1. INFORMATION ABOUT THE OPERATOR
   

The company KRESTON MDM Revizija, headquartered in Belgrade, Kralja Milana 25, 11000 Belgrade, is a business entity engaged in auditing, financial, and accounting consulting services.

Business information:

Registered office address: Belgrade, Kralja Milana 25

Company registration number: 20016515

Tax Identification Number: 103791082

Email: [email protected]

Phone: +381113234377

Current account number: 205-0000000185517-26.

In the course of providing these services and communicating with you, we will collect some of your personal data. Therefore, it is important that you familiarize yourself with this Privacy Policy, in which we will provide all the information required by national legislation.

For any questions regarding our privacy policy, you can contact us at: [email protected].

2. PURPOSE OF PROCESSING AND LEGAL BASIS FOR PROCESSING

The collection and processing of personal data occur due to the need to respond to your requests, interests, preferences, the execution of agreed-upon tasks, and to enhance our services with the aim of providing the best possible user experience. If you contact us through the contact form, when placing an order, submitting comments and complaints, or in any other way, we will collect information regarding all important matters related to potential cooperation, and among that information, there may be personal data. Therefore, these data are collected in order to fulfill the services we provide, or to comply with the contract we enter into with you. Some of the data is also collected to better recognize your interests, which enables us to perform our activities more efficiently and effectively.

Legal Basis for Data Collection:

– Your consent for data processing – Article 12, Paragraph 1, Item 1 of the Personal Data Protection Act.

– Contract performance – data is collected for the purpose of negotiating the conclusion of a contract or fulfilling an already concluded contract – Article 12, Paragraph 1, Item 2 of the Personal Data Protection Act.

– Legitimate interest – our website has a legitimate interest in collecting personal data to provide a better user experience, improve and enhance services, and ensure the highest quality of our activities, especially considering that the processing of data collected for this reason has minimal impact on the privacy of the individual – Article 12, Paragraph 1, Item 6 of the Personal Data Protection Act.

3. INFORMATION WE COLLECT

• Automated Data Processing

It is possible to visit and use our website without revealing your identity or any other related data. When you visit our website, due to the nature of the Internet, data is collected that records user activity, but these data alone are not sufficient to identify a specific individual and are used as statistical indicators to improve the quality of the website. Such information may include the browser type, number of visits, average time spent on the page, computer type, and technical information about the connection used when accessing the website, such as the operating system, Internet service provider, the IP (Internet Protocol) address assigned by providers, which varies for each internet user, date and time of access, and other similar information.

What types of personal data do we use?

We do not collect personal data automatically; rather, these are data that you voluntarily provide and disclose to us in order to conclude and execute a contract. These include the following:

• For contact purposes: first name, last name, email address, phone number
• For payment obligations: bank account number and card number
• For delivery of ordered items: delivery address, name of the person receiving the order if delivery is not to the customer’s address
• For item personalization: name of the gift recipient, gender, date of birth, or any other personal data you disclose to us for personalization

Social Media Data Processing

KRESTON MDM REVIZIJA manages the following social media pages:

• Facebook: https://www.facebook.com/krestonmdm

• Instagram: https://www.linkedin.com/company/kreston-mdm/

We have limited influence over the processing of data by the social media platform operator (e.g., member administration and information sharing). Where we can influence and configure the parameters for processing your data, ensuring that the platform operator complies with data protection regulations, we take all available measures. However, in many instances, we cannot influence the data processing practices of the operator, nor do we know exactly what data the operator processes.

The platform operator manages the entire IT infrastructure of the service, adheres to its own data protection policies, and maintains a separate user relationship with you (if you are a registered user of the social media service). Furthermore, the operator is solely responsible for any issues related to the data of your user profile, to which we, as a company, do not have access.

For more detailed information on data processing by the platform operator and the available options for objections, you can refer to their data protection policy:

Facebook: https://www.facebook.com/privacy/explanatio

Data Processing for Newsletter

You have the option to subscribe to our newsletter on our website. If you have agreed to receive our newsletter, we use your email address and possibly your name to send information about products, promotions, giveaways/contests, news, and store offers. We store and process this data for the purpose of sending the newsletter.

With your consent, which we obtain through cookies, we track your behavior as a user on our website www.krestonedu.com and in the newsletter. User behavior analysis primarily includes data about the sections you visit and the links you click. In this way, we create personalized user profiles with your personal data and/or your email address to facilitate the creation of tailored advertising offers from KrestonMDM in the form of newsletters and printed materials, based on your individual interests, thereby improving our offerings.

You can withdraw your consent to receive the newsletter or to create personalized user profiles at any time. The withdrawal of consent does not affect the lawfulness of processing that was carried out based on consent before its withdrawal. You can do this by unsubscribing from the newsletter list on our website. A link to unsubscribe is provided at the end of each newsletter. If you withdraw your consent, we will delete your data.

Who has access to your personal data?

In order to fulfill our legal obligations and contractual requirements, we share your personal data with third parties we collaborate with, who enable us to offer remote shopping, ensure the secure and orderly functioning of our website, company, and the safe and efficient operation of our services. Specifically, we do not share your personal data with third parties unless:

• You have provided your consent,
• We are legally obligated to share certain information, including your personal data, with authorities such as public bodies; in this case, we are not required to ask for your additional consent for sharing your personal data,
• It is necessary to ensure the highest quality of our service when collaborating with certain third parties.

Your personal data may be shared with the following parties:

• Third parties responsible for safeguarding your personal data, independent of KRESTON MDM Revizija (these may include external parties such as independent auditors, lawyers, tax advisors, etc.),
• Law enforcement authorities or other public bodies.

All our partners have been selected with great care and are contractually bound to keep your personal data confidential in accordance with Article 45 of the Personal Data Protection Act.

4. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We retain your personal data for a period necessary to fulfill the purpose of processing, after which it is deleted or access is disabled—becoming anonymous.

The criteria for determining the retention period are:

• The duration of your contractual relationship;
• As long as we maintain an active relationship with you;
• According to applicable legal requirements.

Automatically collected data is retained temporarily for the duration of your visit to the website and is then automatically deleted. Once you leave our website, geolocation data is erased.

5. RIGHTS OF DATA SUBJECTS

As individuals whose data is being collected, you have the following rights:

1. To request access to your data from the data controller in accordance with Article 26 of the Law.
2. To request the correction, supplementation, or deletion of personal data in accordance with Articles 29 and 30 of the Law.
3. To request the restriction of processing in accordance with Article 31 of the Law.
4. The right to object in accordance with Article 37 of the Law.
5. The right to data portability in accordance with Article 36 of the Law.
6. The right to withdraw consent at any time, where such withdrawal does not affect the legality of processing based on consent before its withdrawal, when you have consented to the processing of your personal data for one or more specific purposes (Article 12(1)(1) of the Law), or when you have provided explicit consent for processing for one or more purposes, unless the law stipulates that processing is not based on consent (Article 17(2)(1) of the Law).
7. The right to file a complaint with the Commissioner for Information of Public Importance and Personal Data Protection, in accordance with Article 82 of the Law.

For further explanation, clarification, and exercise of these rights, you can contact us via email at: [email protected].

6. PRIVACY POLICY UPDATE

Over time, there may be a need to update our Privacy Policy, as we are required to align it with any changes to our website (such as the addition of new features, pages, cookies, etc., and/or if there are changes to legal regulations). It is important for you to be aware of this information when visiting our site and to revisit the policy if you have any doubts or questions.

7. CONTACT US

We are here for you! If you have any further questions or concerns regarding the processing of your data, feel free to contact us, and we will do our best to assist you.

For this purpose, the Data Protection Officer at KrestonMDM is available to you. You can contact them in writing or via email at:
KRESTON MDM Revizija, Beograd, Kralja Milana 25, 11000 Beograd; Data Protection Officer, E-Mail: [email protected].

An integral part of this Privacy Policy is also our Cookie Usage Policy.

WHAT ARE COOKIES AND WHAT ARE THEY USED FOR?

Cookies are small text files stored in your web browser that ensure the smooth functioning of the website (necessary cookies). They can also be used for other purposes, such as improving the user experience and tailoring website content to the preferences and needs of users (e.g., analytical, marketing cookies, etc.).

Our website uses three types of cookies: necessary, session, and persistent. As the name suggests, necessary cookies are essential for the proper functioning of the website, and their use cannot be disabled. Session and persistent cookies are intended to enable normal website usage and facilitate online shopping. Consent from the user is required for the use of these two types of cookies.

COOKIES ON THE WEBSITE krestonedu.com

1. Necessary Cookies

2. Session cookies

3. Persistent cookies

COOKIE USAGE CONSENT

The consent you have provided for the use of cookies can be withdrawn at any time. Withdrawal of consent will take effect immediately. However, since our website does not use statistical or marketing cookies, some parts of the website may be blocked, or you may not be able to complete your order after withdrawing consent.

BLOCKING COOKIES

You can block cookies on our website as soon as you enter the site.

The consequence of blocking cookies is the same as denying consent for cookie usage – the website will not function properly, meaning you will not be able to place an order, as you will not be able to add desired products to the cart or enter your personal information to create an order.

COOKIE USAGE POLICY CHANGES

As with our Privacy Policy and Website Terms of Use, changes may occur in the number, type, and duration of the cookies we use, and we will notify you promptly of any such changes. We are obligated to align this Cookie Usage Policy with any changes to the cookies.