UPDATED: 3 November 2021
1. Who we are
GNUB d.o.o. Beograd-Stari Grad, with its seat at Kosovska Street no. 32, Belgrade, Serbia, registration number 21594482, e-mail [email protected] (“GNUB”, “Company”, “us”, “we”) is a company that operates website located at / (“Website”), whereby we process personal data. We process personal data, as a controller, in full compliance with the provisions and principles prescribed under the Law on Personal Data Protection (“Official Gazette of RS”, No. 87/2018) (“Law”), other laws and bylaws, and existing standards in the field of personal data protection.
We are committed to the protection of personal data, and we collect and process personal data in a fair and transparent manner. Personal data are collected and processed for specific, permitted purposes, while we process only personal data necessary to achieve the purpose of collection and processing. Personal data is kept to the extent necessary to achieve the purpose of processing and in accordance with regulations.
This Privacy Notice (“Notice”) applies to usage of the Website and any other website or service which we operate and references to this Notice. The Notice provides you with information regarding the purposes of personal data processing, the legal basis for the processing of personal data, your rights as data subjects, and other aspects of personal data protection. Please read this Notice to get know more about the types of personal information we collect and process, the purposes of processing, your rights, and other information contained in this Notice. In operating the Website, we apply measures to protect personal data from loss, destruction, damage, as well as from unauthorized access or illegal processing of personal data.
2. What personal data we collect and why we collect it, legal grounds and retention period
While we operate the Website and in order to meet our legal obligations, satisfy the interests of, complete contractual obligations, we process personal data such as name, IP addresses, e-mail addresses, telephone numbers and similar.
The purposes for collection and processing personal data are always clearly defined and we perform these activities in line with prescribed legal grounds such as the consent of a person that can be withdrawn at any time, our legitimate interest, for entering into and executing agreements and fulfilling the mandatory legal obligations we may have.
2.1 Visiting the Website
When you access the Website, we do not directly identify you. A visit of the Website provides information, which may be personal data, such as IP, the type of device you use to access the Website, the date and time of your visit to the Website, the browser you used and the operating system of your device.
The aforementioned data are collected for analytical purposes in order to detect numbers of visits to the Website and for security reasons, to detect or prevent malicious behavior or crime. The ground for this processing is our legitimate interest, which consists in providing proper functionality of the Website, its improvement and prevention of malicious behavior or crime, while this data is stored as long as necessary to achieve this purpose, and exceptionally longer if necessary for the purpose of fulfilling our legal obligations or for the purpose of filing, realizing or defending a legal claim.
2.2 Posting comments
As you are familiar with, we enabled you to post comments regarding the certain content published on the Website, while you determine the content of such comments. When you are posting comments on the Website, you are asked to provide personal data shown in the comments form which is your name and e-mail address, whereby it is your decision whether you will provide your actual name and e-mail address. In this process we also collect your IP address and information regarding your browser.
We collect the aforementioned personal data in order to enable this functionality of the Website to you. In addition, we may process said personal data based on our legitimate interest in order to detect and eliminate errors and technical problems that may arise in connection with the use of the Website and to prevent possible abuse, which includes removal of inappropriate content. These personal data is kept as long as necessary to achieve this purpose, and exceptionally longer if necessary for the purpose of fulfilling our legal obligations or for the purpose of filing, realizing or defending a legal claim.
2.3 Business relationship
If you contact us in connection with establishment of potential business cooperation, we may collect and processes personal data of individuals who are related to potential business partners, as well as when the potential business partners are individuals themselves. In these situations, we may process personal data such as name and surname, e-mail address, telephone number. The stated personal data are processed for the purpose of establishing a business relationship and the realization of the agreed business cooperation. The legal grounds for data processing for this purpose is to perform activities prior entering into agreements as well as the execution of such agreements. Personal data that are processed for the stated purpose, are kept until the stated purpose is achieved, but also longer in accordance with the mandatory regulations relating to our business.
2.4 Competitions or prize draws and giveaways
From time to time we may organize competitions or prize draws or giveaways through the Website.
For each prize draws or similar, we collect and process personal data such as your e-mail address, name of the account on social media networks, your address and similar. We collect and process said personal data for the purpose enabling you to participate in such activities, whereby legal basis for this personal data processing is fulfilment of obligations related to such activities.
Personal data collected in this manner are stored as long as necessary to achieve this purpose, and exceptionally longer if necessary for the purpose of fulfilling our legal obligations or for the purpose of filing, realizing or defending a legal claim.
We keep a record of traffic data which is logged automatically by our servers (both our web site servers and our ad serving technologies), such as your Internet Protocol (IP) address, device information, the website that you visited before ours and the website you visit after leaving our site. We also collect some site and service statistics such as access rates and page views. We are not able to identify any individual from traffic data or site statistics.
You may be able to configure your browser or our website or the websites of our partners to restrict cookies or block all cookies if you wish, however if you disable cookies, you may find this affects your ability to use certain parts of our website, or services. For more information about cookies and instructions on how to adjust your browser settings to accept, delete or reject cookies, see the www.youronlinechoices.co.uk website.
On the Website, there may be targeting or advertising cookies that are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertisers, advertising agencies or ad servicing technologies. They remember that you have visited the Website and this information is shared with other organizations such as advertisers. You can decide whether these cookies will be used or not. For more information about cookies and instructions on how to adjust your browser settings to accept, delete or reject cookies, see the www.youronlinechoices.co.uk website.
There are cookies that are stored for the purpose of analytics. Analytics are intended to help us understand how visitors use our Website to help improve our services. We use third party tools that create cookies and store necessary technical information. To opt-out of Google Analytics storing data in cookies when you visit our Website please visit this page. We also use Alexa Certified Site Metrics for analytical purposes. Click here to opt out of Alexa Certified Site Metrics.
2.6 Third-party content
The content of the Website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
On the Website you may find links to third-party websites that have their own rules regarding the protection of personal data that you can get familiar with on third-party websites, whereby we are not responsible for them.
3. Data processing based on our legitimate interest
We may from time-to-time process personal data for the purpose of achieving our goals based on our legitimate interest and only if our legitimate interest outweighs your interests, rights, and freedoms.We process personal data based on our legitimate interest due to:
- business improvement, upgrading and development of new and existing services and products;
- business protection;
- prevention of fraud;
- ensuring data security;
- securing our users and preventing abuse.
4. Data Processors
In carrying out our activities, we may cooperate with third parties to whom we may provide personal data for processing. Before cooperating with the processors, we assured that these are entities which meet the requirements in terms of appropriate technical, organizational and personnel measures, so that they meet the requirements that data processing is performed in accordance with regulations, and that personal data is secure. If we engage data processors, we conclude contracts with such processors in accordance with the regulations.
We may provide your personal data with:
- our employees;
- accounting agencies;
- third parties which process information on our behalf (e.g. internet service and platform providers, advertising agencies, agency trading desks, supply side platforms and data management platforms) so that they may help us to provide you with the products, services and information you have requested or which we believe is of interest to you;
- third parties where you have a relationship with that third party and you have consented to us sending information (for example social media sites or other third party application providers);
- third parties for marketing purposes (e.g. our partners and other third parties with whom we work and whose products or services we think will interest you);
- law enforcement agencies so that they may detect or prevent crime or prosecute offenders;
- any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order);
- another organization if we sell or buy (or negotiate to sell or buy) any business or assets;
- Government departments where reporting is mandatory under applicable law.
Recipients receive personal data under the conditions of prescribed organizational and technical measures and procedures, where they are obliged by agreements on confidentiality and data protection, except when such obligations arise from mandatory legal provisions.
6. Personal data transfer
Personal data in the European Union is protected by data protection laws but other countries do not necessarily protect your personal data in the same manner. The Website may also be hosted outside of the EEA (which means all the EU countries plus Norway, Iceland and Liechtenstein) (“EEA”) and this means that we may transfer any information which is submitted by you through the Website outside the EEA.
We may use service providers based outside of the EEA to help us provide our Website and services to you and this means that we may transfer your information to service providers outside the EEA for the purpose of providing our advertising and services to you.
We take steps to ensure that where your information is transferred outside of the EEA by our service providers and hosting providers, appropriate measures and controls are in place to protect that information in accordance with applicable data protection laws and regulations. In each case, such transfers are made in accordance with the requirements of Regulations (EU) 2016/679 (the General Data Protection Regulations or “GDPR”) and may be based on the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA.
7. Your rights
If you are based within the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:7.1 Right to access
You have the right at any time to ask us for information on whether we process your personal data, access to that data, as well as other information prescribed by applicable law.7.2 Right to correct
You have the right to ask us to correct your incorrect personal data without undue delay. Depending on the purpose of the processing, you can supplement your incomplete personal data, which includes giving an additional statement.7.3 Right of deletion
You have the right to ask us to delete your personal data, and we will delete such personal data without undue delay in the situations prescribed by applicable law.7.4 Right to limit processing
You have the right to require us to restrict the processing of personal data if conditions prescribed by applicable law are met.7.5 Right to transfer
You have the right, in accordance with applicable law, to receive your personal data that you have previously provided to us from us in a structured, commonly used and electronically readable form and you have the right to transfer this data to another controller without our interference, if conditions defined under the applicable law are met.7.6 Right to object
If you believe that this is justified in relation to the special situation in which you find yourself (for example, in situations where you are in danger), you have the right to object to us at any time for the processing of your personal data under conditions prescribed by applicable law.7.7 Right to notification in case of the personal data breach
In the event of a personal data breach, we will notify you without undue delay of the violation, if the personal data breach may pose a high risk to your rights and freedoms, with such notification stating at least the name and contact details of the person for the protection of personal data within our organization or information on other means of obtaining information about the injury, a description of the possible consequences of the injury, a description of the measures we have taken or proposed to take in relation to the injury, including measures taken to mitigate harmful consequences.7.8 Right to file a complaint
You have the right to lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection in accordance with the Law.
8. Automated decision making
Please note that some data (such as the type of Internet browser you use, the number of visits, the average time spent on the site, the content viewed, etc.) are processed automatically when accessing the Website. The above data is used for the purpose of improving the Website. Please note that you have the right not to be subject to a decision based solely on automated processing, unless such a decision is required under the conditions set out in the applicable law.
9. Our contact details
In connection with the exercise of your rights in accordance with the Law, you can contact us in writing at the address Kosovska 32/2/4, Republic of Serbia, via the e-mail address [email protected]
10. Notice amendments
We may from time to time amend and/or supplement this Notice which can be found on the Website.