We use a cookie to remember your choice. With your agreement, we also use Google Analytics to understand site traffic, and a CRM cookie that links your browsing to your contact record if you get in touch with us. See our privacy policy for details.
STEM Peskalna tehnika, inženiring, marketing d.o.o.
Rožna Dolina, Vipavska cesta 67, 5000 Nova Gorica, Slovenija
VAT: SI 29302196 · Registration no.: 5306779000 · Registered: 2 February 1990
info@stem.si · +386 5 33 52 100
Contact for data protection matters: Igor Bitežnik, igor@stem.si
"STEM d.o.o.", as it appears in the site footer and in everyday use, refers to this same registered entity.
This policy applies to stem.si and its English, Slovenian and German language versions.
This policy is prepared under the Personal Data Protection Act (ZVOP-2, Uradni list RS no. 163/22 and amendments), Regulation (EU) 2016/679 (GDPR), the Electronic Communications Act (ZEKom-2, Uradni list RS no. 133/22 and amendments — the law that specifically governs the cookie consent requirements below), and other applicable Slovenian and European legislation.
Personal data means any information relating to an identified or identifiable natural person. User means a natural person whose personal data is processed under this policy. Processormeans an entity processing personal data on the Controller's behalf and instructions, under a written agreement, as required by Art. 28 GDPR.
Personal data may be disclosed to processors listed above for the purposes described in Section 7, to legal or governmental authorities where required by law, and to third countries only where an adequate level of protection applies or appropriate safeguards are in place (Standard Contractual Clauses, or an equivalent transfer mechanism).
Users may lodge a complaint with the Slovenian supervisory authority, the Informacijski pooblaščenec.
Some parts of this site store information on your device. What is stored, why, for how long, and whether it requires your consent is set out below. You control non-essential storage through the cookie banner shown on your first visit, and can change your choice at any time via "Cookie preferences" in the footer.
| Name | Set by | Category | Purpose | Duration | Consent needed? |
|---|---|---|---|---|---|
| stem_consent | This site | Necessary | Remembers your cookie choices | 6 months | No — storing a consent decision is itself exempt |
| NEXT_LOCALE | This site | Necessary | Remembers your chosen language (English, Slovenščina, Deutsch) | 1 year | No — required for consistent language routing |
| _ga, _ga_<container-id> | Google Analytics (GA4) | Analytics | Distinguishes visitors for aggregate reporting | 14 months | Yes |
| hubspotutk | HubSpot | Personalisation | Links your browsing on this site to your contact record once you get in touch with us — the mechanism behind the "Personalisation" category below | 6 months | Yes |
| __hstc | HubSpot | Personalisation | Main visitor-tracking cookie underlying the same link | 6 months | Yes |
| __hssc | HubSpot | Personalisation | Tracks your current browsing session | 30 minutes | Yes |
| __hssrc | HubSpot | Personalisation | Detects whether your browser has restarted | Session | Yes |
| — | Vercel Web Analytics | — | Traffic and pageview counts | 24 hours, server-side only | No — cookieless by design |
| — | Vercel Speed Insights | — | Core Web Vitals performance monitoring | Not tied to a visitor identity | No — confirmed cookieless via Vercel’s own documentation |
Google Analytics only loads, and only receives data, after you accept the Analytics category in the cookie banner. Before that, this site registers a "denied" signal with Google (Consent Mode v2, Basic mode) so that no request of any kind reaches Google — not even an anonymised one — until you have made a choice.
HubSpot's tracking script behaves the same way for the Personalisation category: the script itself is not added to the page until you accept, and if you later withdraw consent, this site tells HubSpot to stop recording your activity going forward.
You are responsible for the accuracy of any information you provide (for example through the contact form or the newsletter signup), for keeping any account credentials confidential, and for not submitting false or third-party personal data without authorisation.
Legal basis: Art. 6(1)(b) GDPR — steps taken at your request prior to a possible contract
Retention: 24 months from your last contact if no contract follows, reviewed quarterly by the data-protection contact named in Section 1 and deleted once that period has elapsed, unless a contract or a legal retention obligation (see Section 7, Legal obligations) requires it to be kept longer
Personal data: name, email, company, phone, country, message, enquiry type and details
Legal basis: Art. 6(1)(b) / 6(1)(f) GDPR
Retention: Same as the enquiry above
Personal data: campaign parameters and referring site — no device identifier is stored
Legal basis: Art. 6(1)(a) GDPR and ZEKom-2 — explicit, separate consent
Retention: Until you withdraw consent, using the unsubscribe link in any newsletter email; a record of when and how consent was given is kept for as long as the subscription is active, as evidence of that consent
Personal data: email address, consent timestamp, confirmation evidence
Legal basis: Art. 6(1)(f) GDPR — legitimate interest, with a right to object at any time
Retention: 3 months after your last contact with us, reviewed quarterly alongside the enquiry data above
Personal data: name, email
Legal basis: Art. 6(1)(f) GDPR
Retention: Per Cloudflare's retention policy
Personal data: IP address, challenge response
Legal basis: Art. 6(1)(a) GDPR — consent, via the cookie banner
Retention: 14 months
Personal data: pseudonymous client identifier, truncated IP address, page and event data, device/browser category
Legal basis: Art. 6(1)(f) GDPR — legitimate interest; no consent required as no cookie or persistent identifier is used
Retention: Aggregate data only; not linked to an individual
Personal data: aggregated page views, referrer and country; Core Web Vitals metrics
Legal basis: Art. 6(1)(a) GDPR — consent, via the Personalisation cookie category
Retention: For as long as your contact record exists in our CRM, reviewed as part of the same quarterly process described above; you may withdraw consent at any time, which stops new activity being recorded
Personal data: pseudonymous browsing identifier (hubspotutk), pages viewed and their timestamps, if you later contact us, that identifier is linked to your name and email so we can see which pages you viewed before getting in touch, email opens and clicks, once you have a contact record, the campaign or source that brought you to the site
Legal basis: Art. 6(1)(f) GDPR
Retention: Per Vercel's retention policy
Personal data: IP address, request metadata
Legal basis: Art. 6(1)(c) GDPR
Retention: 10 years (Tax Procedure Act, ZDavP-2)
Personal data: invoicing data
If you accept the Personalisation cookie category and later get in touch with us — through the contact form or the newsletter — we combine what you did on this website (pages viewed, when, and what led you here) with your contact details in one record in our CRM. Once you are a contact, we may also see whether you opened or clicked emails we send you.
We use this to understand what you are interested in and to prioritise and personalise how we follow up with you — for example, a salesperson reading your enquiry can see which product pages you looked at beforehand, rather than starting from nothing.
This is not a solely automated decision. A person reads and responds to every enquiry; nothing about your access to our products, services, or any contract with us is decided by this combined record alone, without human involvement. Article 22 GDPR, which specifically governs solely automated decision-making with legal or similarly significant effects, therefore does not apply to this processing.
You can object to this at any time — see Section 9, and in particular your right to object to direct-marketing profiling, which has no exceptions.
You may request access to, rectification of, or erasure of your personal data; request restriction of processing; request data portability; withdraw consent at any time; and lodge a complaint with the Informacijski pooblaščenec. We will respond within one month, extendable by a further two months for complex requests. To exercise any of these rights, contact us at the details in Section 1.
Right to object (Art. 21 GDPR). Where we process your data under legitimate interest (Art. 6(1)(f)), you may object at any time, and we will stop unless we can demonstrate compelling legitimate grounds that override your interests. Where we process your data for direct marketing — including the profiling described in Section 8 that supports it — Art. 21(2) gives you an unconditional right to object: there is no balancing test, and once you object we stop that processing entirely.
We apply technical and organisational measures appropriate to the risk, including encryption in transit and access controls, but no system is completely secure. This policy may be updated; material changes will be indicated by a new effective date.
Data Protection Officer: based on the scale and nature of our processing, we have assessed that a Data Protection Officer is not mandatory under Art. 37 GDPR. Igor Bitežnik (contact details in Section 1) is our named contact for data protection matters and questions about this policy.
Effective date: 30 July 2026.