Privacy Policy

DELTA HOLDING DOO, /DELTA HOLDING LLC/ BEOGRAD, (NOVI BEOGRAD MUNICIPALITY), 8A Vladimira Popovica Street, 11070 Belgrade, Company Reg. No.: 17156730 (hereinafter referred to as: “the Company or We”), respects and protects the privacy of every person (natural persons – clients, potential clients or other persons – hereinafter collectively referred to as: „the Client or You“) whose personal data it collects (hereinafter referred to as: „Personal Data“). Collecting and storing Personal Data is conducted in accordance with the Law on Personal Data Protection (”Official Gazette of the Republic of Serbia” no. 87/ 2018– hereinafter referred to as: „the Law“), as well as the EU General Data Protection Regulation (EU 2016/679)(hereinafter referred to as: „GDPR“), when applicable.

In the event of processing Personal Data of Clients who are citizens of some European Union Member State, We will also apply GDPR provisions, the the extent applicable.

We value you and recognize that privacy is important to you.  In order to protect privacy of every Client whose Personal Data we collect, We have published this Privacy Policy, which defines which Personal Data we collect, in what manner, for what purpose we process it, how we protect it, for how long we keep it, as well as what rights in relation to Personal Data you have. Namely, we have developed this Privacy Policy so as to show you our new practice regarding the collection of Personal Data  that we collect from you or about you on this site, through oral or written communication with us, when you visit our business premises or from other sources.

In any case, feel free to contact the personal data protection officer via e-mail address: gdpr@deltaholding.rs

“Personal Data” is any data related to a natural person whose identity is determined or determinable, directly or indirectly, especially on the basis of the label identity;

“Personal Data Processing” is any action or set of actions performed automatically or non-automatically with personal data or their sets, such as collecting, recording, sorting, grouping, i.e. structuring, storing, matching  or changing, disclosure, inspection, use, disclosure by transmission, i.e. delivery, duplication, dissemination or in other way making available, comparison, restriction, deletion of destruction;

“Sensitive Data” refers to data relating to racial or ethnic origins, political opinion, religious or philosophical beliefs, trade union membership, health, sex life or genderual orientation, genetic information, criminal record and biometric data used for the purpose of unique identification.

We do not collect your sensitive data, unless you make it available voluntarily or if we are required to do that by applicable regulations.

“Personal Data of Children” refers to persons under the age of 18.

We do not collect Personal Data of children. As a parent or a legal guardian, you should not allow your children to make their Personal Data available without your permission.

Personal data is collected directly from you, as the person whose data is being processed, or by other persons.

1. Direct collection of Personal Data from Clients whose data is being processed
a) By sending your Curriculum Vitae via e-mail address in the section called Carrier “Join us”, available on our website

Since you have sent us your Curriculum Vitae we will consider that you have given us consent to process submitted personal data for the purpose of possible employment and contacting you in relation to the possible employment. Additionally, if we think that your Curriculum Vitae is more suitable for a job position i.e. employment at some company associated with us, we will consider that we have your consent to forward your Curriculum Vitae to our related persons in the territory of the Republic of Serbia, which will initially use your Curriculum Vitae for the purpose of contacting you in relation to possible employment. In any further type of processing your Personal Data, Yyou will be notified by a specific member of our group.

If necessary, we can submit your Personal Data to a company employed for the purpose of advertising, selection and recruitment of candidates.

Of course, you can revoke Your consent at any time by sending an e-mail to the e-mail address: gdpr@deltaholding.rs We ask you to keep in mind that the revocation of consent does not affect the admissibility of processing on the basis of consent before revocation.

We will store Personal Data you have provided in your Curriculum Vitae and the questionnaire filled out during your application in our database for a period of five (5) years  from the date of receipt of the Curriculum Vitae, i.e. filling out the questionnaire, after which we will delete it. Of course, if you revoke your consent earlier, your Personal Data will be deleted immediately after revocation of consent.

At any time,  you have the right to request from us: 1) access to Personal Data, 2) Personal Data correction, 3) deletion of Personal Data and/or 4) revocation of consent at any time. Additionally, at any time you can also exercise the following rights: 1) the right to limit data processing, 2) the right to data portability and 3) the right to file a complaint with the Commissioner for Information of Public Importance and Personal Data Protection.

You can exercise your rights by sending a request to: gdpr@deltaholding.rs.

b) By sending your Curriculum Vitae via e-mail address in the section called Carrier “Young Leaders” Program, available on our website

Since You have sent us your Curriculum Vitae and filled out the contact form, we will consider that you have given us your consent for processing the provided Personal Data for the purpose of selection, recruitment and possible employment and contacting you in relation to these activities.

Furthermore, as part of the selection process, We will perform various tests of candidates, through a cognitive test, a personality test and a professional test that you submitted to us when filling out the form before accessing tests (Name and Surname, as well as various data in relation to your education), and before starting tests (Name and Surname, Personal ID number, date of birth, place of birth, gender and various data in relation to your education).

Of course, you can at any time revoke your consent by sending an e-mail to the e-mail address: gdpr@deltaholding.rsWe ask you to keep in mind that revocation of your consent does not affect the admissibility of processing on the basis of consent before revocation.

If you do not revoke your consent, keep in mind that we will store your Personal Data that you have sent us in your Curriculum Vitae in our database for a period of five (5) years from the date of receipt of your Curriculum Vitae, i.e. From the date of filling out the questionnaire, after which we will delete it.

At any time, you have the right to request from us the following: 1) access to Personal Data, 2) Personal Data correction, 3) deletion of Personal Data and/or 4) revocation of consent at any time. Additionally, you can exercise the following rights at any time: 1) the right to limit data processing, 2) the right to data portability, and 3) the right to file a complaint with the Commissioner for Information of Public Interest and Personal Data Protection.

You can exercise your rights by sending a request to gdpr@deltaholding.rs

c) By filling out your application form for participating in D Incubator Program, available on our website it

Keeping in mind that you have filled out the application form available on our website https://dinkubator.rs/prijavi-se/we will consider that you have given us your consent for processing the provided Personal Data for the purpose of possible participation in the program and contacting you in relation to possible participation.

We process your Personal Data, as well as the personal data of your team member for the purpose of cooperation and implementation of D Incubator Program, which We organize with the aim of providing resources for the development of your business.

Of course, You can revoke your consent at any time by sending an e-mail to the e-mail address: gdpr@deltaholding.rs.

We will store your Personal Data that you have provided us when filling out the application form and from your Curriculum Vitae in our database, for a period of five (5) years from the date of receipt of the Curriculum Vitae, i.e filling out the application form, after which we will delete it. Of course, if you revoke your consent earlier, your Personal Data will be deleted immediately after revocation of consent.

At any time, you have the right to request the following from us: 1) access to Personal Data, 2) Personal Data correction, 3) deletion of Personal Data and/or 4) revocation of consent at any time. Additionally, you can exercise the following rights at any time: 1) the right to limit data processing, 2) the right to data portability and 3) the right to file a complaint with the Commissioner for Information of Public Importance and Personal Data Protection. You can exercise your rights by sending a request to: gdpr@deltaholding.rs

d) When sending your Curriculum Vitae via e-mail as part of the cooperation with the University of Belgrade, and in relation to the potential student internship.

Since you have sent us your Curriculum Vitae, we will consider that you have given us your consent for processing provided Personal Data for the purpose of cooperation with the University of Belgrade, and in relation to the potential student internship that we organize for students in cooperation with the University of Belgrade.

Of course, you can revoke your consent at any time by sending an e-mail to the followingaddress: gdpr@deltaholding.rs. We ask you to keep in mind that revocation of consent does not affect the admissibility based on the consent before revocation.

In any case, if you do not revoke your consent, we will store your Personal Data that you have provided to us in our database, for a period of five (5) years from the date of receipt of the Curriculum Vitae, after which we will delete it.

At any time, you have the right to request the following from us: 1) access to Personal Data, 2) Personal Data correction, 3) deletion of Personal Data and/of 4) revocation of consent at any time. Additionally, at any time, you can also exercise the following rights: 1) the right to limit data processing, 2) the right to data portability, and 3) the right to file a complaint with the Commissioner for Information of Public Importance and Personal Data Protection. You can exercise your rights by sending a request to gdpr@deltaholding.rs

e) When providing services to you as our Client

In order to provide you with the service for which you hired us in a timely manner, it is necessary for you to provide us with the following personal data: Name and Surname, gender, Personal ID no., e-mail address, contact number, job title.

Keeping in mind the type of cooperation, which is preceded by the pre-contractual phase, We process Personal Data of the legal representative/contact person/authorized person with you as the client on several grounds.

First of all, We process your Personal Data on the basis of entering into and executing the contract or for taking actions, at your request, before signing the contract. Providing Personal Data of your legal representative/contact person/authorized person is a contractual obligation, i.e. providing Personal Data is a necessary condition for the execution/implementation of the contract, which is why your legal representative/contact person/authorized person has the obligation to disclose the Personal Data to our employees. Otherwise, We will not be able to enter into and implement a specific contract.

Furthermore, in the event that you issue an invoice to us, we will store the received invoice in our database, which may contain Personal Data of your legal representative/contact person/authorized person, in order to fulfill the legal obligations (tax and accounting regulations). Please note that, in that case, Personal Data from the invoice is not processed individually, while the invoices are stored for five years in our databases.

When Personal Data is processed on the basis of  the execution and implementation of a contract or for the performance of some activity that is an integral part of the pre-contractual phase, the purpose of Personal Data processing is signing of a specific contract, i.e. implementation of the contract. Contract implementation actions often imply that Personal Data be made accessible to third parties,in order to fulfill the contract in its entirety.

When we process Personal Data on the basis of fulfilling of legal obligations, we will use that Data exclusively for the purpose of issuing a pre-invoice, i.e. Invoice, in accordance with relevant regulations of the Republic of Serbia.

Furthermore, when we process Personal Data on the basis of Your consent, in that case we will use Personal Data exclusively for the purpose of maintaining communication and invitations to events, including the period after the termination of the specific contract. In that case, since the basis of processing for the stated purpose is your consent, we ask you to keep in mind that your consent can be revoked at any time by sending a request to the e-mail address: gdpr@deltaholding.rs. Revocation of consent does not affect the admissibility of processing that was carried out on the basis of consent before the revocation.

When we process your Personal Data on the basis of the concluded Contract, we store Personal Data in our databases five years. On the other hand, when we process your Personal Data on the basis of consent, we store Personal Data in our databases until the consent is revoked.

We keep Personal Data that we process in order to fulfill our legal obligations in our databases until the expiration of the period defined by law (five years from the date of issuing the invoice, i.e. pro-invoice).

f) When visiting our business premises

We process your Personal Data for the purpose of property protection and general safety of persons in our business premises, as well as for your personal safety when visiting our business premises, i.e. to collect Data in case of emergency events (theft, damage of property, etc.).

Accordingly, We process your Personal Data on the basis of a legitimate interest, which consists of preserving the safety of property and persons in our business premises, i.e. for the purpose of preventing extraordinary events or collecting Data in case of extraordinary events.

We will store Personal Data – Name and Surname, Personal ID no., ID card no., time or entry and exit and licence plate number, in our database for a period of one year, while the footage from surveillance cameras will be stored in our database for the period of 30 days, unless an event occurs that results in the initiation of court proceedings, in which case they are stored until the conclusion of the proceedings, i.e. until  the expiration of statute of limitations in accordance with the Law.

After the expiration of the mentioned deadlines, they will be deleted, i.e. destroyed.

g) When visiting the website www.deltaholding.rs

When visiting our website, Personal Data is also collected through cookies, more about which can be found at www.deltaholding.rs/en/cookie-policy

2. Personal Data provided by other persons
There are cases when you can provide us with Personal Data of third parties, in which case we will consider that you are authorized by such a person for such action, and in no case will we bear responsibility for processing Personal Data of the third party.

Purpose of Data Collection

Svrha prikupljanja podataka jeste:

• compliance with the legal obligations (statutory and sub-statutory) of the Company;
• concluding and implementing concluded contracts, as well as taking actions before concluding contracts;
• protection of property and general safety of persons;
• invitation to events, achieving and/or maintaining communication and cooperation;
• Potential employment or involvement in the “Young Leaders” Program;
• Involvement in the “D Incubator” Program.

Legal basis for Data processing and method of Data collection

The legal basis for Data processing is:

• Your consent

Your Personal Data we have obtained on the basis of your consent will be processed and stored as long as your consent exists, i.e. until it is revoked. You can revoke your consent to the collection, processing and use of your Data at any time by sending an electronic request to the following address: gdpr@deltaholding.rs  

The revocation of consent does not affect the admissibility of processing Personal Data on the basis of your consent before the revocation.

• Implementation of contractual obligations

The Company collects Personal Data that is necessary for the conclusion and implementation of the contract with you and the fulfillment of pre-contractual obligations. If you do not provide us with necessary Personal Data, we will not be able to process your request or conclude the contract.

• Legitimate interest

The Company processes Personal Data for the purpose of storing legitimate interests of the Company. Legitimate interests of the Company particularly mean the protection of property and the general safety of persons.

• Compliance with legal obligations 

To the extent that the processing of your Personal Data in necessary for the fulfilment of legal obligations of the Company, i.e. Obligations defined by various laws, the Company processes and stores your Personal Data within the legal deadlines.

We also disclose Personal Data to specific recipients, i.e. third parties, and so: related parties in the territory of the Republic of Serbia, employees, companies that provide security services for premises, property and persons, legal service providers, IT service providers, external auditors, accounting and bookkeeping agencies

The Company will not make your Personal Data accessible to other recipients, i.e. third parties, except in cases specified in this Privacy Policy nor will your Personal Data be transferred to another country.

Data that the Company collects on the basis of the law as a legal foundation, the Company is obliged to keep it as long as it is determined by a specific law or other positive regulations.

We store the Data that We collect on the basis of the contractual relationship for five (5) years.

Data processed solely on the basis of your consent is stored until the consent is revoked.

Data that we process due to legitimate interest is stored permanently, i.e. within 30 days – Data on extraordinary events (surveillance camera footage), unless an event occurs that results in court proceedings initiation, in which case they are kept until the conclusion of the proceedings, i.e. until the statute of limitations in accordance with the law.

The person to whom the Personal Data refers has the following rights:

• to request information from the Company on whether it processes his Personal Data and whether  it has access to that Data;
• to request correction, addition or deletion of his Personal Data and rights to object to its processing from the Company
• to file a complaint with the Commissioner for Information of Public Importance and Personal Data Protection
• To have his incorrect Personal Data corrected without undue delay. Depending on the purpose of the processing, the Client has the right to complete his incomplete Personal Data, which also includes providing additional  statements;
• To limit the processing of Personal Data by the Company if one of the following cases is met:

1. The person to whom the Data refers contests the accuracy of the Personal Data, within the time limit that allows the Company to verify the accuracy of the Personal Data;
2. The processing is illegal, and the person to whom the Data refers opposes the deletion of the Personal Data and instead of deletion requests restriction of use of the Personal Data;
3. The Company no longer needs the Personal Data to achieve the purpose of processing, but the person to whom the Data refers has requested it in order to submit, implement or defend a legal claim;
4. The person to whom the Data refers has submitted an objection to the processing in accordance with Article 37, paragraph 1. of the Law, and an assessment is underway as to whether the legal basis for the processing outweighs the interests of the Person.

The Company is obliged to notify all recipients to whom Personal Data has been disclosed of any correction or addition or deletion of Personal Data or restriction on their processing in accordance with the Law, unless that is impossible or requires excessive expenditure of time and resources. The Company is obliged to inform the person to whom the Data refers about all recipients at his request.

In accordance with the law, the person the Data refers to has the right to receive his Personal Data which he had previously provided to the Company,in a structured, commonly used electronic readable form and has the right to transfer this Data to another manager without interference from the manager to whom it was provided.

If he thinks that it is justifiable in relation to this particular situation he is in, the Client to whom the Data refers has the right to submit an objection to the Company at any time regarding the processing of his Personal Data, in accordance with the Law.

The Client to whom the Data refers has the right to have the decision made exclusively on the basis of the automated processing, including profiling, not apply to him if that decision produces legal consequences for that person or if that decision significantly affects his position.

Our site can contain links to third-party sites. Keep in mind that we are not responsible for the collection, use, maintenance, sharing or disclosure of Data and information by third parties. If you provide information on third party sites and use those sites, the privacy policy and terms of use of those third parties will be applied. We recommend you read the privacy policy on the websites you visit before sending your Personal Data.

By clicking the Facebook, Twitter, Linkedin or Youtube button on our website, you accept the possibility that the Data on your visit to our site can be processed by the aforementioned social networks if you have an account on them. In order to avoid this situation, We advise you to first log out you user account on these social networks and only then click on the link on our site to visit our web page on one of the aforementioned social networks.

Your Personal Data will be treated as confidential information, and the Company will take adequate measures to protect it in accordance with the Law. Access to it will only be granted to persons who, considering the description of the work they perform, should be familiar with you Personal Data and only to the extent that is necessary for the performance of their work.

This Privacy Policy is available on the website www.deltaholding.rs

If we decide to change our Privacy Policy, the changes will be posted and published on the web site www.deltaholding.rs

If you have any questions or requests regarding the processing of your Personal Data, please contact us at: gdpr@deltaholding.rs  

Your Delta Holding