NOTICE OF DATA PROCESSING    

 This Notice represents the information that the operator is obliged to provide to the person whose personal data is being processed, in accordance with the Law on the Protection of Personal Data ("Official Gazette of RS", No. 87/2018) and the General Regulation on the Protection of Personal Data of the EU Regulation 2016/679 ("GDPR"), if applicable in the specific case.   

 PERSON RESPONSIBLE FOR DATA PROCESSING AND CONTACT 

 Your personal data is collected and processed by KAISEN Properties doo, Subotica, Dimitrija Tucovića 5, PIB 111244143, MB21448176, (Bellaria Spa & Apartments), and as described in more detail in this Notice. This means that, in accordance with the law, KAISEN Properties doo  is the organization responsible for processing your personal data. For all questions related to the processing of personal data and to exercise your rights, you can contact us by e-mail at info@bellaria.rs or by writing to the address of our headquarters: KAISEN Properties doo Dimitrija Tucovića 5, 24000, Subotica. 

 In exceptional cases, KAISEN Properties doo has the role of joint operator. An example is joint liability with a social network operator. Data on social networks is mostly processed by the social networks themselves, and we have limited influence in that area. You can find more detailed information about the processing of data by the operators of social network platforms and about the possibilities of objection in their data protection rules. 

 DATA CATEGORIES, BASIS AND STORAGE TIME   

 When you express your interest in purchasing real estate and contact us regarding the conclusion of the contract, in the first place of the contract related to the purchase and sale of real estate from the offer of KAISEN Properties doo  or from the offer of related parties, for example: when you fill out the form on our website and request information about the available real estate, when you visit official premises or promotional stands, when you send us an email or call us by phone, when you participate in our promotional activities, or when you conclude a contract with us in connection with the purchase and sale of real estate or another contract, we collect data from you necessary for the purpose of a specific type contract, and in accordance with the principles of personal data processing prescribed by law. Especially taking into account the minimally necessary data to achieve the purpose of the processing. This means that we collect from you the data necessary for the preparation and conclusion and execution of the contract we conclude. Before concluding the contract, we process data such as your name, surname and contact information (email and phone number), in order to establish contact with you, in connection with your interest and understanding of your needs, and in order to better present the offer, terms of sale and other information that we believe may be relevant to your decision to purchase real estate. The legal basis for processing prescribed by Article 12, paragraph 1, point 2) of the Personal Data Protection Act, Article 6, paragraph 1(b) GDPR - taking action, at the request of the data subject, before the conclusion of the contract, and by Article 12 Paragraph 1 point 6) of the Personal Data Protection Act, Article 6 paragraph 1(f) GDPR - pursuit of legitimate interests. Providing data is voluntary. Data is processed only if you have expressed interest in purchasing real estate. When you conclude a real estate reservation contract with us, in addition to your name and contact information, your address is required. And, when you conclude a real estate purchase agreement with us, you share with us the information required by the applicable laws, including, among other things, your JMBG and copies of your personal documents. The basis for data processing is the preparation for the conclusion of the contract and the execution of contractual obligations, as well as the fulfillment of the legal obligations of the operator. QUESTIONNAIRES, SURVEYS AND SIMILAR - The basis for processing the data that you optionally and voluntarily share with us is your consent, which you can always withdraw. Withdrawal is effective for the future and does not affect the permissibility of processing before consent was withdrawn. If there is no other basis for processing, after you withdraw your consent we stop processing your data. LEGITIMATE INTEREST - In accordance with the law and if your interests do not prevail, we process your personal data in order to achieve the legitimate interest of us or a third party, such as protecting our systems, detecting and preventing attacks on our website, preventing abuse and fraud, solving problems , answering your questions, direct marketing (except in cases where consent is required to receive commercial messages), video surveillance, and the like. In this context, we have a legitimate interest in processing data from publicly available sources. You have the right to object to this processing of your data at any time. To exercise this right, contact us by e-mail or mail at the address at the beginning of this document. If there is no other basis for processing, after you file an objection, we stop processing your data, unless there are legal reasons for processing that outweigh the interests, rights or freedoms of the data subject or are related to the submission, exercise or defense of legal demands.   

 STORAGE TIME   

 In general, we keep your data for as long as necessary to ful fill the purpose of the processing, or as required by applicable regulations. If you have concluded a contract with us, this means that we store your data while the rights and obligations from the contract last, and after that for as long as required by applicable regulations. We retain your personal data even after termination of the contractual relationship if we need your personal data to establish, exercise or defend legal claims or to comply with applicable laws. To the extent possible, we will limit the processing of your personal data for those limited purposes after the termination of the contractual relationship. The data is stored on our server in the Republic of Serbia.   

 WHO EXCEPT KAISEN Properties doo  HAS ACCESS TO THE DATA 

 In our business, we use the services of various service providers who, in accordance with our instructions, have access to your data as so-called processors. 

SI Investments doo , Dimitrija Tucovića 5   

 Your data can also be accessed by our affiliated companies with whom we share information systems, who provide us or to whom we provide business and operational support and with whom we have concluded a contract: KAISEN Properties doo , Dimitrija Tucovića 5, Subotica We may disclose your data to competent authorities and institutions according to their order or when we believe it is necessary to fulfill legal obligations, or to protect our rights. We may share your data with third parties in case of reorganization, transfer or other disposition of any part of business or property of KAISEN Properties doo  (including execution of mortgage, bankruptcy or other similar procedure) or in other cases of fulfilling legal obligations. 

 TRANSFER OUTSIDE THE REPUBLIC OF SERBIA - In compliance with the rules prescribed by law, data is transferred and processed outside the territory of Serbia. In the event that we forward personal data to recipients outside countries that are members of the Council of Europe Convention on the Protection of Individuals with regard to automatic processing of personal data, the data is forwarded in compliance with the measures prescribed by law (e.g. through standard contractual clauses). 

  SAFETY MEASURES   

 We apply security measures that we continuously improve in accordance with technical and legal trends in order to ensure the protection of your data from accidental or intentional manipulation, loss, destruction or access by unauthorized third parties. However, please note that these protections do not apply to information you choose to share publicly such as on social media or messaging apps.   

  YOUR RIGHTS    

 You have the right, upon request and free of charge, to receive information about your data that we process. You have the right to edit and delete your data, the right to limit processing, and the right to data portability. You can object to the processing carried out in order to achieve our legitimate interests. You have the right not to be subject to a decision made solely on the basis of automated processing, including profiling, if it produces legal consequences for you or significantly affects your position. If we process your personal data based on consent, you have the right to withdraw that consent at any time. This does not affect the permissibility of processing that was carried out before you withdrew your consent. Additionally, you have the option to file a complaint with the Commissioner for Information of Public Importance and Protection of Personal Data, address: ul. Bulevar Kralja Aleksandra 15, 11120 Belgrade, Serbia office@poverenik.rs as well as the right to file a lawsuit in the competent court. For all questions related to the processing of your personal data and to exercise your rights, you can contact us by e-mail or mail at the address at the beginning of this document.