Privacy Policy

01Who we are

The Immortal website and waitlist are operated by the team behind Immortal, based in the Republic of Slovenia (“Immortal”, “we”, “us” or “our”). We are the controller of your personal data under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Slovenian Personal Data Protection Act.

Controller

Immortal, Republic of Slovenia

Contact for privacy

The contact form at the end of this policy

Data protection officer

Not appointed, because our processing does not meet the conditions of Article 37 GDPR. Please send any privacy question through the contact form.

02What this policy covers

This policy applies to the Immortal website, to the Immortal waitlist and to messages you send us. Immortal itself, the app, is not available yet. When it launches it will come with its own privacy notice that explains how the app handles the data you choose to connect, such as wearable and calendar data. Nothing you share through this website is connected to an app account.

03The data we collect

When you join the waitlist

We collect the email address you enter. Our form provider also records technical details of the submission: the date and time, your IP address, your browser’s user agent and the address of the page you submitted from. The form contains a hidden field that only automated bots fill in, which helps us reject spam.

When you visit the website

Like every website, ours has to receive certain technical data from your browser in order to deliver pages to you: your IP address, the date and time of the request, the page requested, the referring page, and browser and device information. Our hosting provider processes this data to deliver the website and to keep it secure. We do not use analytics, advertising, tracking pixels, social media plugins or fingerprinting.

When you contact us

If you use our contact form, we receive your email address, so that we can reply, your name if you give it, the topic you choose and your message. Our form provider records the same technical details as for the waitlist, and checks the message for spam in the same way. If you reply to one of our emails, we receive that email.

What we do not collect

We do not collect health data, wearable data or any other special category of personal data through this website, and we never ask for it. Please do not send us such information through the contact form or by email. We do not buy personal data, and we do not combine your data with data from other sources.

04Why we use it and our legal bases

We only process personal data when the law allows it. For each purpose, here is the legal basis we rely on.

Where we rely on legitimate interests, we have balanced them against your rights and freedoms, and you can object at any time, as explained in section 10. Giving us your email address is voluntary and is not a statutory or contractual requirement. The only consequence of not giving it is that we cannot add you to the waitlist. We do not make decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects for you.

05The emails we send

If you join the waitlist, we will only email you about Immortal: news about the launch, your early access invitation and important updates about the product. We will not send you advertising for other companies, and we will keep emails infrequent.

Every email we send includes a link to unsubscribe. You can also unsubscribe at any time by sending us a request through the contact form. Unsubscribing is free and takes effect without undue delay. This approach follows the GDPR and the consent rules for electronic marketing in the Slovenian Electronic Communications Act.

06Who we share it with

We do not sell, rent or trade your personal data, and we do not share it with advertisers. We only share it with the service providers we need to run the website, who act as our processors under written contracts that meet Article 28 GDPR, and only to the extent they need it.

We may also disclose personal data when the law requires it, for example to a court or public authority with a valid legal request; to professional advisers such as lawyers and accountants, who are bound by confidentiality; and to a successor if Immortal is reorganized, merged or sold, in which case this policy will continue to protect your data and we will inform you in advance.

07Transfers outside the EU

Netlify and its subprocessors are based in the United States, so your data is transferred outside the European Economic Area. We only allow this where Chapter V of the GDPR is respected:

• Netlify, Inc. is certified under the Data Privacy Framework between the European Union and the United States. The European Commission has decided that certified companies ensure an adequate level of protection (Commission Implementing Decision (EU) 2023/1795 of 10 July 2023, Article 45 GDPR).
• Netlify’s data processing agreement also provides for the European Commission’s Standard Contractual Clauses (Article 46 GDPR), which apply if the Data Privacy Framework ever stops covering a transfer.
• Under its data processing agreement, Netlify remains responsible to us for the subprocessors it engages.

You can ask us for more information about these safeguards, or for a copy of them, using the contact details below.

08Cookies and tracking

This website does not use cookies, local storage or any similar technology to store or read information on your device, and it contains no analytics or advertising tags. That is why you do not see a cookie banner.

The fonts and the product film are served from our own website, not from third party services. Your browser may keep its own temporary cache of these files to load the page faster, which you control through your browser settings.

Under the Slovenian Electronic Communications Act, storing or reading information on your device requires your consent unless it is strictly necessary for a service you have asked for. If we ever want to use such technologies for anything that is not strictly necessary, we will ask for your consent first and update this policy.

09How long we keep it

We keep personal data only for as long as we need it for the purposes described above.

• Waitlist email address: until you unsubscribe or ask us to delete it. If you do neither, we delete it no later than 12 months after the public launch of the Immortal app, or promptly if we decide not to launch. If you create an Immortal account, the app’s privacy notice applies from then on.
• Technical details of your submission (time, IP address, user agent, page address): together with the email address they belong to.
• Submissions flagged as spam: reviewed and deleted within 30 days.
• Proof of consent and of withdrawal: a minimal record of your email address and the relevant dates, kept for as long as we need it to demonstrate compliance, and no longer than three years after you unsubscribe.
• Messages you send us through the contact form or by email: for as long as needed to deal with your message, and no longer than two years after our conversation ends, unless we need them to establish, exercise or defend legal claims.
• Website delivery and security data: processed by Netlify only for as long as needed to deliver the website and keep it secure, in line with its own retention practices.

10Your rights

Under the GDPR you have the following rights. To use any of them, send us a request through the contact form, giving the email address the request is about. We will reply to that address.

• Access to your personal data and to information about how we use it (Article 15).
• Rectification of inaccurate data (Article 16).
• Erasure of your data (Article 17).
• Restriction of processing (Article 18).
• Data portability, which means receiving the data you gave us in a structured, commonly used and machine readable format (Article 20).
• Objection to processing based on our legitimate interests, on grounds relating to your particular situation, and objection to direct marketing at any time, without giving a reason (Article 21).
• Withdrawal of consent at any time, without affecting the lawfulness of processing before the withdrawal (Article 7(3)).
• Not to be subject to a decision based solely on automated processing that significantly affects you (Article 22). We make no such decisions.

We respond without undue delay and in any event within one month. If a request is complex, or if we receive many requests, we may extend this by up to two further months and will tell you why. Exercising your rights is free of charge. If we have reasonable doubts about your identity, we may ask for information to confirm it.

Your right to complain

You have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU country where you live, work or where an alleged infringement took place. The authority competent for us is the Information Commissioner of the Republic of Slovenia:

Authority

Informacijski pooblaščenec (Information Commissioner)

Address

Dunajska cesta 22, 1000 Ljubljana, Slovenia

Email and phone

gp.ip@ip-rs.si · +386 1 230 97 30

Website

www.ip-rs.si

We would appreciate the chance to address your concern first, so please feel free to contact us before you complain.

11How we protect it

We use appropriate technical and organizational measures under Article 32 GDPR. The website is served only over encrypted HTTPS connections. Access to waitlist data and messages is limited to the people on our team who need it, through secured accounts. We work only with processors that provide sufficient guarantees, and we collect as little data as possible.

No method of transmission or storage is completely secure. If a personal data breach occurs, we will notify the competent supervisory authority within 72 hours where the law requires it (Article 33 GDPR), and we will inform you without undue delay if the breach is likely to result in a high risk to your rights and freedoms (Article 34 GDPR).

12Children

The website and the waitlist are intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe a child has joined the waitlist, please contact us and we will delete the data promptly.

13If you live outside the EU

We apply the protections described in this policy to everyone, wherever they live.

• United Kingdom: you have equivalent rights under the UK GDPR and may complain to the Information Commissioner’s Office at ico.org.uk.
• Switzerland: you have equivalent rights under the Federal Act on Data Protection and may contact the Federal Data Protection and Information Commissioner.
• United States, including California: we do not sell your personal information and we do not share it for cross context behavioral advertising. We do not use or disclose sensitive personal information.

14Changes to this policy

We may update this policy when our services or the law change. The date at the top shows when it was last updated. If we make a material change that affects people on the waitlist, we will tell you by email before it takes effect. We will never use your data for a new purpose that is incompatible with the original one without informing you and, where required, asking for your consent.

15Contact us

For any question about this policy, or to exercise your rights, email info@immortalx.si or send us a message using the form below. We will reply by email.