KMR DEVELOPMENT d.o.o. Beograd – Savski Venac, a limited liability company with registered seat at the address Kneza Miloša 54, Belgrade, corporate ID no. 21187577 (hereinafter: “we” or “KMR”), as the owner of the website www.knezamilosaresidence.rs , understands the importance of personal data privacy collected and processed by KMR, and hereby informs you of legal basis, purpose, manners and other rules of collecting and processing personal data.
1. Legal basis and purpose of personal data processing
(a) Legal basis for processing personal data
Legal basis for processing your personal data is your explicit consent, as well as legitimate interest of KMR, as the controller of personal data, or third party.
Legitimate interest of KMR for processing personal data exists in case of improving our business and relationship with clients, provided that such interest does not infringe on your rights and freedoms. Legitimate interest of KMR may exist in following situations:
– conducting and analysing our marketing activities/services (e.g. preparing and sending newsletters);
– improving business and advertisement of products of KMR’s affiliated companies, with same or similar business activity;
– fulfilling our responsibility towards the society as a whole, as well as corporate responsible behaviour;
– protection of security and integrity of website;
– preventing and detecting fraud or other prohibited or illegal activity.
(b) Purpose of personal data processing
Your personal data will be processed for the following purposes:
– marketing and promotion of our products;
– communication with you for the purposes of promoting our products, as well as responding to your questions and/or requests;
– following and improving quality of our products and marketing activities and services; and
– cooperation with KMR’s affiliated companies, which conduct same or similar business activity, for purpose of improving their business, marketing and advertisement of their products.
In case of KMR’s intention to process personal data for the purposes other than previously stated, KMR shall provide you with information on such other purpose, as well as all other relevant information in accordance with applicable personal data protection regulation, prior to initiating such processing.
2. Sources and manners for personal data collecting
Your personal data may be collected from the following sources:
(a) directly from you (by visiting out website, filling out website forms, e-mail, telephone);
(b) from publicly available sources (social networks on which you have made your personal data available and other publicly available information).
In cases when we do not collect personal data directly from you, we rely upon the natural persons/companies providing us with your personal data to have given you all required notices, i.e. obtained your consent, if required in accordance with applicable personal data protections regulations.
KMR collects your personal data in several manners:
(a) by using KMR website (please read bellow);
(b) by filling out forms on our website, surveys and other online forms (which may sometimes be conducted by third parties on behalf of KMR);
(c) as part of support and upgrade of our products/services;
(d) while providing technical support, consultation, or product information;
(e) through the process of maintaining and upgrading our products;
(f) through automated means such as communications protocols, e-mail communications and cookies;
(g) through official profiles of KMR on social networks (if such profiles exist) and your use of social connectors in order to network with KMR;
(h) through your interest in KMR advertisement placed on third party sites.
To provide you with timely, high-quality information, we may also ask you to provide us with information regarding your interests and experiences with our products and/or services. Providing us with such information is optional.
Personal data or other data collected online may also be combined with information you provide to us through other sources such as meetings, call centres, or in conjunction with events such as trade shows, training seminars and conferences. Information you supply will relate to the relationship KMR has with you.
Personal data like your name and surname, postal address, e-mail address, telephone and/or mobile number is collected only when voluntarily submitted by filling the corresponding forms and with your consent in cases we have to obtain such consent under the law.
3. Types of personal data we collect and process
We collect only personal data required to fulfil above-mentioned purposes. Depending on circumstances, such may include the following data: name and surname, postal address, your contacts (telephone, mobile number, e-mail) and other personal data required for fulfilling some of the above-mentioned purposes.
In addition, we may collect certain technical information, such as details about your device and IP address by using certain technologies.
We do not collect special types of personal data (e.g. health related data, racial or ethnical background, political opinion, and other data in accordance with applicable regulations).
4. Period of keeping your personal data
Period in which we keep your personal data depends on the particular circumstances and fulfilment of purpose for which personal data was collected.
Your personal data shall be kept only while it is required for the fulfilment of purpose for which they were collected (above-mentioned purposes), responding to your request or longer, in case of statutory obligation.
5. Your rights regarding personal data processing
KMR, as controller, enables you to exercise all rights provided under the personal data protection regulations applicable in the Republic of Serbia, as well as GDPR.
(a) right of access to your personal data:
This right implies you have the option to require to be faithfully and fully informed if we collect and process your personal data, as well as the following information: purpose and type of processing of your personal data, deadline for keeping your personal data, existence of your rights to require correction or deletion of your personal data, as well as other rights.
Before we provide you with such information, and to avoid potential misuse, we may ask you to prove your identity.
(b) right of modification of your personal data:
You have the right to require from us to modify, without unnecessary delay, your personal data which are incorrect, i.e. depending on the purpose of processing, to require additions to incomplete personal data.
(c) right of deletion of your personal data:
Based on this right, you may submit request for deletion of your personal data which we process, if such data are no longer required for fulfilment of the purpose they were processed for, or you have revoked your consent and no other legal basis exists for processing of your personal data (e.g. processing is required for meeting statutory obligations by KMR, i.e. submitting, exercising or defending legal request).
(d) right to restrict processing:
This right implies your option to restrict processing of personal data if:
– you contest accuracy of personal data, within timeframe in which we can check and confirm their accuracy;
– processing is illegal, and you object to deletion of personal data, but instead of deletion you request restriction of use of personal data;
– KMR does not require personal data for the fulfilment of purposes, but you have requested personal data for the purpose of submitting, exercising or defending legal request; or
– you have submitted complaint to processing claiming that legitimate interest does not exist for processing of your personal data, and valuation whether legal basis for processing by KMR outweighs your interests is ongoing.
(e) right to be informed in relation to modification or deletion of your personal data, as well as restrictions to processing;
(f) right to object the personal data processing:
You may object to processing of your personal data to KMR anytime you believe legitimate interest for processing of your personal data does not exist or that the processing is not required for the purpose of conducting activities in public interest/execution of statutory authority. KMR is required to cease personal data processing, unless KMR presents you with existence of statutory reasons that such processing outweighs your interests, rights and freedoms, or are related to submitting, exercising or defending legal request.
You may object to processing your personal data if such processing is done for the purposes of direct advertisement and profiling, to the extent to which it is related to direct advertisement, at any time.
(g) right of personal data portability:
This right implies you may receive from KMR your personal data, previously provided to KMR, in structured, usually used and electronically readable form and transfer them to the other controller, without omissions from KMR, provided that all conditions under applicable personal data protection regulations are fulfilled, as well your right to have your personal data directly transferred to other controller by KMR, provided it is technically possible.
(h) right to revoke consent:
You may revoke consent given to KMR to process your personal data at any moment by contacting us (as specified below in point 13). However, personal data processing done based on a consent prior to revocation shall not be affected by such revocation.
(i) right to file a complaint to the Commissioner:
If you are fully or partially unsatisfied with our response to your question and/or request, or we do not provide you with the response to your question and/or request, i.e. you believe that processing of your personal data is conducted contrary to the applicable laws, you have the option to file a complaint to the Commissioner for information of public importance and personal data protection of Republic of Serbia, in the following manner:
postal address: Bulevar kralja Aleksandra 15, 11000 Belgrade,
contact phone: +381113408900
Related to all question and/or request, you may contact us by using contact information as listed below (point 13).
KMR will respond to your request without delay, or at latest 30 days from the date of receipt of such request. This deadline may be prolonged by additional 60 days (in total: 90 days), provided that request is complex or numerous requests have been submitted. KMR will inform you about such prolongation within 30 days from the date of receipt of the request.
In case of violation of your personal data which may cause risk to rights and freedoms of natural persons, KMR is obliged to inform the Commissioner for information of public importance and personal data protection of Republic of Serbia, without unnecessary delay, or if possible within 72 hours from acknowledgement of such violation. If KMR does not provide notification on violation in aforementioned manner, KMR is obliged to explain the reasons for which it did not act within specified deadline.
In case a violation of personal data is such that it can cause great risk to rights and freedoms of natural persons, KMR is obliged to inform you without unnecessary delay about such violation.
6. Collecting personal data over internet
(a) Web Server Logs
In the process of administering this website, we maintain and track usage through Web server logs. Web server logs provide information such as what types of browsers are accessing our site, what pages receive high traffic, and the times of day our servers experience significant load. We use this information to improve the content and navigation features of our website. Anonymized or aggregated forms of this data may be used to identify future features and functions to develop for the website and to provide better customer service.
Our website may set cookies to collect aggregate usage information that we use to improve how the website works. We use these cookies to improve your user experience so we can better serve you when you return to our website. KMR will consider your use of the website as your consent for KMR to set these types of cookies.
KMR may work with select third-party partners who set cookies to serve you KMR-related content, including KMR advertisements, on their sites or elsewhere on the Internet, based on your prior visits to our website. KMR also sets cookies that look at your preferences when you use the website so that KMR may offer you tailored marketing collateral, such as whitepapers, that you may be interested in. You may need to enable use of these kinds of cookies via the mechanism provided by KMR for these cookies to work. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. By using our website, you agree that we can place these types of cookies on your system. For more information, please refer to user information provided with your Web browser. At any time, you have option to reject such ”advertising” cookies, i.e. participating in so called ”behavioral” advertising, i.e. marketing. Please note that if you disable cookies, some site functionality may be limited.
(c) Web Beacons
Our website and HTML-formatted e-mail use Web beacons in conjunction with cookies to compile aggregate statistics about website usage. A Web beacon is an electronic image, called a single-pixel (1×1) or clear GIF. Web beacons can recognize certain types of information on a visitor’s computer, such as a visitor’s cookie number, time and date of a page view and a description of the page where the Web beacon is placed. You may render some Web beacons unusable by rejecting their associated cookies.
(d) Personalized URL Links and Personalized Message Content
Occasionally, we may create and publish a unique web URL link for certain visitors. If you visit one of these websites, you may find forms that are already filled out with your name, or other types of information you have previously indicated an interest in, based on information you have given us before. We may also personalize the content of newsletters, e-mail offers, invitations, or KMR advertisements served to you on our third-party partners’ websites, based on topics in which you have previously indicated an interest. We collect information about how you consume this type of personalized information in order to help us provide you with other information that is better tailored to your interests. If you choose to visit one of these personalized web URL links, you are agreeing to allow KMR to collect information about your visits and also to associate that information with other information about you and your relationship with KMR. If you do not wish your information to be used in this way, do not accept the invitation to visit these websites.
7. Other Technologies
We may use other technologies to capture specific data, such as the pages you view, the items you download, the links you click, your access times, and your Internet Protocol (IP) address, domain name, and system configurations and settings, to help us understand how you use KMR-affiliated technologies, to serve you relevant content, and to assist you with questions you may have regarding our products and/or services. If you decided that you want to fine-tune the information that KMR is providing to you, we invite you to update your data provided by filling out forms on our website.
KMR may use your personal data in justified reasons to:
– establish communication with you regarding your interests in our products;
– make the website easier for you to use;
– help us customize content most relevant to your interests;
– notify you about important news concerning KMR and/or provide you with other information you may require;
– notify you of new products and services, product updates, events and special offers we think you may be interested in;
– promote our products and services on our website and third-party partners’ websites;
We do analyse some of our Web services such as filling out website forms and e-mail responses at the individual level in order to improve the quality of those offerings and to better tailor our marketing to our customers’ needs.
8. Sharing your personal data and transfer of your personal data outside of territory of Republic of Serbia
(a) Sharing your personal data:
We will not share your personal data with third parties, unless it is required for the fulfilment of our legitimate professional and business needs, to act upon your request, and/or when applicable law or professional standards require or enable such for us.
We may share personal data you provide to us:
– with our affiliated companies: your personal data may be shared with our affiliated companies, which conduct same or similar registered business activity, when necessary or desirable for the purpose of improving business of such companies. Our affiliated companies may use your personal data to establish communication with you for the purpose of promoting its products, as well as conducting, analysing and improving marketing campaign;
– with our service providers: your personal data may be shared with our service providers for development and maintenance of our website, accounts on social networks, as well as other service providers for above described purposes. KMR and all such subjects, which may have access to your personal data and process them upon KMR’s request (thus, they may be considered as processors pursuant to relevant data protection regulations), enter into contracts regulating, among other, personal data protection;
– other receivers with which we share your personal data based on your request: we may share your personal data with other third parties to which disclosure is required, and which do not act on our behalf (e.g. public notaries or banks), as well as competent authorities to fulfil statutory obligations.
We will not sell, rent or lease to others your personal data. KMR reserves the right to disclose any and all of your personal data to law enforcement or other governmental officials, including authorities for criminal prosecution, if obliged so by the law.
(b) Transfer of your personal data outside the territory of Republic of Serbia
KMR may transfer your personal data to affiliated companies and/or service providers with residence and/or registered seat outside the territory of Republic of Serbia for above described purposes.
Such transfer is done subject to all security aspects of your personal data, always justified and in a consistent manner. If it is required to transfer your personal data to the country in which law provides less protection for your personal data, i.e. proper personal data protection levels are not met, such transfer must be regulated by contracts between KMR, as controller, and such third parties, which include standard contractual clauses provided by or contractual provisions previously approved by the Commissioner for Information of Public Importance and Personal Data Protection of Republic of Serbia.
9. Choice / Opt-Out
KMR offers you the choice of receiving different types of communication and information related to our company, products and services. You may subscribe to e-newsletters or other publications (if available). Furthermore, you may elect to receive marketing communications and other special offers from us via e-mail. If at any time you would like to change your communication preferences, please send us information on contact data as prescribed below (point 13).
10. Our Commitment to Data Security
KMR is concerned about the security of your personal data in accordance with personal data protection regulation in force in the Republic of Serbia and GDPR. To prevent unauthorized access or disclosure, to maintain personal data accuracy, and to ensure the appropriate use of personal data, we have put in place reasonable technical, managerial and personnel measures and procedures to safeguard and secure the personal data we process.
11. External Links
Links to third-party websites from this website are provided solely as a convenience to you. If you use these links, you will leave this website. We have not reviewed these third-party websites and do not control them. KMR does not assume responsibility for any of these websites, their content, or their privacy policies. KMR does not endorse or make any representations about them or any information, software or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party websites linked to this website, you do so at your own risk.
12. Changes to this Policy
13. How to Contact Us
Should you have comments, objections or questions related to the processing of your personal data, i.e. enjoying any of your rights in connection therewith, you may contact us by:
Mail: KMR Development d.o.o., Kneza Miloša 54, 11000 Belgrade