Politika privatnosti
The company Kameleon Solutions doo Identification No. 110665696 , with the registered office in Belgrade, Užička 41, Postal Code 11000 (hereinafter referred to as the “Controller”) pays attention to protection of Your personal data, in compliance with applicable legislation, from 15 October 2018 represented in particular by Regulation of the European Parliament and of the Council (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as the “Regulation”). These principles of personal data protection (hereinafter referred to as the “Principles”) relate to all personal data processed by the Controller on the basis of performance of a contractual relationship, given consent, legal obligation or legitimate interest. The Principles describe the means of using and protection of personal data by the Controller.
Contact data of the Controller
The contact data of the Controller are as follows:
address: Užička 41, 11000 Belgrade, Serbia
email: office@kameleonsolutions.com
telephone: +381 11 4141120
The Controller has not designated a data protection officer within the meaning of Article 37 of the Regulation.
Personal data processed by the Controller
Personal data mean any and all information about an identified or identifiable natural person. An identifiable natural person is a natural person who may be directly or indirectly identified, primarily by reference to a particular identifier, e.g. name, identification number, location data, network identifier or to one or more specific elements of physical, physiological, genetic, psychological, economic, cultural or social identity of such natural person.
The Controller is an operator of websites at the address www.kameleonsolutions.com (hereinafter referred to as “websites”), through which it offers its services and products. Contact forms are placed on the mentioned websites the contact forms. The Controller requires the following personal data for completing the contact form: name, surname, telephone, email and also data on the company for which you are working and your work position. The data of the company and the work position serve primarily to adaptation of the Controller´s offers to your needs and demands.
In case of concluding an agreement between You and the Controller, the Controller requires Your identification data (e.g. name, surname, telephone, address, date of birth) or other data necessary for performance of the agreement, if needed.
The Controller is not processing any of Your personal data, unless you have given your consent or in cases where legal regulations enable processing of personal data without any consent. Your consent is only one of the legal bases applicable for personal data processing. The Controller demands your consent to processing of Your personal data in particular in case of sending commercial communications, offers of services and products and information on events organized by the Controller, including sending invitations to such events.
When using the website the Controller registers your IP address and standard data, such as the type of your browser and references to other websites which you were viewing on the Controller´s website. This information serves to monitoring and prevention of frauds, detection of problems and processing of statistical that are anonymous and do not specify Your personal data.
Purposes of personal data processing
The Controller is processing Your personal data for the following purposes:
- pre-contract negotiations;
- performance of contractual relation;
- asserting claims from contractual relations after termination of the contract;
- contacting for the purpose of responding to Your inquiry, providing information on services and products upon Your request;
- sending commercial communications, offers for services and products, information on events organized by the Controller, including invitations to such events and performance of other marketing activities;
- fulfilment of the Controller´s legal obligations in the area of accounting management and taxation;
- improvement of quality of the services provided by the Controller and improvement of the website functions.
Legal basis for personal data processing
The Controller is processing the personal data on the basis of the following legal bases:
- processing is necessary for performance of the contract the party of which being the data subject or for performance of measures adopted prior to concluding the contract upon request of such data subject; providing of personal data is an essential requirement for performance of the contract or for performance of the measures adopted prior to concluding the contract upon request of such data subject; it is not possible to perform pre-contract negotiations, conclude the contract or perform it from the Controller´s side, without provision of personal data;
- processing is necessary for fulfilment of a legal obligation which applies to the Controller;
- processing is necessary for the purposes of legitimate interests of the respective Controller or a third party, excepting cases, where interests or fundamental rights and freedoms of the data subject take precedence requiring personal data protection;
- the data subject has given consent to processing of his personal data for one or more particular purposes. You are giving your consent to processing of Your personal data given to the Controller voluntarily and you have the right to withdraw the consent at any time, through an email sent to the Controller´s email address: office@kameleonsolutions.comproviding Your name and surname by reason of Your identification. Withdrawal of the consent is without prejudice to legality of the processing arising from the consent given before its withdrawal.
The Controller is processing personal data for an unequivocally defined purpose on the ground of the following legal basis:
Purpose of the personal data processing
Processed personal data
Legal basis for personal data processing
pre-contract negotiations
Identification data (name, surname, date of birth), contact data (address for correspondence or permanent address, email, telephone) and information on the company for which you work and your work position, if need be
implementation of measures adopted prior to concluding the contract upon request of the data subject
performance of the contractual relationship
Identification data (name, surname), contact data (address for correspondence or permanent address, email, telephone) and other information necessary for performance of the contract, if need be (e.g. bank account number)
performance of the contract the party of which is the data subject
asserting claims from contractual relations after termination of the contract
name, surname, telephone, email and information of the company for which you work and your work position, as needed
performance of measures adopted prior to concluding a contract upon request of the data subject
sending commercial communications, offers of services and products, information on events organized by the Controller including invitations to such events and performance of other marketing activities
name, surname, telephone, email and information on the company for which you work and your work position, as needed
giving consent to personal data processing and
legitimate interest of the Controller (direct marketing)
fulfilment of the Controller´s legal obligations in the field accounting management and in the field of taxation
Identification data (name, surname, date of birth), contact data (address for correspondence or permanent address, email, telephone), accounting information (bank account number and other information on tax documents).
fulfilment of the Controller´s legal obligations
improving quality of the services provided by the Controller and improving functions of the website
IP address
legitimate interest of the Controller
Period of personal data processing
The Controller is processing Your personal data for the period necessary to ensure all rights and obligations arising from the respective contractual relationship and also during the period for which the Controller is obliged to store personal data according to generally binding legal regulations or for which you have given your consent. In other cases the period of processing follows from the purpose of processing or is stipulated by legal regulations in the area of personal data protection.
The Controller is processing the personal data according to the purpose of their processing for the period stipulated as follows:
Purpose of personal data processing
Processing period
pre-contract negotiations
during the period of pre-contract negotiation
performance of the contractual relationship
during the term of the contractual relationship
asserting claims arising from the contractual relations after termination of the contract
for the period of 15 years after termination of the contractual relationship, in case of a judicial proceeding for the whole proceeding period
contacting for the purpose of answering an inquiry, providing information on services and products upon request of the data subject
during the term of the negotiation for the purpose of responding, providing information on services and products
sending commercial communications, offers of services and products, information on events organized by the Controller, including invitations to such events and performance of other marketing activities
for the period of 5 years from giving the consent to personal data processing or until withdrawal of the consent to the processing
fulfilment of the Controller´s legal obligations in the field of accounting management accountings and in the field of taxation
for the period of 10 years from the following calendar year after providing the performance
The Controller will erase the personal data after expiration of the period for retention of the personal data.
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Automated individual decision incl. profiling
An automated individual decision, incl. profiling means in general any form of decision based on automated personal data processing, i.e. without human intervention, consisting beside others in assessment of some personal aspects relating to the data subject, in particular for the purpose of analysis or estimation or anticipation of aspects relating to his work performance, economic situation, health condition, personal preferences, interests, reliability, behaviour, place in which it is or movement.
Personal data are processed by the Controller both manually and in an automated way. Personal data are processed in an automated way for the purpose of performance of the contractual relationship, in particular in order to ensure the Controller´s internal processes necessary for ensuring the provided services. The automated personal data processing is also performed in cases there the data subject has given consent to personal data processing for the purposes of sending commercial communications, offers of services and products, information on events organized by the Controller, including invitations to such events and performance of other marketing activities. In such cases profiling may be also performed.
Providing personal data to third parties
Personal data are provided to third parties cooperating with the Controller within the framework of providing the services, participating in delivery of products, performance of payments and ensuring marketing services (i.e. particularly providers of mailing services and cloud services). Such third persons need access to Your data in order to be able to perform their activity and are obliged to respect the principles of personal data processing stipulated by the Regulation in processing Your personal data. An update list of third persons is available at your request.
The Controller does not provide Your personal data to third persons other than the above mentioned without your consent, not even sharing the data with other persons or unrelated companies, except for the following cases:
- compliance with legal regulations or in response to requirements of legal regulations;
- protection of the Collector´s rights and property, their representatives, users and other persons, in particular for the purpose of enforcement of their contracts, principles and user conditions and in cases of urgency for the protection of the security of the Controller, users of its services or any other person;
- in connection with any merge, sale of the company´s property, financing or acquisition of all or a part of the Controller´s enterprise by another company or during such process
The Controller will not transfer Your personal data to a third country or an international organization without Your consent, excepting the above mentioned third persons.
Rights of the data subject
As a subject of data, whose data are processed, you have the below mentioned rights which you may enforce any time. This relates to:
- the right to access to one´s personal data (i.e. the right to obtain the information whether Your data are processed, and if so, you have the right to gain access to such information);
- right to rectification of the personal data (i.e. to require a rectification in case you find that the Controller is processing inaccurate or untrue data);
- the right to request explanation (i.e. if you suspect that your personal data processing breaches protection of Your personal and private life or the processing is performed in violation with legal regulations);
- right to restriction of personal data (i.e. the right to require temporary restriction of your personal data processing);
- right to erasure of personal data (i.e. in case Your data are no more need for the purposes for which they were processed);
- the right to object against personal data processing (the controller is obliged to prove that there exists a legitimate reason for personal data processing which prevails over Your interests or rights and freedoms);
- right to data transferability (i.e. the right to require that Your data are obtained by a third person);
- the right to lodge a complaint with the Office for Personal Data Protection (i.e. in case you believe that Your right for personal data protection was breached);
the right to withdraw the consent with processing of Your personal data at any time; the withdrawal of the consent is without prejudice to the processing based on the consent which was given before its withdrawal.
Security measures and personal data providing
The Controller declares that it has adopted any and all appropriate technical and organizational measures to safeguard personal data.
The Controller has adopted technical measures to safeguard data warehouses and personal data warehouses in paper form, in particular by anti-virus programs, encrypted discs, regular advances and password. Data in paper form are secured by lockable cupboards in the Controller´s premises, in the guarded building. The Controller declares that only persons authorized by him have access to the personal data.
Cookies and web beacons
In order that the Controller may provide the services adapted to Your needs, it uses the so-called cookies (session ID cookies and permanent cookies) to store and occasional monitoring of Your visits of the website. Cookie is a small text file which is saved in your computer for the purposes of recording. The Controller is using cookies in order to enable you navigation on the website. After closing of Your browser the validity of the session ID cookie will expire. The permanent cookie remains on Your hard disc for a longer period. The Controller is also saving a resolution of your screen and finds whether JavaScript is allowed in your browser to facilitate browsing of the Portal. Most Internet browsers are set to accept cookies automatically. You may usually remove or refuse Cookies by following instructions in the supporting file of your Internet browser. However, if you remove cookies, you may not have a possibility to use all aspects of the website in full extent.
The Controller may collect data in using the website also by means of Internet beacons. These guides are electronic pictures which may be used on websites in connection with the services offered by the Controller through the website or email sent by the Controller. It is using beacons in order to pass cookies, count visits and in order to advise You whether any email was opened and handled. The Controller may also collect information about Your computer or about another access device in order to reduce risks and prevent fraud.
The Controller may modify and amend the Principles at any time by placing the revised version on the website and such change and amendment will become effective by the date of such placing.
Effective date: 15 October 2018
Kameleon Solutions doo