CCTV PRIVACY NOTICE
CCTV PRIVACY NOTICE
CCTV is in operation at Apartments Seventy Seven. This notice provides information about the processing of personal data through our CCTV system in accordance with the General Data Protection Regulation (GDPR) and the Slovenian Personal Data Protection Act (ZVOP-2).
1. Data Controller
Seventy Seven d.o.o.
Borovška cesta 77
4280 Kranjska Gora
Slovenia
Email: apartments.seventy.seven@gmail.com
Telephone: +386 (0)70 140 507
2. Purposes of CCTV
CCTV is operated for the purposes of:
- protecting people and property;
- preventing and detecting unauthorised access, theft, vandalism and other security incidents;
- monitoring entry to and exit from the property;
- maintaining the security of communal areas and the property’s access systems;
- investigating specific security incidents and establishing, exercising or defending legal claims where necessary.
CCTV is not used to monitor guests inside accommodation units or other areas where individuals reasonably expect privacy.
3. Legal Basis
The legal basis for processing personal data through CCTV is Article 6(1)(f) GDPR – the legitimate interests of the data controller.
These legitimate interests include protecting people and property, securing the property and communal areas, monitoring access, and preventing and investigating security incidents.
CCTV monitoring of access to business premises is also carried out in accordance with the applicable provisions of ZVOP-2.
Before introducing CCTV, the data controller assessed the necessity and proportionality of the processing and carried out a Legitimate Interests Assessment (LIA).
4. Areas Covered by CCTV
CCTV covers only designated communal and access areas of the property where monitoring is necessary for the purposes described above.
Cameras do not cover the interior of apartments, bathrooms, sanitary facilities or other areas where individuals reasonably expect a higher degree of privacy.
Areas covered by CCTV are appropriately signposted.
5. Personal Data We Process
The CCTV system may record:
- images of individuals;
- the date and time of entry, exit or movement through the monitored area;
- other circumstances visible within the monitored area.
Audio is not recorded. The CCTV system is not used for biometric identification, facial recognition or automated identification of individuals.
6. Live Viewing
The CCTV system technically allows an authorised person acting on behalf of the data controller to access live images remotely.
Access is restricted to the authorised person and is used only within the defined purposes of CCTV.
CCTV is not used for continuous monitoring of individuals.
7. Retention of CCTV Recordings
CCTV recordings are retained for a maximum of 7 days, after which they are automatically overwritten or deleted.
A specific recording may exceptionally be retained for longer where this is necessary in connection with a specific security incident, for the establishment, exercise or defence of legal claims, or where retention is required by a competent authority.
In such cases, the recording will be retained only for as long as necessary for the relevant purpose.
8. Storage and Security
CCTV recordings are stored locally on the data controller’s CCTV system, including a local Network Video Recorder (NVR) and memory cards installed in the cameras.
The data controller does not use Reolink Cloud to store CCTV recordings.
The CCTV system allows authorised remote access through the Reolink App. According to information provided to the data controller by Reolink, communication between the App and the device is end-to-end encrypted.
Access to the CCTV system is protected and restricted to an authorised person.
9. Access to Recordings and Recipients
CCTV recordings may only be accessed by an authorised person acting on behalf of the data controller.
Access to recordings is permitted only for lawful and predefined CCTV purposes. Access to and use of recordings is appropriately traceable in accordance with applicable legislation and the data controller’s internal procedures.
Recordings may be disclosed to the police, courts, other competent public authorities or other authorised recipients where there is an appropriate legal basis for doing so.
10. Remote Access and Data Transfers
CCTV recordings are primarily stored locally. Seventy Seven d.o.o. does not use Reolink Cloud to store CCTV recordings.
The system allows authorised remote access through the Reolink App. According to information provided by Reolink, servers located in Germany and other parts of Europe may be used to forward communications between the App and the device, and communication between the App and the device is end-to-end encrypted.
In connection with providing its services, Reolink may process certain CCTV and technical data on behalf of Seventy Seven d.o.o. as a data processor. Reolink may also use authorised sub-processors in accordance with its Data Processing Agreement (DPA).
Where personal data is transferred internationally, such processing is subject to the applicable requirements of the GDPR and appropriate safeguards.
11. Automated Decision-Making
CCTV recordings are not used for automated decision-making or profiling within the meaning of Article 22 GDPR.
12. Your Rights
Subject to the conditions and limitations provided by the GDPR, you may have the following rights in relation to personal data processed through CCTV:
- the right of access to your personal data;
- the right to erasure;
- the right to restriction of processing;
- the right to object to processing based on the legitimate interests of the data controller.
The exercise of these rights may be restricted where necessary to protect the rights and freedoms of other individuals or for other reasons permitted by applicable law.
To exercise your rights, please contact:
Seventy Seven d.o.o.
Email: apartments.seventy.seven@gmail.com
Telephone: +386 (0)70 140 507
Because CCTV recordings are retained for only a short period, we recommend that requests relating to a specific recording are submitted as soon as possible and include the date, approximate time and location concerned.
13. Right to Lodge a Complaint
If you believe that your personal data has been processed in breach of applicable data protection legislation, you have the right to lodge a complaint with:
Information Commissioner of the Republic of Slovenia
(Informacijski pooblaščenec Republike Slovenije)
Dunajska cesta 22
1000 Ljubljana
Slovenia
www.ip-rs.si
14. Contact
For further information about CCTV or the processing of personal data, please contact:
Seventy Seven d.o.o.
Borovška cesta 77
4280 Kranjska Gora
Slovenia
Email: apartments.seventy.seven@gmail.com
Telephone: +386 (0)70 140 507
Effective date: June 2025
Last updated: September 2026
Seventy Seven d.o.o.