Business Association ICT Cluster of Central Serbia Kragujevac, seated at Trg Topolivaca 4, Kragujevac, Serbia, CIN 28117558 TIN 108126274 (hereinafter: "ICT Cluster", "We" or "Cluster"), in the conduct of its business, collects and processes personal data in compliance with all the relevant regulations.
This Privacy Policy (hereinafter: the “Policy”) explains how Cluster collects, uses and manages your personal data. Cluster is committed to securing and respecting your privacy, in other words, protection and security of your personal data is Cluster’s priority.
Please read this Policy carefully to understand all important issues regarding the protection of your privacy.
Cluster is a data controller i.e. an entity that determines the purposes and means in which personal data are processed, in terms of The Law on Personal Data Protection (hereinafter: the “Law”).
We in the ICT Cluster of Central Serbia take the privacy of individuals very seriously, which is why we have transparent and easy to understand rules on personal data protection.
However, if you have any concerns or concerns about the Policy, please contact us at: privacy@ict-cs.org or 066 / 360-188.
To help you understand this Policy, we have defined certain terms that have been applied in the Privacy Policy.
This Policy, as appropriate and in the relevant sections, applies to the following Data subjects:
Cluster is committed to ensuring the privacy and security of minors on the Internet. Our Website is intended for the general public but is not suitable for persons under the age of 15. Persons under the age of 15 are not allowed to disclose their Data to Cluster. If you believe that we have collected Data of the individuals under the age of 15, please let us know at privacy@ict-cs.org without delay.
We collect Data primarily from you, when you visit Cluster’s Website, apply to attend a course, apply for a job, apply for Cluster membership, sign up for the Newsletter.
Data that we collect through the Website is necessary to provide optimum service to our Website Users. In cases where you do not want to provide us with Data that we need, Cluster cannot guarantee that the information and service provided will fully meet your needs.
Your Data is kept strictly confidential, and each means of data collection has its purpose and legal basis based on the Law.
Certain parts of our Website may contain links to Third-Party Websites. Each of these websites may have their own terms of use and their own privacy policy, which may differ significantly from the one applicable to our Website. We have no control over such websites and shall not carry any responsibility neither for the availability of those websites nor for the terms of use and privacy policy that applies to their visitors and users.
Placing links to Third-Party Websites on our Website does not in any way imply that we recommend or approve services or products offered through such websites.
When visiting these websites, please make sure that you fully understand their privacy policies before revealing any Data.
| PURPOSE | DATA WE COLLECT | LENGAL BASIS |
|---|---|---|
1. Candidates for employment | Data contained in the CV and motivation letter, which you choose to provide to us. | Processing is necessary for the performance of the contract concluded with Data subject or to enter into such contract with Data subject. In the absence of such Data, the contract could not be performed. |
2. Course applicants | Name, surname, email address, phone number, date of birth, Data regarding availability for course attendance, Data about prior knowledge and other personal data contained in documents submitted by Course applicant through the Website or entered in their application. | Processing is necessary for the performance of the contract concluded with Data subject or to enter into such contract with Data subject. In the absence of such Data, the contract could not be performed. |
3. Newsletter | Data that is being collected is email. |
Processing is based on your consent. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal. You may unsubscribe from receiving a newsletter from us. If you wish to do so, simply follow the instructions found at the end of each e-mail. |
4. Contacting Cluster
Or contact the Cluster otherwise. | Other Data including, but not limited to, email addresses, phone numbers, message content, etc. | Processing is based on your consent. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal. |
5. Disclosure of photographs of Courses applicants within the Academy | Photograph | You are not required to give this Consent in which case we will not disclose provided Data. In case that you give your Consent, you may withdraw this Consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal. |
6. Applying for Cluster membership | Name and surname, email, company/ organization name and contact Data such as phone number, address of company’s seat, website, as well as other Data that you choose to provide us with, in the message. | Processing is necessary for the performance of the contract concluded with Data subject. If you do not provide this Data, we will not be able to identify you and to give you access to Cluster membership. |
Additionally, we collect certain Data through the use of cookies and other similar technologies as explained further in our Cookie Policy.
All the above-mentioned Data can be processed with the automated decision- making, including profiling. Profiling is a form of automated processing that is used to evaluate a certain aspect of personality related to the individual, using an algorithm. We could use automated decision-making, which may include profiling based on Data you have already provided to us. If you do not agree with the decision, you the right to present your point of view, and the right to challenge the decision by sending a request to privacy@ict-cs.org in accordance with Article 38 of the Law on Personal Data Protection.
Cluster has implemented appropriate technical and organizational measures to protect your Data from unauthorized or unlawful processing, as well as from accidental or unlawful loss, alteration, or access to your Data. However, please be aware that we cannot eliminate any risk concerning the storage of your Data.
We tend to digitize all of Data we process and store it on the servers of our trusted providers.
Access to places where Data is stored is restricted with access control features. Only personnel authorized to access Data can access the secured zones. Our staff who have access to this Data is trained to understand the importance of personal data, as well as to apply internal procedures to protect Data, and are bound to the obligation to maintain confidentiality.
Protecting your privacy is of great importance to Cluster, therefore we will not share your Data with third parties for purposes other than those described in this Policy.
Access to Data collected by Cluster is reserved exclusively for persons employed in Cluster and persons who are members of Cluster's Board of Directors in accordance with strict internal procedures and an obligation of confidentiality. Data will not be shared with any third parties, apart from the cases listed in this section:
Data collected by Cluster from Course applicant are provided to the companies that are full members of Cluster, provided that Course applicant has attended and successfully completed the course.
Data collected by Cluster from Candidates for employment are provided to the companies that are full members of Cluster.
You can find the list of Cluster members at: https://www.ict-cs.org/en/clanice/.
We require from members of Cluster with whom we share Data to use it solely for employment purposes, and not to use it for any other purpose or contrary to Cluster's instructions. We will not share your Data with third parties who are not members of Cluster or use it for any purpose that does not comply with Privacy Policy.
In certain situations, your Data may be shared with third parties, who provide services to us and are our partners. These include service providers for maintaining our IT systems, marketing or advertising purposes, providing legal services or other services.
According to the signed contracts, these service providers are obliged to use provided Data solely in accordance with our instructions and strictly for the stated purpose. We also oblige them to ensure the confidentiality of Data transmitted to them.
When choosing a partner, we use very strict criteria, among which the existence of adequate procedures for maintaining the confidentiality of Data is one of the most important.
The table below shows our current processors, their role and seat.
| PROCESSOR | ROLE | SEAT |
| Oracle America, Inc. | Analytical services | United States |
| Google, Inc. | Analytical services | United States |
| Facebook, Inc. | Analytical and marketing services | United States |
Cluster will process Data collected for the purpose of fulfilling the rights and obligations arising from the business relationship for the duration of the business relationship with Data subject, except in cases where Cluster is obliged to keep Data after the end of business cooperation with Data subject, in accordance with the law, Consent of Data subject or legitimate interest (e.g. in the event of a potential dispute with Data subject).
Data processed solely on the basis of Consent of Data subject is processed in accordance with the purpose for which Data was collected, until the withdrawal of Data subject’s Consent.
In case when judicial, administrative or extrajudicial proceedings are initiated, Data may be stored until the end of such proceedings.
We keep Data about Website Users who have subscribed to the Newsletter until Website User unsubscribes via emai lprivacy@ict-cs.org.
Data provided by Course applicant is stored in a case that Data subject attends the course. After the course is completed, we store Data for two more years.
We keep Data provided by Candidates for employment for two years after the submission of Data.
As a Data subject whose Data we hold, you have the following rights under the Law:
You have the right to submit a request to Cluster to obtain information on whether We are processing your Data. In the case that your Data is processed, you may request at any time a copy of the personal data we hold about you.
The right of access includes information about the processing purposes, the legal basis, the categories of personal data processed, the recipients or categories of recipients, specially the recipients in third countries or international organisations, the planned duration of storage, information about the rights of the data subject such as rectification, erasure or restriction of processing, the right to object, instructions on the right to lodge a complaint with the authorities.
Information is provided to Data Subject at the earliest convenience, but at a maximum of 30 days from the date the request was received. Where the retrieval or provision of information is particularly complex or is subject to a valid delay, the period may be extended by 60 days where necessary. However, this only applies to exceptional circumstances and We will regularly inform you of any delay or reason for the delay during the process.
If We do not agree with the request to right of access, We will inform you within 30 days about the reasons for rejecting the request and the right to lodge a complaint with the Commissioner for Information of Public Importance and Protection of Personal Data.
If your request is unjustified or excessive, and especially if it is repeated, Cluster may charge the necessary administrative costs for acting on your request or refuse to act on the request, in accordance with the Law on Personal Data Protection.
All Data that we process is reviewed and verified as accurate, whenever possible and updated regularly. If you believe that the Data is incorrect or has changed, you have the right to request that Cluster corrects those Data.
You have the right to request from Cluster to delete your Data unless there is a legal obligation to keep that Data or there is a legal basis for refusing a request for deletion of Data (for example, filing, exercising or defending a legal request).
If the accuracy of the personal data is contested, you consider the processing is unlawful but you do not want it erased, we no longer need the personal data but you require it for the establishment, exercise or defense of legal claims or you have objected to the processing and verification, you can exercise your right to the restriction of processing.
You have the right to request the transfer of data to another operator if the processing is based on your consent or by automated means. We make sure that all personal information is readily available and is in a structured, commonly used and machine-readable format.
You have the right to object to the way we handle your Data if the processing of the Data is based on the legitimate interest of Cluster. In addition, you may object to the processing of your Data for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing.
If the data processing is based on your Consent, you may withdraw the consent at any time.
You can withdraw your Consent by sending an email to privacy@ict-cs.org or by sending a letter to Trg Topolivaca 4, Kragujevac.
Withdrawal of consent will not affect the lawfulness of data processing based on the given consent, prior to such withdrawal.
For any questions, requests, and information regarding the processing of Data and the exercise of protection of rights in this field, please contact us at:
Email address: privacy@ict-cs.org
Phone number: 066 / 360-188
In writing to: Business Association ICT Cluster of Central Serbia Kragujevac, Trg Topolivaca 4, Kragujevac
Each of these channels of communication must enable our staff to identify you in accordance with the applicable procedures.
If you believe that your Data is being processed illegally, you can lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection, Bulevar Kralja Aleksandra 15, 11000 Belgrade, Serbia, email: office@poverenik.rs or phone number 011 / 3408-900.
Also, if for any reason we are unable to comply with your request, we will always provide you with a written explanation and inform you that you have the right to complain to the Commissioner.
Cluster regularly revises and updates personal data processing information in accordance with changes in its business processes or based on obligations arising from relevant regulations. A valid version of the Policy will always be published on our Website. If there are any changes that significantly affect the processing of personal data, we will immediately post the information on the Website. All changes will be applicable when we publish an updated Policy.
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