Privacy policy

1.PURPOSE OF PERSONAL DATA PROCESSING

The purpose of this Privacy Policy is to explain the manner in which we use your personal data (hereinafter: Personal Data), which personal data about Clients we collect, for what purpose and on what legal grounds we process them, our practices regarding the collection and processing of personal data, their protection, as well as the choices and options available to client in relation to the manner in which your personal data are used, i.e., what rights Clients (hereinafter: Clients) have with respect to their personal data. Considering that, in interactions with Clients, whether through visits to our website, business premises or sales showrooms, or via telephone, the company Delta Real Estate doo Belgrade (hereinafter: the Company) collects personal data.Company aims to inform every individual about all relevant aspects of the collection and processing of personal data, while fully respecting the privacy of its Clients. In accordance with the above, the main purpose of this Privacy Policy is to protect the privacy of every Client.

The collection and storage of Personal Data is carried out in accordance with the Law on Personal Data Protection (“Official Gazette of the Republic of Serbia”, No. 87/2018 – hereinafter: the “Law”), as well as the EU General Data Protection Regulation (EU 2016/679, hereinafter: “GDPR”), where applicable. In the event of processing Personal Data of Clients who are citizens of one of the European Union member states, the Company shall also apply the provisions of the GDPR, to the extent applicable.

You may contact the Company regarding any questions related to the protection of Personal Data at the following email address: zastitapodataka@deltarealestate.rs

2. KEY DEFINITIONS AND TERMS FROM THE PRIVACY POLICY IN ACCORDANCE WITH THE LAW

1. “personal data” means any information relating to a natural person whose identity is determined or determinable, directly or indirectly, particularly on the basis of an identity marker, such as a name and identification number, location data, identifiers in electronic communication networks, or one or more characteristics of their physical, physiological, genetic, mental, economic, cultural or social identity.
2. “processing of personal data” means any operation or set of operations performed, whether automated or non-automated, on personal data or sets of personal data, such as collection, recording, classification, grouping or structuring, storage, adaptation or alteration, disclosure, access, use, disclosure by transmission or delivery, copying, dissemination or otherwise making available, comparison, restriction, erasure or destruction.
3. “special categories of personal data” refer to data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, genetic information, criminal record and biometric data used for the purpose of unique identification.
   (The Company does not collect special categories of personal data from the Client, unless the Client has made them clearly publicly available voluntarily, or if the Company is obliged to do so under applicable regulations.)
4. “data on minors” refers to all data concerning persons under 18 years of age.
   (The Company does not collect data of children under 18 years of age.)

3. WHAT PERSONAL DATA ARE AND WHICH PERSONAL DATA THE COMPANY COLLECTS

The Personal Data of the Client that the Company collects and processes include:

1. Name and surname
2. Contact telephone number
3. E-mail address
4. The content of the communication sent by the Client, such as free-form messages submitted through the contact form, feedback, questions, additional information provided by the Client, and similar.

In certain situations, during direct communication with the Client, the Company may also collect data on marital status, occupation, employment, number of family members, demographic data and similar.

4. METHODS BY WHICH THE COMPANY COLLECTS DATA, WHICH DATA ARE COLLECTED AND FOR WHICH PURPOSE

1) Direct collection of Personal Data from the Client whose data are being processed

a) Provision of services to the Client, i.e., performance of the Agreement concluded with the Company

In order for the Company to provide the service for which the Client engaged it in a timely manner, it is necessary that the Company possesses the following Personal Data of the Client: name and surname, contact telephone number, e-mail address, residential address and data from the Client’s identity card.

The Company processes the Personal Data of the legal representative/contact person/authorised person of the Client on several grounds.

The Company processes the Personal Data of the Client on the basis of the conclusion and performance of the agreement, or for undertaking actions, at the request of the Client, before the conclusion of the agreement. Providing the Personal Data of the legal representative/contact person/authorised person of the Client is a contractual obligation, i.e., the provision of Personal Data is a necessary condition for the conclusion/performance of the agreement, due to which the legal representative/contact person/authorised person of the Client is obliged to disclose the Personal Data to the employees of the Company. Otherwise, the Company will not be able to conclude and perform the specific agreement.

Additionally, in the event that an invoice is issued to the Company, the Company shall store the received invoice, which may contain the personal data of the legal representative/authorised person of the Client, in its databases for the purpose of fulfilling legal obligations (tax and accounting regulations). For clarification, in this case, the Personal Data from invoices are not processed individually, while the invoices are kept for five years in the Company’s databases.

When Personal Data are processed on the basis of the conclusion and performance of the agreement, or for the performance of an action that forms part of the pre-contractual phase, the purpose of processing Personal Data is the conclusion of the specific agreement or the performance of the agreement. Actions for the performance of the agreement often involve making Personal Data available to third parties, in order for the agreement to be fully executed.

When Personal Data are processed on the basis of fulfilling obligations, the Company shall use such data exclusively for the purposes of issuing a pro forma invoice or invoice, in accordance with the relevant regulations of the Republic of Serbia.

b) Visits of the Client to the Company’s business premises

During visits to the business premises and sales showroom of the Company, the Company collects and processes the following personal data: name and surname, contact telephone number and e-mail address. The Company collects these data in order to inform Clients via Viber/WhatsApp, by telephone or via e-mail about all news, promotions and discounts, as well as for the purpose of presenting current and future projects of the Company and inviting them to events.

During visits to the business premises and sales showrooms of the Company, the Company also processes personal data through security camera recordings for the purpose of protecting property and the general safety of persons present in the business premises and sales showrooms of the Company, as well as for the personal safety of the Client during the visit, and for the collection of data in the event of extraordinary incidents (theft, property damage, etc.).

In accordance with the above, the Company processes the Personal Data of the Client on the basis of legitimate interest, which consists of preserving the safety of property and persons located in the business premises and sales showrooms of the Company, i.e., preventing extraordinary incidents or collecting data in the event of such incidents.

The Personal Data collected in the manner stated above are stored in the Company’s databases without time limitation, i.e., until consent is withdrawn, except for the data collected through security camera recordings, which the Company stores in its database for 30 days, unless an event occurs that initiates court proceedings, in which case the data are stored until the final conclusion of the proceedings, i.e., until the expiry of the statutory limitation period. After the expiry of such periods or withdrawal of consent, the data shall be deleted or destroyed.

c) Conducting marketing and other promotional activities of the Company

During promotions and other promotional activities of the Company, the Company may collect the following Personal Data of the Client: name and surname, contact telephone number and e-mail address. The Company collects these data in order to inform the Client via Viber/WhatsApp, by telephone or via e-mail about all news, promotions and discounts, as well as for the purpose of presenting current and future projects of the Company and projects of persons affiliated with the Company, conducting surveys and inviting Clients to the Company’s events.

The Personal Data collected in this manner are stored in the Company’s databases for as long as the Client does not withdraw consent.

d) Visits to and use of the website – www.deltadistrict.rs

When the Client visits and uses the Company’s website, Personal Data are collected through the completion of the Company’s contact form by the Client, as well as through cookies, more about which you may read in the Cookie Policy.

The Company collects the following Personal Data of the Client in this manner: name and surname, contact telephone number, e-mail address and the content of the communication sent by the Client, such as free-form messages submitted through the contact form, feedback, questions, additional information provided by the Client, and similar. The Company collects these data in order to inform the Client via Viber/WhatsApp or via e-mail about all news, promotions and discounts, as well as for the purpose of presenting current and future projects of the Company, conducting surveys and inviting Clients to the Company’s events.

The Personal Data collected in this manner are stored in the Company’s databases for as long as the Client does not withdraw consent

e) Newsletter subscription.

When subscribing to the newsletter, the Company collects the following Personal Data of the Client: name and surname, and e-mail address.

The purpose of processing the stated Personal Data is the sending of notifications regarding special and personalised offers, news and events organised by the Company, internet promotions and other promotional activities.

The stated Personal Data are stored in the Company’s database for as long as the Client does not withdraw consent.

f) Contacting employees of the Company by the Client

When the Client directly contacts employees of the Company by telephone or any other oral or written means, the Company collects the following Personal Data: name and surname, e-mail address, contact telephone number, as well as the content of the Client’s comment written in free form.

The purpose of processing the stated Personal Data is establishing communication with the Client, in order to provide answers to enquiries or to clarify requests. The provision of the stated Personal Data is a necessary condition for establishing communication between the Client and the Company. Otherwise, the Company would not be able to respond to the Client’s enquiries.

The stated Personal Data are stored in the Company’s database for as long as the Client does not withdraw consent.

2) Personal data provided by other persons

There are instances where the Client may provide the Company with Personal Data of third parties, in which case the Company shall consider that the Client has been authorised to act in such a manner by that person, and in no event shall the Company bear responsibility for the processing of Personal Data of the third party,

5. LEGAL BASIS FOR DATA PROCESSING

The legal bases for data processing are:

• Client’s consent

The Personal Data of the Client obtained by the Company on the basis of consent shall be processed and stored for as long as the Client’s consent exists, i.e., until any possible withdrawal of consent by the Client. The Client may withdraw consent for the collection, processing and use of data at any time by sending an electronic request to the following e-mail address: gdpr@deltaholding.rs. Withdrawal of consent does not affect the lawfulness of the processing of Personal Data carried out on the basis of the Client’s consent prior to the withdrawal.

• Performance of contractual obligations

The Company collects the personal data necessary for the conclusion and performance of the agreement with the Client and for fulfilling pre-contractual obligations. If the Client does not provide the necessary Personal Data, the Company will not be able to process the Client’s request nor conclude an agreement with them.

• Legitimate interest

The Company processes Personal Data for the purpose of safeguarding the legitimate interests of the Company. Legitimate interests of the Company particularly include the protection of property and the general safety of persons.

• Compliance with legal obligations

To the extent that the processing of the Client’s Personal Data is necessary for the fulfilment of the Company’s legal obligations, i.e., obligations defined by various laws, the Company processes and stores the Client’s Personal Data within statutory time limits.

6. RECIPIENT AND THIRD PARTY

The Company discloses Personal Data to certain recipients, i.e., third parties, namely: affiliated persons within the territory of the Republic of Serbia, employees, companies providing security services for premises, property and persons, providers of legal services, marketing associates and external associates for marketing purposes, IT service providers, servers/companies, external auditors, accounting and bookkeeping agencies.

The Company will not make the Client’s Personal Data available to other recipients, i.e., third parties, except in the cases specified in this Privacy Policy, nor will the personal data be transferred to other countries.

7. CLIENT RIGHTS REGARDING THE PROCESSING OF PERSONAL DATA

The person to whom the Personal Data relate has the right:

• to request from the Company information on whether it processes their Personal Data and access to such data;
• to request from the Company the correction, amendment or deletion of their Personal Data and the right to object to the processing;
• to lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection;
• to have their inaccurate Personal Data corrected without undue delay. Depending on the purpose of the processing, the Client has the right to supplement their incomplete Personal Data, which includes providing an additional statement;
• to have the processing of their Personal Data restricted by the Company if one of the following cases is fulfilled:
  
  1. the person to whom the data relate disputes the accuracy of the Personal Data, within a period enabling the Company to verify the accuracy of the Personal Data;
  
  2. the processing is unlawful, and the person to whom the data relate opposes the deletion of the Personal Data and requests the restriction of their use instead;
  
  3. the Company no longer needs the Personal Data for achieving the purpose of processing, but the person to whom the data relate has requested them for the submission, exercise or defence of a legal claim;
  
  4. the person to whom the data relate has submitted an objection to the processing in accordance with Article 37, paragraph 1 of the Law, and an assessment is underway as to whether the legal basis for the processing outweighs the interests of the person.

The Company is obliged to inform all recipients to whom the Personal Data have been disclosed of any correction or amendment or deletion of Personal Data or restriction of their processing in accordance with the Law, unless this is impossible or requires a disproportionate expenditure of time and resources. The Company is obliged to inform the person to whom the data relate, at their request, of all such recipients.

The person to whom the data relate has the right to receive their Personal Data previously provided to the Company in a structured, commonly used and machine-readable format, and has the right to transmit those data to another controller without hindrance from the controller to whom those data were provided, in accordance with the Law.

If considered justified in relation to the specific situation in which they find themselves, the Client to whom the data relate has the right to submit an objection at any time to the Company regarding the processing of their Personal Data, in accordance with the Law.

The Client to whom the data relate has the right not to be subject to a decision based solely on automated processing, including profiling, if such a decision produces legal effects concerning them or significantly affects their position.

Procedure in the event of a Personal Data breach
If a personal data breach may result in a high risk to the rights and freedoms of natural persons, the Company is obliged to notify the person to whom the data relate of the breach without undue delay, in accordance with the Law.

In the event of a personal data breach that may result in a risk to the rights and freedoms of Clients, the Company is obliged to notify the Commissioner for Access to Information of Public Importance and Personal Data Protection without undue delay or, if possible, within 72 hours of becoming aware of the breach. The notification submitted to the competent authority contains all information in accordance with the Law.

Transfer of Personal Data to other countries
The transfer of Personal Data to another country or an international organisation without prior approval may be carried out if it has been established that such other country/international organisation ensures an adequate level of personal data protection. In this regard, the Decision on the list of countries, parts of their territories or one or more sectors of certain activities in those countries and international organisations in which it is considered that an adequate level of personal data protection is ensured (“Official Gazette of the RS”, No. 55/2019) (hereinafter: the “Decision”) determines where an adequate level of personal data protection is deemed to be ensured. However, in this specific case there is no transfer of data to other countries.

Links to third-party websites and services
The Company’s website may contain links to third-party websites. The Client should bear in mind that the Company is not responsible for the collection, use, maintenance, sharing or disclosure of data and information by third parties. If the Client provides information on the websites of third parties and uses those websites, the privacy policies and terms of use of such third parties shall apply. The Company always recommends that the Client read the privacy policies of the websites they visit before submitting Personal Data.

By clicking the LinkedIn, X, Facebook, Instagram, TikTok or YouTube button on the Company’s website, the Client accepts the possibility that data on the visit to the Company’s website may be processed by the aforementioned social networks if they have an account on them. To avoid this situation, the Company advises the Client to log out of their user accounts on the respective social networks before clicking the link on the Company’s website to visit the pages of the aforementioned social networks.

Confidentiality of data and transparency
The Client’s Personal Data will be treated as confidential information, and the Company will take appropriate necessary measures to protect them in accordance with the Law. Only persons who, considering the job description they perform, need to be familiar with the Personal Data will have access to them, and only to the extent necessary to perform their duties.

This Privacy Policy is available on the website www.deltadistrict.rs

If we decide to change our Privacy Policy, the changes will be posted and published on the website www.deltadistrict.rs

This Privacy Policy is adopted by the director of the Company, who is authorised to make amendments and supplements to the Privacy Policy when necessary. The Privacy Policy is binding on the Company from the date of its adoption.

If you have any questions or suggestions regarding the processing of your personal data, do not hesitate to contact the Company at the e-mail: zastitapodataka@deltarealestate.rs