Company ODM Collections doo Beograd (Savski Venac), with its registered seat at No 20 Lomina St., Belgrade, registered number: 20899603 (hereinafter: Company) makes every effort to comply with the relevant regulations on the protection of personal data and to enable the exercise of the rights of the data subjects. Accordingly, this Privacy Policy is made in accordance with the Data Protection Law of the Republic of Serbia (“Official Gazette of the RS”, No. 87/2018), including its by-laws (hereinafter: Relevant laws).

This Privacy Policy provides only the general review of the personal data processing and protection system implemented by the Company. Accordingly, the Company may, if necessary, and in particular at your request, provide you additional information related to the processing of your personal data.

The Company reserves the right to modify and supplement this Privacy Policy if necessary, in particular in the event of change of the relevant laws and/or methods of processing and measures of protection of the personal data. Accordingly, every time you review this Privacy Policy please check when it was last updated.

This Privacy Policy provides information on:

1. METHOD OF COLLECTION AND PROCESSING OF YOUR PERSONAL DATA
2. CATEGORIES OF DATA SUBJECTS COVERED BY THE DATA PROCESSING AND PURPOSES OF DATA PROCESSING
3. PERSONS TO WHO WE DISCLOSE PERSONAL DATA
4. COOKIES
5. DATA TRANSFERS
6. MEASURES FOR PROTECTION OF PERSONAL DATA
7. EXERCISE OF THE RIGHTS OF DATA SUBJECTS
8. COMPANY’S CONTACT DATA
9. METHOD OF COLLECTION AND PROCESSING OF YOUR PERSONAL DATA

The Company seeks to collect personal data directly from the data subject. As a rule, this will be the case when we establish the first contact and cooperation with you. However, in certain cases, collection of personal data directly from the data subject is not possible or is not an effective solution given the nature, legal basis and purposes of the data processing. Accordingly, the Company may collect and process your personal data provided by other parties. Other persons are, as a rule, Clients, i.e. entities with which the Company has a contract. At the same time, given the nature, legal basis and purposes of the data processing, your personal data may be disclosed to the Company by the competent state authorities and other persons in the appropriate judicial, administrative or enforcement and security proceedings. Regardless of the way personal data are collected, the Company is focused on establishing and implementing appropriate mechanisms to enable the exercise of the rights of individuals regulated by the relevant laws.

When processing your personal data, the Company complies with the basic processing principles defined by the relevant laws. Accordingly, the Company strives for the processing of your personal data to be lawful, fair and transparent, and to be conducted solely to the extent necessary for the accomplishment of expressly specified and justified purposes. Considering the fact that the processing of personal data creates a number of obligations for the Company, the Company has an interest in processing the minimum of personal data necessary for the accomplishment of the purposes of the data processing within the deadlines justified by the purpose of the data processing. We strive to keep your personal data updated and accurate and in this regard we invite you to help us by pointing out the need to correct and supplement your data. The Company undertakes a number of measures and invests considerable resources in order of the establishment of the effective system of protection of your personal data.

2. CATEGORIES OF DATA SUBJECTS COVERED BY THE DATA PROCESSING AND PURPOSES OF DATA PROCESSING

The Company processes data of its employees and other engaged persons, as well as personal data of the candidates for employment, i.e. for establishing business cooperation with the Company, solely for the purposes and to the extent necessary for the fulfillment of the Company’s legal obligations in the area of labor, social security, social protection and other legal obligations of the Company related to the establishment of the employment relationship, i.e. establishment of the cooperation with these persons, as well as for the conclusion and execution of the employment contract, or other contract concluded with these persons.

The Company also processes personal data of the persons to whom the Company or a person to whom the Company provides services in the area of the Company’s business, has a claim, in order of collection or realization of the said claim.

The Company also processes the personal data of users of the Website for the purpose of enabling more efficient use of the Website, improving the business and work of the Company and the Website.

3. PERSONS TO WHO WE DISCLOSE PERSONAL DATA

The basic policy of the Company from the aspect of sharing or exchange of personal data is to undertake the same only if it is necessary, in compliance with all the rules and obligations established by the relevant laws regarding such transfer.

Considering the fact that modern terms of doing business require work division and specialization, your personal data may be transferred to the persons engaged by the Company for providing specialized services, or whose applications and technologies the Company uses, to the extent that such delivery is necessary for the performance of a contract concluded with these subjects.

Your personal data may also be disclosed to the competent authorities in proceedings for the exercise of your rights and/or the rights of the Company, as well as for the execution, supervision of execution and proving the fulfillment of your and/or the obligations of the Company established by the law or contract.

4. COOKIES

For more efficient and better use of the functions of our Website, as well as in order to improve the Company’s Website and business, the Company uses Cookies: session cookies and third-party cookies. You can find more information about the processing of personally data via Cookies HERE.

5. DATA TRANSFERS

We would like to inform you that the Company does not transfer personal data outside the borders of the Republic of Serbia, except for the information collected through third-party cookies that may be stored on servers outside the Republic of Serbia.

When considering the nature, legal basis and purposes of processing, the need for the transfer of personal data to other countries and international organizations arises, if such countries and international organizations do not provide an adequate level of protection in accordance with the relevant regulations, the Company will endeavor to provide implementation of appropriate personal data protection measures.

6. MEASURES FOR PROTECTION OF PERSONAL DATA

The Company is taking significant steps related to education of its employees and other engaged persons on issues relevant to the personal data protection. All persons involved in the processing of personal data carry out the processing on the basis of the authority given by the Company in which restrictions on access and processing of personal data, conditions and responsibilities regarding the processing of personal data are regulated. Accordingly, the need-to-know-basis principle applies within the Company. At the same time, all persons involved in the processing are obliged to keep the confidentiality of the data related to the processing.

In order to ensure compliance with relevant regulations, the Company has brought a number of internal procedures and acts applicable to the processing of personal data within the Company. At the same time, the Company also gained a Certificate of Implementation of the Management System that complies with the requirements of ISO / IEC 27001: 2013.

The Company takes appropriate measures of physical and technical protection of personal data which prevents unauthorized access and processing of personal data, but at the same time protects the integrity of personal data. The personal data protection measures applied are tested by the Company in order to assess the need for improvement and modification of such measures.

7. EXERCISE OF THE RIGHTS OF DATA SUBJECTS

For more information on personal data processing carried out in relation with this Website click HERE.

Internal procedures within the Company, as well as contracts concluded by the Company with other persons, establish mechanisms to enable the exercise of the rights of persons whose personal data are processed. If the Company is not authorized to respond to your request in the specific case, the Company will forward your request to the authorized person.

In order to enable the exercise of the rights of persons more efficiently, the Company has prescribed a form of request for the exercise of the rights of persons in relation to the processing of personal data. You can download the form of the request HERE.

Of course, you are not obliged to use the form made by the Company, i.e. you can submit the request in a free form or in any other way you find more appropriate, i.e. in a way that you find simpler and more efficient.

8. CONTACT US

For all additional questions, especially for submission of the request for exercise of your rights arising from data processing, please contact us through the following contact data:

ODM Collections doo Beograd (Savski Venac)
No 20 Lomina St., Belgrade
phone number:  011/26 42 273
e-mail: office@odmc.rs

COMPANY’S DATA PROTECTION OFFICER
No 20 Lomina St., Belgrade
phone number:  011/26 42 273
e-mail: jovan.ninkovic@odmc.rs