Terms of Use and Privacy Policy

Privacy Policy for PULSEC Website Visitors

Introductory Provisions

With this Privacy Policy, PULSEC doo Beograd, for clients and other participants (hereinafter: the “Policy”) PULSEC doo Beograd (hereinafter: “PULSEC”) explains how it processes the personal data of clients and other participants (hereinafter: “Data Subject(s)”, “You”) in accordance with the General Data Protection Regulation (EU) 2016/679 (hereinafter: the “Regulation”) and the “Law on Personal Data Protection” (“Sl. glasnik RS”, no. 87/2018).

With this Policy, PULSEC provides information about the controller of personal data processing, 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 retention period of your personal data, data protection, as well as the rights of the Data Subject. This Policy is available on the PULSEC website (www.pulsec.com).

Who is responsible for processing your personal data?

The data processing is the responsibility of:

• PULSEC d.o.o. Beograd
• Ul. Tošin bunar 272b
• Tel: +381 11 697 9470
• E-mail: [email protected]

Regarding the processing of your data, you can contact the Data Protection Officer (DPO):

• Milorad Zrnić
• Tel: +381 66 8042810
• E-mail: [email protected]
  
  

Personal data we collect and process

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

Furthermore, we process personal data to the extent necessary to provide PULSEC’s services, as well as data generated by web cookies for which you give consent.

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

The personal data that PULSEC processes are: name, surname, email address, position/function at the employer, name of the employer.

Purpose and legal basis for processing personal data

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

1. Execution of a contract and/or taking actions at the request of the Data Subject before entering into a contract
   
   The processing of personal data takes place for the purpose of providing services for the execution of a contract to which you are a party or in order to take actions at your request before entering into a contract.
   
   
2. Legitimate interest of PULSEC or a third party
   

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

   For example:

   • for market research, except for data for which you have objected (the right to object is described in a separate section of this Policy),

   • for the purpose of litigation,

   • ensuring IT security,

   • implementing measures to improve and develop PULSEC’s products and services,

   • for the purpose of detecting and/or preventing crime (including preventing fraud), in accordance with applicable law.
     
     

3. Consent
   

   
   The lawfulness for processing your personal data for one or more specific purposes is based on giving your consent when entering into a business relationship with PULSEC.

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

4. Compliance with PULSEC’s legal obligations or performance of obligations of public interest
   
   As a socially responsible company, PULSEC is committed to fulfilling legally prescribed obligations and regulations (e.g. GDPR).
   
   

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

Within PULSEC

Within PULSEC, access to your data is granted to those organizational units that process your data in order to fulfill our contractual and legal obligations and to realize the legitimate interests of PULSEC and third parties. PULSEC does not provide your data to third parties.

1. Service providers
   
   For the execution 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 primarily aware of the fact that your personal data is a secret, and we only allow access to your data 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 GDPR. Service providers are companies that perform high-tech IT services, support services, telecommunications services, etc.
   
   
2. Other recipients of data based on your request for the transfer of personal data
   
   

How we protect your data

The protection of your personal data is extremely important to us. Some of the protection measures we implement are the following:

• establishing technical and organizational measures necessary to ensure that the processing of personal data is carried out in a secure manner;
• control of physical and logical access to the information system and business premises of PULSEC;
• establishing technical and procedural measures necessary to ensure that the IT infrastructure is implemented in accordance with the highest international security standards;
• establishing electronic and procedural safeguards related to the collection, storage and disclosure of personal data.
  
  

How long is personal data stored?

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

If your data is no longer needed after the expiration of the contractual obligation, we delete it, and no later than after the expiration of all legal deadlines for storing personal data.

Your rights

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

1. Right to access information
   
   

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

   We will respond to your Request as soon as possible, and no later than one month from the date of receipt of a proper Request.
   
   

2. Right to rectification
   
   You have the right to request the correction or amendment of your personal data by submitting a Request. We will respond to your Request as soon as possible, without undue delay.
   
   
3. Right to erasure
   

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

   (I) that data is no longer necessary in relation to the basis for which it was 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 processing;

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

   (IV) the data has been illegally processed;

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

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

4. 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 in a limited manner (in accordance with the restrictions you specify) if you need it to exercise your other rights.

   You can exercise the stated rights by submitting a Request. We will respond to your Request as soon as possible, and no later than one month from the date of receipt of a proper Request.

   In the event of a large number of Requests, as well as in the event of the complexity of your inquiry, it is possible that we will need additional time to respond. In that case, we will inform you in a timely manner and respond to you no later than 3 months from the date of receipt of a proper Request.
   
   

5. Right to data portability
   
   

   You have the right to request the transfer of your personal data. You can exercise the same right by completing a Request. On the Request, it is necessary 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 relates.

   Submit the completed Request to PULSEC via email [email protected]. We will respond to your Request as soon as possible, and no later than one month from the date of receipt of a proper Request. In the event of a large number of Requests, as well as in the event of the complexity of your inquiry, it is possible that we will need additional time to respond. In that case, we will inform you in a timely manner and respond to you no later than 3 months from the date of receipt of a proper Request.
   
   

6. Right to object
   
   Specific instructions regarding the right to object are listed below in these rules.
   
   
7. Right to complain
   
   At any time, you have the right to complain to the competent body 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 concerning you or similarly significantly affects you.

In the event of the need to use these procedures in individual cases, we will inform you specifically.

We process your data partially automatically with the aim of assessing 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 understanding your needs (e.g. certain products, marketing);
  
  

Instructions related to the right to object

1. Right to object based on a specific situation of personal data processing
   
   In the event 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 that case, we may no longer process your personal data unless there are compelling legitimate grounds for the processing that outweigh 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 purpose of direct marketing, you have the right to object at any time to the processing of personal data for the purpose of such marketing, which includes profiling to the extent that it is related to such direct marketing.
   
   

In any case, you can send your objection directly to any branch or in writing:

• PULSEC doo Beograd
• Tošin Bunar 272b
• Belgrade, Republic of Serbia
• E-mail address: [email protected]