Privacy protection and cookie policy

Privacy protection and cookie policy

1. Overview
Promedia d.o.o. processes your information when you visit this website. On this occasion, various data are exchanged between your device and our server, which can be personal data. The data collected in this way is, among other things, used to optimize our website or for the purpose of displaying advertisements in the browser of your device.

2. Visit our website
Purpose of data processing / legal basis:
When you visit our website, the browser you use on your device will automatically and without your activity send to the server of our website:
– IP address of the device from which the request was sent and which has Internet access,
– date and time of access,
– name and URL of the downloaded file,
– website / application from which it is accessed (referrer URL),
– the browser you are using and, if necessary, the computer operating system that supports the Internet, as well as the name of your provider.
The server temporarily stores the specified data in a so-called log file for the following purposes:
– ensuring the establishment of a smooth connection,
– providing comfortable use of our website / application,
– assessment of system security and stability.
If you have accepted the so-called in your browser, operating system or other settings of your device. geolocation, we use this feature to offer you individual services based on your current location (for example, the location of the nearest store). We process information about your location solely for the stated purpose.
The legal basis for IP address processing is Article 12, paragraph 1, item 6) of the Law on Personal Data Protection (legitimate interest). Our legitimate interest arises from the above stated purposes of data processing.
Recipients / recipient categories:
We do not transfer this information to third parties.
Retention period / criteria for determining the retention period:
The data is stored temporarily during the visit to the page, and then deleted automatically. After you leave our website, the geolocation data is deleted.

3. Contact form / contact by email / phone call
Purpose of data processing / legal basis:
We treat confidential personal data, which you provide to us via the contact form, by phone or by e-mail. We process your data exclusively in accordance with the established purpose, and in order to respond to your inquiry. The legal basis for data processing is Article 12, paragraph 1, item 6) of the Law on Personal Data Protection (legitimate interest). Our and at the same time your (legitimate) interest in such data processing stems from the need to answer your questions, if necessary to solve existing problems and to ensure your satisfaction as our customer or as a user of our website.
If you participate in any of our surveys, such participation is voluntary. In anonymous surveys, we do not store data that allows us to conclude who the participant in the survey is. We only keep the date and time of your participation. We consider any personal data that you have given us through the survey to have been voluntarily provided and to keep them in accordance with the provisions of the Personal Data Protection Act. Please do not enter names or similar information in the free fields, which would allow us to conclude who it is, whether it is about you or other persons. In case you have given your consent to conduct the survey, the legal basis for data processing is based on your consent in accordance with Article 12, paragraph 1, item 1) of the Law on Personal Data Protection. In that case, you have the right to revoke your consent at any time. Revocation of consent does not affect the admissibility of processing carried out on the basis of consent prior to revocation. Details on the processing of data related to surveys are regulated by the data protection rules of each individual survey.
Recipients / recipient categories:
The data obtained is used only for our needs, we do not pass this data to third parties, unless you have given us your express consent.
Retention period / criteria for determining the retention period:
All personal data that you provide to us (suggestions, compliments or criticisms, job applications) via this website or via e-mail, are deleted or anonymized no later than 90 days after the final response.

4. Data processing of business partners
The following notes regarding data processing apply to you if you have contacted us, if you are negotiating with us for the purpose of concluding a contract and / or you have already concluded a contract with us and if personal data are processed in this regard.
Which data is processed in an individual case depends primarily on the contracted services, for that reason not all parts of this section will be relevant to you.
How do we collect your data and what categories of data do we process?
We generally collect data directly from you.
However, we may also collect data from other companies, government agencies or third parties, e.g. credit bureau, tax administration, APR, etc.
We can process the following personal data: personal data (eg name and surname, address and other contact data, date and place of birth, as well as citizenship), identification and authentication data (eg business register excerpt, ID card data, example signatures), data regarding our business relationship (eg payment data, order data), creditworthiness data, company structure and ownership structure data, photographs and videos (eg when delivering goods), as well as other similar data with the above categories of data.
You always have the choice, to decide whether to communicate with us by e-mail or by mail.
Purpose and legal basis of data processing
Processing for the purpose of fulfilling contractual obligations (Article 12, paragraph 1, item 2) of the Law on Personal Data Protection)
Data are processed for the preparation of the conclusion of the contract, which precedes the contractual relationship as well as for the purpose of fulfilling obligations after the conclusion of the contract.
Processing for the purpose of fulfilling legal obligations (Article 12, paragraph 1, item 3) of the Law on Personal Data Protection)
The purpose of data processing derives, depending on the individual case, from legal regulations. Thus, for example, data are processed for the purpose of fulfilling the obligations of keeping documentation and in connection with identification, e.g. on the basis of regulations for the prevention of money laundering, on the basis of tax control and reporting and data processing within the inquiries of state bodies.
Processing for the purpose of fulfilling legitimate interests (Article 12, paragraph 1, item 6) of the Law on Personal Data Protection)
There may be a need for the personal data you have made available to be processed in a framework that goes beyond the original performance of the contract. Our legitimate interests for such processing are the selection of an appropriate business partner, fulfillment of legal requirements, elimination of liability requirements, access control, clarification of possible violations, prevention of criminal offenses and processing of damages arising from the contractual relationship.
In the case of concluding a contract, in order to fulfill the above legitimate interests, in individual cases, we collect information about your creditworthiness through a credit bureau. We process the creditworthiness data, which we received from the credit bureau, in order to check your creditworthiness. The credit bureau keeps data, which e.g. they receive from banks or companies. These data include, above all, last name, first name, date of birth, addresses and information on the payment history. You can get information about the stored data that applies to you directly from the credit bureau.
Who has access to your data?
Within our company, access to the data, which you have made available to us, has only those sectors to which they are necessary for the fulfillment of contractual or legal obligations or for the purpose of fulfilling legitimate interests. As part of the contractual relationship, we hire other service providers, who may gain access to your personal information. Compliance with the regulations on the protection of personal data in these cases is provided by the contract.
How long do we keep your data?

We store personal data as long as necessary to fulfill the above purposes. In doing so, we take into account the legal obligations of custody, in accordance with the Law on Accounting.
Are you obliged to provide us with your data?
Within our business relationship, you are obliged to provide us with those personal data, which are necessary for the beginning, implementation and termination of the contractual relationship and for the fulfillment of obligations related to it, as well as for the collection of which we have a legal obligation or right based on legitimate interest. Without this information, as a rule, we will not be able to start a business relationship with you.
What rights do you have as a data subject?
You have the right, on request and free of charge, to receive information about your data that we process. In addition, in accordance with legal requirements, you have the right to correct and delete your data, the right to data portability, as well as the right to limit processing. If we process your personal data on the basis of consent, you have the right to revoke that consent at any time. Revocation of consent does not affect the admissibility of processing carried out on the basis of consent prior to revocation. In these cases, please contact us in writing or by e-mail at the address below of our data protection officer. Additionally, if you do not agree with the processing of your personal data, you have the opportunity to lodge a complaint with a public authority (Commissioner for Information of Public Importance and Personal Data Protection).
Responsible person (operator)

These rules on personal data protection refer to the website www.proready.rs, and the person responsible for the processing of your data or data controller is the company with which you have planned or have a business relationship, and in this case it is Promedia doo, Kralja Petra I 114, 23300 Kikinda, office@promedia.rs

Do you have additional questions?

Our person in charge of personal data protection is at your disposal at the following address:
Ivana Stojković, Legal Affairs Manager, Promedia d.o.o. Kikinda, Kralja Petra I 114, 23000 Kikinda, e-mail: ivana.stojkovic@promedia.rs

5. Internet presence and website optimization
5.1 Cookies – General information
On our website, we use so-called cookies in accordance with Article 12, paragraph 1, item 6) of the Law on Personal Data Protection (legitimate interest). We believe that the interest in optimizing our website is justified in terms of the above provision. Cookies are small files that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our website. Cookies do not harm your device, do not contain viruses, trojans or other malicious software. Cookies store information obtained about the device you are using. However, that does not mean that we are aware of your identity. On the one hand, the use of cookies serves to make your visit to the website more pleasant. For example, we use so-called session cookies to recognize that you have already visited certain parts of our site or that you are already logged in to your user account. They are automatically deleted after you leave our website. In addition, we use temporary cookies that are stored on your device for a certain period of time. When you revisit our website, it is automatically recognized that you have already been to the page and what settings you have made, so you will not have to repeat these actions.
On the other hand, we use cookies to statistically record the use of our website, in order to optimize the offer and display information that is tailored to your interests. These cookies allow us to automatically recognize you when you visit our website again. These cookies are automatically deleted after a certain time. Most browsers automatically accept cookies. However, you can set your browser so that cookies are not stored on your computer or if a message always appears before a new cookie is created. However, completely disabling cookies may mean that you cannot use all the features of our website.
For more detailed information about the cookies we use (type, retention period, possibility of objections) you can find in the section on cookie rules.

5.2 Google Analytics
Purpose of data processing / legal basis:
For the purpose of customizing the design and continuous improvement of our website, we use the so-called Google Analytics – a web analytics service provided by Google Inc. (“Google”), and in accordance with Article 12, paragraph 1, item 6) of the Law on Personal Data Protection (legitimate interest). Our legitimate interest arises from the purpose described. In this context, pseudonymized user profiles are created and cookies are used. Cookies generate the following information about your use of this website:
– browser type / version,
– operating system used,
– referrer URL (previously visited page),
– hostname of the computer from which it is accessed (IP address),
– server query time.
The data is used to evaluate the use of our website, to compile reports on activities on the site and to provide other services related to the use of the site and the use of the Internet. The data is processed for the purpose of market research and customization of this website. IP addresses are anonymized, so it is not possible to establish identity (so-called IP masking).
You can prevent the installation of cookies in your browser settings. However, please note that not all features of this page can be fully used in this case. Additionally, you can prevent the collection of data by cookies relating to your use of the site (including your IP address) and the processing of such data by Google by downloading and installing the Browser-Add-on. Alternatively or in addition to Browser-Add, especially for browsers on mobile devices, you can prevent data collection by Google Analytics by clicking on this link. Selecting this option will set an opt-out opt-out cookie, which will prevent further collection of your data when visiting this website. The opt-out cookie is valid only for the browser where it is installed and only for our site and will be saved on your device. If you delete cookies in that browser, you must set your opt-out cookie again. For more information about Google Analytics data protection, visit the Google Analytics website.
Recipients / recipient categories:
The information collected through cookies is sent to a Google server in the USA and stored there. Under no circumstances will your IP address be linked to other Google data. This information may be transferred to third parties in the event of a legal obligation or if a third party processes this information on order.
Retention period / criteria for determining the retention period:
After anonymizing your IP address, your identity can no longer be determined. Statistically processed data is deleted in Google Analytics after 14 months. There is no longer a personal reference in the generated Google Analytics reports.

6. Your rights
6.1 Overview
In addition to the right to revoke your consent, if the legal requirements are met, you have the following rights:
– the right to information about your personal data that we process, in accordance with Article 26 of the Law on Personal Data Protection,
– the right to correct inaccurate or incomplete data, in accordance with Article 29 of the Law on Personal Data Protection,
– the right to delete your stored data, in accordance with Article 30 of the Law on Personal Data Protection,
– the right to restrict data processing, in accordance with Article 31 of the Law on Personal Data Protection,
– the right to data portability, in accordance with Article 36 of the Law on Personal Data Protection,
– the right to object, in accordance with Article 37 of the Law on Personal Data Protection.

6.2 The right to information in accordance with Article 26 of the Law on Personal Data Protection
In accordance with Article 26 of the Law on Personal Data Protection, you have the right to request from us free of charge information on whether we process your personal data, access to such data, as well as information:
– on the purpose of processing;
– on the types of personal data that are processed;
– the recipients or types of recipients to whom personal data have been or will be disclosed, and in particular recipients in other countries or international organizations;
– on the envisaged period of keeping personal data, or if that is not possible, on the criteria for determining that period;
– the existence of the right to request from the controller the correction or deletion of personal data, the right to restrict processing and the right to object to processing, o the right to file a complaint to a state authority (Commissioner for Information of Public Importance and Personal Data Protection); the source of personal data (available information), if personal data have not been collected from the person to whom they relate (from you), the existence of an automated decision-making process, including profiling under Article 38, paragraphs 1 and 4 of the Personal Data Protection Act, and , at least in these cases, relevant information on the logic used, as well as on the significance and expected consequences of that processing for the data subject (according to you).
If personal data are transferred to another country or international organization, you have the right to be informed of the appropriate protection measures related to the transfer, in accordance with Article 65 of the Law on Personal Data Protection.

6.3 The right to correction in accordance with Article 29 of the Law on Personal Data Protection
You have the right to request that your incorrect personal data be corrected without undue delay. Depending on the purpose of the processing, you have the right to supplement your incomplete personal data, which includes giving an additional statement.

6.4 The right to erasure in accordance with Article 30 of the Law on Personal Data Protection
You have the right to request that your personal data be deleted from us in the following cases:
– personal data are no longer necessary to achieve the purpose for which they were collected or otherwise processed;
– you have revoked the consent on the basis of which the processing was performed, in accordance with Article 12, paragraph 1, item 1) or Article 17, paragraph 2, item 1) of the Law on Personal Data Protection, and there is no other legal basis for processing;
– when you file an objection to processing in accordance with Article 37 paragraph 1 or 2 of the Law on Personal Data Protection, and there is no other legal basis for processing that prevails over the legitimate interest, right or freedom of the data subject;
– personal data have been processed illegally;
– personal data must be deleted in order to fulfill our legal obligations;
– personal data are collected in connection with the use of information society services referred to in Article 16, paragraph 1 of the Law on Personal Data Protection.
If we have publicly disclosed personal data, and if we are required to delete the data, we will take all reasonable measures, including technical measures, in accordance with available technologies and cost-effectiveness options, to inform other controllers of that data, that you have submitted a request to delete all copies of data and references, ie electronic links to that data.

6.5 The right to restrict processing in accordance with Article 31 of the Law on Personal Data Protection
You have the right to request that we restrict the processing of your personal data if one of the following cases is met:
– you dispute the accuracy of personal data, within the period that allows us to check the accuracy of personal data;
– the processing is illegal, and you oppose the deletion of personal data and instead of deleting you demand a restriction on the use of data;
– the controller (us) no longer needs personal data to achieve the purpose of processing, but you need them in order to submit, realize or defend a legal claim; or
– you have filed an objection to the processing in accordance with Article 37, paragraph 1 of the Law on Personal Data Protection, and the assessment of whether the legal basis for processing by the controller (us) outweighs your interests is in progress.

6.6 The right to data portability in accordance with Article 36 of the Law on Personal Data Protection
You have the right to receive your personal data, which you have previously provided to us, in a structured, commonly used and electronically legible form and you have the right to transfer this data to another controller without interference from us, if the following conditions are cumulatively met:
– processing is based on consent in accordance with Article 12 paragraph, 1 item 1) or Article 17 paragraph 2, item 1) of the Law on Personal Data Protection or on the basis of a contract, in accordance with Article 12 paragraph, 1 item 2) of the same Law processing is done automatically.
This right includes the right to have your personal data transferred directly to another controller directly by us, provided that this is technically feasible.

6.7 Right to object in accordance with Article 37 of the Law on Personal Data Protection Under the conditions of Article 37, paragraph 1 of the Law on Personal Data Protection, data processing may be the subject of an objection for reasons that depend on your specific situation.
The stated general right of objection refers to all purposes of processing described in these rules on data protection, which are processed on the basis of Article 12, paragraph 1, item 6) of the Law on Personal Data Protection. Unlike the right to object to the processing of data for commercial purposes (see point 6), we are obliged under the Personal Data Protection Act to exercise such a general right to object only if the reasons for it are of great importance, for example, potential danger to life or health. In addition, you have the option of contacting the state authority responsible for personal data protection or the person in charge of data protection at the data controller.

Your consent applies to the following domains: www.proready.rs

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