1. Introduction

This Privacy Policy (hereinafter: “Privacy Policy”) defines the ways in which Comtrade System Integration d.o.o. Belgrade may collect and process your personal data.

The meanings of certain terms that we use in this Privacy Policy is as follows:

  • “We”, “us” and “our” mean Comtrade System Integration d.o.o. Belgrade with which you have established a relationship, for example, with which you have a business relationship or that organises an event in which you participate or manages the website you use;
  • “Site-page/website-webpage” means a website that you visit or interact with; and
  • “You” and “your” mean you, a person who interacts with us, does business with us, registers for our events or services or visits our website.

By visiting our website, registering for some of our events, cooperating with us, registering for our services or otherwise interacting with us, we may collect or process your personal information. We are strongly committed to protecting and keeping confidential any information collected in this way, and to always abide by the applicable laws.

2. Our contact information:

Comtrade System Integration d.o.o. Belgrade, Savski nasip 7, 11070 Belgrade-New Belgrade, identification number: 17335847, TIN: 100181280, is the Personal Data Controller in accordance with the Law on Personal Data Protection (“Official Gazette of RS”, No. 87/2018) (hereinafter: “Law”).

Address: Savski nasip 7, 11070 Belgrade, Serbia

E-mail: security@comtrade.com

3. Data we may collect

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

4. Purposes of processing

We collect and process your personal data to:

  • Provide you with the information or services that you have requested from us – this information may include your name, address, e-mail address, telephone number and other relevant information;
  • 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, e-mail address, telephone number, position, company name and other relevant information;
  • Fulfill our contractual obligations to you – this information may include your name, address, e-mail address, telephone number, position, place of work, company name and type of cooperation with us;
  • Improve our website – this information may include your IP address, geographical location, information about your device, type of browser, 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 11 below;
  • Comply with or abide by legal obligations or requirements;
  • Send you promotional messages about our activities, including invitations to other events – this information may include your name, address, e-mail address, telephone number, position, company name and other relevant information;
  • Recruit new employees – this information may include your name, address, e-mail address, telephone number, date of birth, education profile and work experience, CV, a photo and other relevant information;
  • 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, position, company name, e-mail address, telephone number, short biography with a picture (for speakers/performers) and event-related audio, video and photographic documentation.

5. The legal basis of personal data processing

We process your personal data on the following legal basis:

  • In order to execute the contract that we conclude with you in accordance with Article 12, Paragraph 1, Item 2. of the Law on Personal Data Protection, for example: when you have a business relationship with us or when you have registered to participate or exhibit at an event;
  • Our legitimate interest in accordance with Article 12, Paragraph 1, Item 6. of the Law on Personal Data Protection, for example: our desire to improve the website; to inform you about our business activities and events;
  • Your consent in accordance with Article 12, Paragraph 1, Item 1. of the Law on Personal Data Protection, for example: when you accept the use of cookies on the website;
  • Fulfilment of a legal obligation to which we are subject in accordance with Article 12, Paragraph 1, Item 3. of the Law on Personal Data Protection.

6. Disclosure of personal data

We may disclose your personal data to:

  • Our affiliates;
  • Data processors who will process personal data on our behalf in accordance with our written instructions for the above purposes;
  • Other users, if we are obliged to do so by a court order or an order issued by another authority, or by applicable law.

7. The transfer and processing of personal data outside the territory of the Republic of Serbia

We may transfer your personal data to recipients located outside the Republic of Serbia, i.e. to our affiliated companies and data processors. Such data transfers take place using the following security measures:

– The Government of Serbia has adopted a Decision on the List of States, parts of their territories or one or more economic sectors in those states and international organisations considered to exercise an adequate level of personal data protection, namely member states and international organisations that have signed the Council of Europe Convention on the Protection of Individuals with regard to the Automatic Processing of Personal Data and states, parts of their territories or one or more economic sectors in those states and international organisations that the European Union considers to provide an appropriate level of protection.

In such cases, we will make every effort to ensure that your personal data receives an appropriate level of protection, which includes the application of Standard Contractual Clauses adopted and enacted by the Commissioner for Information of Public Importance and the protection of personal data when transferred to countries not designated as having an appropriate level of protection. Standard contractual clauses are available in Serbian at the following link:

https://www.poverenik.rs/sr/%D0%BF%D0%BE%D0%B4%D0%B7%D0%B0%D0%BA%D0%BE%D0%BD%D1%81%D0%BA%D0%B8-%D0%B0%D0%BA%D1%82%D0%B84/3251-%D0%BE%D0%B4%D0%BB%D1%83%D0%BAa-%D0%BE-%D1%83%D1%82%D0%B2%D1%80%D1%92%D0%B8%D0%B2%D0%B0%D1%9A%D1%83-%D1%81%D1%82%D0%B0%D0%BD%D0%B4%D0%B0%D1%80%D0%B4%D0%BD%D0%B8%D1%85-%D1%83%D0%B3%D0%BE%D0%B2%D0%BE%D1%80%D0%BD%D0%B8%D1%85-%D0%BA%D0%BB%D0%B0%D1%83%D0%B7%D1%83%D0%BB%D0%B0.html. For more information on using the Standard Contract Clauses, you can contact us at security@comtrade.com.

In other cases, we may only transfer your personal data outside the territory of the Republic of Serbia on the basis of your explicit consent.

8. Storage period

We only retain your personal information to the extent reasonably necessary to fulfil the purposes for which we collected or obtained it, or to comply with legal requirements/obligations. Where the legal basis for the processing of your personal data is your consent, we keep personal data until you revoke consent.

9. 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 require our data processors, on a contractual basis, to protect your personal data.

10. Your rights

In addition to certain exceptions and limitations provided by the Law on Personal Data Protection, you have the following rights:

  1. The right to revoke the consent to the processing of personal data at any time, which will not affect the admissibility of the processing carried out before the revocation (Article 15. of the Law),
  2. The right to transparency and information regarding the exercise of rights and the manner of data collection (Articles 22. and 23. of the Law),
  3. The right to request from the Data Controller access to the collected personal data (Article 26. of the Law),
  4. The right to request from the Data Controller the correction and supplementation of the collected personal data (Article 29. of the Law),
  5. The right to request from the Data Controller the deletion of the collected personal data (Article 30. of the Law),
  6. The right to request from the Data Controller the limitation of the processing of the collected personal data (Article 31. of the Law),
  7. The right to data portability, i.e. the right to receive data previously submitted to the Data Controller from the Data Controller in a structured, commonly used and electronically readable form and/or for the data to be transferred by the Data Controller to another Data Controller without interference (Article 36. of the Law),
  8. The right to submit a complaint to the Data Controller on the processing of the collected personal data (Article 37. of the Law),
  9. The right to not be subject to a decision made solely on the basis of automated processing, including profiling, if that decision produces legal consequences for you or if that decision significantly affects your position (Article 38. of the Law),
  10. The right to lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection regarding personal data processing (Article 78. of the Law),
  11. The right to file a lawsuit with the competent court in connection with the processing of personal data (Article 84. of the Law).

If you wish to exercise any of the above rights or have any questions about them, kindly email us at: security@comtrade.com

11. 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 webpage/website and your online behaviour. The types of data that we collect in this way may include your previous destination, the type of browser, the operating system, the browser 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 go to the following link

(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).

12. Links to other websites

The webpage may contain links to third party websites. We do not control such websites, we do not have any business relationship with them, we do not approve such websites and we cannot be held liable for any damages arising from the content of those websites. Links to other websites are only provided for convenience and we recommend that you read the Terms of Use and Privacy Policy on these third-party websites.

13. 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.