NOTICE ON PROCESSING OF PERSONAL DATA BY THE CONTROLLER

This notice refers to the processing of personal data by the controller “Banja Komerc Bekament” DOO Banja

“Banja Komerc Bekament” DOO Banja processes personal data only of those data holders with whom it comes into contact in order to conduct its business, either by collecting data directly from these persons, or through their employers, contractors, business partners or, where applicable, third parties.

Personal data are always processed by “Banja Komerc Bekament” DOO Banja in accordance with the principle of limiting the retention period, in the minimum period of time in which in order to fulfil the specific purpose of the company it is important that the persons to whom the data relate can be identified.

The rules on the processing of personal data by “Banja Komerc Bekament” DOO Banja include, but are not limited to, the following main categories of personal data holders and types of personal data:

1. Employees and persons engaged outside employment, former employees and pensioners

“Banja Komerc Bekament” DOO Banja processes personal data of employees and persons engaged outside employment, as well as personal data of former employees and pensioners and members of their families, primarily in order to enforce and comply with applicable regulations governing the handling of this type of data, including but not limited to labour regulations and records in the field of labour, pension, disability, health and social insurance, tax and accounting regulations, occupational safety and health regulations, as well as relevant sector regulations governing data processing in the pharmaceutical industry and other sector regulations.

Data of employees and other people engaged in work are also processed to the extent necessary in order to conclude and execute an appropriate contract with these persons. Data of this category of persons are also processed on the basis of their consent whenever it is necessary for such consent to be obtained in accordance with applicable regulations, i.e. on the basis of a legitimate interest, when such a legitimate interest exists.

2. Persons who apply for employment, i.e. engagement outside employment

Data of persons applying for employment, i.e. engagement outside employment or applying for professional practice, are processed only to the extent necessary for the process of recruitment and selection of candidates to be carried out in an efficient manner, taking into account the interests of “Banja Komerc Bekament” DOO Banja and the freedoms, the rights and interests of the candidate. Candidates who have not passed the selection process and whose data have been collected for this purpose are provided with all the rights they have under the relevant regulations.

3. Persons who sell or buy real estate the seller (buyer) of which is “Banja Komerc Bekament” DOO Banja

Data of persons buying (selling) real estate are processed only to the extent necessary for the process of purchase and solemnization of sales contracts to be carried out in a lawful manner, taking into account the interests of “Banja Komerc Bekament” DOO Banja and freedoms, rights and interests of candidates.

4. Persons entering the business domain of  “Banja Komerc Bekament” DOO Banja

“Banja Komerc Bekament” DOO Banja has a legitimate interest to process personal data of all persons entering the business domain and business premises of “Banja Komerc Bekament” DOO Banja, regardless of their location, and to keep records of these visits in accordance with all applicable regulations, including but not limited to regulations governing personal security and video surveillance.

5. Professional public

“Banja Komerc Bekament” DOO Banja provides the consent for the processing of personal data of persons who make up the professional public, in order to process personal data within the internal collections that are kept for the purposes of cooperation with these persons and communication with them. The consent of these persons is not required if the processing of their personal data is necessary for the execution of contracts concluded by these persons, as well as in order to comply with certain legal obligations applicable to “Banja Komerc Bekament” DOO Banja or if  “Banja Komerc Bekament” DOO Banja  processes the personal data of the persons from this category in certain situations on the basis of legitimate interest.

6 Persons who report product complaints

Personal data of persons who report product complaints are processed exclusively in accordance with the positive regulations that apply and this includes the execution of contracts with appropriate partners.

7. Business associates and natural persons hired by business associates – legal entities

In order to organize business, “Banja Komerc Bekament” DOO Banja collects personal data of both natural persons who act independently, and natural persons who are employed by business partners (legal entities) and potential business partners, or persons who are engaged with them on another basis. The subject processing is performed both for the purpose of concluding these contracts, and for the purpose of their execution and fulfilment of all legal obligations that “Banja Komerc Bekament” DOO Banja has in this regard. If the contracting party is not a natural person but a legal entity hiring them, “Banja Komerc Bekament” DOO Banja will have a legitimate interest in processing personal data to the extent necessary for the contract to be executed.

If certain personal data are not necessary for the conclusion and execution of a contract with a specific natural person who is the data subject, such personal data may be processed if “Banja Komerc Bekament” DOO Banja has a legitimate interest to perform specific processing, because not doing so would cause the execution of the contract to be impacted negatively, and the processing in question does not jeopardize the rights or interests of the data subjects.

Personal data of business associates and natural persons hired by business associates may also be processed if those persons have given valid consent for a purpose not related to the execution of the contract, and in accordance with applicable regulations.

8. Natural entities with which normal and appropriate business and partnership relations are maintained

“Banja Komerc Bekament” DOO Banja processes data of natural persons with whom normal and appropriate business and partnership relations are maintained, both with natural entities and persons who are engaged or represent other legal entities, institutions or authorities, but only to the extent necessary and suitable for this purpose (sending invitations to celebrations and events, sending appropriate and usual gifts, sending promotional material), and in compliance with all principles of data processing, applicable regulations and internal rules.

9. Natural entities which are beneficiaries of donations and sponsorships, in surveys and contests

“Banja Komerc Bekament” DOO Banja processes data of natural persons for the purposes of using donations and sponsorship as well as participation in certain contests, surveys or questionnaires organized by “Banja Komerc Bekament” DOO Banja either on the basis of legitimate interest or consent of these persons, depending on which categories of persons participate in a specific testing, what kind of testing it is, what type of personal data is processed, etc.

10. Photographing natural entities at events organized by “Banja Komerc Bekament” DOO Banja

At the events organized by it, “Banja Komerc Bekament” DOO Banja can take photos of natural persons – participants in the event, from the category of employees and other persons engaged in work activities as well as third parties who are invited to these events. It will be considered that the processing of personal data in this way is based on the legitimate interest of companies to report to their employees, other persons engaged in work activities, business partners and the general public, as long as such processing is in accordance with established and common business practices of “Banja Komerc Bekament “DOO Banja, whereby the persons to whom the data refer will have all the rights provided according to the applicable regulations.

The rights of the persons whose data are processed

Natural persons whose data are processed, in accordance with the applicable regulations on personal data protection, may exercise the following rights with “Banja Komerc Bekament” DOO Banja

  • The right to be informed
  • Right of access / copy
  • The right to correction
  • The right to restrict processing
  • The right to object
  • Right to erase / “right to forget”

In order to realize one of the above rights, the natural person can contact us at any time.

If the processing of personal data is based on consent, i.e. the natural person has the right to object or withdraw their consent at any time, which will be valid in the future. The legality of processing on the basis of consent until the withdrawal of consent remains unchanged. The given consent can, of course, be cancelled at the following address at any time, and will be valid in the future as well:

„Banja Komerc Bekament“DOO Banja
Kralja Petra Prvog 132 Banja Arandjelovac
34304 Banja
tel: +381 34 6777 500
Faks: +381 34 6777 505
E-mail: info@bekament.com

In addition, the natural person whose data are processed has the right to object to the data protection supervisory authority regarding the processing of their personal data. Contact details of the competent authority can be found on the web page https://www.poverenik.rs/sr/.

Contact

If you have any questions or comments regarding this notice on processing of personal data, you may contact us at info@bekament.com