To achieve personal data protection, we take care of the security of your personal data. This Privacy Policy informs you in a transparent and unambiguous way about the collection, usage, nature, and scope of processing of your personal data by ICT Hub Ltd Beograd, st. Kralja Milana no. 10, MB: 20388307, when we process your personal data in the role of data controller (hereinafter: ICT Hub and/or "we" "our" "us" "own" and all other personal and possessive pronouns related to ICT Hub)
This Privacy Policy provides information about all the data we collect about you, especially given the data we collect when you access our icthub.rs website.
Personal data means any data relating to a natural person whose identity is determined or determinable, directly or indirectly, in particular by reference to an identifier, such as name or identification number, location data, an identifier in electronic communication networks, or one or more characteristics of physical, physiological, genetic, mental, economic, cultural or social identity (hereinafter" PD").
The Legal Framework for Personal Data Protection is determined by the Law on Personal Data Protection ("Official Gazette of RS", No. 87/2018), hereinafter, "Law").
PD within ICT Hub Ltd is protected under the ICT Hub Personal Data Protection Rulebook as of March 15, 2022.
In the case there is a connection on our website to other websites, we inform you that we are neither familiar with nor responsible for the way these sites handle the collection or processing of personal data, and therefore we cannot and shall not bear the responsibility of protection of your personal data on such websites.
Methodology of processing of PD and legal basis for the processing of PD
When you access the ICT Hub website, all the information we process, we receive directly from you, i.e. when you:
- fill out or use any form on the site (e.g. "Contact", application for "Newsletter" or "Become our tenant"),
- submit the request for additional services,
- are applying for a contest,
- sign up for educational programs, webinars, and events organized by ICT Hub,
- provide us with other information in the abovementioned or similar way.
All your personal information is treated as confidential, and ICT Hub stores it adequately.
Acting in accordance with applicable data protection rules, we may process your PD in accordance with the following legal grounds:
- processing is necessary for the performance of a contract or similar act to which the data subject and ICT Hub are parties;
- processing is necessary for compliance with a legal obligation to which ICT Hub is subject;
- processing is necessary for the purposes of the legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data;
- the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
We shall be obliged to process PD only when processing is necessary for compliance with a legal obligation to which we are subject.
We shall not be obliged to process PD in other cases, but please note that if you choose not to disclose your personal data to us, we may not be able to undertake or perform our part in the contract or in a similar act to which you may be part.
Please note that all of the above legal grounds apply depending on the purpose for which we collect your data, and for which we shall notify you in each particular case.
Processing of PD
The ICT Hub collects several categories of personal data, depending on the specific request of the user.
Contacting ICT Hub – different types of queries (by email, phone, via the contact form, via social media).
Depending on how you contacted us, as well as the types of queries, we may collect your name, last name, phone number, e-mail address, and other information that you forward to us in connection with your query.
Purpose of processing:
Sign up for educational programs, webinars, and events — to process the application, we well as to organize programs, webinars, and events and to inform you promptly about the course of the event for which you are signed in.
Newsletter – to receive regular monthly notifications about ICT Hub activities;
Send a co-operation query or contact via the contact form — for potential cooperation;
Filling out the contact form "become our tenant" - to use the services of our coworking space as a tenant;
Fill out a contact form "book a venue. " - to use our coworking space services to organize events.
The legal ground for processing: consent of the person to whom the data relates;
Period of saving: during the provision of services for which personal data is processed, as well as after that period, as long as the controller has a legal obligation to comply with, and at the latest until the withdrawal of consent or until you invoke the right to be forgotten.
Protection measures:
Personal data is being stored in the databases to which access has limited personnel. Passwords for such databases are being updated on regular basis. Persons accessing such databases have a special obligation to keep a business secret, including personal data, whereby personnel accessing such databases have undergone training in the field of personal data protection.
Transfers of personal data to third countries or international organizations: The ICT Hub does not transfer personal data to other countries and international organizations.
Website’s visitors
With your consent, we record your behaviour as a user of our website icthub.rs, which includes the following:
- domain and IP address,
- type of browser and operating system that accessed our site,
- access time and visit length
- the pages you visit,
- the address of another website if you have linked our portal from another website,
- information regarding you if you disclose such information to us.
ICT Hub processes your data when visiting websites when using apps and other platforms. On this occasion, different data is exchanged between your device and our server, where some of those data may be personal data. The data collected in this way is used, among other things, to optimize our website or to display advertisements in your device's browser, as well as for the statistical analysis of the use of our pages, all with the aim to improve the quality of our service.
When visiting our website, the browser you use on your device will automatically and without your activity send to the server of our website:
- the IP address of the device from which the query was sent,
- date and time of access,
- name and URL of downloaded files,
- accessed web page/application (URL referrer),
- the browser that you are using and, if necessary, the operating system of a computer that supports the internet, as well as the name of your provider.
The abovementioned data are temporarily saved by the server to the so-called log file, for the purposes:
- to ensure a smooth connection,
- to ensure comfortable use of our website/application,
- to assess the security and stability of the system.
The legal ground for processing the IP address is the consent of the person to which the data relates. Consent is in the form of notifications about the use of cookies. Each time you visit the website, you will have the opportunity to reject the consent in which case your personal data will not be processed, which may result in your inability to access to the website. We do not transmit this data to third parties. The data is saved temporarily, and then automatically deleted.
OTHER FORMS OF PROCESSING
Cookies policy
HTTP cookies (hereinafter: "cookies") are information collected based on the access point – the IP address of the service that enables ICT Hub to customize the content of the service or information society services (hereinafter: both service and information society services can be referred as service) according to access points or IP addresses.
"Cookies" are text files, which are stored on the computer of the user who, through the IP address, accesses the service. After accepting "cookies", when accessing the service, "cookies" are used to customize the content that such service has to offer.
A user who does not want to use "cookies" may enable that when accessing the service. In this case, certain content of the service, may not be available or maybe just partially available.
ICT Hub uses cookies as follows:
Necessary cookies
The necessary cookies improve the website functionality by enabling basic features such as page navigation and access to secure areas of the website. Without these cookies, the website could not be able to function properly.
Performance Cookies
Performance cookies allow us to track visits to our website, as well as to measure and improve performance. They provide us with information about the most and least visited pages and monitor how visitors move on our website. All information collected by these cookies is aggregated and therefore anonymous.
Setup Cookies
Setup cookies allow the website to remember information that changes the way the website features or appearance, such as user language or geographic settings.
Marketing cookies
Marketing cookies are used to track visitors to the website. They are used to show relevant and appropriate advertising content tailored to individual users, thus achieving greater value for external (third parties) advertisers and publishers.
There are different types of cookies
Session cookies are temporarily saved on your computer when you visit our website and are removed as soon as you close your browser.
Permanent cookies remain on your computer until you remove them or until their predefined save period expires.
First-page cookies - they are placed by ICT Hub on your computer when you browse our website.
Third-party cookies are cookies posted to the ICT Hub website by partner advertising websites and are used to collect information to advertise and place custom content, as well as web statistics. These cookies provide insight into your interests when searching the ICT Hub website, and can be blocked. They don't store personal data directly, but they work by uniquely identifying your browser and device.
Google Analytics
To customize our website, we use Google Analytics - a web analytics service provided by Google Inc. ("Google"). In addition to these cookies, we use Google Tools - Google Analytics, Google Tag Manager, Google Ads (for conversion marketing tracking). Google Analytics is a web analytics service created by Google, which is used to track and notify visitors to Websites. Google uses the data collected to track and monitor the usage of our website.
In this context, pseudonymized user profiles are created and cookies are used. Cookies generate the following information about your use of our website:
- browser type/version,
- operating system used,
- referrer URL (previously visited page),
- "hostname" of the computer from which it has been accessed (IP address),
- server query time.
The data is used for information about the assessment of the usage of our websites by the visitors and to collect statistical reports on activities on the website. IP addresses are anonymized, so the identity cannot be determined. Under no circumstances shall your IP address be linked to other Google data.
For more information about data protection related to Google Analytics, visit the Google Analytics website.
Rights of data subjects
When personal data is collected from you, ICT Hub may provide you with the following information:
- identity and contact data of the controller, as well as its representative, if specified;
- personal data protection officer, if specified;
- purposes of the intended processing and legal ground for processing;
- the existence of a legitimate interest of the controller or third party, if the processing is done based on processing that is necessary to achieve the legitimate interests of the controller or third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child;
- recipient or group of personal data recipients, if they exist;
- the period of storing personal data or, if this is not possible, the criteria for its determination.
You, as the data subject, have the right to:
- require access, correction, or deletion of personal data, i.e. the right to restrict processing, the right to object, and the right to data portability;
- to object the processing of personal data. The data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. This shall apply if the processing is undertaken on the ground of the consent of data subject for the processing for one or more specific purposes or for processing of special categories of data;
- lodge a complaint with a supervisory authority,
- transparent information, communication and modalities for the exercise of the rights of the data subject. The controller shall have obligation to inform the data subject regarding the legal or contractual obligations which made ground for the processing of personal data, as well as whether processing of personal data is a condition for concluding a contract. The controller shall have obligation to inform the data subject about possible consequences if the data subject decides to reject to provide personal data relating to him or her,
- receive information about the automated individual decision-making, including profiling, with meaningful information about the logic involved, as well as the implications and intended effects of such procedures to data subjects.
To exercise your rights, as well as to request additional information regarding the processing of personal data reach us out by the following e-mail address: info@icthub.rs.
This privacy policy enters into force on 15.04.2022.
This Privacy Policy is written in Serbian and English, and in the case of a misunderstanding in the interpretation of its provisions, the Serbian version shall prevail.
ICT Hub reserves the right to make changes and updates to this Privacy Policy. Any changes and updates will be published on the following hyperlink https://icthub.rs/privacypolicy