Dear Sir/Madam,

DELTA BUSINESS PROPERTIES DOO, BELGRADE (NEW BELGRADE), Vladimira Popovića 6, 11070 Belgrade, registration number: 21594075 (hereinafter: the “Company” or “We”), respects and protects the privacy of every individual (natural persons – clients, potential clients, or other persons – hereinafter collectively referred to as: the “Client” or “You”) whose personal data it collects (hereinafter: “Personal Data”).
The collection and storage of Personal Data are 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: the “GDPR”), where applicable.

In the event of processing Personal Data of Clients who are citizens of one of the European Union Member States, we shall also apply the provisions of the GDPR, to the extent applicable.

We value you and recognize that privacy is important to you. In order to protect the privacy of every Client whose Personal Data we collect, we have published this Privacy Policy, which defines what Personal Data we collect, how and for what purpose we process it, how we protect it, how long we retain it, and what your rights are in relation to Personal Data.
Specifically, we have developed this Privacy Policy to inform you of our practices regarding the collection of Personal Data that we collect from you or about you through this website, via written or oral communication with us, when you visit our business premises, or from other sources.

In any case, you are free to contact the Personal Data Protection Officer at the following email address:gdpr@deltaholding.rs

Basic Terms and Personal Data Processed by the Company

“Personal Data” means any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier.

“Processing of Personal Data” means any operation or set of operations performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, classification, grouping or structuring, storage, adaptation or alteration, disclosure, access, use, disclosure by transmission or delivery, duplication, dissemination or otherwise making available, alignment, restriction, erasure, or destruction.

“Sensitive Data” refers to data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sexual life or sexual orientation, genetic data, criminal records, and biometric data used for the purpose of unique identification.

We do not collect your sensitive data unless you voluntarily make it available to us or if we are obliged to do so under applicable regulations.

“Children’s Personal Data” refers to persons under the age of 18.

We do not collect children’s Personal Data. As a parent or legal guardian, you should not allow your children to disclose their Personal Data without your consent.

Personal Data Collected and Processed by the Company collects and processes about you includes:

  • first and last name,
  • contact phone number,
  • email address,
  • data from your correspondence with the Company.

Method of Collecting Personal Data

1) Direct collection via visits to and use of the website https://deltabusinessproperties.rs/

Personal Data is collected directly from you, as the data subject.
Personal Data that you provide or that we obtain through this website will be used exclusively for responding to your inquiries and/or improving our services, informing you about offers, as well as additional information and updates that may be of interest to you as a user in relation to Delta Business Properties.

2) Indirect collection from third parties

In such cases, the Company shall consider that the person from whom the data was collected was authorized to act on behalf of the data subject, and the Company shall not bear any responsibility for the processing of Personal Data of third parties.

When visiting our website, Personal Data is also collected through cookies, as further explained at:

Purpose of Data Collection

The purposes of data collection are:

  • compliance with the Company’s legal obligations (statutory and regulatory);
  • responding to inquiries, requests, and expressions of interest;
  • preparation of statistical reports on platform usage;
  • invitations to events, establishment and/or maintenance of communication and cooperation.

Legal Basis for Data Processing and Collection

The legal bases for data processing are:

  • Your consent

Personal Data obtained on the basis of your consent will be processed and retained as long as your consent exists, i.e., until it is withdrawn. You may withdraw your consent at any time by sending an electronic request to: gdpr@deltaholding.rs

Withdrawal of consent does not affect the lawfulness of processing carried out based on consent prior to its withdrawal.

  • Legitimate interest

The Company processes Personal Data for the purpose of protecting its legitimate interests, which in particular include protecting the platform against misuse.

  • Compliance with legal obligations

To the extent that processing of your Personal Data is necessary for compliance with the Company’s legal obligations, defined by applicable laws, the Company processes and retains your Personal Data within the statutory retention periods.

Recipients and Third Parties

The Company discloses Personal Data to certain recipients and third parties, including: affiliated entities within the territory of the Republic of Serbia, employees, companies providing security services for premises, property, and persons, legal service providers, marketing partners and external marketing collaborators, IT service providers, external auditors, and accounting and bookkeeping agencies.

The Company shall not make Clients’ Personal Data available to other recipients or third parties except as stated in this Privacy Policy, nor shall Personal Data be transferred to other countries.

Personal Data Retention Period

Data collected on the basis of legal obligations shall be retained for the period prescribed by the relevant law or regulation.

Data processed exclusively on the basis of the Client’s consent shall be retained until the consent is withdrawn.

Your Rights Regarding Personal Data Processing

The data subject has the right to:

  • request information from the Company on whether it processes their Personal Data and access to such data;
  • request correction, supplementation, or deletion of Personal Data, and to object to processing;
  • file a complaint with the Commissioner for Information of Public Importance and Personal Data Protection;
  • have inaccurate Personal Data corrected without undue delay; depending on the purpose of processing, the Client also has the right to complete incomplete Personal Data, including by providing a supplementary statement;
  • request restriction of processing where one of the following applies:
    1) the data subject contests the accuracy of the Personal Data, for a period enabling verification;
    2) processing is unlawful and the data subject opposes erasure and requests restriction instead;
    3) the Company no longer needs the Personal Data for processing purposes, but the data subject requires it for legal claims;
    4) the data subject has objected to processing pursuant to Article 37, paragraph 1 of the Law, pending verification of overriding grounds.

The Company is obliged to inform all recipients to whom Personal Data has been disclosed of any correction, supplementation, erasure, or restriction of processing, unless this proves impossible or involves disproportionate effort. Upon request, the Company shall inform the data subject of such recipients.

The data subject has the right to receive Personal Data previously provided to the Company in a structured, commonly used, and machine-readable format, and to transmit such data to another controller without hindrance, in accordance with the Law.

If justified by their particular situation, the Client has the right to object at any time to the processing of their Personal Data.

The Client has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.

Procedure in Case of a Personal Data Breach

If a Personal Data breach is likely to result in a high risk to the rights and freedoms of natural persons, the Company shall notify the affected data subject without undue delay, in accordance with the Law.

If a Personal Data breach is likely to result in a risk to the rights and freedoms of Clients, the Company shall notify the Commissioner without undue delay, or where feasible, within 72 hours of becoming aware of the breach. The notification shall include all information required by law.

Transfer of Personal Data to Other Countries

Transfer of Personal Data to another country or international organization without prior approval may occur if it has been established that such country or organization ensures an adequate level of Personal Data protection.
The Decision on the List of Countries, Territories, or International Organizations Ensuring an Adequate Level of Protection (“Official Gazette of RS”, No. 55/2019) defines such cases.
However, in the present case, no transfer of Personal Data to other countries takes place.

Links to Third-Party Websites and Services

Our website may contain links to third-party websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data by third parties.
If you provide information on third-party websites, the privacy policies and terms of use of those third parties will apply. We recommend that you read the privacy policies of the websites you visit before submitting Personal Data.

By clicking on Facebook, Twitter, LinkedIn, YouTube, or Instagram buttons on our website, you acknowledge that data related to your visit may be processed by those social networks if you have an account with them. To avoid this, we recommend logging out of your accounts before visiting our social media pages via our website.

Data Confidentiality and Transparency

Your Personal Data will be treated as confidential information, and the Company will take all appropriate measures to protect it in accordance with the Law. Access will be granted only to persons who need such data for the performance of their job duties, and only to the extent necessary.

This Privacy Policy is available on the website deltabusinessproperties.rs.

If we decide to amend this Privacy Policy, changes will be posted and published on the website.

deltabusinessproperties.rs

If you have any questions or requests regarding the processing of your Personal Data, please contact us at:: gdpr@deltaholding.rs

Yours sincerely,
Delta Business Properties