PRIVACY POLICY

Version effective from August 28, 2023

This Privacy Policy governs how Start-Serbia.com  (“Start-Serbia“) collects, processes, and shares data about you. This Privacy Policy applies to information we collect when you use our products and services (“Services“). We especially emphasize that this Privacy Policy does not apply to your access and use of third-party websites, services, or platforms through which you access our Services. We advise you to review the privacy policies of those third parties for more information regarding their privacy practices.

I  AMENDMENTS TO THE PRIVACY POLICY
Start-Serbia may periodically amend the Privacy Policy. We will notify you of all changes and additions to the Privacy Policy, with an indication of the date from which the changes come into force. We advise you to review our Privacy Policy each time you access the Services, in order to be informed of our data processing practices and to protect your privacy.

II  DATA COLLECTION
When accessing the Services via the online platform (“Platform“), and in accordance with positive regulations of the Republic of Serbia (“Law”), EU regulations governing the protection of personal data (“GDPR“), Start-Serbia will collect certain data about you, which are listed below in this Privacy Policy.

II.I  Data you provide to us
Start-Serbia collects data that you directly provide to us through your interactions with us or when using the Services. The specific data we collect depends on the content of your interaction with Start-Serbia.

Users of the platform
A registered user of the Platform who uses our Services (“User“) is required to provide certain personal data in order to register an account, such as: first and last name, username, email address, phone number, place of residence, address place of residence, occupation, date of birth, place of birth, passport number, personal photo, personal registration number in the country of residence, gender, competent public authority for issuing passports, date of passport issuance, passport expiration date, personal signature. This data is collected during registration in order to:

1. Create your account;
2. Issue an order to a lawyer for representation;
3. Issue an order to a real estate agent for drawing up a contract on mediation in real estate transactions and a contract on renting/purchasing real estate;
4. Issue an order to a court interpreter for the translation of documents;
5. Issue an order to a notary public for the certification of documents;
6. Issue an order to the bank agent to open an account and conclude an electronic banking contract;
7. Issue an order to a business entity that deals with bookkeeping for the submission of an offer and a proposal for a contract on business cooperation;
8. Submit a request to the Ministry of Internal Affairs of the Republic of Serbia (“MIA“) to report the residence and temporary residence of a foreigner in the Republic of Serbia;
9. Submit a request to the National Employment Service of the Republic of Serbia (“NES“) for the issuance of a work permit;
10. Submit a request to the certification body for issuing an electronic signature (“Certification Body“);
11. Provide you with appropriate information and questionnaires that are specific to your business interests.

During the use of our Services, you will provide us with data that we will use in order to adapt our Services to your needs. For example, in order to help you register a suitable business entity, you will fill out questionnaires that will help us suggest the appropriate organizational form of the business entity, its characteristics, and type of activity. You will also be required, through answers to a series of questions about your business and personal needs, to provide us with data on the basis of which we will be able to issue appropriate orders for action to third parties and competent public authorities in order to perform the Service. The lawyer and real estate agent will have insight into your answers to the questionnaire so that you can get the appropriate Service according to your needs.

You may be asked to express your opinion about the Start-Serbia’ Services and their quality. Your feedback and responses will be used to improve our Services. In some cases, the lawyer and the real estate agent may be informed about this data, but without revealing your identity, in order to improve the quality of the Services.

Sensitive Personal Data and Demographic Data
While using the Services, you will generally not be required to provide any sensitive personal data, such as financial or demographic data. Since it is necessary to provide us with a copy of your passport to perform our Service, demographic data such as gender, nationality, date of birth, and place of birth will be collected and processed. The provision of such data is voluntary, but withholding it may affect your right to use the Services if you withdraw your consent to their processing. Your consent can be withdrawn at any time.

II.II  Data that we collect automatically during the use of the Services

Start-Serbia does not automatically collect personal data while using the Services.

II.III  Data we collect through “cookies”
Start-Serbia does not collect personal data through cookies. We advise you to review the privacy policies of the third parties, services, or platforms through which you access our Services to obtain more information regarding their practices related to the collection of personal data through “cookies”.

II.IV  Data we collect from other sources
Start-Serbia may collect data from other publicly available sources and combine it with data it has collected through the performance of the Service. There may be isolated cases when we collect data about you from third parties with whom you interacted when receiving the Service, if a problem arose during the execution of the Service, or if you expressed disagreement or concern regarding the choice or behavior of third parties and if third parties need additional data from us.

III  USE OF DATA
Start-Serbia uses the data it has collected for the purpose of providing, preserving, and improving the Services, which includes evaluating the quality of the Service.

The data we collect from Users can be used for the purpose of:

• Performing the services you request, processing transactions, and delivering notifications;
• Confirmation of your identity;
• Respond to your questions, comments, and requests;
• Communicating with you about products, services, offers, promotions, rewards, and events offered by us, or third parties, and delivering notifications and news that we think may be of interest to you;
• Monitoring and analysis of trends, usage, and activities related to the Services;
• Conducting research, analysis, and creating questionnaires;
• Personalization and improvement of Services in order to adapt to the User’s profile and interests;
• Contact via phone calls, SMS messages, email, and other communication applications;
• Issuing orders to lawyers, real estate agents, court interpreters, bank agents and bookkeepers;
• Submission of requests to MIA, NES, and the Certification body;
• Uses for other purposes for which the data was collected.

IV  DATA SHARING
In order to enable you to use the service, we will share information about you, such as personal and contact information, with our associates and business partners.

We may share information about you in accordance with this Privacy Policy in the following cases:

• With our employees, consultants, and service providers who need access to that data in order to perform work on our behalf, and for which they have an appropriate basis and reason;
• By responding to a request for the provision of data, if such request is in accordance with the Law or other regulation, provided that such request is made in a legally regulated procedure, in accordance with any law, rule or regulation that applies to our relationship;
• If we believe that your actions are not in accordance with the provisions of the Terms of Use that you have accepted, and in order to protect the rights that belong to us, you, or third parties;
• In the case of negotiations with another business entity, on a merger or acquisition, sale of our assets, acquisition of investment capital, or transfer of our business, partially or in full;
• When, during the use of the Service, we inform you that we want to share with third parties certain data that you have provided to us, and you give us your consent for that.

V  ANALYTICS AND ADVERTISING
For the purposes of providing our Services, we may engage external analytical service providers. These persons monitor the activities on the Platform for us in order to help us identify the fields of application of our Services and improve your user experience. Those persons, with your express consent, may use cookies, web beacons, device identification, and other technologies in order to collect data about your use of the Services, including your IP address, internet browser, mobile network usage data, the websites you have viewed, time spent on websites or applications, links you have followed and communication data. Start-Serbia and analytical service providers process this data in order to analyze the data and better understand your activities on the Platform while using our Services.

The user can at any time, through the Platform or through the Start-Serbia’ notification, withdraw their consent to the use of data for analytical and marketing purposes. Please note that the User will receive generic ads regardless of whether he has withdrawn his consent to the use of data for analytical and marketing purposes.

VI  TRANSFER OF DATA TO OTHER COUNTRIES
Our headquarters are in the Republic of Serbia and we collect data in accordance with the law of the Republic of Serbia. By accessing the Services and using them or providing data to us in another way, you agree to the processing and sharing of data in the Republic of Serbia. It is possible that the same rights and obligations are not regulated in the same way as in your country of origin.

Start-Serbia ensures that the recipient of your personal data provides an appropriate level of data protection, e.g. through a binding contract between Start-Serbia and the recipient of the data, which contains the usual contractual provisions on the transfer of data in accordance with the decision of the European Commission (see Art. 46 GDPR).

If you have unresolved questions about privacy or the use of data, which we have not answered satisfactorily, please contact our legal advisor directly by email: boda.janosevic@Start-Serbia.com . Communication with our legal advisor is free of charge. At any time, you have the right to propose a settlement of the dispute through mediation, in accordance with the Law. In accordance with the Law, Start-Serbia is an entity over which the Commissioner for Information of Public Importance and Personal Data Protection of the Republic of Serbia has the right to supervise. In the event that we share EU data with third-party service providers who process data on our behalf and for our account, in the event of a violation of the provisions of the GDPR, we are liable for the processing of data by those third parties, unless we prove that we are not responsible for the event which caused the damage.

VII DATA STORAGE
We keep the data we have collected about you for as long as is necessary to fulfill the purpose for which it was collected, or for other legitimate business reasons, including the performance of our legal and regulatory obligations.

VIII  RIGHT OF OPTION

VIII.I  Your data
You have the right to update, correct, or request deletion of your data at any time by contacting Start-Serbia at the email address: office@Start-Serbia.com . Please note that we may retain certain data in accordance with the Law, or if our legitimate business interests require it. Also, during a certain period, we can keep saved and archived data about you.

VIII.II  Marketing communication
You may choose not to receive our marketing and promotional communications by following the unsubscribe instructions in those communications or by sending an email to: office@Start-Serbia.com . If you have opted out, you may still receive communications from us that are not of a marketing or promotional nature, such as notifications about your user account or notifications about our ongoing business relationship.

IX SERBIAN USERS
If you access the Platform or use our Services from the territory of the Republic of Serbia, you dispose of your personal data in accordance with the current version of the Personal Data Protection Act (“Official Gazette of RS”, No. 87/2018), including:

• The right to know what personal data we collect, process and share;
• The right to revoke your consent to the processing of personal data;
• The right to have personal data deleted (with exceptions specified by law)…

Start-Serbia does not sell your data but may share it in accordance with the provisions of this Privacy Policy with employees, consultants, and other service providers who process data on our behalf and for our account, with whom Start-Serbia has a contractual relationship in accordance with the Law. The aforementioned persons have the right to process and store your data only for the purpose of performing Start-Serbia’ services.

If you wish to exercise any of your rights in relation to personal data, in accordance with the Law, you may contact the following addresses in writing, by telephone or by email:

START-SERBIA
Address: Kralja Milana 8/2
Postal code and city: 11000 Belgrade-Stari Grad
Phone.: +381642491922
E-mail: office@Start-Serbia.com

X  EU USERS
If you access the Platform or use our Services from the territory of the countries of the European Union, you have certain rights that are guaranteed to you in accordance with the current version of the General Data Protection Regulation of the European Commission (EU 2016/769) (GDPR).

X.I  Legal Basis for Processing
Your personal data will be processed exclusively in the following situations:

• You have given us your consent to process your personal data;
• Your data is necessary for us to perform the Services that we have committed to you or another person who bears compensation for your use of the Services, for which you have given consent to those persons;
• We have a legitimate interest in the processing. For example, we process your data to perform the Service, to notify you of changes to the Services, and to improve them.

X.II  Processing requirements
You have the right to access the Personal Data that we have collected, and to request its correction, deletion, or return. You also have the right to request that we restrict data processing in a certain way. You can make a request through the Platform, from your user account, or you can contact us in writing, by phone or email at the following addresses:

START-SERBIA

Address: Kralja Milana 8/2
Postal code and city: 11000 Belgrade-Stari Grad
Phone.: +381642491922
E-mail: office@Start-Serbia.com

X.III  Questions, objections and appeals
If you are concerned about our processing of your personal data, or have questions that we could not resolve in mutual communication, you have the right to file an objection or appeal to the personal data protection authority of the EU territory where you are located. Contact details of the local authority responsible for the protection of personal data can be found at the link: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm