Privacy Policy

This Privacy Policy (“Privacy Policy”) is drafted in accordance with the Law on Personal Data Protection of the Republic of Serbia ("Official Gazette RS", No. 87/2018) (“Law”).

If you do not agree with our Privacy Policy, we kindly ask you not to use our website/mobile application or provide us with your personal data.

If our website/mobile application contains links to other websites, we encourage you to familiarize yourself with the privacy policies of those websites and how they process personal data. Project Codes has no control over the content of other websites and cannot be held responsible for protecting your privacy when visiting them.

Data Controller

The company for trade and services Project Codes d.o.o. Beograd-Novi Beograd, with a registered office address at Bulevar Zorana Đinđića 181a, Novi Beograd, Belgrade, registration number: 20880694, TIN: 107836522 (hereinafter referred to as “Project Codes” or the “Controller”).

Types of Personal Data, Scope, Purpose, and Legal Basis for Data Processing

Below are details on the types of personal data processed, categorized by functionality and purpose.

You may withdraw your consent for personal data processing at any time via your user account or by email at office@projectcodes.rs. Withdrawal of consent does not affect the legality of processing based on consent before its withdrawal.

Visiting the Website

When visiting the website, the browser you use on your device will automatically and without your intervention send to our website server the following:

• The IP address of the device from which the request was sent and which has internet access,
• Date and time of access,
• Name and URL of the retrieved file,
• The browser you use and, if necessary, the operating system of the internet-capable computer, as well as the name of your provider.

User Account

To use some of our features, you must register a user account.

Marketing, Notifications, and Newsletter

In connection with our marketing activities, we may use your phone number and user account to send notifications and information about products, promotions, news, and offers (“direct marketing”), if you have provided your consent.

If you have given consent to receive notifications, offers, and information about products, promotions, news, benefits, and offers, notifications will be sent to you via SMS and other messaging apps you may use, as well as in the form of notifications within the mobile application.

Recipients of Personal Data

Within Project Codes, access to the data you have provided is granted only to those organizational units or employees who need it to fulfill the purpose for which the personal data was collected.

Third parties may use personal data exclusively for the purposes listed above and only in accordance with Project Codes instructions. Only personal data necessary for achieving the purpose of processing is shared with third parties.

In addition to Project Codes, personal data may also be used by affiliated entities of Project Codes for the purposes of internal administration, including processing personal data for the same purposes listed in this Privacy Policy, as well as by competent authorities in legally prescribed cases (e.g., tax authorities, prosecutors, courts, police, etc.).

Additionally, Project Codes engages third parties to provide certain services. Where necessary for the appropriate processing purposes, personal data is shared with these service providers (or access to it is granted) and processed by them as data processors, particularly service providers such as lawyers, IT providers, communication service providers, customer support, accountants, auditors, insurance companies, etc.

Transfer of Personal Data Abroad

If personal data is transferred to a country that does not provide an adequate level of personal data protection in accordance with the Law, Project Codes will fulfill all relevant conditions and take all necessary measures to ensure appropriate safeguards for the processing of personal data and ensure an adequate level of protection. These may include, for example, the application of standard contractual clauses approved by the Commissioner for Information of Public Importance and Personal Data Protection (hereinafter referred to as the “Commissioner”), binding corporate rules, approvals issued by the Commissioner, etc. (For more details on the applied measures, please contact us at office@projectcodes.rs).

How Personal Data Is Protected

Project Codes will take all appropriate and necessary technical, organizational, and personnel measures to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, deletion, or destruction.

Retention Period for Personal Data

Personal data will be stored for as long as necessary to achieve the above-stated purposes of personal data processing or permanently if such an obligation is prescribed by law or until the withdrawal of consent for personal data processing. If consent is the legal basis for personal data processing in a specific case, Project Codes will cease processing personal data upon withdrawal unless there is another legal basis for the specific processing. Withdrawal of consent does not affect the legality of processing based on consent prior to withdrawal.

Rights of Data Subjects

Data subjects have the right to:

• Access;
• Correct and/or supplement personal data;
• Delete data;
• Restrict processing;
• Data portability;
• Withdraw consent at any time (withdrawal of consent does not affect the legality of processing based on consent before its withdrawal);
• Object;
• Submit a complaint to the Commissioner.

Changes to the Privacy Policy

Project Codes reserves the right to modify this Privacy Policy at any time. Any changes become effective after their publication on the website/mobile application or in another appropriate manner. In this regard, we recommend regularly checking the section regarding the Privacy Policy to stay informed of the latest updates.