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PERSONAL DATA PROCESSING NOTICE

This document comprises information that the controller has to be provide to a person whose personal data are being processed, in accordance with the Law on Personal Data Protection (“Official Gazette of RS”, no. 87/2018) and General Data Protection Regulation, Regulation (EU) 2016/67 (“GDPR”), if applicable.

Examples of situations when your data are collected and processed:

  • when you visit Belgrade360Deck,
  • when you fill in a contact form, send us an email, contact us at info desk or give us a phone call,
  • when you participate in our promotional activities,
  • when you enter into an agreement with us (e.g. you are our customer or you are our supplier).

I IDENTITY AND CONTACT DETAILS OF THE CONTROLLER

Your personal data are collected and processed by BW Kula d.o.o., Beograd, Karadjordjeva 48, corporate id no 21318256 (“BGD360Deck”), as further detailed in this Personal Data Processing Notice. This means that in accordance with the law BGD360Deck is accountable for processing of your personal data.

or any questions about processing of your personal data and to exercise your rights you can contact us by email [email protected] or write to our office address:

BW Kula d.o.o., Beograd – Savski venac,
Karadjordjeva 48,
11000 Beograd.

In certain cases, BGD360Deck has a role of a joint controller. An example is joint liability with a social network operator. On social networks data are mostly processed by such a social network, and in that regards our influence is limited. Detailed information on data processing by operators of social network platforms and options to object can be found in their respective privacy policies.

II CATHEGORIES OF DATA, GROUNDS FOR PROCESSING AND RETENTION

Info desk, Contact center

If you contact our customer service (e.g. call the contact center, or staff at the info desk), directly or through a specific means of communication available to you, we will need your contact information in order to resolve the issue you contacted us about. Such data will be used only for this purpose. Legal basis for processing set out in article 12, paragraph 1, point 6) of the Law on Personal Data Processing, article 6 (1)(f) of the GDPR – pursuing legitimate interests.

Your conversations with the contact center are recorded. These recordings are used to prove the content of the conversation, and to improve the quality of our service. If you do not want the conversation between you and a person from our contact center to be recorded, we recommend that you use another form of communication, such as the contact form, or visit the info desk at the entrance of BGD360Deck.

Tickets

Although the tickets are depersonalized, in the context of the purchase of the tickets on the respective points of sale, the entity that sells tickets collects and processes your data as the controller. Processing is necessary for the performance of the contract (legal basis for processing prescribed by Article 12, paragraph 1, point 2) of the Law on Personal Data Processing, Article 6, paragraph 1(b) GDPR).

Video surveillance (CCTV)

BGD360Deck uses CCTV video surveillance for the safety of people, property and business, as well as for the detection of offences. BGD360Deck clearly and unambiguously, in a visible place, informs its visitors upon entering about the use of video surveillance. This information is stored in a manner that ensures adequate protection of personal data and access is restricted to qualified security personnel only. Legal basis for processing prescribed by Article 12, paragraph 1, point 6) of the Law on Personal Data Processing, Article 6, paragraph 1(f) GDPR – pursuing legitimate interests.

We do not monitor places where it could lead to a violation of your privacy (e.g. toilets). We use recordings exclusively for the purpose of protecting the safety of people, property and business, and we do not perform additional analysis on them. Records are not shared with anyone, except possibly with competent authorities, as evidence for legal proceedings. We have limited the storage time of recordings to 30 days, and after this time, they are permanently deleted.

Commercial Messages

If you subscribed to commercial messages (such as “newsletter”) consent is legal basis to contact you in that way and to inform you on the latest in our and our related parties offer, latest events, and fun that awaits you with us. At any time, you can unsubscribe by clicking on an “unsubscribe” link available in each such message. If there is no other legal basis for processing, after you revoke consent, we will stop processing your data.

LEGITIMATE INTEREST – In accordance with the law and if your interests do not prevail, we process your data for the legitimate interest pursued by us or by a third party, such as protection of our systems, discovery and prevention of attacks to our web site, prevention of fraud and malicious use, resolving problems, response to your questions, direct marketing (outside of situations when consent for receipt of commercial messages is required), video surveillance, and the like. In this context, we have legitimate interest to process data from publicly available records.
You have the right to object to this type of processing at any time. To exercise this right please send us an email or write to the address stated at the beginning of this document. If there is no other legal basis for processing, after you object, we will stop processing your data, unless there are compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.

RETENTION

Generally, we keep your data for the period necessary to achieve purpose of the processing, or for the period required by the applicable laws. If you signed an agreement with us, this means that we will keep your data for the duration of contractual rights and obligations, and thereafter for the period set out in applicable laws.

We retain your data even after the termination of our contractual relationship if we need your data for the establishment, exercise, or defense of legal claims or for compliance with a legal obligation. To the extent possible, we will limit processing of your data to such limited purposes after the termination of contractual relationship.   Data are kept on our server in the Republic of Serbia.

III WHO ELSE HAS ACCESS TO THE DATA

In our operations we use various service providers who, in accordance with our instructions, have access to your data as so-called processors.
Our related parties with whom we share IT systems, who provide us with or to whom we provide business and operations support and with whom we have signed an agreement have access to your data:

  • Eagle Hills Properties LLC, Abu Dhabi, UAE, PO Box 34888
  • Beograd na vodi d.o.o., Karadjordjeva 48, Beograd
  • BW Galerija d.o.o., Karađorđeva 48, Beograd

We can reveal your data to the competent authorities and institutions upon their order or when we believe that is necessary for compliance with legal obligations, or to protect our interests.

We can disclose your data to third parties in case of corporate reorganisation, transfer, or other disposal of any part of busines or assets of BGD360Deck (including mortgage foreclosure, bankruptcy or similar proceeding) or in other case of compliance with legal obligations.

TRANSFER OUTSIDE OF REPULIC OF SERBIA – In compliance with by the law prescribed rules, data are transferred and processed out of Serbia. If data are transferred to recipients outside of the countries members to the Convention of the Council of Europe for the Protection of Individuals with regard to Automatic Processing of Personal Data, transfer is done in compliance with by the law prescribed measures (e.g. by way of standard contract clauses).

IV COOKIES

Read our Cookie Policy here.

V SECURITY MEASURES

We implement safeguards (technical, organizational and personnel measures) to achieve appropriate security level in respect of the risk, in accordance with the level of technological advances and the costs of their implementation, nature, scope, context and purpose of processing, as well as the likelihood of risk occurrence and risk severity to the rights and freedoms of the natural persons.

However, please note that such protection measures do not cover information you choose to share in public e.g. through social networks or messaging applications.

VI YOUR RIGHTS

Upon request, you have the right to receive information about your personal data processed by us free of charge. You have the right of rectification and deletion of your personal data, a right to limitation of processing and a right to data transferability. You have the right to object to processing done by us for our legitimate interests. You have the right not to be subject to a decision based solely on automated means including profiling, if the decision produces legal effects concerning you or significantly affects you. If our processing of your personal data takes place on the basis of your consent, you have the right at any time to revoke this consent. This revocation does not make unlawful the processing that took place before you revoked consent.

In addition, you may complain to the Commissioner for Information of Public Importance and Personal Data Protection, address: 15, Bulevar kralja Aleksandra str, Belgrade 11120, Serbia о[email protected] and you may file lawsuit to the competent court.

For any questions about processing of your personal data and to exercise your rights, you can contact us by email or by mail to the address at the beginning of this document.