Privacy Policy

 

Comtrade Distribution d.o.o. Belgrade is a company from Belgrade, having its registered seat at No. 125i Bulevar Zorana Đinđića Street, 11070 Belgrade, registration number: 17172140, PIB: 100000104, which with great pleasure and a sense of responsibility arranges, as an organizer (“Organizer”), different types of closed events (“Event”) on the territory of the Republic of Serbia.

When organizing an Event, the Organizer collects, processes, uses, and/or discloses (if necessary) personal data of those who apply and/or participate in the Event, as detailed in this Privacy Policy.

The Organizer, as the data controller, processes your personal data in accordance with the applicable Serbian Law on Personal Data Protection (hereinafter referred to as ‘’Law’’).

Organizer’s contact details:

Comtrade Distribution d.o.o. Belgrade
Bulevar Zorana Đinđića 125i
11070 Belgrade
Serbia
E-mail: security@comtrade.com

 

1. Categories of personal information we collect

We collect and process personal data you provide to us through the website https://events.comtradedistribution.com or otherwise.

Depending on the type of Event we organize, we may collect and process the following categories of your personal data:

  • Your first and last name;
  • Your email address;
  • Your phone number;
  • Audio and video recordings and photographs of the Event;
  • Other information that may indirectly identify you (e.g. the name of the company you are working for).

Thus, in order for the Organizer, data controller, to organize a team building for his employees, it is necessary for those who want to participate in a team building to fill out an application, leaving the following information/personal data:

  • Your first and last name,
  • Gender,
  • E-mail,
  • Phone number.

In order for the Organizer, data controller, to successfully organize lectures and/or partner summits, it is necessary for those who want to participate in the lectures and/or partner gatherings to fill out an application, leaving the following information/personal data:

  • Your first and last name,
  • E-mail,
  • Phone number,
  • Company’s name,
  • Position in the company.

In order for the Organizer, data controller, to successfully organize consultations and enable their scheduling, as well as downloading of the brochures, it is necessary for those who want to attend the consultations and download the brochures to fill out an application, leaving the following information/personal data:

  • Your first and last name,
  • E-mail,
  • Phone number,
  • Company’s name,
  • Position in the company.

For the webinars’ organization and realization through Microsoft Teams application for the exchange of messages related to the presentation and sale of the Organizer’s, data controller’s, products. Webinars will be recorded and the recordings used exclusively for the internal needs of the Organizer. It is necessary for those who want to participate to fill out an application, leaving the following information/personal data:

  • Your first and last name,
  • Phone number,
  • E-mail,
  • Company’s name,
  • Position in the company.

In addition to information/personal data that participants will leave when filling out the webinar application, depending on how participants will participate in the webinar, by turning on the camera or uploading an image to a Microsoft Teams account, the Processor may obtain the following information/personal data:

  • Photo of the participant,
  • Audio and video recordings of participants.

 

2. Purpose of processing

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

  • To enable you to participate in the Event in accordance with the article 12, paragraph 1, item 2 of the Law on Personal Data Protection;
  • Successful and efficient organization of the Event, including promotional activities and posting audio and video recordings and photographs of the Event on social networks, such as Facebook, Instagram, LinkedIn, Twitter, as well as on the website comtradedistribution.com in accordance with the article 12, paragraph 1, item 6 of the Law;
  • For sending promotional messages regarding Organizer’s activities, including other Events invitations, if you have given us your consent in accordance with the article 12, paragraph 1, item 1 of the Law.

 

3. Legal basis for processing personal information

We process your personal data on the following legal bases:

  • Your consent;
  • Performance of a contract concluded with you;
  • Legitimate interest of the Organizer in order to organize the Event more effectively.

* Minor website users

A minor who has reached the age of 15, may consent to the processing of personal data on his/her own. In a case of a minor who has not reached the age of 15, the consent of the parent exercising parental right, or other legal representative of the minor, must consent to the processing of his/her personal data.

 

4. Disclosure of personal data

We may disclose your personal data to the following users and in the following cases:

  • To our affiliated companies;
  • To subcontractors, suppliers, and other service providers, who process personal data on behalf of the Organizer, when necessary to provide services to the Organizer, in accordance with our written instructions and for the purposes as stated above;
  • To other recipients, if we are obliged to do so by a court order or an order issued by another authority or by applicable law.

 

5. Transfer of your personal data outside the EU/EEA (this section applies for citizens of EU/EEA)

We may transfer your personal data to the recipients located outside the territory of the Republic of Serbia (“Third Countries”) or to our affiliates and data processors. Having in mind that:

  • The Government of the Republic of Serbia has adopted the Decision on the lists of states, parts of their territories or one or more sectors of certain activities in the Third Countries and international organizations, where it is considered that an adequate level of protection of personal data is ensured;
  • Above-mentioned Decision lists the Third Countries and international organizations that are parties to the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data, providing an adequate level of protection;
  • Above-mentioned Decision lists the Third Countries, parts of their territories or one or more sectors of certain activities in those countries and international organizations, that have been found by European Union to provide an adequate level of protection;
  • The Government of the Republic of Serbia has not decided, due to the local legislation of a country or the international obligations it has undertaken, that the country in question provides an adequate level of protection.

In such cases, Organizer will do its best to ensure that your personal data is given an appropriate level of protection, which includes the use of Standard Contractual Clauses approved by the Commissioner for Information of Public Importance and the protection of personal data for transferring them to the countries that are not labeled as providers of an adequate level of protection. Standard Contractual Clauses are available at the following link: https://www.poverenik.rs/sr/%D0%B7%D0%B0%D1%88%D1%82%D0%B8%D1%82%D0%B0-%D0%BF%D0%BE%D0%B4%D0%B0%D1%82%D0%B0%D0%BA%D0%B0/pravni-okvir-zp.html. For more information regarding the use of Standard Contractual Clauses, please contact us at security@comtrade.com.

In all other cases, we may transfer your personal data to the Third Countries only on the basis of your explicit consent in accordance with the article 69, paragraph 1, item 1 of the Law.

 

6. Transfer of personal data outside the EU/EEA (this section applies to EU/EEA citizens)

As our company’s headquarters are located outside the EU/EEA, we will do our best to ensure that your personal data is given an appropriate level of protection.

We may transfer your personal data to the recipients located outside the EU/EEA (“Third Countries”) or to our affiliates and data processors.

Such data processing and transfer is protected by the following security measures:

  • The European Commission has decided that a specific Third Country provides an adequate level of protection;
  • The US user is bound by the EU-U.S. Privacy Shield, with the European Commission deciding that such companies provide an adequate leve lof protection;
  • The European Commission has not decided, due to the local legislation of a country or the international obligations it has undertaken, that the country in question provides an adequate level of protection.

In such cases, Organizer will do its best to ensure that your personal data is given an appropriate level of protection, which includes the use of Standard Contractual Clauses approved by the European Commission for transferring them to the countries that are not labeled as providers of an adequate level of protection. Standard Contractual Clauses are available in different languages at the following link: https://www.poverenik.rs/sr/%D0%B7%D0%B0%D1%88%D1%82%D0%B8%D1%82%D0%B0-%D0%BF%D0%BE%D0%B4%D0%B0%D1%82%D0%B0%D0%BA%D0%B0/pravni-okvir-zp.html. For more information regarding the use of Standard Contractual Clauses, please contact us at security@comtrade.com.

In all other cases, we may transfer your personal data to the Third Countries only on the basis of your explicit consent.

 

7. The period for which the personal data will be stored

We will keep your personal information for only as long as is reasonably necessary to fulfill the purpose for which the personal information was collected or received, or to act on any request made in accordance with the law. Where your consent is the legal basis on which we process your personal data, we will retain personal data until your consent is withdrawn.

 

8. Protection and security

The Organizer is taking precautionary measures to protect your personal data from loss, misuse and unauthorized access, disclosure, alteration, and destruction. We have taken appropriate technical and organizational measures to protect the information systems where your personal data is stored, and we require that our data processors protect your personal data as agreed in the contract.

 

9. Principles relating to processing of personal information by the Organizer

Except for certain exceptions and limitations foreseen by the Law on Personal Data Protection and applicable regulations, you have the following rights:

  1. Right to be informed about: identity and contact details of a data controller; contact details of persons who provide personal data protection, if specified; the purposes of the intended further processing and legal basis for processing; the existence of the legitimate interests pursued by the data controlleror by a third party; recipient, or a group of a personal data recipients, if any; the fact that the data controllerintends to transfer personal data to a Third Country or an international organization;
  2. Right of access by the data subject which can be limited, in whole or in part, only to the extent and in the duration in which such a partial or total limitation is necessary and is a proportionate measure in a democratic society, with respect to your basic rights and legitimate interests in order to: avoid obstructing official or legal inquiries, investigations or procedures; enable prevention, investigation and disclosure of criminal offences, prosecution of criminal offences, or enforcement of criminal sanctions; protect public safety, protect national security and defense; protect the rights and freedoms of other persons;
  3. Right to rectification of the collected personal data;
  4. Right to erasure (‘right to be forgotten’) of the collected personal data;
  5. Right to restriction of processing if: the accuracy of the personal data is contested by the data subject, for a period enabling a data controller to verify the accuracy of the personal data; the processing is unlawful and you are opposing the erasure of the personal data and request the restriction of their use instead; data controller no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise or defense of legal claims; you objected to processing, pending the verification whether the legitimate grounds of a data controller override yours;
  6. Right to data portability if the processing is based on consent or on a contract and the processing is carried out by automated means;
  7. Right to object to the processing of personal data that you submit to the Organizer as the controller;
  8. Right to not be the subject to a decision based solely on automated processing, including profiling, if that decision produces legal consequences for you or that decision significantly affects your position.

When the processing of your personal data is based on your consent, you have the right to withdraw consent at any time. The withdrawal of consent for future processing of your personal data will not affect the lawfulness of the processing conducted based on your consent prior to the withdrawal. You may withdraw your consent by sending request to: security@comtrade.com.

If you want to exercise any of your above-mentioned rights, or have questions about them, please contact us by sending email to the address: security@comtrade.com.

Also, in addition to the above-mentioned rights, you have the following rights as well:

  1. Right to file a complaint to the Commissioner for Personal Data Protection in the Republic of Serbia;
  2. Right to submit a lawsuit to the governing Supreme Court in the Republic of Serbia.

 

10. Changes to Privacy Policy

We may periodically update this Privacy Policy. The updated Privacy Policy will be published on the website https://events.comtradedistribution.com/, thus visit the website occasionaly in order to be aware of any changes in a timely manner.