


We use your personal data to match your skills, experience and education with our training, consulting, coaching or certification offers . We will initially collect basic information on you such as contact details, job role and experience. We are not passing this information, but use in our company solely to make you most appropriate offer and provide you with best service matching with your needs and current competencies.



Who do we share your personal data with?


Your personal data is shared with the trainer or consultant or third party who works for us as a contractor in providing services.



What legal basis do we have for using your information?


For prospective clients, our processing is necessary for our legitimate interests in that we need the information in order to be able to assess and to enable suitability of our service offer to your needs and current competences.

For clients, we may also rely on our processing being necessary to perform a contract for you, for example in contacting you.



What happens if you do not provide us with the information we request or ask that we stop processing your information?


If you do not provide the personal data necessary, or withdraw your consent for the processing of your personal data, we may not be able to match your needs with the best suitable consulting or training etc. opportunities.



Do we make automated decisions concerning you?


We may make personal decisions  to assess whether you meet the specific criteria for a particular training program, consulting and/or entering specific certification track. These assessments are made by the experts and are not automated. We also carry out personality profiling on candidates with the candidate’s consent.



Do we transfer your data outside the EEA?


No, we do not transfer personal data out of the EEA.



What rights do you have in relation to the data we hold on you?


By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.


Rights What does this mean?
1.       The right to be informed


You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.


2.       The right of access You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy).

This is so you’re aware and can check that we’re using your information in accordance with data protection law.


3.       The right to rectification

You are entitled to have your information corrected if it’s inaccurate or incomplete.


4.       The right to erasure This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.


5.       The right to restrict  processing You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.


6.       The right to data portability You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new service provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.


7.       The right to object to processing You have the right to object to certain types of processing, including processing for direct marketing.


8.       The right to lodge a complaint You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.


9.       The right to withdraw consent If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.




We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

  • baseless or excessive/repeated requests, or
  • further copies of the same information.


Alternatively, we may be entitled to refuse to act on the request.


Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll contact you and let you know.



How will we contact you?


We may contact you by phone, email or social media. If you prefer a specific contact means over another please let us know.



How can you contact us?


If you are unhappy with how we’ve handled your information, or have further questions on the processing of your personal data, contact Elena Averboukh here: