Dear visitors of the website, business premises of the Society and our clients,
DELTA – DOO BELGRADE (NOVI BELGRADE), ul. Vladimira Popovića 8A, floor: 8, 11070 Belgrade-Novi Beograd, MB: 20675071, PIB: 106758755 (hereinafter: “The Society”), hereby informs website visitors, visitors of the business premises and clients/potential clients Lični podaciof the Company or other person (hereinously marked together as: “Kient “) whose personal data is collected by the Company. The collection and storage of Personal Data is carried out in accordance with the Law on Personal Data Protection (“Official Gazette of the Republic of Serbia” No. 87/2018 – hereinafter: Zakon“Law”, as well as with the General Regulation of the EU Personal Data Protection Regulation (EU 2016/679, below: “GDP”, when applicable. In the case of processing of Personality Data of Clients who are citizens of one of the member states of the European Union, the Company will also apply the provisions of the GDPR, to the extent applicable.
The Company has published this Privacy Policy, in order to protect the privacy of each Client and to inform the Client that Personal Data The Company collects, for what purpose and on what basis it processes them, how the Data is protected and how they are collected, as well as what rights they are related to the Personal Data that the Client has.
You can contact the company regarding all questions regarding the protection of Personal Data at the e-mail address:mailto:gdpr@deltaholding.rs
Key definitions of the concepts from the Law on Personal Data Protection of the Republic of Serbia
“Personal Data” is any data relating to a natural person whose identity is determined or definable, directly or indirectly, specifically on the basis of the identity designation;
“Freedom of personal data” is any action or set of actions that are performed automated or unautomaticized with personal data or their sets, such as collection, recording, sorting, grouping, i.e. structuring, storing, comparing or changing, detecting, inspecting, use, transmission, or delivery, multiplication,
“Sensitive data” refers to data relating to racial or ethnic origin, political opinion, religious or philosophical beliefs, union membership, health, sex life or sexual orientation, genetic information, criminal record and biometric data used for the purpose of unique identification.
The company does not collect sensitive data of the Client unless you make it available voluntarily or if the Company is required to apply to this by applicable regulations.
“Personal data of children” applies to people under the age of 18.
The company does not collect data of children under the age of 18, and to this end it requires always the customer’s confirmation that he is 18 or older. A legal representative (parent or legal guardian) should not allow children to make their Personal Data available without his permission and consent.
Društvo ne prikuplja osetljive podatke Klijenta, osim ako ih Klijent ne učinite dostupnim dobrovoljno ili ako je Društvo na to obavezano važećim propisima.
„Lični podaci dece“ se odnose na osobe mlađe od 18 godina.
Društvo ne prikuplja podatke dece mlađe od 18 godina, te u tom cilju zahteva uvek potvrdu Klijenta da ima 18 ili više godina. Zakonski zastupnik (roditelj ili zakonski staratelj) ne treba da dozvoli deci da bez njegove dozvole i saglasnosti čine dostupnim svoje Podatke o ličnosti.
The personal data of the Client collected and processed by the Company includes:
1. Name and surname;
2. Email address;
3. The data contained in the text of the Client’s comments written in free form, if applicable.
Ways of Collecting Personal Data
Personal data is collected directly from the Client, as persons whose data is processed or by other persons.
1. Immediate collection of Personal Data from Clients whose data is processed
a) Providing services to the Client
In order for the Company to provide a service in a timely manner, for which the Client hired him, he needs to have the following Personal Data Kijente: Name and surname, e-mail address.
The Company processes Personal Data of the Legal Representative/Contact of Person/authorized Person at the Client on several grounds.
The Company processes Personal Data of the Client on the basis of the conclusion and execution of the contract or for taking actions, at the request of the Client, before the conclusion of the contract. Giving Personal Data of a Legal Representative/contact of a person/authorized person with the Client is a contractual obligation, i.e. Giving Personal Data is a necessary condition for the conclusion/enforcement of the contract, which is why the legal representative/contact person/authorized person at the Client has the obligation to disclose Personal Data to the employees of the Company. Otherwise, the Company will not be able to conclude and execute a specific contract.
In addition, in case the invoice is issued to the Society, the received invoice, which may contain personal data of the legal representative/authorized person of the Client, the Company will be kept in its databases, and in order to fulfill legal obligations (tax and bookkeeping regulations). In this case, Personal data from invoices are not processed individually, while invoices are kept for five years in the bases of the Company.
When Personal Data is processed on the basis of conclusion and execution of the contract or for the purpose of executing some action that is an integral part of the pre-contractual phase, the purpose of processing the Personal Data is to conclude a specific contract, i.e. the execution of the contract. Acts of execution of the contract often imply that Personal Data seems to be available to third parties, in order to fulfill the contract in full.
When Personal Data is processed on the basis of fulfillment of obligations, the Company shall use this data exclusively for the purpose of issuing a invoice or invoice, pursuant to the relevant regulations of the Republic of Serbia.
Further, when we process Personal Data on the basis of the Client’s consent, the Company shall in this case use Personal Data solely for the purposes of maintaining communication and reference to events, including the period after the termination of the specific contract. In this case, as is the basis of the processing, for the stated purposes, the consent of the Client, you need to keep in mind that you can revoke the consent at any time by sending the request to the e-mail address: gdpr@deltaholding.rs. The impeachment of consent does not affect the permissibility of the processing carried out on the basis of the consent before the impeachment.
When the Company processes the Personal Data of the Client on the basis of the concluded Contract, personal data is kept in its databases for five years. On the other hand, when processing Personal Data on the basis of consent, the Personal Data Company keeps in its database until the recall of the consent.
Data on the person that the Company processes in order to fulfill legal obligations, the Company keeps in the databases until the expiration of the deadline defined by the law (five years from the day of issuing invoice or invoice).
b) Visits Client to business premises of the company
Personal data is processed by the Client Company for the purpose of protecting property and general safety of persons located in the office premises of the Company, as well as the personal safety of the Client during the visit of our business premises, i.e. for the purpose of collecting data in case of extraordinary events (theft, property damage, etc.).
Accordingly, the Company processes the Client’s Personal Data on the basis of a legitimate interest consisting in the preservation of the safety of property and persons located in the business premises of the Company, i.e. in order to prevent extraordinary events or collect data in the event of extraordinary events.
Personal data – Name and surname, e-mail address, Company keeps in its database within a year, unless the event arises in which the court proceedings are initiated, in which case they are kept until the final completion of the proceedings, i.e. until the occurrence of limitations in accordance with the law.
After the aforementioned deadlines, the same will be deleted, i.e. destroyed.
c) Maintaining marketing and other promotional activities of the Company
During the promotion of the products of the Company and other promotional activities, the Company may collect the following Personal Data of the Client: Name and Sum and e-mail address, in order to inform the Client about all the news and benefits prepared by the Society.
The purpose of the processing of these Personal Data is to promote, marketing of the Company, as well as the annexation of Persons who buy products and services.
The above-mentioned Personal Data is stored in the Company’s database until the Client revokes the consent.
d) Visits and website use – www.deltapak.rs
When the Client visits and uses the Company’s website, Personal Data is also collected through cookies, which is more in the cookie policy document.
e) Application for newsletter
When applying for the newsletter, the Client gives consent to the Company to collect the following Personal Data of the Client: name and surname and email address.
The purpose of processing of the said Personal Data is to send notifications about special and personalized offers, news and events organized by the Society, Internet Promotions and other promotional activities.
The above-mentioned Personal Data is stored in the Company’s database until the Client revokes the consent.
f) Contacting employees in the Company
On occasions when the Client contacts (by phone or through our website or social networks) employees in the Company for answers to various queries regarding the products and services of the Company or leave a specific comment in the form of a free form of text, thus giving consent to the Company to collect the following Personal Data: name and surname, email address, as well as the content of the comments of the Client written in a free form.
The purpose of processing the said Personal Data is to establish communication with the Client, and for the purpose of giving a response to queries or to specify the request. Giving unreal Personal Data is a necessary condition for establishing communication between the Client and the Company. Otherwise, the company could not respond to the client’s inquiries.
2. Personality data submitted by other persons
There are cases when the Client may submit to the Company Personal Data of Third Persons, in which case the Company will consider that the Client for such treatment was authorized by such a person and in no case will the Company bear responsibility for the processing of data on the personality of a third party,
The Purpose of Collecting Data
The purpose of collecting data is:
– respect for legal obligations (law and by-law) of the company;
– the conclusion and execution of concluded contracts, as well as taking actions before the conclusion of the contract;
– protection of property and general safety of persons;
– Calling for events, realization and/or maintenance of communication and cooperation;
Legal basis for data processing and how data is collected
The legal basis of data processing, are:
– Consent Of The Client
The personal data of the Client obtained by the Company on the basis of the consent will be processed and stored as long as there is consent of the Client, i.e. until the eventual impeachment of the consent by the Client. Consent for collecting, processing and use of data Klient may be recalled at any time by sending an electronic request to the e-mail address: gdpr@deltaholding.rs
The impeachment of the consent does not affect the permissibility of processing of Personal Data performed on the basis of the consent of the Client before the recall.
– Execution of contractual obligations
The company collects the personal data it needs for the conclusion and execution of the contract with the Client and the fulfillment of pre-contractual obligations. If the Client does not provide us with the necessary Personal Data, the Company will not be able to process the request of Klinet or to conclude a contract with him.
– Legitimate interest
Society processes Personal Data for the purpose of preserving the legitimate interests of the Society. The legitimate interests of the Society in particular include the protection of property and general safety of persons..
– Respect for legal obligations
To the extent that the processing of Personal Data is necessary for the purpose of fulfilling the legal obligations of the Company, i.e. obligations defined by different laws, the Company processes and stores the Personal Data of the Client within the legal deadlines.
Recipient and third party
The Company reveals Personal Data to certain recipients, i.e. third parties, namely: related persons in the territory of the Republic of Serbia, employees, companies that perform the tasks of securing space, property and persons, legal service providers, IT service providers, external auditors, accounting and accounting agencies.
The Company shall not make the Client’s personal data available to other recipients, i.e. third parties, except in cases specified in this Privacy Policy, nor will personal data be transferred to other states.
The Period of Personal Data
– the data collected by the Company on the basis of the law as a legal basis is obliged to keep as much time as determined by a particular law or other positive regulation.
– the data collected by the Company on the basis of the contractual relationship is kept for five (5) years.
– data processed solely on the basis of the Client’s consent shall be kept until the omission of the dock.
– the data that the Company processes for the legitimate interest shall be kept permanently i.e. within 30 days – data on extraordinary events, unless the event occurs – due to which the court proceedings are initiated, in which case they are kept until the final conclusion of the proceedings, i.e. until the occurrence of limitations in accordance with the law.
The Right Client Regarding Personal Data Processing
The person to whom the Personal Data relates has the right:
– to require information from the Society about whether it processes its Personal Data and access to that data;
– to require the Company to correct, amend or delete its Personal Data and the right to object to processing;
– to file a complaint with the Commissioner for Information of Public Importance and Personal Data Protection;
– that his inaccurate data on personality without undue delay be corrected. Depending on the purpose of processing, the Client has the right to recharge his incomplete Personal Data, which includes giving additional statement;
– to limit the processing of Personality Data by the Company if one of the following cases is fulfilled:
1) The person to whom the data relates disputes the accuracy of the Personal Data, within the timeframe that allows the Company to verify the accuracy of the Personal Data;
2) The processing is illegal, and the person to whom the data relates is against the deletion of personal data and instead of deletion requires restriction of the use of Personal Data;
3) The company no longer needs Personal Data to achieve the purpose of processing, but the person to whom the data relates has requested them in order to submit, exercise or defend the legal request;
4) The person referred to the data has filed an objection to the processing in accordance with Article 37, paragraph 1. The law, and it is underway to assess whether the legal basis for processing prevails over the interests of the Persons.
The company shall notify all recipients to whom the Personal Data is disclosed on each correction or refueling or deletion of personal data or restriction of their processing in accordance with the Law, unless it is impossible or requires excessive expenditure of time and means. The company is obliged to inform the person to whom the data, at his request, about all recipients.
The person to whom the data relates has the right to receive his Personal Data, which he previously submitted to the Company from him in a structured, commonly used and electronically readable form, and has the right to transfer this data to another controller without interference by the controller to whom this data was submitted, in accordance with the Law.
If he considers this to be justified in relation to the special situation he is in, the Client to whom the data relates has the right to submit to the Company at any time the objection to the processing of his Personal Data, in accordance with the Law.
The client to whom the data relates has the right not to apply a decision made solely on the basis of automated processing, including profiling, if this decision produces legal consequences for that person or that decision significantly affects his position.
Procedure in case of personal data breach
If a violation of personal data may produce a high risk to the rights and freedoms of natural persons, the Company shall notify the person to the data subject to, in accordance with the Law without undue delay.
In case of violation of personal data that may produce a risk to the rights and freedoms of Clients, the Company is obliged to inform the Commissioner for Access to Information of Public Importance and Personal Data Protection without undue delay or, if possible, within 72 hours from the knowledge of the injury. The notification submitted to the competent authority contains all information in accordance with the Law.
Transfer of Personal Data to Other Countries
The transfer of Personal Data to another state or international organization without prior approval may be made if it is determined that the other state/international organization provides an appropriate level of personal data protection. In this regard, the Decision on the list of states, parts of their territories or one or more sectors of certain activities in those countries and international organizations in which it is considered that an appropriate level of personal data protection (“Official Gazette of RS”, No. 55/2019) (hereinafter referred to as “Decision”), it was established where it is considered to be an appropriate level of personal data protection. However, in this particular case, there is no transfer of data to other countries.
Links to Websites and Third-Party Services
The website of the Company may contain links to third-party websites. The client should keep in mind that the Company is not responsible for the collection, use, maintenance, share or disclosure of data and information by third parties. If the Client provides information on the pages of third parties and use those pages, the privacy rules and conditions of use of these third parties will be applicable. The company always recommends the client to read the privacy rules of the websites he visits before he sends Personal Data.
By clicking the LinkedIn, X, Facebook, Instagram, Tiktok or YouTube on the Company’s website, the Client accepts the possibility that the data on the website of the Society can be processed by the said social networks if it owns an account on them. In order to avoid this situation, the Company advises the Client to pre-review from his user accounts from the social networks concerned, and only then click on the link on the website of the Society visit the pages from the said social networks.
Data Confidentiality and Transparency
Client personal data will be treated as confidential information and the Company will take appropriate measures to protect them in accordance with the Law. They will only be accessed by persons who, in view of the job they perform, should be familiar with the Personal Data, and only in the scope that is necessary for the performance of their tasks.
This Privacy Policy is available on the website www.deltapak.rs
If we decide to change our Privacy Policy, the changes will be posted and posted on the website www.deltapak.rs