Last updated: December 31, 2025
This Privacy Policy explains how we collect, use, store, and protect your personal data when you access or use our website, programs, services, and live or recorded content. It also describes your rights under applicable data protection laws, including the EU General Data Protection Regulation (GDPR).
By using our website or services, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.
This Privacy Policy is intended to comply with the laws of Slovenia, the European Union (including GDPR), and, where applicable, the United States.
1. Interpretation and Definitions
Interpretation
Words with capitalized initial letters have meanings defined below. These definitions apply whether the terms appear in singular or plural form.
Definitions
Account
A unique user profile created to access parts of our Service.
Company
VURSHY SMART Urška Jakobčič s.p.,
28 Nova Loka, Črnomelj, Slovenia
(referred to as “the Company,” “we,” “us,” or “our”).
Cookies
Small files stored on your device that help improve functionality and user experience.
Country
Slovenia.
Device
Any device capable of accessing the Service, such as a computer, smartphone, or tablet.
Personal Data
Any information relating to an identified or identifiable individual.
Service
Our website, digital products, programs, coaching services, live sessions, recordings, and related content.
Service Provider
Any third party that processes data on behalf of the Company.
Third-Party Social Media Service
External platforms enabling login, interaction, or content sharing.
Usage Data
Data collected automatically through use of the Service.
Website
All pages and subpages under vurshysmart.com, including landing and thank-you pages.
You / Data Subject
The individual accessing or using the Service, or the legal entity on whose behalf such individual acts.
2. Personal Data We Collect
Personal Data
We may collect and process the following information:
First and last name
Email address
Phone number
Billing and/or shipping address
Postal code, city, country
Payment-related information (processed securely via third-party providers)
Any information you voluntarily provide (e.g. messages, applications, feedback, survey responses)
Usage Data
Collected automatically and may include:
IP address
Browser type and version
Pages visited and time spent
Device identifiers
Interaction data (e.g. form submissions, purchases)
User-Generated Content
This includes content you choose to share during live sessions, group programs, chats, comments, or community spaces.
3. Purpose and Legal Basis for Processing (GDPR)
We process your personal data on the following legal bases:
Contractual necessity – to deliver purchased services or requested access
Consent – where you explicitly agree (e.g. marketing communications, recordings)
Legitimate interest – to operate, improve, and secure our services
Legal obligation – to comply with applicable laws
Your data may be used to:
Provide and manage our services
Communicate with you (service updates, offers, support)
Personalize your experience
Analyze performance and improve content
Process payments via third-party providers
Comply with legal and accounting obligations
Display your name in closed groups (e.g. challenges or giveaways)
4. Live Sessions, Recordings, and Public Use of Content
Some of our services include live video sessions, group calls, trainings, or events, which may be recorded.
By participating in live sessions, you acknowledge and agree that:
Sessions may be recorded for internal, educational, or quality purposes
Selected excerpts (audio, video, or transcript) may be used publicly for:
Marketing
Educational content
Social media
Website or promotional materials
We take reasonable steps to avoid sharing sensitive personal disclosures. However:
Participation is voluntary
If you choose to speak, appear on camera, or share information, you do so at your own discretion
If you do not wish to appear in public materials, it is your responsibility to:
Keep your camera off
Use anonymized names
Contact us in advance at [email protected]
We do not sell personal data and do not use private session content for targeted advertising without a lawful basis or explicit consent, in accordance with GDPR.
5. Use of Service Providers
We may work with third-party Service Providers to support and operate our business, including but not limited to:
Payment processing
Website and data hosting
Email marketing and CRM systems
Analytics, advertising, and performance measurement tools
These Service Providers may include advertising and analytics partners (such as Meta Platforms) that help us deliver relevant content, measure campaign performance, and conduct retargeting activities.
Only limited data is shared for these purposes, such as cookie identifiers, device information, or website interaction data. We do not sell personal data and do not share sensitive personal information for advertising purposes without a lawful basis or explicit consent.
All Service Providers are contractually obligated to process personal data only on our instructions and to apply appropriate technical and organizational safeguards.
6. Cookies and Tracking Technologies
We use cookies and similar technologies to:
Enable essential website functionality
Remember user preferences
Analyze traffic and performance
Support marketing and retargeting activities
You can control or disable cookies through your browser settings. Disabling cookies may limit certain features of the Service.
7. Data Retention
We retain personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, or as required by law. When data is no longer required, it is securely deleted or anonymized.
8. Your Rights Under GDPR
You have the right to:
Access your personal data
Request correction of inaccurate data
Request deletion (“right to be forgotten”)
Restrict or object to processing
Request data portability
Withdraw consent at any time
Lodge a complaint with a supervisory authority
Requests can be sent to:
📧 [email protected]
9. Children’s Privacy
Our services are not intended for children under the age of 16. We do not knowingly collect personal data from minors. If such data is identified, it will be deleted promptly.
10. Third-Party Links
Our Service may contain links to third-party websites that are not operated or controlled by us. We are not responsible for their content, privacy policies, or practices. We encourage you to review their privacy policies before providing any personal data.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Updates will be posted on this page with a revised “Last updated” date. Continued use of the Service constitutes acceptance of the updated policy.
12. Contact Information
For questions, concerns, or data protection requests:
📧 Email: [email protected]