Digital Serbia Initiative’s Privacy Policy for the “Venture an Idea” Project

The Digital Serbia Initiative, with its seat at the address 11a Milutina Milankovića, 11000 Belgrade, Republic of Serbia, with the corporate identification number 28231083, TIN 110058888 (hereinafter: the “DSI”) responsibly and seriously approaches the protection of your personal data.

The data controller regarding your personal data is the DSI, which collects and processes your personal data in accordance with the Law on Personal Data Protection (“Official Gazette of RS”, No. 87/2018, hereinafter: the “Law”), as well as in accordance with this Privacy Policy. The data collected is processed legally and transparently, and only for the purpose it was collected. The collected data is accurate, and, should it be necessary, updated. Taking into account the purpose of processing, the DSI undertakes all reasonable measures to ensure that inaccurate personal data is deleted, or corrected, without delay.

The DSI is, in cooperation with USAID, implementing the “Venture an Idea” project (hereinafter: the “Project”). This Privacy Policy is applied to the personal data received in the course of the Project, and to all persons visiting the www.preduzmi.rs website (hereinafter: the “Website”), as well as to:

• Persons participating in research and other activities carried out by the DSI in connection with the Project;
• Persons who contact the DSI in connection with the Project through the contact form available on the Website.

Should you have any questions regarding this Privacy Policy, data we have collected about you, or any other matter regarding the subject data, please contact us via email preduzmi@dsi.rs.

1) Your personal data that we collect

a) Personal data you voluntarily provide

The DSI collects and processes personal data you voluntarily share with us:

• Your name and surname;
• Your contact information, such as your email address and/or phone number;
• Data you decide to share with us, when filling out research-related forms;
• Data you share with us when contacting the DSI.

b) Personal data that we collect automatically

When you access or search the Website, the DSI automatically collects certain data about you. This includes:

Visitor data. We collect certain data from the moment you arrive on the Website. This may include data on your computer’s hardware or software (IP address, browser type, domain, access time, location) that allows us to provide you with customized user access to the Website.

Data collected through cookies. Cookies are also a source from which we receive data on you as a user. Cookies are small units of data that your browser stores on the device through which you access the Website, and which the browser directs towards the Website when you use it. We use this data to improve your user experience, to better understand you and your needs, and to customize the visual aspects of the Website. Due to the importance of this data, as soon as you visit the Website you will receive a notification related to cookies. Additional information about cookies can be found in the section of this document titled “Cookies”.

Location information. We may obtain and process data in connection with your location. For instance, we may collect data on the unique location of your mobile device (using GPS or Bluetooth technology). We may also obtain data on your approximate location through the IP address.

2) Purpose and legal grounds for data processing

Your personal data is being processed in an electronic format, and the processing may in particular include the following: collection, classification, use, analysis, disclosure, sharing, storage and deletion.

We process the data about you in order to:

• Build, maintain and improve the Website;
• Improve the experience that you, as a user, have when browsing the Website’s content;
• Provide you with the information that really interests you, in the form that best suits your needs and preferences;
• Analyze the ongoing trends and treat them as goals that our users set for us;
• Keep you informed about all projects, events, and news related to the DSI (please note that you can unsubscribe from our newsletter at any time);
• Cooperate with the USAID, with the aim to fully implement the Project.

The legal ground for processing of your personal data is your consent, in accordance with the Article 12, Paragraph 1, Item 1) of the Law, and you may revoke it at any time, and such revocation will not affect the lawfulness of the processing of your personal data performed prior to the revocation. In the event of revocation, further processing of your personal data will cease as soon as reasonably possible, unless there is some other legal basis for data processing.

We also collect your personal data in order to keep you informed on all projects, events and news related to the DSI (hereinafter: the “Direct Marketing”). We collect your personal data for this purpose in accordance with the Article 12, Paragraph 1, Item 1) of the Law, i.e. on the basis of your consent. However, your consent to the processing of your data for the purpose of Direct Marketing must be given independently and separately from the consent you give to the processing of your personal data. In that sense, you can separately withdraw your consent regarding the use of personal data for the Direct Marketing purpose by sending an email to the following email address: preduzmi@dsi.rs. Should you do so, your personal data will no longer be used for Direct Marketing.

The legal ground for processing your personal data may also be a DSI’s or a third party’s (e.g. our business partners, and/or DSI member companies) legitimate interest, all in relation to the functioning of the Website, and/or conduct related to the use of the Website.

3) How do we use your personal data?

We will use your personal data only with your explicit consent, or in case that there is some other legal basis for the use. Your personal data will not be used for purposes other than those for which it was collected, on which you are properly informed. Should at any time the DSI intend to process your personal data for any other purpose, we will inform you on that other purpose, as well as on all other matters as prescribed by the Law. All of our team members will keep your personal data confidential.

4) How long do we keep personal data?

We do not keep your personal data longer than necessary for the realisation of the purpose for which they were collected, and no longer than the duration for which we have your consent.

5) Sharing your personal data

We will not make your personal data available to third parties without your explicit consent, or share it with persons outside the system preparation, editing, and technical maintenance of the Website (who may be the employees of the DSI, or of third parties with whom the DSI has a services contract related to the design and maintenance of the Website, as well as of their subcontractors). Your personal data is protected from misuse, destruction, loss, unauthorised changes and access, both when we process it directly and when it is done by the mentioned third parties with whom we have entered into contractual relations, or by their subcontractors.

When you share certain personal data with us, there is a group of people that will have access to such data.

When you contact us via the contact form that can be found on the Website, or directly via email, the content of your message is available only to those employees that are responsible for communicating with you. We do not share, sell, or disclose the content of your message to persons outside of the DSI.

Exceptions to this rule relate to persons who are not a part of our team, but may have access to your personal data because they are:

• Our partners. We may share your personal data with our business associates, consultants, as well as with other service providers who need this information to assist us in carrying out our daily business, as well as Project-related activities.

• Representatives of our members. Representatives of organizations and companies that are DSI members will have access to your personal data in case that you have requested to have contact with a member by contacting us, or if the content of your request implies the need to contact a representative of a member company.

• Representatives of government bodies. We will share your personal data with representatives of government bodies, in case that there is a legal ground for such sharing, and only under an official request. In case that we receive such a request, we will inform the person to which the personal data relates as soon as possible, unless such disclosure is forbidden by law.

• USAID. Given that the DSI is implementing the Project in cooperation with USAID, your personal data may be shared with USAID for the purpose of Project implementation, as well as for the reporting purpose.

Also, we may use your personal data to initiate and conduct appropriate legal proceedings in the event that your activity on and/or in connection with our Website violates this Privacy Policy, the rules of use of the Website, other existing rules and procedures and/or laws or other Republic of Serbia’s statutes, with the purpose to protect our rights, right of DSI member companies, and/or other users of our Website, or of any other person.

When creating various trend reports on our website, your data may be incorporated into group views of individual trends, but in a manner so that it will in no way be possible to identify you as a user.

6) Your rights under the Law

In accordance with the applicable Law, you have the following rights related to the processing of your personal data:

• The right to access personal data

You have the right to receive confirmation from us as to whether we are processing your personal data, and also, if necessary, to request access to such personal data.

• The right to correct and supplement personal data

As a data subject, you have the right to have your inaccurate personal data removed without undue delay. Depending on the processing purpose, you have the right to supplement your incomplete personal data.

• The right to be forgotten

In accordance with the Law, you have the right to ask us to delete your personal data. In such cases, however, there is a possibility that the purpose for which your personal data was collected may not be achieved.

• The right to limit the processing of your personal data

In accordance with the Law, you have the right to request a restriction on the processing of your personal data. In that case, such personal data will be marked, and we will be able to process it only for certain purposes.

• The right of portability of personal data

In accordance with the Law, you have the right to receive the personal data you provided to us. We are obligated to deliver you the data in a structured, commonly used and electronically readable format (i.e. digitally), and you have the right to transfer the personal data to another controller, or to request a transfer to a third party without any obstructions from our part, given that such transfer is technically possible.

• The right to object to the processing of personal data

In accordance with the Law, you have the right to, for reasons related to the processing of your personal data, object to our processing of your personal data and to request that we no longer process it. You have the right to object at any time to the processing of your personal data that is processed for the purposes of Direct Marketing.

• The right to withdraw a consent given for processing of personal data

In accordance with the Law, in cases where the processing of your personal data is based on your consent, you can withdraw your consent at any time, free of charge and without giving any reasoning for the withdrawal. Withdrawal of consent shall not affect the lawfulness of the processing that happened prior to the withdrawal. Should you withdraw your consent to the processing of your personal data by the DSI, we may not be able to provide you (in whole or in part) with the services you request, or achieve the purpose for which the consent was given.

• The right to appeal to supervisory authorities

In accordance with the Law, if you find that the processing of personal data was carried out contrary to the provisions of the Law, you have the right to file a complaint with the Commissioner for Information of Public Importance and Personal Data Protection. Filing a complaint with the Commissioner will not affect your right to initiate other administrative or judicial proceedings.

In order to exercise your rights regarding the processing of personal data, please contact us via the email address preduzmi@dsi.rs.

7) How does the DSI store your personal data

We use appropriate technical, organisational and personnel measures to protect the personal data we collect and process about you. The measures we use are designed to provide an appropriate level of security, so that the processing of your personal data is carried out in accordance with the provisions of the Law, and to ensure the protection of your rights and the rights of data subjects.

8) To which countries is your data transferred?

Your personal data is transferred to companies in countries both inside and outside of the EU. The countries outside of the EU may not be able to provide the same level of personal data protection as your country. In such cases, the DSI shall ensure that the party receiving the data adequately protects the personal data.

Adequate protection includes signing a contract with the party receiving the data, in accordance with which such party should maintain the same high level of privacy and data security as practiced by the DSI. The contracts in question encompass standard clauses provided by the Commissioner in accordance with the Article 45 of the Law, which fully regulate the relationship between the DSI as the controller of your data and the processor. You can get acquainted with the subject provisions on the link https://www.poverenik.rs/sr-yu/ .

9) Cookies

Our website www.preduzmi.rs uses cookies. Cookies are small units of data that your browser stores on the device you have used to access our website and sends them to us whilst you are browsing our website.

We only use the cookies listed in the table below. Their purpose and expiration are also given in the table.

You can set your browser to block these cookies but bear in mind that if you do so, you won’t be able to use our website’s functionalities or you won’t be able to use them fully.

If you haven’t blocked them, you can delete the initially enabled cookies when you use our website later. However, bear in mind that after you have deleted them you won’t be able to use our website’s functionalities or you won’t be able to use them fully. In any case, you can find out more about how it all works by clicking on the relevant option on your browser menu.

10) Changes to the Privacy Policy

The DSI reserves the right to update and/or amend this Privacy Policy from time to time, in order to keep up with the changes in legislation and technical innovations. All changes will take effect only upon publication of the updated version of the Privacy Policy on the Website. We suggest that you periodically review our Privacy Policy. If we have your email address, we will notify you of these changes. If you do not agree with our Privacy Policy, please stop using the Website immediately.

11) Contact us

In case that you want to use any of your rights as a person whose personal data we collect, or in case of any other questions related to our Privacy Policy, please contact us via email preduzmi@dsi.rs.