1. TERMINOLOGY

The following terminology applies to these Use of Terms:
Client, User, You, Your or Data Subject refers to any natural person that shares personal data with us;
Cookies refers to a small piece of data stored on your device (computer, mobile or any other device). This information is used to track your use of the www.inviggo.com website and to compile statistical reports on website activity. For further information about the use of cookies and how you can manage them, please read our Cookies Policy, available at __.
Consent refers to your explicit, freely given, informed and unambiguous consent on the processing of personal data. Persons who are 15 years of age or older may freely give their consent to the processing of their personal data. Controller or Data Controller refers to the company Inviggo d.o.o. Novi Sad, that determines the purposes and means of the processing of personal data;
EEA refers to the European Economic Area;
EU refers to the European Union;
GDPR refers to the EU General Data Protection Regulation available at https://eur-lex.europa.eu/eli/reg/2016/679/oj;
Personal Data Protection Act or PDPA refers to the Act on Personal Data Protection of the Republic of Serbia (Official Gazette of Republic of Serbia; no. 87/2018);
Privacy Policy refers to this Privacy Policy;
Inviggo, We, Us, or Our refers to the company Inviggo d.o.o. Novi Sad and any of its affiliates;
Personal Data, Personal information or Data refers to information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, either directly or indirectly (such as by name, identification number, location data, URL address, or any other identifier to physical, physiological, genetic, mental, economic, cultural or social identity of that natural person). Therefore, data about a company or any legal entity is not considered to be personal data but registering on behalf of a legal entity may include sharing personal data. For example, the information in relation to one-person companies may constitute personal data where it allows the identification of a natural person. The rules also apply to all personal data relating to natural persons in the course of professional activity, such as the employees of a company or organization, business e-mail addresses like firstname.surname@company.com
Processor, Data Processors refers to any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various service providers in order to process your data more effectively.
Processing or Data processing refers to any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Website refers to our website www.inviggo.com;
Service refers to services, features, software, Website;
Supervisory authority refers to an independent public authority that is authorized for the protection of your personal data in your country;
Third party refers to a natural or legal person, other than you and us, who is authorized to process personal data;
USA refers to the United States of America.
Any use of the above terminology or other words in the singular, plural, capitalization and/or he/she or they, are taken as interchangeable and therefore as referring to the same.

2. CONTROLLER

We are a company registered and existing under the laws of the Republic of Serbia, with its seat at Augusta Cesarca 18, 21000 Novi Sad, Republic of Serbia, registration number: 21718726 which, as a controller, determines the purposes and means of the processing of your personal data. Controller is responsible for your personal data.

3. APPLICATION OF THIS POLICY

This Privacy Policy applies to:

1. all individuals who visit our Website;
2. all individuals who contact us/send requests and inquiries via our Website;
3. all individuals who engage our services and become our client;

WHAT PERSONAL DATA DO WE COLLECT?

• Information you voluntarily provide us in your inquiry and/or by contacting us;
• Information we collect through the use of cookies in accordance with our Cookies Policy;
• Information automatically collected.

4. WHY DO WE COLLECT PERSONAL DATA?

Purpose
Legal Basis
To process inquiries and request you sent us via the contact form or by mailing at office@inviggo.com to respond and improve services we provide you.
Processing is necessary for the performance of the Agreement for Provision of Services or to conclude other agreements with you;


If you send us an inquiry, we will collect data you decide to share with us.Your consent - unless providing personal data is necessary to provide a Service or part thereof, the provision of your personal data is not a statutory or a contractual requirement and you may refuse to disclose any data. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal. 


By using cookies we collect some of your personal data to help us measure traffic and usage trends for the Service, to enable proper functionalities of features and tools at the Website, and to improve our Services.
Processing is based on your consent you explicitly gave by accepting our Cookies Policy and allowing the usage of cookies. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal. You may block or opt-out any of the cookies used, in accordance with our Cookies Policy.


Provision of our Services to existing and new clients
Processing is necessary for the performance of contractual obligations we have towards you.

5. WHAT DO WE NOT DO?

We will never:

• Sell any kind of personal information or data;
• Disclose personal information or data;
• Process your personal data and information in any way other than the one stated in this Privacy Policy.

6. PROCESSING PERSONAL DATA

We are the only processor of your data. We do not engage any natural or legal person to process your data on our behalf and/or for our account.

7. PERSONAL DATA SECURITY

We take administrative, technical, organizational and other measures to ensure the appropriate level of security of personal data we process. Upon assessing whether a measure is adequate and which level of security is appropriate, we evaluate the nature of personal data we are processing and the nature of the processing operations we perform, the risks to which you are exposed to by our processing activities, the costs of implementation of security measures and other relevant matters in each particular case.
Some of the measures we apply include access authorization control, information classification (and handling thereof), protection of integrity and confidentiality, data backup, firewalls, data encryption and other appropriate measures. We equip our staff with the appropriate knowledge and understanding of the importance and confidentiality of your personal data security.

8. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

We will not share your personal data with third parties, unless:

• You give us your consent;
• We are legally obliged to share certain information, including personal data, with state authorities, governmental bodies etc;
• We need to share your personal data with specialist or experts abroad to obtain their competent advices;

Inviggo utilizes external processors for certain processing activities. We use information audits to identify, categorize and record all personal data that is processed outside the company, so that the information, processing activity, processor and legal basis are all recorded, reviewed and easily accessible.
We have strict due diligence procedures and measures in place and review, assess and background check all processors prior to forming a business relationship. We obtain company documents, certifications, references and ensure that the processor is adequate, appropriate and effective for the task we are employing them for.
We audit their processes and activities prior to forming a business relationship and during the contract period to ensure compliance with the data protection regulations and review any codes of conduct that oblige them to confirm compliance.
This is the list of processors with whom we share your personal data: 
Processor
Role
Seat
Google, Inc.
Analytics 
USA

9. INTERNATIONAL TRANSFER OF YOUR PERSONAL DATA AND INFORMATION

We collect your personal data in the Republic of Serbia. We may transfer your data only to the following countries:

• The countries of the EEA;
  
• The countries which do not form the EEA but are considered to ensure an adequate level of protection in accordance with the PDPA;
• The countries which do not belong to those specified under item 1 and 2, but only by applying the appropriate safeguard measure in accordance with the GDPR. For example, in case of transfer of personal data to the USA, we will ensure to have a Data Processing Agreement with the applicable standard data protection clauses.

10. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We keep your information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless otherwise required or permitted by law.
The period for which we store your personal data depends on a particular purpose for processing of personal data within the use of our Website. 
In determining data retention periods, we take into consideration local laws, contractual obligations, and the expectations and requirements of our customers and suppliers. We securely delete or destroy your personal information when we no longer need it, or when you request us to delete your personal information. For example, in the event that you unsubscribe from our Newsletter, your personal data will be erased automatically.

11. YOUR RIGHTS RELATING TO THE PERSONAL DATA PROTECTION

If you have any questions or comments regarding our Privacy Policy and/or rights related to the personal data protection, please get in touch with us at ___@inviggo.com.

12. CHANGES TO PRIVACY POLICY

We reserve the right to change our Privacy Policy from time to time at our sole discretion. If we make any changes, we will publish the new Privacy Policy on our Website.
If you have previously consented to our Privacy Policy, your continued use of the Website after the changes we have made shall be deemed as your acceptance of the updated rules. 

13. CONTACT US

If you have any questions or comments regarding our Privacy Policy and/or rights related to the personal data protection, please get in touch with us at ___@inviggo.com.