INFORMATION NOTICE ON PERSONAL DATA PROCESSING
To Whom It May Concern,
DELTA TRANSPORT SYSTEM - D.T.S. DOO BELGRADE, Žorža Klemansoa 37, Belgrade, company number: 20443120 (hereinafter: “Company or We”), respects and protects the privacy of each person (natural person - client, potential client and other persons – hereinafter collectively referred to as: “Client or You”) whose personal data are being collected (hereinafter: “Personal Data”). Collection and storage of Personal Data is carried out in accordance with the Law on Personal Data Protection (“Official Gazette of the Republic of Serbia” No. 87/2018) (hereinafter: “Law”) and General Data Protection Regulation of the European Union (EU 2016/679) (hereinafter: “GDPR”), when applicable.
When processing Personal Data of a Client who is a national of an EU Member State, provisions of GDPR will also be implemented, to the extent applicable.
We respect You and realize that You care for Your privacy.
Nevertheless, feel free to contact the person in charge of personal data protection at: firstname.lastname@example.org
Basic notions and Personal Data processed by the Company
“Personal Data” is any information that relates to a natural person who can be identified or identifiable, directly or indirectly, in particular by reference to an identifier;
“Processing of Personal Data” means any operation or set of operations which is performed on personal data or sets of personal data, by automated means or otherwise, such as collection, recording, organising, grouping, i.e. structuring, storage, adaptation or alteration, disclosure, consultation, use, disclosure by transmission, i.e. delivery, copying, dissemination or otherwise making available, comparing, restricting, erasing, or destroying;
"Sensitive Data" is any data revealing racial or ethnic origin, political opinion, religious or philosophical belief, membership in a trade union, health condition, sexual life or sexual orientation, genetic data, criminal records or biometric data used for unique identification.
We do not collect Your sensitive data, unless you voluntarily make them available or if We are bound to do so in accordance with applicable regulations.
"Children’s Personal Data” are data relating to persons under the age of 18.
We do not collect Children’s Personal Data. As a parent or legal guardian, you should prevent your children from making their Personal Data available without your permission.
The Company collects and processes the following Personal Data about You:
- Name and surname;
- Unique Master Citizen Number;
- No. of passport/identity card;
- Email address;
- Landline telephone number;
- Mobile phone number;
- Address of domicile (street and number, postal number, place/town);
- Job title;
- Place of work;
- Vehicle registration number.
Manner of collecting Personal Data
Personal Data are collected directly from You, as a person whose information is being processed, or from other persons.
- Direct collection of Personal Data from Clients whose data are being processed
When You send Your resume to the email address in the section “Career” on our website
When You send us Your Resume, it will be considered that You gave your consent for the delivered personal data to be processed for the purposes of potential employment and communication in relation to potential employment. In addition, if we find Your resume more appropriate for a work position i.e. employment in an affiliated company of ours, it shall be deemed that You gave your consent for Your resume to be forwarded to an affiliated legal entity of ours on the territory of the Republic of Serbia, which will use Your resume solely for the purpose of potential employment and communication in relation to potential employment.
We will keep the Personal Data that you provide in your resume in our database in the period of five (5) years from the day of receipt of resume, after which they will be deleted.
When You fill in the Cooperation Inquiry on our website
We invite all owners of one or more transportation vehicles to cooperate with us. For this reason, our website features an invitation for anyone who wants to fill in the Cooperation Inquiry. When You fill in the Cooperation Inquiry, it shall be considered that, by doing so, You gave us Your consent for processing of the following personal data: name and surname, gender, address, email address, telephone number.
We will use the Personal Data You make available to us solely for the purposes of potential engagement and communication in relation to potential engagement.
We will keep the Personal Data you provided in the Collaboration Inquiry in our database in the period of five (5) years from the day the Collaboration Inquiry was sent, after which they will be deleted.
When You fill in the Offer Inquiry on our website
We invite everyone in need of transport, warehousing, freight forwarding or customs clearance to send us an inquiry without obligation, and we will send You an offer as soon as possible. For this reason, our website features an invitation where anyone can send an Offer Inquiry. When You fill in the Offer Inquiry, it shall be considered that, by doing so, You gave us Your consent for processing of the following personal data: name and surname, gender, address, email address, telephone number.
We will use the Personal Data that You make available to us solely for the purposes of potential communication in relation to the preparation and delivery of the offer for which You have shown interest.
We will keep the Personal Data you provided in the Offer Inquiry in our database in the period of five (5) years from the day the Offer Inquiry was sent, after which they will be deleted.
When We provide services to You, as our client
In order to be able to provide the services You engaged us for in a timely manner, We need you to submit the following personal data: name and surname, gender, email address, telephone number, job title, place of work.
In view of the type of our cooperation, which is preceded by a pre-agreement stage, We process Your Personal Data on several grounds.
Primarily, Personal Data are processed on the ground of executing service agreement (including forwarding of Your contact information, so that You can be contacted by a carrier/freight forwarder/customs officer) or undertaking of operations, at Your request, prior to the conclusion of a service agreement. Provision of Your Personal Data constitutes a contractual obligation, i.e. provision of Personal Data is a mandatory for the conclusion of the said agreement, for which reason You are obliged to disclose Your Personal Data to Us. Otherwise, we would not be able to conclude and execute a service agreement.
Furthermore, We process Your Personal Data for the purpose of issuing an invoice or pro-forma invoice, in order to fulfil our legal obligations (issuance of invoices and pro-forma invoices), in which case a relevant legal regulation constitutes the ground for processing (Law on Value Added Tax).
When We process Personal Data in order to execute a service agreement or perform an operation which is an integral part of the pre-agreement stage, the purpose of Data processing is the conclusion of the agreement in question (e.g. sending of offer) i.e. the execution of agreement. Operations in relation to execution of a service agreement often imply that Data should be made available to third parties (e.g. carriers), in order for a service agreement to be fulfilled to the full extent (e.g. delivery of goods, verifying the status of shipment, notification of defects).
When We process Personal Data on the ground of fulfilling legal obligations, We use Data solely for the purpose of issuing an invoice or a pro-forma invoice, under applicable regulations of the Republic of Serbia.
When We process Personal Data on the ground of a concluded agreement, We retain Personal Data in Our databases until the expiry of outstanding receivables from the contractual relationship.
We retain the Personal Data which We process in order to fulfil our legal obligations until the expiry of the period defined by law (ten years from issuance of an invoice or pro-forma invoice).
When You visit our business premises
When You visit our business premises, we collect the following Personal Data from You: name and surname, gender, unique master citizen number, number of identity card and vehicle registration number; we collect these in order to keep records about the persons who visit our premises, all with the aim of protecting the property and interests of the Company (legitimate interest).
The abovementioned personal data are processed for the purpose of protecting the property and safety of Company’s employees.
In view of the above, We process your Personal Data on the ground of a legitimate interest - protection of safety of the property and persons within our premises.
The abovementioned Personal Data are kept in the Company’s database in a period from 30 (thirty) to 80 (eighty) days depending on the memory of the hard disk which stores video recordings.
When You visit our website
When the Company runs marketing and other promotional campaigns
When You contact our employees
When You contact our employees (by phone, through our website or social networks) in order to obtain answers to various inquiries with regard to our services, You give consent for the Company to collect the following Personal Data about you: name and surname, gender, email address and mobile phone/landline phone number.
The abovementioned Personal Data are processed for the purpose of establishing communication with You, in order to answer Your inquiries or obtain specifics about Your request.
Provision of the said Personal Data is a mandatory precondition for the communication to be established between You and the Company. Otherwise, we will not be able to respond to Your inquiry.
These Personal Data are kept in the Company’s database until You revoke Your consent.
When You are hired to transport goods
In order for Us to fulfil contractual obligations towards our clients, We have to make available some of Your Personal Data (as a carrier) to the client, i.e. we need to process them with the aim of proper performance of transportation service. We process the following personal data: name and surname, gender, mobile phone number, email address, unique master citizen number, number of identity card/passport, vehicle registration number, job title, place of work.
Personal data are processed for the following purposes: a) to inform clients about the person who performs the transport; b) for Us, or our clients, to be able to contact You to verify current location and status of the shipment, to verify the time of delivery or handover of goods, to change the address of loading or unloading, for communication about possible delays; c) to carry out loading or unloading of goods; d) to keep records about clients’ claims and objections (complaints) about the goods they received after transportation; e) to consider clients’ complaints and objections; f) to keep records about vehicles and drivers that transport the goods; g) for performance review; h) for keeping records about delivery of goods.
The ground for Personal Data processing is a legitimate interest (our legitimate interest lies in the fact that we have obligation towards our clients to fulfil contractual and legal obligations – e.g. to act upon complaints).
Personal data will be permanently stored in our database.
- Personal data delivered by other persons
There are circumstances when You may deliver personal data of third parties, e.g. in order to prepare and deliver promotional offer which you find interesting to someone You know, in which case we will consider that You are authorised by such person to do so and we will not be responsible for processing of Personal Data of a third party.
Purpose of data collection
Data are collected for the following purposes:
- for the Company to be able to fulfil its legal obligations (arising from the contract and the law),
- to conclude and execute service agreements;
- to fulfil pre-contractual obligations (information about the prices of goods that we are selling, creation of purchase offer and like);
- to establish contacts and allow Clients to get information about offers and additional information on the latest events they are interested in, which are in connection with the Company and the services We are offering, and for Clients to be able to exercise their rights in relation to provided services
- for the Company to exercise a legitimate interest as an operator, or a third party, except in the event that such interest is subordinate to interests and basic rights and liberties of the persons to whom the data which require protection relate.
Legal grounds for data processing and method of data collection
Data are processed on the following legal grounds:
- Your consent
Your Personal Data which we obtained on the ground of Your consent will be processed and stored as long as Your consent is effective, i.e. until You revoke your consent. You may revoke Your consent for collection, processing and use of Your data anytime by sending request to: email@example.com
Revocation of consent will not affect the permission for Personal Data processing carried out on the basis of Your consent before the revocation.
- Execution of contractual obligations
The Company collects Personal Data which are necessary for the conclusion and execution of agreements with You and performance of pre-contractual obligations (e.g. to send offers).
If you do not provide us with the necessary Personal Data, we will not be able to process Your request or conclude a contract.
- Legitimate interest
The Company processes Personal Data with the aim of preserving legitimate interests of the Company and legitimate interests of third parties. Legitimate interests of the Company include in particular: maintenance of functionality of IT system, prevention of abuse, performance of contractual obligations, protection of the Company’s business premises and like.
- Observance of legal obligations
Your Personal Data are processed to the extent necessary for the performance of Company’s legal obligations, i.e. obligations stipulated by various laws.
Receiver and third party
We disclose Personal Data to specific receivers, i.e. third parties: our affiliated entities on the territory of the Republic of Serbia, Bosnia and Herzegovina, and Montenegro, to our employees, companies which secure our premises, property and persons, persons who provide legal services to us (e.g. attorneys), IT maintenance personnel, external auditors, accounting and bookkeeping agencies.
The Company will not make Your Personal Data available to other receivers, i.e. third parties, except in the events specified in this Notice.
Personal Data retention period
The Company will keep the data it collects on the ground of legal regulations in the period specified by the specific law or other applicable regulation.
The data which the Company collects on the basis of a contractual relationship will be retained until the expiry of receivables arising from the contractual relationship, if any.
The data which are processed solely on the basis of Your consent will be retained until revocation of consent.
The data which are processed for legitimate interests will be retained permanently, or in the period from 30 (thirty) to 80 (eighty) days depending on the memory of the hard disk which stores video recordings.
Client’s rights in connection with processing of Personal Data
The person to whom personal data relate has the right to:
- request access to data and information from the Company about whether the Company processes his/her Personal Data;
- request that the Company corrects, amends or erases his/her Personal Data and the right to object to processing;
- file a complaint to the Commissioner for Information of Public Importance and Personal Data Protection;
- have his/her incorrect Personal Data corrected without undue delay. Depending on the purpose of processing, the person has the right to supplement his incomplete Personal Data, which includes giving an additional statement;
- request that the Company limits processing of Personal Data if any of the following conditions is met:
1) The Person to whom data relate denies accuracy of Personal Data, within the period which allows the Company to verify the accuracy of Personal Data;
2) Processing is illegal, but the Person to whom data relate disagrees with the erasure of Personal Data and instead of erasure, requests limitation of their use;
3) The Company no longer needs Personal Data for the realization of processing purposes, but the Person to whom data relate requested them in order to file, exercise or defend a legal claim;
4) The Person to whom data relate filed an objection to processing in accordance with Article 37 paragraph 1 of the Law, and the estimate on whether the legal ground for processing prevails over the Person’s interests is ongoing.
1) The Client to whom data relate denies accuracy of Personal Data, within the period which allows the Company to verify the accuracy of Personal Data;
2) Processing is illegal, but the Client to whom data relate disagrees with erasure of Personal Data and requests limitation of their use instead;
3) The Company no longer needs Personal Data for the realization of processing purposes, but the person to whom data relate requested them in order to file, exercise or defend a legal claim;
4) The Client to whom data relate filed an objection to processing in accordance with Article 37 paragraph 1 of the Law, and the estimate on whether the legal ground for processing prevails over the Person’s interests is ongoing.
The Company is obliged to notify all receivers to whom Personal Data were disclosed about every correction or supplement or erasure of Personal Data or limitation of their use in accordance with the Law, except in the event that it is impossible to do so or if it requires unreasonable efforts and means. The Company is obliged to inform the person to whom data relate about all receivers, if the said person requests so.
The person to whom data relate has the right to receive his Personal Data which were delivered to the Company beforehand in a structured, generally used and readable electronic form, and to transfer these data to another operator without interference of the operator to whom these data were delivered, in accordance with the Law.
If Client believes that it is justified in view of his/her specific situation, the Client to whom data relate has the right to file an objection to Company’s processing of his/her Personal Data anytime, in accordance with the Law.
The Client to whom data relate has the right not to be subject to the decision brought exclusively on the basis of automated processing, including profiling, if such decision produces legal effects on the said person or if such decision has a significant influence on his position.
Procedure in the event of Personal Data breach
If a Personal Data breach may result in a high risk to rights and liberties of natural persons, the Company shall, without undue delay, inform the person data relate to about such breach, in accordance with the Law.
In the event of personal data breach which may result in risk to rights and liberties of a Client, the Company is obliged to inform the Commissioner for Information of Public Importance and Personal Data Protection without undue delay or, if possible, within 72 hours from becoming aware of such breach. Notice delivered to the competent authority contains all information stipulated by the Law.
Transfer of Personal Data to another country
Personal Data may be transferred to another country or an international organization, without prior consent, if it is established that such country/ international organization implements an appropriate level of personal data protection. In this respect, the Decision on the list of countries, parts of their territories or one or more sectors of certain activities in those countries and international organizations which are considered to implement an appropriate level of personal data protection ("Official Gazette of RS", No. 55/2019) (hereinafter: “Decision”) determines the places where an appropriate level of protection of personal data is ensured.
Personal Data may be disclosed to the following persons: our affiliated entities on the territory of the Republic of Serbia, Bosnia and Herzegovina, and Montenegro.
Links to third parties’ websites and services
By clicking on Facebook, Instagram or LinkedIn featured on our website, you accept the possibility that the information about Your visit to our website may be processed by these social networks, if You have an account on the said social networks. In order to avoid this, We recommend You to log out of Your user accounts on these social networks, and then click on the link on our website to visit a page on one of the said social networks.
Confidentiality of data and transparency
Your personal data will be treated as confidential and the Company will undertake appropriate steps to protect them in accordance with the Law. Access to these data will be granted only to the persons who need to be aware of them due to the nature of their work, and only to the extent necessary for the performance of their duties.
For further questions and inquiries in relation to processing of Your Personal Data, please contact us at: firstname.lastname@example.org
Your Delta DTS