This Cookies Policy governs the use of cookies and similar tracking technologies in connection with the Trasido marketplace platform, website, digital interfaces, applications, and related services (collectively, the “Platform”), operated by AC/DC d.o.o., Partizanska cesta 14, 2230 Lenart, Republic of Slovenia (“Trasido”, “we”, “us”, or “our”).
This Cookies Policy governs the deployment, operation, management, and regulatory compliance of cookies and similar tracking technologies used in connection with the Trasido marketplace platform, including its website, applications, digital interfaces, APIs, and related electronic services (collectively, the "Platform"), operated by AC/DC d.o.o., Partizanska cesta 14, 2230 Lenart, Republic of Slovenia ("Trasido", "we", "us", or "our").
This Policy establishes the legal framework under which information is stored on, or accessed from, a user's terminal equipment, in accordance with Article 5(3) of Directive 2002/58/EC as amended (ePrivacy Directive), Regulation (EU) 2016/679 (General Data Protection Regulation – "GDPR"), Regulation (EU) 2022/2065 (Digital Services Act), and applicable Slovenian implementing legislation.
The Policy applies to all users who access, browse, register with, transact through, or otherwise interact with the Platform, irrespective of whether such users act as consumers, independent sellers, business users, or other categories of Platform participants. It applies to users located within the European Union and, where required under Article 3 GDPR, to users located outside the European Union whose personal data is processed in connection with the offering of services or monitoring of behaviour within the Union.
This Policy governs both first-party cookies deployed directly by Trasido and third-party cookies deployed through integrated service providers, including payment processors, hosting infrastructure providers, analytics services, fraud prevention tools, advertising networks, and other technological partners whose services are integrated into the Platform's infrastructure.
The use of cookies and similar technologies under this Policy serves purposes that may include, without limitation, the technical operation of the Platform, security and fraud prevention, authentication and session management, transaction processing, performance monitoring, analytics, functional customisation, marketing optimisation, and regulatory compliance monitoring.
This Cookies Policy does not replace the Privacy Notice but operates in conjunction with it. Where information collected through cookies constitutes personal data within the meaning of Article 4(1) GDPR, such processing shall additionally be governed by the Privacy Notice, including provisions relating to lawful basis, data subject rights, retention, security safeguards, and international data transfers.
Nothing in this Policy shall be interpreted as limiting mandatory rights granted to users under applicable data protection or electronic communications legislation. Where statutory provisions impose stricter requirements than those described herein, such statutory provisions shall prevail.
The deployment and use of cookies and similar tracking technologies on the Platform are carried out strictly in accordance with Article 5(3) of Directive 2002/58/EC (ePrivacy Directive), Regulation (EU) 2016/679 (General Data Protection Regulation – "GDPR"), and applicable Slovenian legislation governing electronic communications and personal data protection.
Where cookies are strictly necessary for the transmission of communications over an electronic communications network or for the provision of an information society service explicitly requested by the user, such cookies may be deployed without the requirement to obtain prior consent. The necessity threshold shall be interpreted narrowly and in accordance with regulatory guidance issued by competent supervisory authorities. The burden of demonstrating necessity rests with the Platform operator.
All cookies and similar technologies that are not strictly necessary for the operation of the Platform shall be deployed only on the basis of prior, valid, and demonstrable user consent. Consent shall be obtained through a compliant consent management mechanism that ensures that consent is freely given, specific, informed, and unambiguous, as required under Article 4(11) and Article 7 GDPR.
Consent shall not be inferred from silence, inactivity, pre-ticked boxes, default settings, or continued browsing. Users shall be provided with clear and accessible information regarding the purpose, scope, duration, and third-party involvement associated with each category of non-essential cookies prior to the activation of such technologies. No non-essential cookies shall be placed on a user's device before consent has been affirmatively granted.
The consent mechanism implemented by the Platform shall enable users to granularly manage their preferences by category, withdraw consent at any time with effect for the future, and modify previously selected preferences through accessible and user-friendly controls. Withdrawal of consent shall not affect the lawfulness of processing carried out prior to withdrawal.
Records of consent shall be securely maintained in accordance with the accountability principle under Article 5(2) GDPR and shall be capable of demonstrating compliance in the event of regulatory audit or supervisory authority inquiry. Consent logs shall document the time, scope, and configuration of consent provided.
Where cookies involve the processing of personal data, such processing shall also rely on an appropriate legal basis under Article 6 GDPR. In most cases, such legal basis shall be the user’s consent. Where strictly necessary cookies involve limited personal data processing, the legal basis may be the performance of a contract or the legitimate interests of the Platform operator, provided that such interests do not override the fundamental rights and freedoms of the data subject.
The Platform shall not condition access to core services upon acceptance of non-essential cookies, except where such cookies are objectively necessary for the requested service or where legally permissible under applicable guidance. The Platform shall avoid the use of coercive consent mechanisms, deceptive design patterns, or consent fatigue techniques that may compromise the validity of user consent.
The consent management framework shall be periodically reviewed to ensure continued compliance with evolving regulatory standards, including guidance issued by the European Data Protection Board, national supervisory authorities, and applicable court jurisprudence.
Users retain full control over the use of non-essential cookies and similar tracking technologies deployed through the Platform. The exercise of such control is implemented through a structured consent management mechanism designed to ensure transparency, granularity, and regulatory compliance.
Prior to the activation of any non-essential cookies, users are presented with clear and comprehensible information regarding the nature, purpose, and functional classification of such technologies. Users are afforded the opportunity to provide or withhold consent on a category-specific basis. No non-essential cookies shall be deployed before valid consent has been obtained in accordance with applicable legal requirements.
Users may modify or withdraw previously granted consent at any time through the Platform's accessible consent management interface. Withdrawal of consent shall take effect for the future and shall not affect the lawfulness of processing carried out prior to such withdrawal. The mechanism for withdrawing consent shall be as easily accessible as the mechanism used to provide consent, and shall not impose unnecessary technical or procedural barriers.
In addition to the consent management interface provided by the Platform, users may manage cookie settings through their browser configuration. Most browsers permit users to block, restrict, or delete stored cookies and to configure alerts for cookie placement. Users are informed, however, that disabling strictly necessary cookies may affect the functionality, security, or availability of certain Platform features.
Where cookies involve the processing of personal data, users may exercise their rights under Regulation (EU) 2016/679 (GDPR), including the right of access, rectification, erasure, restriction of processing, objection to processing, and data portability, subject to the conditions and limitations provided by law. Requests relating to personal data processed by AC/DC d.o.o. in connection with cookie deployment may be submitted through the contact details provided in the Privacy Notice.
Where third-party cookies are deployed and the third party acts as an independent controller, users may also exercise their rights directly against the relevant third party in accordance with the applicable privacy documentation of such provider.
The Platform shall not condition access to core services on the acceptance of non-essential cookies, except where such cookies are objectively necessary for the requested service or where legally permissible.The consent framework shall avoid coercive design practices, deceptive interface configurations, or mechanisms that undermine the validity of user choice.
AC/DC d.o.o. maintains internal governance procedures to ensure that user preferences are respected, technically enforced, and periodically reviewed.Consent configurations are recorded and implemented in a manner consistent with the accountability and transparency principles established under applicable data protection legislation.
Nothing in this Section shall limit or restrict mandatory rights granted to data subjects under applicable European Union or Slovenian law.
AC/DC d.o.o. implements appropriate technical and organisational measures designed to ensure a level of security appropriate to the risk associated with the deployment of cookies and similar tracking technologies, in accordance with Article 32 of Regulation (EU) 2016/679 (GDPR) and applicable Slovenian data protection legislation.
Security measures are designed to protect information collected through cookies against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, or other forms of unlawful processing. Such measures are proportionate to the nature of the data processed, the likelihood and severity of potential risks to data subjects, and the operational structure of the Platform.
Technical safeguards may include secure transmission protocols, encrypted communications, access control mechanisms, environment segregation, secure server configurations, logging systems, anomaly detection mechanisms, and system integrity monitoring. Organisational safeguards include internal governance policies, access authorisation frameworks, role-based access restrictions, incident response procedures, periodic compliance reviews, and staff training obligations relating to data protection and cybersecurity.
Where third-party service providers deploy cookies or process personal data through integrated technologies, AC/DC d.o.o. undertakes reasonable due diligence and contractual oversight to ensure that such providers implement appropriate security standards consistent with GDPR requirements. Data processing agreements, confidentiality obligations, and technical security commitments are incorporated where required under applicable law.
The Platform maintains internal procedures for the identification, assessment, and management of potential security incidents relating to cookie-related data processing. In the event of a personal data breach, AC/DC d.o.o. shall act in accordance with Articles 33 and 34 GDPR, including notification to the competent supervisory authority and affected data subjects where legally required.
Security measures are subject to ongoing review and may be updated in response to technological developments, evolving threat landscapes, regulatory guidance, or risk assessments. Such updates are implemented to ensure continued compliance with the principles of integrity, confidentiality, and accountability under applicable data protection legislation.
While AC/DC d.o.o. undertakes reasonable and proportionate measures to safeguard data processed through cookies, users are also responsible for maintaining the security of their own devices, browsers, and network environments. The effectiveness of security protections may be influenced by external factors beyond the reasonable control of the Platform operator.
Nothing in this Section shall be interpreted as providing an absolute guarantee against security incidents. The security framework is designed to mitigate risks to a level appropriate to the nature of processing and applicable regulatory standards.
