Privacy Policy & Legal Notice

1. Legal Notice (Impressum)

2. Privacy Policy

SwinLabs d.o.o. ("we", "us", "our") respects your privacy and is committed to protecting your personal data in accordance with the General Data Protection Regulation (GDPR — Regulation (EU) 2016/679) and the Slovenian Personal Data Protection Act (ZVOP-2).

3. Data Controller

The data controller responsible for the processing of your personal data is:

SwinLabs d.o.o.

Email:

4. What Data We Collect

4.1 Website hosting

Our website is hosted by Webtasy, d.o.o. (domenca.com), a hosting provider based in Slovenia. The hosting server may automatically collect:

• IP address
• Browser type and version
• Operating system
• Date and time of access
• Referring URL

This data is processed for the purpose of delivering the website content and maintaining server security. The legal basis is our legitimate interest (Art. 6(1)(f) GDPR) in providing a secure and functional website. As the hosting provider is based in Slovenia (EU), no transfer of data to third countries occurs.

4.2 Cloudflare (DNS proxy & security)

We use Cloudflare as a DNS proxy and web application firewall (WAF). All traffic to our website passes through Cloudflare's network before reaching our hosting server. Cloudflare may process your IP address and request metadata for the purpose of DDoS protection, bot management, and performance optimization. Cloudflare may set technical cookies (e.g. __cf_bm) that are strictly necessary for security. These do not require consent.

Cloudflare Inc. is based in the USA and complies with the EU-U.S. Data Privacy Framework. More information: Cloudflare Privacy Policy.

4.3 Google Fonts

We use Google Fonts to display fonts on our website. When you visit our site, your browser establishes a connection to Google servers and transmits your IP address. The legal basis is our legitimate interest (Art. 6(1)(f) GDPR) in a consistent visual presentation.

Google LLC is based in the USA and complies with the EU-U.S. Data Privacy Framework. More information: Google Privacy Policy.

4.4 Cloudflare Web Analytics

Cloudflare automatically enables privacy-focused web analytics on our website. This collects aggregated, non-personally-identifiable data such as page views, referrers, and browser information. Cloudflare Web Analytics does not use cookies, does not track individual users across sites, and does not collect personal data. The legal basis is our legitimate interest (Art. 6(1)(f) GDPR) in understanding website usage.

More information: Cloudflare Web Analytics.

4.5 Contact

When you contact us via email or phone, we process the personal data you provide (name, email address, phone number, message content) for the purpose of responding to your inquiry. The legal basis is Art. 6(1)(b) GDPR (pre-contractual measures) or Art. 6(1)(f) GDPR (our legitimate interest in responding to inquiries).

5. Cookies

This website does not use analytics cookies, advertising cookies, or tracking cookies. We do not use Google Analytics, Facebook Pixel, or any similar tracking services.

The only cookies that may be set are:

• Cloudflare security cookies (e.g. __cf_bm) — strictly necessary for website security and bot protection. These are exempt from the consent requirement under Art. 5(3) of the ePrivacy Directive.
• Theme preference — a local storage entry that remembers your dark/light mode preference. This is strictly necessary for functionality and does not contain personal data.

6. Data Sharing

We do not sell, trade, or otherwise transfer your personal data to third parties, except:

• Webtasy, d.o.o. (domenca.com) — website hosting (see section 4.1). Based in Slovenia (EU).
• Cloudflare Inc. — DNS proxy, firewall, and web analytics (see sections 4.2 and 4.4). Complies with the EU-U.S. Data Privacy Framework.
• Google LLC — font delivery (see section 4.3). Complies with the EU-U.S. Data Privacy Framework.

7. Data Retention

Server log data is retained by our hosting provider (Webtasy/domenca.com) and Cloudflare according to their respective data retention policies. Contact data (emails, inquiries) is retained for as long as necessary to fulfill the purpose for which it was collected, and is deleted when no longer needed, unless legal retention obligations apply.

8. Your Rights

Under GDPR, you have the following rights regarding your personal data:

• Right of access (Art. 15) — You may request information about the personal data we hold about you.
• Right to rectification (Art. 16) — You may request correction of inaccurate data.
• Right to erasure (Art. 17) — You may request deletion of your data ("right to be forgotten").
• Right to restriction of processing (Art. 18) — You may request restriction of processing in certain circumstances.
• Right to data portability (Art. 20) — You may request your data in a structured, machine-readable format.
• Right to object (Art. 21) — You may object to processing based on legitimate interests.

To exercise any of these rights, contact us at:

9. Supervisory Authority

If you believe that the processing of your personal data violates the GDPR, you have the right to lodge a complaint with the supervisory authority:

Informacijski pooblaščenec Republike Slovenije

Phone:
Email:
Website: www.ip-rs.si

10. Changes to This Policy

We may update this privacy policy from time to time. Any changes will be posted on this page with an updated revision date. We encourage you to review this page periodically.

11. Accessibility Statement

SwinLabs d.o.o. is committed to ensuring digital accessibility for all users, in accordance with Directive (EU) 2019/882 (European Accessibility Act).

We strive to comply with the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA. Measures we have implemented include:

• Semantic HTML structure with appropriate ARIA landmarks
• Keyboard navigation support with visible focus indicators
• Skip-to-content navigation link
• Descriptive alternative text for all images
• Sufficient color contrast ratios
• Reduced motion support for users who prefer it
• Responsive design that works across devices and screen sizes

If you encounter any accessibility barriers on our website, please contact us at and we will do our best to address the issue.