Privacy
policy

1. Data Protection Policy

Protecting your privacy when using our website Autokomerc doo is of great importance to us. For this reason, we will provide you with detailed information below about the collection of anonymous and personal data. Autokomerc doo strictly adheres to all regulations on the protection of personal data. Autokomerc doo reserves the right to process personal and anonymous data within the limits permitted by law.

2. Data Protection

Autokomerc doo has implemented specific technical and organizational measures to protect your data from loss, manipulation, or unauthorized access. These measures are subject to regular checks and are continuously improved and adapted in line with technological advancements.

3. Access Protocol

Regarding your access to content on this website and each time a page or file is opened, access data is stored in so-called log files. Specifically, the following data is stored for each access:

• IP address of the requesting computer
• Date and time of access or request for access
• Page title or file accessed
• Referrer URL
• Browser, including version used by the user
• User’s operating system

This information is used for statistical purposes. These are exclusively data that do not provide any information about you as an individual. As an individual user, you are anonymous.

4. Collection and Processing of Personal Data

Personal data is only stored if you provide it yourself – for example, within registration, inquiry submissions, participation in competitions, or newsletter subscriptions – and give consent for their processing. If your personal data is required for using the services offered, supplementation with data from logging via IP address for the purpose of creating a user profile is excluded.

If consent is given for the use of your data for the aforementioned purposes, this may include transferring your data to (dealer, service), financial institutions for service provision (leasing), or public opinion research institutes. Furthermore, their transmission to third parties, such as email list providers, direct mailing companies, or advertising agencies, does not occur.

1. Data You Provide
   Personal data is only stored if you disclose it to us yourself and give consent for its processing, e.g., within registration, inquiries, competitions, or newsletter subscriptions. More on this in point 4.
2. Data Collected by Us
   When you visit our website, certain data will be collected automatically via “Cookies”. For more information about “Cookies”, please refer to the specific explanation on the following page: Cookie Guidelines.
3. Partners
   Autokomerc doo processes all collected data itself. Additionally, Autokomerc doo does not transmit any information to third parties such as email list providers or direct mailing companies.
4. Data Processing Not Requiring Explicit Consent

General Contact Forms

• Contact Form: When submitting a general inquiry via the form, your personal data (vehicle data, dealer information, name, address, contact, and message) will be processed.
• Purpose: Adequate response to your inquiry
• Retention Period: 12 months

5. Collection and Processing of Anonymous Data

This page uses usage analysis software. Through analysis of this data, valuable insights into the needs of our users can be obtained. These insights contribute to further enhancing the quality of our offerings. The following data is recorded for each access:

• Anonymous form of the requesting computer’s IP address
• Date and time of access or request for access
• Page title or file accessed
• Referrer URL
• Browser, including the version used by the user
• User’s operating system

This information is used for statistical purposes. These are exclusively data that do not provide any information about you as an individual. As an individual user, you remain anonymous.

In connection with this, so-called cookies are used. Cookies are textual data stored on the visitor’s computer, allowing anonymous visitor recognition. 

Cookie name	Duration
PHPSESSID	session
wordpress_test_cookie	session
wp-wpml_current_language	session

6. Data Protection Policy

This informs you about the processing of your personal data and your rights under the Law on Personal Data Protection (“Official Gazette of RS” no. 87/2018).

The responsibility for data processing lies with the company Autokomerc doo.

In order to achieve the processing purposes defined in the following text, we process personal data provided directly by the client at the time of submitting their request, and other personal data voluntarily provided by the client or already held within the current business relationship. Such data can theoretically fall into the following categories:

• Identification data: surname, first name, gender, personal identification number, ID card series and number, date and place of birth, citizenship, nationality, etc.
• Contact details: residence/postal address, email address, landline telephone number, mobile telephone number, etc.
• Contractual data relating to products and services purchased from Autokomerc doo
• Professional reputation data: education level data, profession, occupation, employer’s name, nature of own business, public position held, political exposure (if applicable)
• Financial reputation data: income, individual employment contract number, pension file number
• Family status data: civil status, number of minor children, type of accommodation
• Banking data: account number (IBAN), transaction details and/or history, card number
• Vehicle identification and/or usage data: license number, chassis series, location, GPS data, etc.

In certain situations, based on the scope of data processing arising from the client’s request, the personal data we process, in addition to the client’s personal data, may relate to the following categories of data subjects: client’s contractors and/or legal or conventional representatives, client’s contact persons, client’s attorneys or users, co-debtors, guarantors, actual owners or family members, client’s insurance policy users, client’s payment transaction users. Their personal data is obtained from documentation for initiating and/or executing a contractual relationship with the client, and Autokomerc doo does not have practical means to directly inform such data subjects about the processing of their personal data. In such cases, the client is obliged to inform these data subjects about the processing and scope or purpose of processing their personal data, regarding them.

Please do not provide us with categories of special nature data, such as data on membership in trade unions, your political opinions or religious beliefs, your health status, etc., in the documents you provide.

7. Legal Basis for Data Processing

For the purpose of concluding or executing a contract, or for the realization of pre-contractual formalities, such as issuing offers, purchasing vehicles, using our service, etc., processing is based on the execution of a contract in which you are a contracting party and/or necessary formalities in terms of concluding the given contract, at your request.

We are legally obligated to process and retain your data in accordance with the requirements to know our clients, applying all measures to identify the client, as well as the client’s capacity as the actual owner and/or politically exposed party. We also have a legal obligation to retain specific documentation in order to know our clients in accordance with the law on prevention and control of money laundering and terrorism financing.

Your data is also processed and retained for the purpose of fulfilling legal obligations for documentation and storage: for financial management and accounting purposes, in accordance with tax legislation; for internal or financial auditing purposes; for reporting to government authorities under applicable regulations; for control and/or responding to authority requests, data security in systems and documents, as well as physical security in our premises.

To fulfill the purposes or scope of processing as stated, your data is transmitted to our service providers, acting as processors, strictly operating according to documented instructions received from us.

Depending on the case, your data may also be disclosed to the following recipients/categories of recipients, in order to fulfill our legal obligations, pursue legitimate interests related to debt collection, or enforce and defend our rights and interests, or if we have your consent:

Ministry of Finance – Tax Administration – Reason: Legal obligation;

Recipients of your payments, recipient banks, SWIFT – Reason: To execute payment instructions and fulfill legal obligations related to automated interbank commercial payments;

Insurance companies – Reason: To issue insurance policies;

Autokomerc doo, in R. Serbia – Reason: Reporting obligations and internal audit;

Judicial authorities, i.e., courts, public prosecution, as well as police, Municipal police, JP Roads of Serbia in the case of unpaid highway tolls and other competent holders of public authority – Reason: If necessary to defend and enforce any legal rights and interests or to fulfill legal obligations.

We retain your data only for the duration necessary to achieve the aforementioned processing scopes or if there is a legal obligation to do so. For processing requiring your consent, data will be processed and retained until the date of consent withdrawal.

If we have concluded a contract with you (for purchase, lease, or other contract within our business scope), we will comply with legal obligations to retain relevant data and documentation as follows:

• Personal data of employees is retained for 10 years after termination of the employment contract;
• Personal data of our clients included in all accompanying documents related to registrations and financial accounting are archived by companies for 10 years from the date of completion of the financial year in which the accompanying documentation was prepared, in accordance with internal rules for retaining accounting documents.
• In defense and enforcement of our legal rights, your data necessary to achieve these rights are retained in accordance with general time limits.

8. Your Rights Regarding Data Protection:

Right to withdraw consent – The data subject has the right to withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Before giving consent, the data subject must be informed of the right to withdraw consent and the effect of withdrawal. Withdrawal of consent must be as simple as giving consent.

Right of access – The data subject has the right to request information about whether their personal data is being processed, access to that data, as well as information about the purpose of processing, types of personal data being processed, recipients or categories of recipients to whom personal data have been or will be disclosed, the envisaged period for which personal data will be stored, or if not possible, the criteria used to determine that period, the existence of the right to request rectification or erasure of their personal data, the right to restrict processing, and the right to object to processing, the right to lodge a complaint with the Commissioner, and the existence of automated decision-making, including profiling.

Right to erasure – The data subject has the right to request the erasure of their personal data by the controller, who is obliged to erase collected data without undue delay within the deadline previously mentioned and in cases where personal data are no longer necessary for the purpose (employment contract execution) for which they were collected or otherwise processed.

Obligation to inform regarding rectification or erasure of data, as well as restriction of processing – The controller is obliged to inform all recipients to whom personal data have been disclosed about any rectification or erasure of personal data or restriction of their processing in accordance with the law, unless this is impossible or requires excessive time and resources.

Right to restriction of processing – The data subject has the right to request restriction of processing of their personal data by the controller if the data subject disputes the accuracy of personal data, within a period that allows the controller to verify the accuracy of personal data, if processing is unlawful, and the data subject opposes erasure of personal data and instead requests restriction of their use, if the controller no longer needs personal data for processing purposes, but the data subject has requested them for the purpose of submitting, enforcing, or defending a legal claim, if the data subject has objected to processing, and during the evaluation of whether the legal basis for processing by the controller outweighs the interests of that person.

Right to data portability – The data subject has the right to receive their personal data previously provided to the controller in a structured, commonly used, and machine-readable format and has the right to transmit this data to another controller without hindrance if processing is based on consent or on a contract and if processing is carried out by automated means. This right also includes the right of the data subject to have their personal data transmitted directly from one controller to another, where technically feasible.

Right to object – If deemed justified in relation to their particular situation, the data subject has the right to object at any time to the processing of their personal data. The controller is obliged to cease processing of data concerning the person who has objected, unless it has demonstrated compelling legitimate grounds for processing that outweigh the interests, rights, and freedoms of the data subject or are related to the submission, enforcement, or defense of a legal claim. The data subject has the right to object at any time to the processing of their personal data for the purposes of direct marketing, including profiling, to the extent that it is related to direct marketing. If the data subject objects to processing for direct marketing purposes, personal data cannot be further processed for such purposes.

Automated decision-making and profiling – The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects their position. This right does not apply if the decision is necessary for the conclusion or performance of a contract between the data subject and the controller.

Right to lodge a complaint with the Commissioner – The data subject has the right to lodge a complaint

Commissioner for Information of Public Importance and Personal Data Protection ul. Bulevar kralja Aleksandra 15, 11120 Belgrade Telephone +381113408900, e-mail: office@poverenik.rs

if they believe that the processing of their personal data has been carried out in violation of the provisions of the Law on Personal Data Protection. Lodging a complaint with the Commissioner does not affect the right of the data subject to initiate other administrative or judicial remedies.

To fulfill the above requirements, we may request additional information necessary to confirm your identity. After your identification, we will respond to your request for the exercise of the above rights within a maximum period of one month from the date of receipt of the request.

To exercise the aforementioned rights, you can submit a written application (i) via email to:

Data Protection Officer.

• Vlada Milosevic
• vlada.milosevic@autokomerc.rs
• +381 63 353 171