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Privacy Policy

1. INTRODUCTION

This Privacy Policy (the “Privacy Policy”) sets out how Comtrade Distribution d.o.o. Belgrade and its affiliated companies may collect and process your personal data.

In this Privacy Policy:

  • “we,” “us,” “our” refers to the part of the Comtrade Group with which you have established a relationship. For example, the part you are doing business with, that is organizing an event you are attending, or that operates the website you are using. We will clearly indicate which part of the Comtrade Group is involved;

  • “website” refers to the website you are visiting or are connected with; and

  • “you” and “your” refers to you, the individual interacting with us, conducting business with us, registering for our events or services, or visiting our website.

By visiting any of our websites, registering for one of our events, cooperating with us, signing up for our services, or otherwise interacting with us, we may collect or process your personal data. We are committed to protecting and keeping confidential any such information collected, and to always comply with applicable laws.

2. OUR CONTACT INFORMATION

Name: Comtrade Distribution d.o.o. Belgrade
Address: Bulevar Zorana Đinđića 125i, 11070 Belgrade, Serbia
Email: distribution.rs@comtrade.com
Data Protection Officer: Dejan Perkovski
Contact email: dejan.perkovski@comtrade.com

3. PERSONAL DATA WE MAY COLLECT

We may collect and process your personal data that you have provided to us, that we have lawfully collected from third parties with whom we closely cooperate, or from publicly available sources.

4. PURPOSES OF PROCESSING

We collect and process your personal data for the following purposes:

  • To provide you with information or services you have requested from us, including but not limited to product information, exercising your rights arising from marketing campaigns we conduct, etc. This data may include your full name, email address, and other relevant information;

  • To fulfill our contractual obligations to you. This may include your name, address, email, phone number, job title, place of work, company name, and nature of your cooperation with us;

  • To improve our websites. This may include your IP address, geographical location, device information, browser type, referral source, visit duration, operating system, page views, pages visited, and similar data. For more information about cookies, please see Section 11 below;

  • To comply with legal obligations or regulatory requirements.

5. LEGAL BASIS FOR PROCESSING PERSONAL DATA

We process your personal data based on the following legal grounds:

  • Performance of a contract concluded with you, under Article 12(1)(2) of the Law on Personal Data Protection (“Official Gazette RS”, no. 87/2018) and Article 6(1)(b) of the GDPR – e.g., when you are in a business relationship with us or have registered to participate in or exhibit at an event;

  • Our legitimate interest under Article 12(1)(6) of the Law and Article 6(1)(f) GDPR – e.g., our interest in improving the website;

  • Your consent under Article 12(1)(1) of the Law and Article 6(1)(a) GDPR – e.g., when you accept the use of cookies;

  • Compliance with a legal obligation under Article 12(1)(3) of the Law and Article 6(1)(c) GDPR.

6. DISCLOSURE OF YOUR PERSONAL DATA

We may disclose your personal data:

  • To our affiliated companies;

  • To data processors, who will process personal data on our behalf in accordance with our written instructions and for the purposes stated above;

  • To other recipients if we are required to do so by court order, regulatory authority, or applicable law.

7. TRANSFER OF PERSONAL DATA OUTSIDE THE EU/EEA

We may transfer your personal data to recipients outside the EU/EEA (“third countries”), including to our affiliated companies and data processors. Such data transfers are protected by the following safeguards:

  • The European Commission has determined that certain third countries provide an adequate level of protection;

  • In cases where the European Commission has not determined adequate protection due to local laws or international obligations, we will ensure that appropriate safeguards are in place. This means we will use the European Commission’s Standard Contractual Clauses for data transfers to countries not deemed to offer sufficient protection. These clauses are available in multiple languages at:
    https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1401799946706&uri=CELEX:32010D0087
    For more information on our use of these clauses, contact us at: distribution.rs@comtrade.com

In all other cases, we may transfer your personal data to third countries only based on your explicit consent.

8. DATA RETENTION

We retain your personal data only as long as reasonably necessary to fulfill the purposes for which we collected it, or to comply with applicable legal requirements. If the legal basis for processing is your consent, we retain the data until you withdraw your consent.

9. DATA PROTECTION AND SECURITY

We take precautions to protect your personal data from loss, misuse, unauthorized access, disclosure, alteration, or destruction. We have implemented appropriate technical and organizational measures to secure the information systems where your personal data is stored, and we require our data processors to do the same through contractual obligations.

10. YOUR RIGHTS

Subject to certain exceptions and limitations under applicable law, you have the right to:

  • Request access to your personal data,

  • Request correction, deletion, or restriction of processing,

  • Object to processing and data portability,

  • Not be subject to decisions based solely on automated processing, including profiling, which produces legal or similarly significant effects on you.

If we process your personal data based on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing before the withdrawal.

To exercise any of these rights or ask any questions, contact us at: distribution.rs@comtrade.com
You also have the right to lodge a complaint with the relevant supervisory authority.

11. COOKIES

We use cookies to ensure you get the best experience from our website. Cookies also allow us to collect information about how you use the website and your online behavior. This may include your previous website, browser type, operating system, browser used, and duration of your visit. For more details on how we use cookies, please refer to our Cookie Policy available at the bottom of our website.

12. LINKS TO OTHER WEBSITES

Our website may contain links to third-party websites. We do not control, are not affiliated with, and do not endorse these websites, nor are we responsible for any harm arising from their content. We provide these links for your convenience only and recommend you read their Terms of Use and Privacy Policies.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. Updated versions will be posted on the appropriate Comtrade websites or provided to you upon request.