PRIVACY POLICY
Updated on 20.04.2023.
Welcome to our Privacy Policy!
We are KeyOPS Lab DOO BEOGRAD-ČUKARICA, with the registered seat at the address KADINJAČA 61 1, 3, 11030 Belgrade (Čukarica), Serbia, CIN: 21325872, TIN: 110257144 (hereinafter: „KeyOPS Lab“ or „us“).
This Privacy Policy is a document that reflects KeyOPS Lab's detailed approach to User Privacy and shows you how we collect, share and use your personal data. In addition, the Privacy Policy explains how you can exercise your rights as a data subject.
As we highly value the privacy of all our Users, by creating this Privacy Policy we wanted to make the processing of your data clear, transparent and understandable.
Please note that this Privacy Policy applies to all Users, as well as other persons who contact us via email.
We have the role of controller of personal data, which means that we determine the purpose and basis of processing personal data in connection with interactions in the App and the use of our Service.
Together with the Terms of Use and Cookie Policy, this Privacy Policy represents a part of the Agreement that applies to you. Therefore, please read it carefully, so that you understand all the necessary information related to the protection of your data.
All capitalized terms that are not defined in this Privacy Policy have the same meaning as in our Terms of Use.
In case you have any questions regarding this Privacy Policy, please contact us at privacy@keyops.org.
- Defined terms
- What personal data do we collect?
- Why do we collect personal data?
- Persons under the age of 15
- How do we use collected Personal Data?
- How long do we keep Personal Data?
- Who do we share your Personal Data with?
- Your rights
- Changes to Privacy Policy
- Get in touch
1. Defined terms
| Term | Meaning |
|---|---|
Consent
|
Your explicit consent on the processing of your Personal Data. Persons who are 15 years of age or older may give free consent to the processing of their Personal Data. |
Cookies
|
Small pieces of data stored on your device, used to track your behavior or to create statistical reports on activity within the App. For a more detailed explanation of the use of cookies and similar technologies, as well as how you can manage them, please go to our Cookie Policy. |
Data Processor
|
Any natural or legal subject who processes Personal Data on our behalf. We may use the services of various service providers in order to process your Personal Data more effectively. |
Data Subject or you
|
Any natural person who shares their Personal Data with us. |
| Law | Law on Personal Data Protection („Official Gazette RS“, no. 87/2018) |
Personal Data or data
|
Any information relating to an identified or identifiable natural person - Data Subject.
• An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, identification number, location data, online identifier or to one or multiple factors specific to its physical, physiological, genetic, mental, economic, cultural, or social identity. Consequently, data about a legal entity cannot be considered to be Personal Data but registering on behalf of a legal entity may include sharing Personal Data. For instance, information related to one-person companies may constitute Personal Data where it allows the identification of a natural person. These rules also apply to all Personal Data in relation to a natural person in the course of the professional activity, such as the fact of employment in the company or organization, employee’s business telephone number, or a business email address such as “firstname.surname@company.com”. This Privacy Policy does not apply to information that cannot reasonably result in the identification of an individual (anonymized information). |
Processing
|
Any activity or set of activities performed on Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction. |
Service
|
Making available any content by us within the App. Service does not include any other (if any) services provided by us without the use of the App. |
2. What personal data do we collect?
We may collect and receive your Personal Data in several ways:
- voluntarily – the data you intentionally share with us, for example, by getting in touch via email.
- automatically – certain data that we collect when you access the App.
- through the use of cookies – explained in detail in our Cookie Policy.
(a) Data provided by you
Contact and additional information
If you contact us by email, we may collect certain data such as your email address and data related to it, including the content of your message.
(b) Automatically collected data
Technical Data
When you access the App, some information about you will be collected automatically. Such data includes your IP address, device type and unique identification number, browser, broad geographical location (e.g., country or city) and other similar technical information. This technical data also includes the information that we collect through the use of cookies and similar tracking technologies. You can read more about it in our Cookie Policy.
We measure traffic and usage trends of our App by using analytic tools, which collect information sent by your device. Such analytics information is collected and used along with identical information from other Users, so it cannot reasonably be used to identify any particular individual.
Information about your use of the App
Since we collect and record data and sessions about access to the App and its use, there is a possibility that in such a case we will also process your personal data.
In order to analyze and improve the performance of the App, we collect certain data such as the type of your mobile device, identification number, date and time stamps of the use of the App. The tracking technologies we use allow us to collect aggregate, not personal, statistical data in this case as well.
3. Why do we collect personal data?
Data we collect
|
Purpose of collecting
|
Legal ground
|
|---|---|---|
| Responding to your request/inquiry | ||
| Email address and related information, email content / Your message, as well as any other additional information you share with us. | We collect your data in order to respond to your inquiries sent via email. | OThe processing is necessary for the performance of the contract, the conclusion of such a contract with you, as well as for the purpose of providing answers to your questions and requests regarding the use of our App or Services. If you refuse to provide such information, we will not be able to process your request. |
| Analyzing, managing, and improving the use of the App and Services | ||
| Technical data and data related to the mobile device. | Automatically collected data is used to:
|
The processing of automatically collected data is necessary for the performance of the contract. However, all other data is processed based on your consent. Therefore, unless it is necessary to provide the services or part of them, the sharing of your data is not a legal or contractual requirement, and you can choose not to share such data. Where the processing is based on your consent, you can withdraw your consent at any time, and this will not affect the lawfulness of the processing that was based on your consent before you withdrew it. |
| Displaying non-personalized advertising/content | ||
| Contextual data (which does not allow the identification of an individual User and does not include the analysis of the User's previous behavior), IP address and other data about the device | Given that our App is free for all Users, in order to ensure our economic interests, duration and improvement of the App, we have allowed third parties to advertise within the App. These are non-personalized advertising messages, which means that for the purposes of such marketing, data on your previous behavior was not collected and processed. | Data processing is necessary in order to achieve the legitimate interests of the controller, consisting of the realization of economic interests and financing. Since these are non-personalized advertising messages, the interests/fundamental rights and freedoms of the data subjects do not prevail over the interests of the controller. |
| Tracking behavioral patterns and displaying personalized messages and ads | ||
| Your reaction/activity to an ad or other in-app content, advertising ID (IDFA – Apple Identifier for Advertisers or GAID – Google Advertising Identity) IP address and other device data | After becoming a User, you can choose to give your consent to the tracking of your behavior patterns, as well as to the display of personalized messages and advertisements from third parties, based on the observed behavior patterns. These cookies enable tracking of your behavior through various applications. | We use your data for the stated purpose only if you agree that your behavior is monitored. You are not required to give this consent, and if you do not, we will not monitor your behavior or send you personalized messages. This also means that the ads that will be shown to you in the App will be less relevant to you. However, if you agree, you can withdraw your consent at any time, provided that this will not affect the data processing that took place while your consent existed. |
No Personal Data are processed outside the specific purposes. We do not sell any kind of Personal Data, or disclose Personal Data to other marketers, nor do we provide your Personal Data to any third party unless we are strictly compelled to do so by law.
4. Persons under the age of 15
The App is not intended for children, and we do not knowingly collect data relating to a person under the age of 15. If you are under the age of 15, we kindly ask you to not provide any personal information about yourself to us.
In case we detect that we have collected personal information from a person under the age of 15, such information will be deleted promptly.
If you believe we have collected personal information from a person under the age of 15, please contact us at: privacy@keyops.org.
5. How do we use collected Personal Data?
We do not use any of the collected data relating to you, without your consent, or without another appropriate legal basis – in accordance with the section “Why do we collect personal data?”.
We use your data only for the purposes for which we collected it, and only when we have a reasonable and lawful legal basis for doing so.
In order to ensure the highest level of data security, we use appropriate technical and organizational measures designed to provide an appropriate level of security, in accordance with the risk associated with the processing of your data. In addition, our staff is legally bound by professional secrecy rules.
However, please keep in mind that no method of transmitting information via the Internet, or method of electronic data storage, is absolutely secure. Therefore, we cannot guarantee 100% security or confidentiality of data.
If you have questions about the technical, organizational, and security measures we apply, you can contact us at privacy@keyops.org.
6. How long do we keep Personal Data?
We keep your Personal Data solely for the time it takes to fulfill the purpose for which it is collected, i.e., for the time for which we have your consent.
When determining the period of data retention, we take into consideration domestic laws, contractual obligations, and the expectations and requirements of our Users.
Once we no longer need your Personal Data, or upon your request for the deletion of such information pursuant to the law, we will securely delete or destroy the data in accordance with the applicable law and our internal policies.
7. Who do we share your Personal Data with?
To conduct certain processing activities, we are sometimes required to engage some external processors. We use information audits to identify, categorize and make records of all Personal Data that is processed outside of the KeyOPS Lab. That way, all the Personal Data, as well as the information on processing activities, processors, and legal grounds are recorded, reviewed, and easily accessible.
External processing includes, but is not limited to:
- IT systems and services
- Direct marketing services
The list of processors with whom we share your Personal Data is the following:
| PROCESSOR
|
ROLE
|
SEAT
|
|---|---|---|
| Google, Inc. | Analytics, tracking and advertising | USA |
Under the law, we may be required to share certain information, including your Personal Data, with e.g., public authorities or governmental bodies on their request. In that case, your further consent will not be required, in order to share your Personal Data in accordance with such a request.
International transfer of Personal Data
We may transfer your personal data to countries other than the one you reside in. In these cases, we will transfer your personal data only:
- To the countries within the EEA;
- To the countries which do not form the EEA but are considered to ensure an adequate level of protection;
- To the countries which do not belong to those specified under items 1. and 2, but only by applying the appropriate safeguard measure in accordance with the Law (for example, applying standard contractual clauses).
If you require further information about these protective measures, please contact us at privacy@keyops.org.
We use servers located in Serbia.
8. Your rights
As a Data Subject whose Personal Data we process, you have the following rights:
 |
right to be informed about the collection and usage of your Personal Data, |
 |
right to access the Personal Data we hold about you, |
 |
right to have your Personal Data corrected (rectified) if any of them is incomplete or inaccurate, |
 |
right to be forgotten, i.e., the right to ask us to delete or dispose of any of your Personal Data that we have, |
 |
right to the restriction of processing of your Personal Data, |
 |
right to data portability, in case you have provided your Personal Data to us, and that data is processed using automated means, you have the right to ask us for a copy of such Personal Data, as well as to have those data transmitted to a third-party data controller, |
 |
right to object to using your Personal Data in case processing is based on our legitimate interest, as well as if the processing is performed with a purpose of direct marketing, which includes profiling. |
 |
right to lodge a complaint, if you have any concerns or requests in relation to your Personal data, please contact us, and we will respond within 30 days.
If you are unsatisfied with how we process your data, you may also contact the competent supervisory authority – the Commissioner for information of public importance and personal data protection of the RS. |
To exercise any of these rights, please contact us at privacy@keyops.org.
9. Changes to Privacy Policy
We reserve the right to update and modify this Privacy Policy from time to time as we find appropriate. Any changes will be effective upon posting within the App, so we recommend that you periodically review our Privacy Policy.
In case you do not agree with the changes to our Privacy Policy, please stop using the App without delay.
10. Get in touch
If you wish to exercise any of the rights you have as a data subject or you have a question regarding our Privacy Policy, please contact us at privacy@keyops.org.