Privacy Policy

1. Introduction

With this Privacy Policy (hereinafter: “Privacy Policy”) we intend to inform you about the scope and purpose of your personal data that may be collected, used and processed while you visit website https://comtradeintegration.com (hereinafter: “Website”).

COMTRADE SYSTEM INTEGRATION D.O.O. BEOGRAD, with its registered seat at No. 7 Savski nasip Street, 11070 Belgrade, Serbia, ID number: 17335847, TIN: 100181280, is the Controller of personal data for visitors of this Website, job applicants and/or attendees of the webinars and events organized in the Republic of Serbia in accordance with the Law on personal data protection (“Official Herald of RS”, No. 87/2018) (hereinafter: LPDP of RS) whose contact details are as follows:

Company: Comtrade System Integration d.o.o. Beograd

Address: No. 7 Savski Nasip Street, 11070 Belgrade, Serbia

e-mail: info.rs@comtrade.com

Certain terms in this Privacy Policy shall have the following meaning:

• “We”, “us” and “our” shall mean the legal entity that is part of the Comtrade Group with which you have established a relationship. For example, the entity you have a business relationship with, or organizing the event you are attending, or managing the website you are using. We will make it clear to you which entity it is;

• ‘the site/website’ means this website you are visiting or engaging with; and
• “You” and “your” shall mean you, a person who interacts with us, does business with us, registers for our events or services or visits our Website.

By visiting this Website, applying for open job positions, registering for one of our events and webinars that may be organized by us, cooperating with us, registering for our services or otherwise interacting with us, we may collect or process your personal data. We are strongly committed to protecting and keeping confidential any information collected in this manner, and to always abide by the applicable laws.

2. Data protection officer (DPO)

Comtrade System Integration d.o.o. Beograd has designated Data protection officer (DPO):

Danijel Stošić, DPO

Address: No. 7 Savski nasip Street, 11070 Belgrade, Serbia

Phone number: + 381 11 201 5600

Mobile number: + 381 65 314 0552

Email: danijel.stosic@comtrade.com, dpo@comtrade.com

3. Legal basis for the processing of personal data

We may collect and process the personal data that you have personally provided us with, that we have collected from third parties with whom we work closely, or from publicly available sources.

Legal basis for the processing of personal data may be:

• the performance of a contract with you (in compliance with i) Article 12(1)(2) of LPDP of RS, and ii) Article 6(1)(b) of GDPR), for example where you have a business relationship with us (for the performance of a contract or in order to take steps prior to entering into a contract) or where you have registered to attend or display at an event;
• our legitimate interest (in compliance with i) Article 12(1)(6) of LPDP of RS, and ii) Article 6(1)(f) of GDPR), for example our desire to improve the Website; to keep you up to date on our business activities and events;
• your consent (in compliance with i) Article 12(1)(1) of LPDP of RS, and ii) Article 6(1)(a) of GDPR), for example when you accept the use of cookies on the Website or when you give consent for the processing of your personal data for one or more specific purposes;
• to comply with a legal obligation to which we are subject (in compliance with i) Article 12(1)(3) of LPDP of RS, and ii) Article 6(1)(c) of GDPR).

4. Purposes of processing

We may collect and process your personal data for the following purposes:

• to provide you with the information or services that you have requested from us – this information may include your name, address, email address, phone number and other relevant information;
• to keep in touch with you as our business partners and to keep you informed about our business activities and events in a timely manner – this information may include your name, address, email address, phone number, title (position in your organization), company name and other relevant information;
• Fulfill our contractual obligations towards you – this information may include your name, address, email address, phone number, title (position in your organization), place of work, company name and type of cooperation with us;
• to improve our Website – this information may include your IP address, geographical location, information about your device,  browser type, the source from which you accessed the page, the duration of the visit, operating system, number of page views, which pages you viewed and similar information. For more information on cookies, please see Article 13 below;
• to comply with or abide by legal obligations or requirements;
• to send you promotional messages about our activities, including invitations to other events – this information may include your name, address, email address, phone number, title (position in your organization), company name and other relevant information;
• to recruit new employees – this information may include your name, address, email address, phone number, date of birth, education profile and work experience, CV, a photo and other relevant information;
• to successfully and efficiently organise our events, which includes promotional activities and publishing event-related audio, video and photo documentation – this information may include your name, title (position in your organization), company name, email address, phone number, short biography with a picture (for speakers/performers in such events) and audio, video and photo documentation from such events.

5. Personal data collection and processing

Personal data collection and processing when visiting this Website

If you only use this Website for informational purposes, i.e., if you do not register or otherwise provide us with information, we only collect the data your browser sends our server (’’server log files’’). This Website collects a range of general data and information each time you access it or an automated system. General data and information are stored in the server log files and may be collected such as:

1. the browser types and versions used,
2. the operating system used by the accessing system,
3. the website from which an accessing system accesses this Website (called a referrer),
4. the sub-pages accessed via an accessing system on this Website,
5. the date and time this Website is accessed,
6. an internet protocol address (IP address),
7. a truncated internet protocol address (anonymized IP address) and
8. the accessing system’s internet service provider.

No conclusions are drawn about you when using this general data and information and this  information is needed to fulfill the following purposes:

1. properly deliver content of this Website,
2. to optimize the content of this Website as well as to advertise it,
3. to ensure the continued functioning of our information technology systems and this Website’s technology,
4. to provide the information necessary for law enforcement authorities to prosecute in the event of a cyber-attack.

This collected data and information is therefore statistically analysed and further analysed by us to increase data protection and data security within the company to ultimately ensure an optimum level of protection for the personal data being processed by us. The data from the server log files are stored separately from all personal data provided by you.

The legal basis for processing of personal data when visiting this Website is Article 12(1)(6) of LPDP of RS and when data subjects situated in EU are visiting this Website is Article 6(1)(f) of GDPR whereas our legitimate interest is based on the purposes listed above for the collection of data.

Personal data collection and processing when contacting us / filling contact form

Personal data is collected when you contact us (e.g. using our contact form on our Website or by email). If you use a contact form to get in touch with us, the contact form you use will indicate the data being collected. This personal data is stored and used exclusively for the purpose of responding to your query or establishing contact and the associated technical administration.

The legal basis for personal data processing is our legitimate interest in responding to your request pursuant to Article 12(1)(6) of LPDP of RS. The legal basis for personal data processing of data subjects situated in EU is our legitimate interest in responding to request of such data subject pursuant to Article 6(1)(f) of GDPR.

If you are contacting us in order to conclude a contract, processing is legally based on Article 12(1)(2) of LPDP of RS. If data subjects situated in EU is contacting us in order to conclude a contract, processing is legally based on Article 6(1)(b) of GDPR.

Personal data collection and processing when applying for job

We collect and process personal data of job applicants to carry out the application process. Processing may also be carried out electronically. That is particularly the case if an applicant submits corresponding application documents to us electronically, for example by email or via a web form on the Website. If we conclude an employment contract with an applicant, the data submitted will be stored to process the employment relationship in compliance with the statutory provisions.

The legal basis for personal data processing is the fulfillment of contractual obligations as stated in Article 12(1)(2) of LPDP of RS and for the data subjects situated in EU the legal basis for personal data processing is the fulfillment of contractual obligations as stated in Article 6(1)(b) of GDPR.

As part of the application process, you must provide the personal data required by law. Without this data we will generally not be able to consider you appropriately in the decision-making process for filling the position. The legal basis for such data processing is the compliance with legal obligations we are subject to pursuant to Article 12(1) (3) of LPDP of RS and for the data subjects situated in EU pursuant to Article 6(1)(c) GDPR).

If you have agreed that we are allowed to process you personal data for the purpose of using them in future job recruiting processes, personal data shall be processed in accordance with your informed consent pursuant to Article 12(1)(1) of LPDP of RS and for the data subjects situated in EU pursuant to Article 6(1)(a) of GDPR.

If you are applying for job positions that are opened at Comtrade System Integration d.o.o. Sarajevo, with its registered seat at No. 179 Džemala Bijedića Street, 71000 Sarajevo, Bosnia and Herzegovina, ID number: 65-01-1251-09, JIB: 201204010005, member of Comtrade Group, Comtrade System Integration d.o.o. Sarajevo will be considered as the controller and the following Privacy policy for job positions created and webinars organized by Comtrade System Integration d.o.o. Sarajevo shall be applicable for job applicants.

If you are applying for job positions that are opened at Comtrade SI Sistemske Integracije d.o.o., with its registered seat at No. 29b Letališka cesta Street, 1000 Ljubljana, Slovenia, Registration No.: 8371741000, VAT ID No.: SI 60227818, member of Comtrade Group, Comtrade SI Sistemske Integracije d.o.o. will be considered as the controller and the following Privacy policy for job positions created and webinars organized by Comtrade SI Sistemske Integacije d.o.o. shall be applicable to job applicants.

Personal data collection and processingwhen attending our webinars or events

When planning, organizing and performing the webinars or events we process your data for the purpose of realisation of the webinars and events. We use your data to contact you regarding your attendance and for this purpose we store your personal data in our database given to us by you through the application form. Webinars and events are recorded and may be shared with other companies members of the Comtrade Group as well as with other companies outside Comtrade Group.

We process your personal data in accordance with Article 12(1)(2) of LPDP of RS and for the data subjects situated in EU we process personal data of such data subjects in accordance with Article 6(1)(b) of GDPR.

Without providing your required information it is not possible for you to attend webinars or events.

If further information is obtained in the course of contact, this will also be processed in our database and used for subsequent conversations regarding your attendance at webinar or event. The legal basis for this is our legitimate interest in organizing and attending the webinars and events in accordance with Article 12(1)(6) of LPDP of RS and for the data subjects situated in EU the legal basis for this is our legitimate interest in organizing and attending the webinars and events in accordance with Article 6(1)(f) GDPR.

If you are applying for webinar(s) or events in Bosnia and Herzegovina that is organized by Comtrade System Integration d.o.o. Sarajevo, with its registered seat at No. 179 Džemala Bijedića Street, 71000 Sarajevo, Bosnia and Herzegovina, ID number: 65-01-1251-09, JIB: 201204010005, member of Comtrade Group, Comtrade System Integration d.o.o. Sarajevo will be considered as the controller and the following Privacy policy for job positions created and webinars organized by Comtrade System Integration d.o.o. Sarajevo shall be applicable for attendees of the webinars or events that apply for them.

If you are applying for for webinar(s) or events in Slovenia that is organized by Comtrade SI Sistemske Integracije d.o.o., with its registered seat at No. 29b Letališka cesta Street, 1000 Ljubljana, Slovenia, Registration No.: 8371741000, VAT ID No.: SI 60227818, member of Comtrade Group, Comtrade SI Sistemske Integracije d.o.o. will be considered as the controller and the following Privacy policy for job positions created and webinars organized by Comtrade SI Sistemske Integacije d.o.o. shall be applicable for attendees of the webinars or events that apply for them.

Newsletter

If you have provided us with your email address, we reserve the right to send you regular emails, newsletters, with offers on products or services from our collection similar to those you have already purchased or been interested in.

The sole basis for the personal data processing is our legitimate interest in personalised direct marketing in accordance with Article 12(1)(6) of LPDP of RS and for the data subjects situated in EU the legal basis for the personal data processing is our legitimate interest in personalised direct marketing in accordance with Article 6(1)(f) GDPR.

We will not send you any emails should you expressly object to the use of your email address for that purpose. You are entitled to object to the use of your email address for the aforementioned purpose at any time with immediate effect by notifying the Controller listed in the opening of this Privacy Policy. After receipt of your objection, your email address will immediately be removed from mailing list for marketing purposes.

6. Processing of personal data of data subjects under 15 years of age

Except in those cases where Controller organizes educational events specifically designed for children, we do not intentionally collect the personal data of individuals under 15 years of age. If you are under 15 years of age please do not send us your personal data e.g. your name, address and email address. If you wish to contact Controller in a way that requires you to submit your personal data (such as for education or similar events) please get your parent, exercising parental rights, or your legal guardian to do so on your behalf.

7. Disclosure of personal data

We may disclose your personal data to the following subjects:

• our affiliated companies;
• our business partners;
• contractual data processors (suppliers, service providers, consultants etc.), who might process personal data in our name in accordance with our written instructions and for the purposes as stated above;
• to other recipients, if obliged to do so subject to a court order or order issued by other governement authority or valid law.

8. Transfers of personal data to other countries and international organizations

We may transfer your personal data to the recipients in third countries or international organisations, located outside of the Republic of Serbia or EU/EEA,to our affiliated companies and contractual data processors. Such transfers take place under the safeguard measures as defined in LPDP of RS or GDPR depending on the country where you reside.

1. transfer of personal data to recipients located outside the Republic of Serbia, i.e. to our affiliated companies and contractual data processors takes place using the following security measures:

• • transfer of personal data without prior authorization based on adequate level of personal data protection
    • to another country, part of its territory or one or more economic sectors in those countries or international organisations can be carried out if it has been determined that said country, part of its territory or one or more economic sectors in those countries and international organisations ensures an adequate level of protection of personal data.
      It is considered that an adequate level of protection is provided in the countries and international organizations that have signed the Council of Europe Convention on the Protection of individuals with regard to the automatic processing of personal data and countries, parts of their territories or one or more economic sectors in those countries and international organisations that have been determined by the European Union to provide an adequate level of protection of personal data.
  • • to another country, to a part of its territory or to one or more economic sectors in those countries and international organisations for which the existence of an adequate level of protection of personal data has not been determined as described above, we will do everything to ensure that your personal data will receive an appropriate level of protection, which includes the use of Standard Contractual Clauses adopted and issued by the Commissioner for Information of Public Importance and Personal Data Protection. The aforementioned clauses and are available in Serbian language at the following link: Oдлукa о утврђивању стандардних уговорних клаузула („Службени гласник РС“, број 5/2020) – Повереник за информације од јавног значаја и заштиту података о личности.
  • In other cases, we may transfer your personal data to third countries based on your explicit consent.

2. transfer of personal data of data subjects located in EU to recipients located outside the EU, i.e. to our affiliated companies and contractual data processors takes place using the following security measures:

We may transfer your personal data to recipients who are located outside the EU/EEA area (hereinafter referred to as ”Third countries”), to our affiliated companies and service providers. Such transfers take place under the following safeguard measures:

• the European Commission has decided, on the basis of Article 45 of GDPR, that the country outside the EU, Third country, in question ensures an adequate level of data protection (European Commission adopted Adequacy decisions);
• the European Commission has decided that commercial organisations from the United States, which participate in the EU-US Data Privacy Framework, ensure an adequate level of data protection;
• the European Commission has not decided, due to the local legislation of such country or international obligations it has concluded, that such a country ensures an adequate level of protection of personal data. In such cases, we will do everything to ensure that your personal data will receive an appropriate level of protection, which includes the use of Standard contractual clauses for the transfer of personal data outside the EU/EEA, approved by the European Commission for transfer to countries that are not determined as countries that provide an adequate level of protection of personal data, Third countries. Standard contractual clauses are available in various languages on the following link: Publications on the Standard Contractual Clauses (SCCs) – European Commission.
• in other cases, we may transfer your personal data to third countries based on your explicit consent.

For more information regarding the use of the Standard contractual clauses as detailed in parts I. and II. of this point 8 you may contact us by sending email to dpo@comtrade.com.

9. Links to other websites

This Website may contain links to third parties websites. We disclaim any control over, relationship with, or endorsement of these sites and shall not be liable for data protection while visiting such websites. Links to other websites are provided only as a convenience and we encourage you to read these third-party websites’ Terms of Use and Privacy Policies.

Such websites may be:

The social media platforms such as LinkedIn, Facebook, Instagram, Youtube,  etc. LinkedIn, Facebook, Instagram, Youtube and others are independent personal data controllers and will process your personal data following their privacy policies, such as:

LinkedIn Privacy Policy

Meta | Privacy Center | Manage your privacy on Facebook, Instagram and Messenger | Facebook Privacy

Privacy Policy – Privacy & Terms – Google

Google, who is an independent personal data controller and services provider (ex. Google Maps, Google Analytics), processes your personal data following their own privacy policy: Privacy Policy – Privacy & Terms – Google.

10. Retention period

We retain your personal data to the extent reasonably necessary to fulfil the purposes for which we collected or obtained them or to comply with legal requirements/obligations.

Where your consent is the legal basis for the processing of your personal data, we shall keep your personal data until you withdraw your consent.

11. Protection and Security

We take precautions to protect your personal data from loss, misuse, unauthorised access, disclosure, alteration and destruction. We have taken appropriate technical and organisational measures to protect the information systems on which we store your personal data and we require our data processors to protect your personal data by contractual means.

12. Your rights

Subject to certain exceptions and restrictions set out in applicable legislation, you may exercise the following rights:

1. Right of access to your personal data (in compliance with i) Article 26 of LPDP of RS, and ii) Article 15 of GDPR),
2. Right to rectification and supplementation of your personal data (in compliance with i) Article 29 of LPDP of RS, and ii) Article 16 of GDPR),
3. Right to erasure of your personal data (the right to be forgotten) (in compliance with i) Article 30 of LPDP of RS, and ii) Article 17 of GDPR),
4. Right to restriction of processing of your personal data (in compliance with i) Article 31 of LPDP of RS, and ii) Article 18 of GDPR),
5. The right to data portability (in compliance with i) Article 36 of LPDP of RS, and ii) Article 20 of GDPR),
6. Right to object to the processing of your personal data (in compliance with i) Article 37 of LPDP of RS, and ii) Article 21 of GDPR),
7. Right to withdraw your consent to the processing of your personal data (in compliance with i) Article 15 of LPDP of RS, and ii) Article 7(3) of GDPR),
8. Right not be subject to a decision based solely on automated processing, including profiling, which produces legal effects for you or affects you significantly (in compliance with i) Article 38 of LPDP of RS, and ii) Article 22 of GDPR),
9. Right to lodge a complaint with the Commissioner for information of public importance and personal data protection regarding personal data processing (in compliance with i) Article 82 of LPDP of RS, and ii) Article 77 of GDPR).

You can file a complaint or make a request regarding the processing of your personal data by sending  email to dpo@comtrade.com.

You can also lodge a complaint with the competent supervisory authority. Contact information of the  competent supervisory authority in Serbia: Poverenik za informacije od javnog značaja i zaštitu podataka o ličnosti, Bulevar kralja Aleksandra 15, 11120 Beograd, phone: +38111 3408 900, email: office@poverenik.rs.

13. Cookies 

We use cookies and similar technologies to ensure that you get the most out of our Website. We may also use cookies to collect information about how you use our Website and your online behavior. The types of data that we collect in this way may include your previous destination, the type of browser, the operating system, the browser (search engine) used, as well as the duration of your visit to the Website. For more information on how we use cookies and similar technologies and how you can control them, please see our Cookie Policy published at the bottom of the Website.

For more information on how to disable email tracking, please check out the following links:

https://www.wikihow.com/Stop-Email-Tracking

https://nordvpn.com/blog/how-to-block-email-tracking/;

https://www.hongkiat.com/blog/detect-disable-email-tracking/

or to the documentation within your e-mail application (if you use it) or your e-mail service provider (if you use an Internet browser to read e-mail).

14. Changes to this Privacy Policy 

We may update our Privacy Policy from time to time. An updated Privacy Policy will be posted on the relevant websites or will be provided to you upon request.

Last updated on 1.2.2026