Privacy policy for PULSEC website visitors

Introductory provisions

By privacy protection rules for clients and other participants of the PULSEC d.o.o. Belgrade (hereinafter: “Rules”), PULSEC d.o.o. Belgrade (hereinafter: “PULSEC”) explains how to process personal data of clients and other participants (hereinafter: “Data holder”/ “Data holders”, “You”) in accordance with the General Data Protection Regulation (EU) 2016/679 (hereinafter: “Regulation”), and the “Law on Personal Data Protection” (“Official Gazette RS”, No. 87/2018).

With these Rules, PULSEC provides information about the personal data processing controller, the personal data protection officer, the data that PULSEC collects and processes, for what purpose and on what legal basis, the personal data processor, the storage time of your personal data, data protection and the rights of the Data Holder. These Rules are available on the PULSEC website ( www.pulsec.com ).

Who is responsible for processing your personal data?

The responsible for data processing is:

PULSEC d.o.o. Beograd

Tošin bunar 272b

Telephone: +381 11 697 9470

e-mail: [email protected]

Regarding the processing of your data, please contact the Personal Data Protection Officer (DPO):

Milorad Zrnić

Telephone: +381 66 8042810

e-mail: [email protected]

Personal data we collect and process

We primarily process personal data that you provide us directly, when visiting our website and establishing a business relationship with PULSEC.

Furthermore, we process personal data, to the extent necessary for the provision of PULSEC services, as well as data generated by web cookies and for which you give your consent.

We also process personal data that we have collected from publicly available sources.

Personal data that PULSEC processes are: first name, last name, e-mail address, position/function at the employer, name of the employer.

Purpose and legal basis of personal data processing

We process personal data on the basis and for the purposes of:

1. Implementation of contract and/or undertaking of actions at the request of Data Holder before conclusion of contract

Processing of personal data takes place for the purpose of providing services for the implementation of a contract to which you are a party or in order to take actions at your request before concluding a contract.

1. Legitimate interest of PULSEC or a third party

We also process your data if the processing is necessary for the legitimate interests of PULSEC or a third party.

For example:

• for market research, except for the data you objected to (the right to object is described in a separate section of these Rules),
• for the purpose of court disputes,
• to ensure IT security,
• for implementation of measures for improvement and development of PULSEC’s products and services,

• to detect and/or prevent crime (including fraud prevention), in accordance with applicable law.

1. Consent

The legality of processing your personal data for one or more special purposes is based on your consent when entering into a business relationship with PULSEC.

You can withdraw/revoke your consent at any time. Withdrawal of consent does not affect the legality of processing based on consent that was performed before its withdrawal. Withdrawing consent is as simple as giving it.

1. Compliance with PULSEC’s legal obligations or performance of public interest obligations

As a socially responsible company, PULSEC is committed to fulfilling statutory obligations and regulations (e.g. GDPR).

Who has access to your personal data and to whom we provide your data

Inside PULSEC

Within PULSEC, those organizational units that process your data for the purpose of fulfilling our contractual and legal obligations and achieving the legitimate interests of PULSEC and third parties have access to your data. PULSEC does not provide your data to third parties.

1. Service providers

For the performance of certain services, PULSEC has authorized other service providers (hereinafter: “Service Providers”) to whom it provides your data for the purpose of performing the contracted services. Service Providers are first of all familiar with the fact that your personal data is a secret, and we allow access to your data only to executors, i.e. service providers, who guarantee us the protection of personal data in accordance with the provisions of the Law on Personal Data Protection and the GDPR. Service providers are companies that provide high-tech IT services, support services, telecommunications services, etc.

1. Other recipients of data based on your request for the transfer of personal data

How we protect your data

Protection of your personal data is extremely important to us. Some of the protective measures we implement are as follows:

• establishment of technical and organizational measures necessary to process personal data in a safe manner;
• control of physical and logical access to the information system and business premises of PULSEC;
• establishment of technical and procedural measures necessary for the IT infrastructure to be implemented in accordance with the highest international security standards;
• establishment of electronic and procedural protective measures related to the collection, storage and disclosure of personal data.

How long is personal data kept?

We process and store personal data as long as it is necessary to fulfill contractual and legal obligations or for as long as the session on the website lasts.

If we no longer need your data after the expiration of the contractual obligation, we delete it, and at the latest after the expiration of all legal deadlines for storing personal data.

Your rights

As Data Holders within the meaning of the law and GDPR you have the following rights:

• Right to access information

You have the right to request confirmation as to whether we are processing your personal data, as well as access to your personal data that we are processing. You can exercise the same rights by completing the Request for the exercise of rights (hereinafter: Request).

We will respond to your Request as soon as possible, and at the latest within one month from the date of receipt of the proper Request.

• Right to rectification

You have the right to request the rectification or addition of your personal data by submitting a Request. We will respond to your Request as soon as possible, without unnecessary delay.

• Right to deletion

You have the right to request the deletion of your personal data if:

(I) those data are no longer necessary related to the basis for which they were collected or otherwise processed;

(II) you withdraw the consent on which the processing of your personal data is based, and if there is no other basis for the processing;

(III) you file an objection to the processing and there is no stronger legitimate reason for the processing, i.e. if you file an objection to the processing of data that is processed for the purposes of direct marketing, which includes profiling to the extent that it is related to such direct marketing;

(IV) data were illegally processed;

(V) data must be deleted in order to comply with the legal obligation defined by the Law on Personal Data Protection.

You can exercise your right by submitting the Request. We will respond to your Request as soon as possible, without unnecessary delay.

• Right to restriction of processing

You have the right to request that we do not delete your personal data, but that it continues to be processed on a limited basis (in accordance with the restrictions that you specify) if you need it to exercise your other rights.

You can exercise the aforementioned rights by submitting the Request. We will respond to your Request as soon as possible and at the latest within one month from the date of receipt of the proper Request.

In case of a large number of Requests, as well as in case of the complexity of your query, it is possible that we will need additional time to respond. In that case, we will inform you in a timely manner and answer you not later than 3 months from the date of receipt of the proper Request.

• Right to transfer data

You have the right to request the transfer of your personal data. You can exercise such right by completing the Request. On the Request, you need to select the categories of personal data that are of interest to you as well as to indicate the time period to which your Request refers.

Submit the completed Request to PULSEC via e-mail [email protected]. We will respond to your Request as soon as possible, and at the latest within one month from the date of receipt of the proper Request. In case of a large number of Requests, as well as in case of the complexity of your query, it is possible that we will need additional time to respond. In that case, we will notify you in a timely manner and answer you not later than 3 months from the date of receipt of the proper Request.

• Right to object

Special instructions regarding the right to object are provided below in these rules.

• Right to complain

At any time, you have the right to file a complaint with the competent authority for the protection of personal data of the Republic of Serbia – the Commissioner for Information of Public Importance and Protection of Personal Data, regarding the processing and protection of your personal data.

Profiling – Automated individual decision making

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects that relate to you or similarly significantly affect you.

In case of need to use these procedures in individual cases, we will inform you separately.

We process your data partially automatically with the aim of evaluating certain personal aspects (profiling).

For example, we use profiling in the following cases:

• in order to be able to inform and advise you about products, we use special programs for the purpose of better insight into your needs (e.g. certain products, marketing);

Instructions related to the right to object

1. Right to object based on the special situation of personal data processing

In case that we process your data by applying special regulations of the Republic of Serbia adopted on the basis of Chapter IX of the Regulation, you have the right to object at any time to the processing of personal data relating to you, including profiling based on those provisions. In such case, we may no longer process your personal data unless there are compelling legitimate reasons for the processing that go beyond your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

2. Right to object to the processing of personal data for direct marketing purposes

If personal data is processed for the purposes of direct marketing, you have the right at any time to object to the processing of personal data for the purposes of such marketing, which includes profiling to the extent related to such direct marketing.

In any case, you can send us a complaint directly at any branch office or in writing:

PULSEC d.o.o. Beograd

Tošin bunar 272b

Beograd, Republika Srbija (Belgrade, Republic of Serbia)

e-mail address: [email protected]

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Terms of use of the website

Data collection

Access to this website and the information contained therein is subject to the terms and conditions set forth below:

All information available on this website is for informational purposes only and may not be used for commercial purposes or distributed to third parties.

PULSEC automatically collects data about your computer. This data may not include your IP address, but may include browser type, domain name, access time and web page addresses. PULSEC uses this data in order to offer its services, maintain and improve their quality and collect statistical data related to the use of its website.

The collected data is analyzed by PULSEC in order to record website visits and provide adequate information to its clients about products and services. PULSEC can use the collected data in order to improve customer service, enable easier use of the website by eliminating the need to repeatedly enter the same data.

PULSEC does not sell, rent or lend personal data of its website visitors to third parties and applies organizational and technical security measures to prevent unauthorized access.

By consenting to cookies on the website, you confirm that you have voluntarily made your personal data available to PULSEC and that you agree to PULSEC processing them for the above purposes.

Any user can revoke the given consent at any time, by submitting a written notification to PULSEC, and can also exercise all legal rights in the event that they believe that there has been unauthorized data processing (right to notification, access to data, etc.).

Copyright

The content of this website is a legally protected and exclusive copyright belonging to the owner. All copyright and other intellectual property rights in terms of content, editing, conception and design belong to the owner of the Internet presentation. Trademarks, logos, names of individuals and other similar intellectual property are owned by the owner or owned by third parties. Non-compliance with the binding conditions of use is subject to the application of the relevant legal regulations. Unauthorized copying, reproduction, public display or distribution of the content of the website in any way is prohibited.

PULSEC reserves the right to change these privacy policies. All changes will be published on the website www.pulsec.com. We kindly ask you to periodically check for possible changes to these Privacy Policy in order to be timely informed about its changes.

Cookies

By using PULSEC’s Internet presentation, the User accepts the use of HTML cookies that are placed on the User’s computer and that are text files which, when visiting PULSEC’s Internet presentation, send back information about the Internet sites from which the User came to PULSEC’s Internet presentation, as well as the path of the User through the Internet presentation of PULSEC. This information helps PULSEC to get to know the users of its Internet presentation better, with the aim of improving the search and improving its functionality. The User can disable cookies by activating a setting on his browser that allows setting of all or some cookies. The User can find more information about managing cookies at the following links: https://support.google.com/chrome/answer/95647?hl=sr           , and

https://www.google.com/intl/sr/policies/technologies/cookies/.

The pages on the site use Google Analytics statistics. User can find the third-party cookie policy on Google Analytics. Data on how users use PULSEC’s internet presentation can occasionally be collected using other tools similar to the Google Analytics service (e.g. Google Tag Manager, etc.). You can find more information about Google Analytics at the link:

https://developers.google.com/analytics/devguides/collection/analyticsjs.

Terms of use of re-advertising and remarketing function on the Internet           

The leased forms for advertising on the PULSEC website allow the re-display (directly or by activating the leased form) of the characteristics of its products to the visitors of the specified pages. Advertising of this type can be done on the entire Internet network without restrictions regarding the initial purpose of the site, its origin, activity or appearance. Remarketing would be used in situations in which the display of new content would be shown exclusively to visitors who had previously accessed the pages on which it was advertised, i.e. visitors to whom the original message was already displayed.

During Internet advertising, PULSEC uses several channels for distributing ads and advertising messages. The advertising message is displayed on websites all over the Internet by interested portals and/or websites enabling advertising networks to set up advertising blocks through which advertising networks (including Google) place ads. Ads are displayed depending on the content displayed on the pages where the ad blocks appear. As advertising is intended exclusively for people with pre-defined characteristics, who are familiar with the materials / products / services that are re-advertised / remarketed, the existence of a specific cookie whose presence in the Internet browser activates the process of remarketing is taken as a confirmation of existing knowledge about the subject of remarketing.

PULSEC reserves the right to change the Terms of Use at any time. The Terms of Use come into force on the day of publication on PULSEC’s Internet presentation. PULSEC’s Internet presentation as well as the Terms of Use were created in accordance with the positive regulations of the Republic of Serbia and the EU. All possible disputes arising from the use of the PULSEC Internet presentation or the Terms of Use will be resolved by applying the relevant regulations of the Republic of Serbia and the EU.