Privacy Policy

Effective date: 23 July 2026.

At DeNobilis d.o.o., trading as Frankly Executive, we are committed to protecting your privacy and handling your personal data responsibly, securely, and in accordance with the EU General Data Protection Regulation (GDPR) and Slovenian law.

This Privacy Policy explains how we collect, use, store, and protect your information when you use our website, contact us, or book a chauffeured transport service through us.

1. Who we are

Frankly Executive is a brand of DeNobilis d.o.o.

  • Registered office: Ferrarska ulica 5B, 6000 Koper, Slovenia

  • Company registration number (matična številka): 9672583000

  • Tax number (davčna številka): 91689198

  • Contact for privacy matters: info@franklyexecutive.com

References below to "we," "us," or "Frankly Executive" mean DeNobilis d.o.o.

2. What information we collect

When you visit our website, contact us, or place a booking, we may collect:

  • Full name

  • Email address

  • Phone number

  • Company name, where relevant

  • Pickup and drop-off details

  • Flight information

  • Booking preferences and special requests

  • Billing information

  • IP address and browser information when you use the website

  • Communication history with us

We only collect information that is necessary to provide and improve our service.

3. How we use your information

We use your information to:

  • Process and manage bookings

  • Deliver chauffeured ground transport services

  • Communicate with you about your booking or enquiry

  • Issue invoices and manage payments

  • Improve our website and service

  • Prevent fraud and misuse

  • Comply with legal and tax obligations

We do not sell your personal data to third parties.

4. Legal basis for processing

Under GDPR, we process personal data on the following legal bases:

  • Performance of a contract (Article 6(1)(b)): to arrange and deliver the transport service you have booked.

  • Legal obligation (Article 6(1)(c)): to comply with Slovenian tax, accounting, and record-keeping requirements.

  • Legitimate interest (Article 6(1)(f)): to communicate with prospective clients who have expressed interest in our service, to improve our website, and to prevent fraud.

  • Consent (Article 6(1)(a)): where you have specifically agreed to a particular use of your data, such as marketing communications.

5. Sharing information with chauffeurs and operators

To deliver your booking, we share the details necessary for the journey with the chauffeur or local operator assigned to it. This may include:

  • Passenger name

  • Pickup and drop-off location

  • Flight details

  • Contact information

  • Special requests related to the booking

Operators are required to handle this information confidentially and only for the purpose of completing the journey. Where an operator is based outside the European Economic Area (for example, in Switzerland or the United Kingdom), transfers are made under the safeguards required by GDPR.

6. Payments

Where payment is made by card, the transaction is processed by a third-party payment provider. We do not store full credit card numbers on our systems.

Payment providers may process billing information, card details, and transaction verification data, and are contractually required to handle it in accordance with applicable data protection and payment security standards, including PCI DSS where relevant.

Where payment is made by bank transfer against an invoice, we receive and store the transaction reference and the payer's details as required by Slovenian accounting law.

7. Cookies and analytics

Our website may use cookies and similar technologies to remember preferences, analyse traffic, and improve performance. We may also use website analytics tools to understand how visitors use the site in aggregate.

Where cookies are not strictly necessary for the site to function, we rely on your consent. You may disable non-essential cookies through your browser settings at any time.

8. Email communications and tracking

When we send emails, either in response to your enquiry or as part of outreach, the emails may include standard delivery and open-rate tracking used by our email service provider.

You may opt out of tracking or of receiving further emails at any time by using the unsubscribe link in the footer of any message, or by writing to info@franklyexecutive.com.

9. Data processors we work with

We use the following categories of third-party services to run our business:

  • Website hosting and forms: our website is hosted on Framer, which processes form submissions and website analytics on our behalf.

  • Email service provider: outbound emails and marketing communications are handled through an EU-based email service provider, which processes recipient addresses and delivery data.

  • Email hosting: business email at franklyexecutive.com is provided by a third-party email hosting service.

  • Payment providers: where card payment is offered, transactions are handled by a licensed payment provider.

  • Accounting and invoicing: invoice data is stored in accounting software required to meet Slovenian tax obligations.

Each of these providers acts as a processor under GDPR and is bound by a written agreement to handle your data only on our instructions and in accordance with data protection law.

10. Data retention

We retain personal data only for as long as necessary:

  • Booking and enquiry data: for the duration of the client relationship and for a reasonable period afterwards, to handle follow-up questions and repeat bookings.

  • Invoices and accounting records: for at least ten years, as required by Slovenian tax and accounting law.

  • Marketing contacts: until you unsubscribe or ask us to delete your data.

  • Website analytics: in aggregated, non-identifying form only.

When data is no longer required, it is securely deleted or anonymised.

11. Data security

We apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, disclosure, or alteration. This includes encrypted connections, access controls, and vetted service providers.

No online transmission or storage system can be guaranteed as 100% secure. Where a data breach affecting your rights occurs, we will notify you and the competent authority as required by GDPR.

12. Your rights

Under GDPR you have the right to:

  • Access the personal data we hold about you

  • Correct inaccurate or incomplete information

  • Request deletion of your data, where the law allows

  • Restrict or object to processing

  • Withdraw consent, where processing is based on consent

  • Receive a copy of your data in a portable format

  • Lodge a complaint with the Slovenian Information Commissioner (Informacijski pooblaščenec, www.ip-rs.si) or your local supervisory authority

Requests may be sent to info@franklyexecutive.com. We respond within one month, as required by GDPR.

13. International transfers

Where personal data is transferred outside the European Economic Area, for example to an operator in Switzerland or the United Kingdom, we rely on the safeguards permitted by GDPR, including adequacy decisions and standard contractual clauses.

14. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our service, the law, or best practice. The current version, with the "effective date" at the top, is always available on our website. Significant changes will be brought to your attention where reasonably possible.

15. Contact

For any privacy-related question or request, write to: