Date of issue: 25.02.2021 | Last updated: 15 April 2021
Purpose of this Notice
This Privacy Notice (Notice) aims to provide you with information in a clear and transparent manner about how we process the personal data of all data subjects, which categories of personal data are processed, and what rights data subjects have. We process your personal data in order to provide you with all the benefits of using the Benefiti.rs website (Website) and the Benefiti.rs software platform (Platform), through which we provide companies (Clients) with (i) “one-stop” shop services for personalising benefits within their budget, and (ii) the ability to provide their employees as end users (End Users) with personalised, flexible and measurable benefits and incentives within a predefined budget (Benefits).
All personal data referred to in this Notice is processed and protected in full compliance with the Serbian Personal Data Protection Act (PDPA) and the General Data Protection Regulation (GDPR).
We process personal data adhering without exception to the following basic principles: lawfulness, fairness and transparency; purpose limitation; data minimisation; accuracy; storage limitation; integrity and confidentiality.
Amendments
This is the latest version of the Notice (15 April 2021). If this Notice is amended or supplemented, we will include the date of the latest version. We will notify you of any changes to this Notice in a timely manner.
About Us
In this Notice, “SBT”, “we” and “our” refers to Smart Benefit Technologies d.o.o. Belgrade, with registered office at Takovska 12, Belgrade-Palilula, Republic of Serbia.
SBT acts as a data controller, joint controller with its Partners, or data processor, depending on the circumstances, as explained in detail in this Notice.
SBT acts as a data controller when:
- Processing personal data of representatives of (potential) Clients to enable them to contact us via our Website;
- Processing personal data of Client representatives in connection with use of the Platform and delivery of Benefits to End Users;
- Processing personal data of Partner representatives in connection with the purchase of Benefits;
- Processing personal data of Website visitors collected via cookies and other technologies used by the Website;
- Processing personal data for development, direct marketing, or internal security purposes;
- Processing personal data of our employees and job candidates.
For questions, complaints, requests to exercise your rights, and additional information, please contact us at: gdpr@benefiti.rs.
Personal Data We Collect
SBT as Data Controller
Completing the Contact Form on the Website
When you wish to contact us as a potential Client via our Website, we collect the following personal data: full name of the company representative, company name, position within the company, business email address, and business phone number.
Business Cooperation with Clients
We process personal data of Client representatives for pre-contractual and contractual purposes. The personal data we process includes, but is not limited to:
- Personal identification data such as full name, photograph, gender, position and title;
- Business contact data such as business email address, business phone number, website;
- Personal identification numbers and government-issued documents such as ID card and passport.
Business Cooperation with Partners
We process personal data of Partner representatives for pre-contractual and contractual purposes related to the purchase and promotion of Benefits.
Business Correspondence
We may occasionally send business content to Client or Partner representatives regarding our services. If you wish to have your personal data deleted or to cease business communications, please contact us at: gdpr@benefiti.rs.
SBT as Joint Controller
Enabling Delivery of Benefits to Clients
To enable delivery of Benefits to End Users, we jointly with our Partners process End User personal data provided by Clients, including: personal identification data, contact data, employment data and digital service account data.
Purpose and Legal Basis for Processing
- Contract - Processing necessary to perform or prepare a contract with Clients and Partners.
- Consent - Processing based on consent you have given for a specific purpose. You may withdraw consent at any time by contacting: gdpr@benefiti.rs.
- Legal obligations - Processing required by Serbian law.
- Vital interests - Processing necessary to protect vital interests.
- Legitimate interests - Processing based on our legitimate interests where these do not override your fundamental rights and freedoms.
Data Retention
We retain personal data for as long as necessary to fulfil the purpose for which it was collected, in accordance with applicable law. After the retention period expires, we delete or anonymise the data.
Your Rights
Under applicable data protection law, you have the following rights:
- Right of access to your personal data;
- Right to rectification of inaccurate data;
- Right to erasure (“right to be forgotten”);
- Right to restriction of processing;
- Right to data portability;
- Right to object to processing;
- Right to withdraw consent.
To exercise these rights, please contact us at: gdpr@benefiti.rs.
Contact
For all questions regarding personal data protection, please contact us at: gdpr@benefiti.rs.