I NOTICE ON THE COLLECTION AND PROCESSING OF PERSONAL DATA AND GENERAL NOTES
Article 1.
DIVANTIS PR respects the privacy of Users. This notice will help you understand our privacy policy and we ask you to read it carefully. If you do not agree with any provision of the Personal Data Protection Policy (hereinafter: the Policy), please refrain from using DIVANTIS PR services and do not provide us with your personal data.
Article 2.
In order to protect your privacy, DIVANTIS PR applies appropriate technical, organizational and personnel measures and constantly works on their improvement in order to ensure that your data is processed in accordance with applicable regulations and your consent (when such consent is required by law). In this regard, DIVANTIS PR may occasionally change and improve this Policy, in which case it will ensure that the updated version is available to you on the website, with a clearly indicated start date of application. We invite you to check whether the Policy has been amended after your last visit to our website, and if so, to familiarize yourself with the content of the new Policy. If you do not agree with the new rules, please refrain from using our website and submitting your data in any way, or withdraw your consent for the processing of personal data in accordance with the Policy.
Article 3.
You can access the text of the valid Policy via the link in the footer of our website whenever you have access to the Internet. By continuing to use the website, you are deemed to have read and understood the valid Policy, and that after reading and understanding it, you have agreed to its application.
Article 4.
The regulations of the Republic of Serbia apply to this Policy and its possible amendments and supplements.
II DATA ON THE DATA CONTROLLER
Article 5.
The identity and contact information of the Controller, i.e. the legal entity responsible for managing your data, is defined in this article.
The controller of your data is:
Business name: DIVNA ANTIĆ PR VELEPRODAJA I INTERNET TRGOVINA DIVANTIS VRANJE
Registration number: 68206910
VAT ID: 115238299
Registered office address: Republic of Serbia, city of Vranje, Franca Rozmana st. No. 8, postal code 17500
E-mail: divantis.pr@gmail.com
Activity code: 4690 – Non-specialized wholesale trade
4791 – Retail sale via mail order houses or via Internet
Contact information of the controller for exercising the right to personal data protection are:
Divna Antić
Republic of Serbia, city of Vranje, Franca Rozmana st. No. 8, postal code 17500
Working hours: Monday to Friday from 4:00 PM to 8:00 PM
Tel: +381 63 847 3722
Email: divantis.pr@gmail.com
III METHOD OF DATA COLLECTION
Article 6.
We collect your personal data in the following ways:
– directly from you, when you directly provide us with your data. For example, when you contact us by post, e-mail, or by telephone or
– automatically, when using our website, in which case we or our partner third parties on our behalf use so-called “cookie” technologies for adequate display of content and tracking the amount of visits and movement on our pages and the like (hereinafter “cookie”). Please read more information on how we use “cookies” in a separate section of this Policy.
IV DATA PROCESSED BY THE CONTROLLER, METHOD AND BASIS OF USE
Article 7.
DIVANTIS PR collects data that is adequate, relevant and limited to what is necessary in relation to the specific purpose of processing.
Article 8.
We use or may use your data to achieve several purposes that are predetermined in this Policy. For each processing we undertake, there is a corresponding basis prescribed by the Law on Personal Data Protection and other laws of the Republic of Serbia.
Article 9.
We may compare and combine the data we collect directly with the data we have collected automatically, and in this way, data collected as anonymous (for example, data on the frequency of visits to certain content on our website) may become personal data (for example, how often you visit certain content on our website). This allows us to provide you with a personalized experience when visiting the website.
Article 10.
Also, we may anonymize certain data and use it for statistical and analytical purposes, without individual persons to whom the data relates being able to be identified, either directly or indirectly. For example, we may obtain data on the percentage of visitors who have viewed a particular video or visited other content on the website.
Article 11.
DIVANTIS PR processes or may process some or all of the data listed here. We are constantly working on the development of the website and the improvement of available services, as a result of which it is possible that the processing of certain data listed below will begin later, as the functionalities of the website increase. Also, the scope of data we process depends, for example, on how and for what reasons you contact us or how you use the website.
| Data Processed | Purpose of Processing | Legal Basis for Processing |
|---|---|---|
| First name, last name, email address and/or postal address (city, postal code, street, house number) and/or phone number | Communication with you – responding to your inquiries and requests submitted via the website contact form or other communication channels (email, regular mail or telephone) | Our legitimate interest in managing customer support and responding appropriately to user inquiries and requests |
| Username, email address and password for your website account | Creation of a user account on the website enabling electronic purchase of products | Our legitimate interest in providing a personalized user experience, namely concluding a sales contract at your request |
| First name, last name, postal address (city, postal code, street, house number), payment information (credit/debit card number and bank where the account is held) | Execution of electronic product purchase | Performance of the sales contract and compliance with our legal obligations (maintaining transaction records in accordance with accounting regulations) |
| First name, last name, contact details (postal address – city, postal code, street and house number, and/or email address and/or phone number), purchased product details, purchase date, complaint resolution method | Handling complaints regarding product conformity purchased through the online store on the website | Compliance with our legal obligations in the field of consumer protection |
| Data regarding selected display preferences on the website | Ensuring website functionality by temporarily storing selected content display settings | Our legitimate interest in ensuring visitors are shown website content in their chosen language during each visit for a certain period (usually one day) |
| Device identification data (unique device identifier), device type (computer, tablet, smartphone), IP address, operating system, web browser | Technical administration of the website and ensuring optimal display of content on the device used | Our legitimate interest in ensuring proper use of the website and optimal presentation of its content |
| Data on how you use the website (visited pages, number of visits, login times, clicked content, etc.) | Understanding visitor interests, improving user experience, developing the website, products and services, statistical and analytical purposes | Your consent |
| Data regarding online marketing content accessed before visiting the website | Identifying trends and improving the website, products and services, statistical and analytical purposes | Your consent |
Detailed information about the data we automatically collect through “cookies” can be found in a separate section of this Policy.
Article 12.
If a need subsequently arises to process your data for another purpose that is different from the one for which the data was collected, DIVANTIS PR will, before starting further processing, provide you with information about that other purpose, as well as all other relevant information in accordance with the law.
Article 13.
DIVANTIS PR will never intentionally or purposefully collect and process data about minors, but we cannot exclude the possibility of providing inaccurate data by persons who contact us. If you are a parent or legal guardian of a minor and you are aware that the data of that person has been provided to us, please inform us immediately so that we can take appropriate measures and stop further processing of this data.
V “COOKIE” DATA – COOKIES
Article 14.
Our website uses “cookies” to provide you with the best user experience. They allow us, for example, to display the content of the website in an adequate way on each of your devices or web browsers through which you access it, or to adapt the content we place on the website to your interests. The information we collect in this way may in some cases be personal data, but it does not have to be. Since DIVANTIS PR respects your privacy, in this section we want to explain to you what “cookie” data is and how we use it, as well as to show you that in certain cases you can manage the way we use “cookies”, in connection with your use of the website. When the website allows you not to select or exclude certain “cookies” and you decide to use that option, it may reduce the functionality of the website. Also, keep in mind that you will have to turn off the settings you have decided to turn off for each other device or web browser separately.
Cookies are simple text files that are stored in the user’s web browser, i.e. on his device. The task of “cookies” is primarily to enable the website to “recognize” the user when he accesses it next time. In that situation, the website uses the data stored in the “cookie” and thus automatically obtains information about the user’s previous activity on the website. Cookies cannot access your data that you store on your devices, but they can collect data about your online activities.
Cookies are not harmful to the user or his device and should not be confused with viruses. Cookies do not contain viruses or other malicious code.
Depending on how long they are stored in the user’s web browser, we distinguish between “cookie” sessions (they are only stored during a specific browsing session and are automatically deleted after its completion, and are used to allow you to access specific content) or permanent “cookies” (longer or shorter period, “remember” information for future visits to the website, are retained until you delete them manually or until they expire according to the intended duration, e.g. “cookies” that allow the website to “remember” login information in case of account creation or “cookies” for tracking).
Depending on who they belong to, there are first-party “cookies” (“cookies” set by DIVANTIS PR as the owner of the website you are browsing) and third-party “cookies” (“cookies” set by our selected partner companies that provide us with various services, e.g. analytical because they collect and process certain data about how the website is used and provide us with information in anonymized form, or these “cookies” allow you to display related content on their websites or other locations on the Internet).
Cookies can contain different information and be used for different purposes. DIVANTIS PR uses the following types of “cookies”:
MANDATORY – absolutely necessary “cookies” – Mandatory cookies make the page usable by enabling basic functions such as page navigation and access to protected content. DIVANTIS PR uses cookies that are necessary for the proper functioning of our website, in order to enable certain technical functions and thus ensure a positive user experience.
PERMANENT – necessary for easier access – These cookies usually have an expiration date far in the future and as such will remain in your web browser until they expire, or until you manually delete them. We use persistent cookies for functionalities such as “Stay logged in”, which makes it easier for the user to access as a registered user. We also use persistent cookies to better understand user habits, so that we can improve the website according to your habits. This information is anonymous – we do not see individual user data.
STATISTICS – statistical “cookies” – Statistical cookies help website owners understand how visitors interact with the page by collecting and sending data anonymously. These are cookies that enable DIVANTIS PR to perform web analytics, i.e. analysis of the use of our pages and measurement of visits, which DIVANTIS PR carries out in order to improve the quality and content of the services offered.
MARKETING – “cookie” data for marketing purposes – Marketing cookies are used to track visitors through web pages. They are used to show users relevant ads and encourage them to participate, which is important for publishers and third-party advertisers.
You can manage the use of “cookies” by selecting the appropriate settings in your web browser. More information can be found on the following links:
VI PROFILING
Article 15.
Profiling is a form of automated data processing used to evaluate certain personality traits, particularly for the purpose of analyzing or predicting personal preferences, interests, behavior, etc. Profiling via cookies (cookie profiling or web profiling) involves the use of persistent cookies to track users’ online activities. Based on the data obtained, we can profile visitors to the website and/or users of our products in order to tailor content and communication to them.
VII DATA THAT DIVANTIS PR DOES NOT PROCESS
Article 16.
DIVANTIS PR does not collect or process special categories of personal data, such as data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of unique identification of an individual, data concerning health or data concerning a person’s sex life or sexual orientation, nor data relating to criminal convictions, offenses, and security measures.
Please do not disclose or send us this data.
VIII EXISTENCE OF AN OBLIGATION TO PROVIDE DATA
Article 17.
In most cases, you are not required to provide us with your data, but you do so on a voluntary basis. This will, for example, be the case when you contact us and provide your contact details so that we can respond to your question or request, or when you use our website.
In some cases, there may be an obligation to provide your data. For example, in connection with the online sale of our products, it will be necessary for you to provide us with your data in order to execute the contract or when making a complaint so that we can process it in accordance with the law.
IX RECIPIENTS OF PERSONAL DATA
Article 18.
Your data is processed and used primarily by DIVANTIS PR.
In some cases, it may be necessary to make your data available to third parties. These may include members of the group of companies to which DIVANTIS PR belongs, who help us respond to your questions or requests, or our business partners who help us maintain the functionality of the website or provide us with analytical and other services. In order to ensure that your data is handled in a lawful manner, we have entered into appropriate agreements with third parties relating to the processing of personal data, which, among other things, provide for their obligation to handle the data exclusively in accordance with our instructions and this Policy, so that you, regardless of such processing, have the rights established by the Law and this Policy.
Also, in certain legal situations, there may be a legal obligation to make your data available to the competent authorities (e.g., court or prosecutor’s office, etc.).
X TRANSFER OF DATA ABROAD
Article 19.
We use your data on the territory of the Republic of Serbia.
In addition, we store the data we collect on servers located in the Republic of Serbia, which are owned and controlled by a domestic hosting company. In accordance with the hosting company’s policy, a high degree of technical and software protection of these servers is ensured, while access to the data stored on them is not allowed.
If it is necessary to make your data available to recipients in countries that are not considered to provide an adequate level of protection of personal data, we will ensure an appropriate basis for such transfer, including the possible application of appropriate standard contractual clauses drawn up by the competent supervisory authority, i.e. other appropriate safeguards, which will oblige the recipient to protect your data in a manner that is in accordance with the protection standards established by the regulations of the Republic of Serbia.
XI DATA RETENTION PERIOD
Article 20.
We store your data only for as long as is necessary to achieve the purpose for which the data was collected, after which we will safely remove it from our systems and delete it.
We will generally keep your data to which this Policy applies for two years, unless regulations require us to keep the data for a longer or shorter period of time, or in the case of cookies (more information about cookies can be found in a special section of this Policy).
XII YOUR RIGHTS REGARDING DATA PROCESSING
Article 21.
It is important for you to know that, under certain conditions, you have rights regarding the processing of your data that are guaranteed by law:
Right of access – you have the right to request information on whether we process your personal data, as well as access to that data. At your request, we will provide you with a copy of your data that we process.
Right to rectification and completion – you have the right to have inaccurate data relating to you corrected without undue delay, as well as to have incomplete data completed, including by providing an additional statement.
Right to erasure – you have the right to request the erasure of your data, especially:
(a) if the data are no longer necessary for the purposes for which they were collected or otherwise processed;
(b) if you have withdrawn your consent on the basis of which the processing was carried out, and there is no other legal basis for the processing;
(c) if you have objected to the processing in accordance with the law.
Right to restriction of processing – you have the right to restrict the processing of your data if one of the following cases is met:
(a) if you dispute the accuracy of the data, within a period that allows us to verify the accuracy of the personal data;
(b) if the processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of their use;
(c) if we no longer need the personal data for the purposes of the processing, but you have requested them for the purpose of filing, exercising, or defending a legal claim;
(d) if you have objected to the processing carried out on the basis of the legitimate interest of the controller, and it is being assessed whether the legal basis for the processing by DIVANTIS PR overrides your interests.
Right to object – if you consider it justified in relation to your particular situation, you have the right to object at any time to the processing of your personal data which is carried out on the basis of the legitimate interest of the controller, including profiling based on those provisions.
Right to data portability – you have the right to receive the personal data that you have previously provided to us in a structured, commonly used, and machine-readable format and the right to transfer this data to another controller without hindrance, if the processing is based on consent or a contract and is carried out by automated means. You also have the right to have this data transferred directly to another controller, if this is technically feasible.
Right to withdraw consent – if the processing is carried out on the basis of your consent, you have the right to withdraw your consent at any time, whereby the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to lodge a complaint – you have the right to lodge a complaint regarding the processing of your personal data with the Commissioner for Information of Public Importance and Personal Data Protection, whose contact details are:
Commissioner for Information of Public Importance and Personal Data Protection
Bulevar kralja Aleksandra 15, Belgrade 11120
Working hours: Monday to Friday from 7:30 AM to 3:30 PM
Tel: +381 11 3408 900
Fax: +381 11 3343 379
Email: office@poverenik.rs
Website: www.poverenik.rs
XIII SECURITY OF YOUR DATA
Article 22.
The security of your data is very important to us. Therefore, DIVANTIS PR takes physical, technical, and electronic protection measures to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data. These measures are aimed at persons both outside and within our organization, as access to your data is limited only to those persons whose duties necessarily require such access and who have been trained in the protection of personal data.
Unfortunately, there are no impenetrable security systems, so we cannot guarantee that the security of the systems over which we have direct control will never be compromised. In the event of a personal data breach, we will take all available measures and notify the competent authorities in accordance with the regulations, as well as the individuals whose data is involved, if possible.
XIV VALIDITY OF THE POLICY
Article 23.
This Policy shall enter into force on the date of publication and shall apply from September 1, 2025.