I – NOTICE ON COLLECTION AND PROCESSING OF PERSONAL DATA AND GENERAL NOTES
In order to protect your privacy, the Company implements certain technical, organizational and personnel-related measures, and constantly works on their improvement to make sure that your data is handled in accordance with applicable regulations and your consent (when such consent is required by law). With regards to that, the Company may occasionally change and improve these Rules, in which case an updated version will be available on the website, with a clearly stated starting date of application. While visiting our websites, we invite you to check whether the Rules were changed since your last visit, and if so to familiarize yourself with contents of the new Rules. If you do not agree with new regulations, we ask you to refrain from using our websites and from submitting your personal data in any way, i.e. to rescind your consent for personal data processing in accordance with the Rules.
You can reach the currently valid Rules by following the link at the bottom of our websites whenever you have internet access. By continuing to use our website it is implied that you have read and understood the currently valid Rules, and that you have agreed to its application afterwards.
Regulations of the Republic of Serbia apply to these Rules and its potential changes and additions.
II – HANDLER DATA
The identity and contact information of the Handler, i.e. legal person responsible for managing your data, is defined in this article.
Your data Handler is: Vladimir Mijin
Business name: KOV TECHNOLOGY LLC BELGRADE
Office address: Živojina Žujovića st. 14, 11120 Belgrade- Zvezdara, Republic of Serbia
ID number: 21151335
Tax ID: 109262399
Activity code: 6202 – Consulting activities in the field of information technology
Contact information of the Handler for realizing rights to personal data protection:
KOV TECHNOLOGY LLC BELGRADE
Živojina Žujovića st. 14, 11120 Belgrade- Zvezdara, Republic of Serbia
Working hours: Monday to Friday from 9:00h to 17:00h
Phone: +381 11 4072 229
III – METHODS OF DATA COLLECTION
We collect your personal data in following ways:
- Directly from you, when you submit your data to us. For example, when you contact us by mail, email, or by phone, and/or
- Automatically, while using our websites, in which case we, or our third party partners in our name, use so-called “cookie” technology to adequately present content and to follow the amount of visits and movement on our pages, etc. (hereinafter – “cookie”). We ask you read more information on our “cookie” usage in a special section of these Rules.
IV – DATA PROCESSED BY THE HANDLER, METHOD AND BASIS OF USAGE
The Company collects data that is appropriate, important and limited to what is necessary in relation to the specific purpose of processing.
We use or may use your data to achieve several purposes predetermined by these Rules. For each processing there is an adequate basis determined by the Law on Personal Data protection and other laws of the Republic of Serbia.
The data we collect directly may be compared and combined with the data collected automatically, and in that way the data collected as anonymous (e.g. the frequency of visit to specific content on our website) may become personal data (e.g. how often you visit certain content on our website). This allows us to provide you with a personalized experience during your visit to our website.
Also, certain data may become anonymous and used for statistic and analytic purposes, without direct or indirect identification of individuals related to the data. In that way, for example, we may reach the data on percentage of visitors who have viewed certain video material or who have visited other content on the website.
The Company processes or may process some or all data stated herein. We constantly work on the development of the website and improvement of available services, which may result in processing of certain following data starting later, as functionalities of the website increase. Also, the scope of the data we process depends, for example, on your method or manner of contact, or the method you use the website.
|Processed data||Purpose of processing||Legal basis of processing|
|Name, surname, email and/or mailing address (place of residence, postal code, street, house number), and/or phone number||Communication with you – answering all your questions and requests sent to us via contact form on the website or other communication channels (email or regular mail or telephone)||Our legitimate interest to manage the user service and to adequately answer users’ questions and requests|
|Username, email address and password for your profile on the website||Creating a user profile on the website which enables electronic purchase and sale of products||Our legitimate interest to provide personalized user experience, or concluding a contract of sale at your request|
|Name, surname, contact information (mailing address – place of residence, postal code, street and house number, and/or email address, and/or phone number), information on a purchased product, date of purchase, method of resolving a complaint||Resolving a complaint in relation to the conformity of a product purchased through the online shop on the website||Adherence to our legal obligations of customer protection|
|Data on chosen settings for displaying the website||Providing website functionality with regard to temporarily “remembering” the chosen content display settings of the website||Our legitimate interest to ensure that visitors of the website receive the website contents in their chosen language during each visit within a certain time period (usually during one day)|
|Identification data of your device which you use to access the website (so-called Unique Device Identifier), the type of the device (computer, tablet, smartphone), IP address of the device, operating system of the device, and the browser used to access the website||Technical administration of the website and ensuring that the website content is displayed optimally on the device you are using||Our legitimate interest to ensure adequate usage of the website in accordance with technical functionalities of the website, and to display it in the most optimal manner|
|Information on the manner in which you use websites (for example, which pages within the website you have visited, how many times and when you have logged in, which contents you have clicked on, etc.)||Understanding tendencies and interests of visitors of the website, improvement of user experience and development of the website, our products and services, statistical and analytical purposes||Your consent|
|Information on online marketing contents you have accessed before accessing the website||Determining trends and development of the website, our products and services, statistical and analytical purposes||Your consent|
You can find further information on the data we automatically collect through “cookies” in a special section of these Rules.
If a need to process your data for a purpose other than the one for which the data is collected subsequently appears, the Company will, before continuing with processing, provide you with information about the other purpose, as well as other important information in accordance with the law.
Although the Company will never collect or process data on minors intentionally or with a purpose, we cannot exclude the possibility of receiving false information by the persons contacting us. If you are a parent or a legal representative of a minor and you know that we have received information of that minor, we ask you to inform us about it immediately so that we can take necessary steps and terminate further processing of the information.
V – „COOKIES“
Our website uses “cookies” in order to ensure the best user experience. They allow us, for example, to display website content in an adequate way on your every device or web browser through which you access it, or to adjust the content we place on the website to your interests. Information that we collect in such a way may be personal data in some cases, but not necessarily. Since the Company respects your privacy, in this section we want to explain what “cookies” are and how we use them, as well as to point out that in some case you may change how we use “cookies”, in relation to your website use. When the website gives you the option to not choose or turn off certain “cookies” and you select that option that may reduce the website’s functionality. Also, keep in mind that you will have to turn off the settings of your choice for each device or web browser individually.
Cookies are simple text files that are saved in the user’s web browser, i.e. on their device. The task of “cookies” is primarily to enable a website to “recognize” a user when they access it next time. In that case, the website uses data saved in a “cookie” and automatically receives information about previous user’s activity on the website. Cookies cannot access your data that you have saved on your devices, but they can collect information on your online activities.
Cookies are not harmful for the user or their device and they should not be confused with viruses. Cookies do not contain viruses or any other malicious code.
Depending on how long they stay in the user’s web browser, we differentiate “cookie” sessions (they exist only during a specific browsing session and are automatically deleted after the session is done, and they are used to enable you access to specific content) or permanent “cookies” (for a longer or shorter period they “remember” information for future visits to the website, they are kept until you delete them manually or until their specified time period expires, for example “cookies” that enable a website to “remember” login data in case of account creation, or tracking “cookies”).
By ownership, there are first-party “cookies” (“cookies” created by the Company as the owner of the website you are browsing) and third-party “cookies” (“cookies” created by our chosen partner companies that provide us with various services, e.g. analytics because they collect and process certain data on website usage and deliver us information in anonymous form, or these “cookies” enable their websites or other locations on the internet to display related content).
“Cookies“ may contain different information used for different purposes. The Company uses the following types of “cookies”:
- STATISTICAL – Analytics cookies – statistical cookies help website owners through anonymous collection and sending of data to realize how visitors communicate with the website. These cookies provide the Company with web analytics, i.e. analysis of usage of our websites and tracking attendance, which the Company implements to improve quality and content of offered services. Analytics cookies help us with collection of statistical data and creation of website usage report.
- MARKETING – Marketing cookies – Marketing cookies are used to track visitors through web pages. They are used to display relevant ads to users and to encourage participation, which is important for third-party publishers and advertisers. We use Marketing cookies to place relevant and adequate material that you receive during our marketing campaigns.
|Google Chrome||Prevent installation and delete existing cookies||Serbian||https://support.google.com/chrome/answer/95647?hl=sr|
|Firefox||Prevent installation of cookies||Serbian||https://support.mozilla.org/sr/kb/omogucavanje-i-onemogucavanje-kolacica|
|Firefox||Delete existing cookies||Serbian||https://support.mozilla.org/sr/kb/brisae-kolachi?redirectlocale=en-US&redirectslug=delete-cookies-remove-info-websites-stored|
|Internet Explorer||Prevent installation and delete existing cookies||Serbian||https://support.microsoft.com/sr-latn-rs/help/17442/windows-internet-explorer-delete-manage-cookies|
|Safari||Prevent installation and delete existing cookies||English||https://help.apple.com/safari/mac/8.0/#/sfri11471|
VI – PROFILING
Profiling is a form of automatic processing of data used to evaluate certain personality traits, especially for analysis or prediction of personal tendencies, interests, behaviors, etc. Cookie profiling or web profiling includes the use to permanent cookies for tracking online activities of a user. Based on such information we can profile visitors of the website and/or users of our products, in order to adjust our content communication accordingly.
VII – DATA NOT PROCESSED BY THE COMPANY
The Company does not collect and process special types of personal data, such as the data related to racial or ethnic origin, political opinion, religious or philosophical beliefs or syndicate membership, genetic data, biometric data for unique facial identification, health data or sexual life or sexual orientation data, as well as data related to criminal convictions, criminal offences and security measures.
We ask you not to disclose or send such data to us.
VIII – OBLIGATION TO PROVIDE DATA
In most cases, you are not obliged to provide us with your data, and instead you are doing so voluntarily. For example, that will be the case when you contact us and deliver your contact information so that we can answer your question or request, or when you use our website.
In some cases there can be an obligation to provide your data. For example, electronic sale of our products will require that you provide us with your data for the purpose of performing a contract, or during submission of a complaint so that we can process it in accordance with the law. Also, data collection on geographic location via GPS technology is necessary to provide roadside assistance service, since without such data this service is impossible to provide.
IX – PERSONAL DATA RECEIVERS
Your data is processed and used primarily by the Company.
Also, in certain legal situations, there may be a legal obligation to make your data available to responsible authorities (e.g. court or prosecutor’s office, etc.).
X – TRANSFER OF DATA ABROAD
Your data is used on the territory of the Republic of Serbia.
Additionally, the data which we collect is saved on servers located in the Netherlands / Germany / Republic of Serbia, and which is in ownership and under control of a domestic / foreign hosting company (alternatively: foreign / domestic hosting company Mainstream LLC Belgrade, Studentski Trg st. 4, 11000 Belgrade, ID number: 20076682, Tax ID: 104037252). In accordance with the hosting company’s policy, a high degree of technical and software protection of the servers is ensured, while access to the data saved on them is not allowed.
If your data needs to be made available to receivers in countries which are under suspicion that they do not provide adequate levels of protection of personal data, we will provide an appropriate basis for such transfer, including possible application of adequate standard contractual clauses constructed by the competent supervising authority, i.e. other appropriate security measures, which will make the receiver obliged to protect your data in a way which is in accordance with protection standards determined by regulations of the Republic of Serbia.
XI – METHOD AND PERIOD OF DATA SAVING
Your data is saved only for the period necessary to achieve the purpose for which such data is collected, after which they will be safely removed from our systems and deleted.
By regulation, your data related to these Rules will be kept for two years, except for when we are obliged by provisions to keep the data for a longer or shorter period, or when “cookies” are in question (more information on “cookies” can be found in a special section of these Rules)
XII – YOUR RIGHTS RELATED TO DATA PROCESSING – How is data we collect deleted?
It is important for us that you know that under certain circumstances you have rights related to processing of your data, guaranteed by the law:
Right of access – you have a right to demand information on whether we are processing your personal data, as well as access to such data. At your request, we will deliver a copy of your processed data.
Right of correction and amendment – you have a right to correct the invalid data related to you without unnecessary delay, as well as to amend incomplete data, which includes providing an additional statement.
Right to delete data – you have a right to request deletion of your data, especially:
- if the data is no longer necessary to achieve the purpose for which they are collected or otherwise processed;
- if you have cancelled your consent based on which processing was taking place, and there are no other legal bases for processing;
- if you have submitted a complaint for processing in accordance with the law.
Right to limit processing – you have a right to limit processing of your data if one of the following cases is met:
- if you deny the correctness of the data, in a period which allows us to check the correctness of personal data
- if the processing is illegal, and you object deletion of personal data and request limitation of data use instead of deletion;
- if we no longer need personal data to achieve processing purposes, but you require them for the purpose of submission, realization and defense of a legal request.
- If you have submitted a processing complaint performed based on the handler’s legitimate interest, and if there is an assessment of whether the legal basis for processing by the company takes precedence over your interests.
Right to object – if you believe it justified based on a specific situation you are in, you have a right to submit at any time an objection to the processing of your personal data performed based on the handler’s legitimate interest, including profiling based on such provisions.
Right to data transferability – you have a right to request the personal data you have previously delivered to us in a structured, widely used and electronically readable form, and a right to transfer this data to another handler without interference, if the processing is based on a consent or a contract and if it is performed automatically. Additionally, you have a right to have this data directly transferred to another handler, if that is technically possible
Right to cancel consent – if the processing is performed based on your consent, you have a right to cancel your consent at any time, taking into consideration that consent cancellation does not affect admissibility of consent-based processing prior to cancellation.
Right to submit a complaint – you have a right to submit a complaint related to processing of your personal data with the Commissioner for Information of Public Importance and Personal Data Protection, whose contact details are:
Commissioner for Information of Public Importance and Personal Data Protection
Bulevar kralja Aleksandra 15, Belgrade 11120
Working hours: Monday to Friday from 7:30h to 15:30h
Phone: +38111 3408 900
Fax: +38111 3343 379
XII – SAFETY OF YOUR DATA – abuse – or available access
The safety of your data is very important to us. That is why the Company takes measures of physical, technical and electronic protection in order to prevent accidental or illegal destruction, loss, amendments, unauthorized disclosure or access to personal data. These measures are aimed at persons outside of our organization as well as at persons inside it, since access to you data is limited only to those persons whose duties require such access and who are familiar with the law on personal data protection.
Unfortunately, there are no impenetrable security systems, so we cannot guarantee that the safety of systems under our direct control will never be compromised. In case of violation of personal data we will take all available measures and inform responsible authorities in accordance with regulations, as well as individuals whose data is in question, if possible.
XIV – VALIDITY OF RULES
These Rules shall enter into force on the eighth day from the day of their publication on the Company’s website.
After these Rules enter into force, the previous Rules on Personal Data Protection will become invalid.
In Belgrade, on October 5th, 2020
Published on October 13th, 2020
Start of application on October 13th, 2020
KOV TECHNOLOGY LLC BELGRADE
Vladimir Šijaković, Director