(updated on 24th August, 2022)
1. METHOD OF COLLECTION AND PROCESSING OF YOUR PERSONAL DATA
The Company seeks to collect personal data directly from the data subject. As a rule, this will be the case when we establish first contact and cooperation with you. However, in certain cases, collection of personal data directly from the data subject is not possible or is not an effective solution given the nature, legal basis and purposes of the data processing. Accordingly, the Company may collect and process your personal data provided by other parties. Other persons are, as a rule, Clients, i.e. entities with which the Company has a contract. Regardless of the way personal data are collected, the Company is focused on establishing and implementing appropriate mechanisms to enable the exercise of the rights of individuals regulated by the relevant laws.
When processing your personal data, the Company complies with the basic processing principles defined by the relevant laws. Accordingly, the Company strives for the processing of your personal data to be lawful, fair and transparent, and to be conducted solely to the extent necessary for the accomplishment of expressly specified and justified purposes. Considering the fact that the processing of personal data creates a number of obligations for the Company, the Company has an interest in processing the minimum of personal data necessary for the accomplishment of the purposes of the data processing within the deadlines justified by the purpose of the data processing. We strive to keep your personal data updated and accurate and in this regard we invite you to help us by pointing out the need to correct.
2. CATEGORIES OF DATA SUBJECTS COVERED BY THE DATA PROCESSING AND PURPOSES OF DATA PROCESSING
The Company processes the personal data of users of the Website for the purpose of enabling more efficient use of the Website, improving the business and performance of the Company and the Website.
3. PERSONS TO WHO WE DISCLOSE PERSONAL DATA
The basic policy of the Company from the aspect of sharing or exchange of personal data is to undertake the same only if it is necessary, in compliance with all the rules and obligations established by the relevant laws regarding such transfer.
In order to provide you with the best user experience, we may share your personal data with Our affiliates or business partners, which may also be marketing agencies, in order to constantly improve and strengthen our brand.
In accordance with our corporate social responsibility, we may be required to share your data with the following entities in accordance with relevant regulations:
Authorities and law enforcement agencies – Your personal data may be disclosed to representatives of the executive authority and/or law enforcement agencies, in proceedings to exercise your and/or the Company’s rights, if it is prescribed by law or necessary for the legal protection of the Company’s legitimate interests in accordance with the law.
To partners – In case of organizing and/or conducting joint programs, events or promotions with other companies on their websites or applications. In that case, the Company’s partner can use your personal data, only if the Company has implicitly obtained your consent for that purpose. If you do not want your personal data to be collected or shared with any company other than the Company, you can always opt out of participating in the relevant programs, promotions or events.
To advisors of a potential buyer – If at some point the business activities of the Company are sold or integrated with another company, your personal data in that case may be disclosed to the advisors of the Company and advisors of the potential buyer, as well as to new owners in the event of a possible sale.
Given that modern business conditions dictate the division of tasks and specialization, your data may be provided to entities that the Company hires to provide specialized services, i.e. whose applications and technologies the Company uses, including marketing service providers for the purpose of promoting the Company’s products and services, and to the extent that such delivery is necessary for the performance of the contract concluded with these subjects.
5. DATA TRANSFERS
We would like to inform you that the Company does not transfer personal data outside the borders of the Republic of Serbia, except for the information collected through third-party cookies that may be stored on servers outside the Republic of Serbia.
When considering the nature, legal basis and purposes of processing, the need for the transfer of personal data to other countries and international organizations arises, if such countries and international organizations do not provide an adequate level of protection in accordance with the relevant regulations, the Company will endeavor to provide implementation of appropriate personal data protection measures.
6. MEASURES FOR PROTECTION OF PERSONAL DATA
The Company is taking significant steps related to education of its employees and other involved persons on issues relevant to personal data protection. All persons involved in the processing of personal data carry out the processing on the basis of the authority given by the Company in which restrictions on access and processing of personal data, conditions and responsibilities regarding the processing of personal data are regulated. Accordingly, the need-to-know-basis principle applies within the Company. At the same time, all persons involved in the processing are obliged to keep the confidentiality of the data related to the processing.„need-to-know-basis“). . All persons involved in data processing are required to keep data safe.
In order to ensure compliance with relevant regulations, the Company has brought a number of internal procedures and acts applicable to the processing of personal data within the Company. The Company takes appropriate measures of physical and technical protection of personal data which prevents unauthorized access and processing of personal data, but at the same time protects the integrity of personal data. The personal data protection measures applied are tested by the Company in order to assess the need for improvement and modification of such measures.
7. EXERCISE OF THE RIGHTS OF DATA SUBJECTS
Internal procedures within the Company, as well as contracts concluded by the Company with other persons, have established mechanisms for enabling the exercise of the rights of persons whose personal data is processed. If the Company is not authorized to act on your request in a given case, it will be forwarded to an authorized person.
First of all, we inform you that we will act to the extent and in the manner prescribed by law; in certain cases, where the law prescribes our obligation to store your personal data in a certain way and in the state in which they are, we will refuse your requests, and such refusal will be explained.
Access to your personal data – You have the right to request access to your personal data. This also includes data on the following, as well as other relevant data exhaustively prescribed by the Personal Data Protection Act:
Complaint to a regulatory/supervisory authority – If you are not satisfied with the way we access and treat your rights, or our privacy principles set out in this document, you have the right to complain to the competent authority, in accordance with the laws (eg the Commissioner for Information of Public Importance in the case complaints regarding privacy principles).
Destruction of your personal data – If you no longer wish to use our products and services, or if you do not want us to have access to your personal data, you have the right to ask us to destroy all of your personal data from our systems. However, in the event of a legal obligation that we would have to comply with, we may be forced to refuse your requests or to store certain data.
Correction of your personal data – You have the right to be sure that your personal data is accurate and complete and to request its correction.
If you want to stop receiving marketing information about promotions, campaigns and other marketing communications, you can simply unsubscribe from our newsletter list.
Data portability – You have the right to request and receive a copy of your personal data.
Of course, the use of the form created by the Company is not binding on you, and if you think it is simpler and more efficient, you can submit the request in a free form, that is, in a way that you consider adequate.
8. CONTACT US
For all additional questions, especially for submission of the request for exercise of your rights arising from data processing, please contact us through the following contact data: