DATA PROTECTION

PRIVACY POLICY – PERSONAL DATA PROCESSING NOTICE

Your privacy and the security of your data are important to us, therefore, the company VICTORY GARDENS DOO BELGRADE – NEW BELGRADE (hereinafter: Company) as a data controller towards you, as a person from whom data relating to you is collected, provides you with the information listed below at the time of collecting such data, in accordance with the Law on Personal Data Protection (“Official Gazette of RS”, No. 87/2018, hereinafter: the Law). These Privacy Policy (hereinafter: Policy) apply to natural persons, and personal data refers to all data through which we can directly or indirectly identify you. All of your personal information is treated as strictly confidential, and the Company and/or our trusted partners keep them in an adequate manner. Please carefully read these privacy policy. If you do not agree with our actions, please do not provide us with your personal data. If you continue to browse our website, you confirm that you agree to these policies listed here.

DATA CONTROLLER AND DATA RECIPIENT

The responsibility for the processing of personal data as a data controller is borne by: VICTORY GARDENS DOO BELGRADE – NEW BELGRADE, Milutina Milankovića 11V, New Belgrade, MB: 21730963, VAT: 112744771.

The recipient of personal data may be the company KADENA INTERNATIONAL REALTY DOO BELGRADE – NEW BELGRADE, Milutina Milankovića 11V, New Belgrade, MB: 21496987, VAT: 111529348.

In case of any questions or requests regarding the handling or protection of your personal data, you can contact us at the email address: info@kadenaproperties.com or in writing to the above-mentioned address of our headquarters.

SUBJECT OF PRIVACY POLICY

These Rules encompass the ways in which your personal data is processed when you interact with the Company, i.e. when you express interest in purchasing real estate or contact us regarding the conclusion of a contract for the sale of real estate within a residential and commercial complex, or when you:

• visit our website or pages that serve to advertise the Company’s projects;
  • visit our profiles on social media pages;
  • communicate with us by phone or through the contact form on the website or via email or in any other way;
  • use our systems and applications;
  • visit our sales outlets;
  • attend our presentations or business events;
  • participate in our promotional or marketing activities (e.g. newsletter sign-up), surveys, and similar activities;
  • conclude a contract with us regarding the sale of real estate or another contract.

It is mandatory to provide only those personal data that we collect to fulfill certain legal obligations. Providing personal data for all other legal grounds is voluntary, but we note that if you deny us certain data, we may not be able to provide you with certain services in certain situations.

PERSONAL DATA WE COLLECT

1. Personal data of visitors to our website – When you visit our website, or websites that advertise the Society’s projects, the browser you use on your device will automatically and without your activity send to our website server: the IP address of the device from which the query was sent and which has access to the internet, date and time of access, name and URL of the downloaded file, the website/application from which access is made (referrer URL), the browser you use, and, if necessary, the computer operating system that supports the internet, as well as the name of your provider. The server temporarily stores this information in a so-called log file for the following purposes:

• Ensuring uninterrupted connection;
• Providing comfortable use of our website/application or websites that advertise the Society’s projects;
• Assessing the security and stability of the system.

The data is stored temporarily during the visit to the website and is automatically deleted thereafter. The legal basis for processing the IP address is Article 12, paragraph 1, point 6) of the Law on Personal Data Protection (legitimate interest), arising from the above-mentioned purpose of data processing.

2. Marketing and other activities – Personal data is collected solely on the basis of consent of the data subject (for example, in case of signing up for a newsletter, direct marketing, etc.) for the purpose of sending commercial messages and carrying out marketing activities. The data provided by you through contact forms, phone calls or e-mails are used in accordance with the purpose stated here. If you have given consent to receive newsletters via e-mail, SMS, Viber, and/or other marketing materials containing information on current offers and promotions related to services offered by us, we will use your e-mail address, phone number, name and surname to send information about available properties, promotions, news, and offers for real estate purchases. We keep and process this data for the purpose of sending commercial messages, newsletters, and/or other marketing materials that include actions (offers, promotions, etc.). The legal basis for processing data for the purpose of sending commercial messages, newsletters, and/or other marketing materials is your consent in accordance with Article 12, paragraph 1, item 1) of the Law on Personal Data Protection. You can withdraw your consent to receive newsletters/marketing materials at any time. The revocation of consent does not affect the legality of processing that was carried out based on consent prior to revocation. You can do this by unsubscribing from the newsletter list on our website or on the website that serves for advertising the projects of the Company. The unsubscribe link can be found at the end of each newsletter, and you can unsubscribe from Viber or SMS directly through the Viber application or SMS message if you have given consent for this type of notification. If you revoke your consent, we will delete your data. We would like to inform you that in case of sending newsletters/Viber/SMS, we may engage external partners to perform these services, so your data may be transferred to these entities (data on e-mail addresses and phone numbers).
3. Personal data of real estate buyers – The Company processes personal data of individuals that are necessary for the preparation, conclusion of contracts and execution of contractual obligations, or the exercise of rights and obligations from concluded contracts on the sale of real estate within the residential and business complex. The personal data we collect from you are: name and surname, address (street, house number, postal code, city, country), ID number, ID card/passport number, copies of personal documents, and contact information (phone number, email address). We obtain all your personal data directly from you. In addition to the Sale and Purchase Agreement, the Company may also conclude contracts with you in the phase preceding the process of buying and selling, such as reservation agreements for real estate, deposit agreements for the purchase of real estate, etc., and in that case, we collect the following data from you: name and surname, address (street, house number, postal code, city, country), and contact information (phone number, email address). We process your data for the purpose of preparing the Sale and Purchase Agreement of real estate, as well as preparation, conclusion, and other agreements listed in this section. The legal basis for the processing of this data is Article 12, paragraph 1, points 2) and 3) of the Law, taking into account the execution of contractual and legal obligations.
4. Other personal data you have provided to us – We process those personal data that you have voluntarily provided to us during the initial contact, during later communication (e.g. through phone calls, e-mails, questionnaires, etc.), during visits to the Company’s website or websites that serve to advertise the Company’s projects or social media profiles, as well as those personal data that have arisen from our communication or business cooperation, which include your identification data (name and surname), as well as your communication data (contact phone and e-mail address). We process your data in accordance with the established purpose, in order to respond to your inquiry based on your interests, to present our offer in more detail, and provide other requested information. 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 this processing of data arises from the need to answer your questions, to solve existing problems if necessary, and thus ensure your satisfaction as a user of our services, or as a user of our website. If you participate in one of our surveys/questionnaires, such participation is voluntary. In anonymous surveys, we do not keep data that would allow us to conclude who the survey participant is. We only keep the date and time of your participation. Every personal data that you have provided us through the survey is considered voluntarily given, and we keep them in accordance with the provisions of the Law. In case you have given your consent for conducting 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. The revocation of consent does not affect the admissibility of processing that was carried out based on the consent before the revocation. By providing personal information, the visitor of the Company’s website, or the website that serves to advertise the Company’s projects, understands and agrees that the security, integrity, and privacy of their data cannot be 100% guaranteed, despite the fact that the Company constantly takes all optimal measures to protect them.
5. Personal data of social media users – On the Society’s social media pages, we process data for the purpose of informing individuals about our business-residential complex, real estate properties that we offer for sale, services that we provide, promotions, important information, news in the company, all for the purpose of interacting with social media visitors and communicating with individuals interested in our services. Data processing is carried out in the interest of communication, i.e., for the purpose of interaction and improving relationships with followers. The legal basis for processing your data is Article 12, paragraph 1, point 6) of the Law (legitimate interest). We have limited influence on the processing of data by social media platform operators (e.g. member administration and information sharing). Where we can influence and adjust parameters for processing your data so that the social media platform operator acts in accordance with data protection, we take all measures available to us. However, in many places, we cannot influence the processing of operator data, nor do we know exactly what data the operator is processing. The platform operator manages the entire IT infrastructure of the service, adheres to its own data protection rules, and has a special user relationship with you (if you are a registered user of the social media service). In addition, the operator is solely responsible for all questions regarding data from your user profile, to which we as a company do not have access. For more information on data processing by platform operator of social media and opportunities for objections, please refer to their data protection rules. The data you enter on our social media pages, such as comments, videos, images, likes, public notices, etc., are published by the platform operator, and we do not process them for any purpose other than intended. We reserve the right to delete illegal or inappropriate content, if necessary. We also process your data for the purpose of communicating with you. We may share your content on our page if it represents a function of the social media platform.

ACCESS TO YOUR DATA

We consider your personal data to be a business secret, and we protect it in accordance with applicable legal regulations and best practices. Within our company, only those organizational units or employees who require the data for the purpose for which the personal data was collected have access to the data you have provided us. We will process your personal data ourselves, while third parties have the right to access and process your personal data only in the following situations:

• Our trusted partners or legal entities with whom we do business and who assist us in our regular business activities. These can be entities that develop and maintain IT solutions and platforms, servers, as well as entities that provide services to you on behalf of the Company, for example, for marketing purposes. In this case, these legal entities process your personal data solely for our needs. These service providers are obliged under the concluded agreements to use the data entrusted to them exclusively in accordance with our instructions and strictly for the purpose we have defined, with the obligation to adequately protect your data and keep it confidential;
• Parties with whom we do business, when we assess that it is necessary to protect our specific and legitimate interests, for example, tax advisors, accountants, insurance companies, lawyers, and other advisors. In this case, these parties process your personal data solely for our needs;
• Competent authorities in supervising the legality of business operations and proceedings, as well as other legal entities when it is necessary to perform our legal obligations, for example, auditors. In this case, these legal entities process your personal data for the purpose assigned to them by law;
• Other parties in connection with business transactions such as the sale of the company or part of the company, reorganization, merger, joint investment or any other type of disposal of our company or property. Also, there may be a need to forward part of your inquiries to contractual partners (e.g. suppliers, architects or contractors in case of inquiries regarding specific products/materials, etc.) for the purpose of processing your inquiry. However, in these cases, the inquiry is anonymized beforehand so that the third party cannot link them to you in any way. If it is necessary to forward your personal data in an individual case, we will inform you in advance and request your consent. Third parties are limited in their ability to use your personal data for any other purpose, except as specified, and are obliged to protect and process your personal data in accordance with legal, regulatory, and contractual obligations. All legal entities with whom we cooperate are selected very carefully and, where required by law, are contractually obligated to keep personal data confidential, in accordance with Article 45 of the Personal Data Protection Act.

TRANSFER OF YOUR PERSONAL DATA TO OTHER COUNTRIES

In certain cases, we may share your personal data, or transfer it to other countries in accordance with the Law. When we do this, we transfer your data to servers located in the EU or in a country that provides an adequate level of protection in accordance with the legislation of the Republic of Serbia. Access will only be granted to a limited number of individuals, or authorized persons exclusively for the purpose of maintaining server functionality.

WAY IN WHICH WE PROTECT YOUR PERSONAL DATA

Some of the protective measures we implement are as follows:

• Application of modern protection methods and control of access to data sources containing personal data;
• Restriction of access to sensitive data as well as restriction of user accounts that can have access to certain data, introducing a role and authorization system that will ensure that only certain employees who require access to data for work tasks can have access and process appropriate data;
• Continuous monitoring of all resources (physical spaces where your data is stored) used for processing personal data.

The purpose of implementing these measures is to prevent the risks of destruction, loss, alteration, unauthorized disclosure or access to your personal data. Using appropriate protective measures with respect to your personal data, we also request them from third parties who have the right to access and process your personal data. All personal data is stored on our server in the Republic of Serbia. Please note that the aforementioned protective measures do not apply to information or data that you choose to share publicly through social media or messaging applications.

RETENTION PERIOD OF YOUR PERSONAL DATA

Personal data is kept for as long as it is necessary to ensure the purpose for which the personal data was collected. If you have concluded a contract with us, we keep your data for the duration of the rights and obligations under the contract, and then as long as applicable regulations require. We retain your personal data even after the termination of the contractual relationship if we need your personal data to establish, exercise or defend legal claims or to comply with applicable laws. To the extent possible, we will limit the processing of your personal data for these limited purposes after the termination of the contractual relationship. After the purpose has been fulfilled or the legally prescribed retention period for personal data has expired, the personal data will be permanently deleted.

YOUR RIGHTS

If you decide to exercise one or more of your rights listed below, we have the right to verify your identity, all for the purpose of protecting personal data. You exercise your rights free of charge. Exceptionally, if your request is obviously unfounded or excessive (for example, you are requesting personal data that you already possess), and especially if the same request is repeated frequently, we have the right to charge necessary costs for processing your request or to refuse to act on your request. Please send all questions and requests related to your rights in written form to the address listed in the section Data Controller. We will respond to your request immediately, and at the latest within one month, unless the exceptional complexity of the individual case requires an extension of the stated deadline. In order to protect you as the data subject, it is necessary for you to properly identify yourself as the applicant, which will represent a guarantee for the Company that personal data is being provided to its owner.

Access to your personal data – You have the right to ask us if we are processing your personal data, to access that data, as well as information about the processing in accordance with Article 26 of the Law.

Correction of inaccurate, supplementation, erasure and limitation of use of personal data – You have the right to request the correction of your inaccurate personal data, as well as the right to supplement, delete, and limit the use of your personal data.

Portability of personal data – You have the right to download and request the transfer of your personal data.

Right to withdraw consent and right to be forgotten – You have the right to withdraw your consent for the processing of personal data, as well as to request the permanent deletion of your personal data that we processed based on your consent.

Objection to processing or treatment of your personal data – You have the right to object to the processing of your personal data, as well as to our general treatment of your personal data. Send your request to us by email at the address listed in the Data Controller section, where you state the Objection to Processing in the subject of the message and explain the reason for the objection and your request in the message itself.

Right to complain to the Commissioner for Information of Public Importance and Personal Data Protection – At any time, you have the right to complain to the competent authority for the protection of personal data – the Commissioner for Information of Public Importance and Personal Data Protection (https://www.poverenik.rs/).

PRIVACY POLICY CHANGES

The Company reserves the right to change these privacy rules at any time. Any change becomes effective after it is published on the Company’s website or by other appropriate means. In this regard, we recommend that you regularly check the section related to the Privacy Policy to have the latest information.

Belgrade, 17.03.2023.