PRIVACY POLICY

PERSONAL DATA PROCESSING NOTICE

Your privacy and the security of your data are important to us. Therefore, the company
MV INVESTMENT DOO BEOGRAD (SAVSKI VENAC) (hereinafter referred to as: the Company), fulfilling its obligations as a data controller, provides you, as an individual from whom data is collected, with the following information at the time of data collection, in accordance with the Personal Data Protection Law (“Official Gazette of RS”, No. 87/2018, hereinafter referred to as the Law). These Privacy Rules (hereinafter referred to as: Rules) apply to individuals, and personal data refers to all information through which we can identify you, directly or indirectly. All your personal information is treated as strictly confidential, and the Company and/or our trusted partners store it appropriately. Please read these privacy rules carefully. If you do not agree with our practices, please do not provide your personal data. If you continue to browse our website, you confirm that you agree with the rules outlined here.

DATA CONTROLLER AND RECIPIENT INFORMATION

The responsibility for processing personal data as the data controller is held by:
MV INVESTMENT DOO BEOGRAD (SAVSKI VENAC), Žanke Stokić 39, Belgrade, MB: 21730963, PIB: 104553271. 

The recipient of the personal data may be the company KADENA INTERNATIONAL REALTY DOO BELGRADE-NEW BELGRADE, Milutina Milankovića br. 11V, New Belgrade, MB: 20183209, PIB: 111529348. 

For any inquiries or requests regarding the handling or protection of your personal data, you can contact us by email at: info@kadenaproperties.com or by mail at the address of our headquarters listed above.

SCOPE OF PRIVACY RULES

These Rules cover the processing of your personal data when you interact with the Company, such as when you express interest in purchasing real estate or contact us regarding the conclusion of a property purchase agreement within the residential-commercial complex, including when: 

• You visit our website or pages used to advertise the Company’s projects; 
• You visit our profiles on social media platforms; 
• You communicate with us by phone, via contact forms on our website, via email, or in any other way; 
• You use our systems and applications; 
• You visit our sales properties; 
• You attend our presentations or business events; 
• You participate in our promotional or marketing activities (e.g., signing up for a newsletter), surveys, etc.; 
• You enter into a contract with us related to the purchase of property or any other contract. 

It is mandatory to provide only those personal data necessary to fulfill specific legal obligations. The provision of personal data based on other legal grounds is voluntary, but please note that if you withhold some data, in certain situations, we may not be able to provide you with certain services.

PERSONAL DATA WE COLLECT

1. Visitor Data on our Website – When you visit our website or pages used for advertising the Company’s projects, your browser will automatically send the following data to the server of our website: IP address of the device from which the request was made and which has internet access, the date and time of access, the name and URL of the downloaded file, the referring website/application (referrer URL), the browser you use, and if necessary, the operating system of your device supporting internet access, as well as the name of your provider. These data are temporarily stored in a log file for the following purposes:

• Ensuring the smooth connection.
• Ensuring comfortable use of our website/application or pages advertising the Company’s projects.
• Assessing security and system stability.

These data are stored temporarily for the duration of the visit and are automatically deleted afterward. The legal basis for processing the IP address is Article 12, Paragraph 1, Point 6) of the Personal Data Protection Law (legitimate interest), which arises from the above-mentioned purpose of data processing.

1. Marketing and Other Activities – For the purposes of sending commercial messages and conducting marketing activities, personal data is collected solely on the basis of consent (e.g., signing up for a newsletter, direct marketing, etc.). These data, which you provide to us via contact forms, phone calls, or emails, are used in accordance with the purpose defined here. If you have consented to receive newsletters via email, SMS, Viber, or other marketing materials containing updates on current offers and promotions related to our services, we use your email address, phone number, and name to send information on available properties, promotions, news, and offers for real estate sales. We store and process these data for the purpose of sending commercial messages, newsletters, and/or other marketing materials, including actions (offers, promotions, etc.). The legal basis for processing data when sending commercial messages, newsletters, and/or other marketing materials is your consent in accordance with Article 12, Paragraph 1, Point 1) of the Personal Data Protection Law. You can withdraw your consent to receive the newsletter/marketing materials at any time. The withdrawal of consent does not affect the legality of processing that occurred before the withdrawal. You can unsubscribe from the newsletter directly on our website or by using the unsubscribe link found at the end of every newsletter. For Viber or SMS, you can unsubscribe directly through the Viber app or SMS message, if you gave consent for such notifications. If you withdraw your consent, we will delete your data. Please note that in case of sending newsletters/Viber/SMS, we may engage external partners to execute these services, so your data (email address and phone number) may be transferred to those parties. 
2. Personal Data of Property Buyers – The Company processes personal data necessary for preparing, concluding, and executing contracts, or for fulfilling rights and obligations arising from signed property purchase agreements within the residential-commercial complex. The personal data we collect from you includes: full name, address (street, house number, postal code, city, country), personal identification number (JMBG), identity card/passport number, copies of personal documents, and contact details (phone number, email address). All your personal data is obtained directly from you. In addition to the Property Purchase Agreement, the Company may also conclude contracts with you prior to the purchase process, such as property reservation agreements, deposit agreements for property purchases, etc. In such cases, we collect the following data: full name, address (street, house number, postal code, city, country), and contact details (phone number, email address). The legal basis for processing this data is Article 12, Paragraph 1, Points 2) and 3) of the Law, considering the execution of contractual obligations and legal obligations. 
3. Other Personal Data Provided by You – We process personal data that you voluntarily provide to us during initial contact, later communication (e.g., through phone calls, emails, surveys, etc.), during visits to the Company’s website or pages used for advertising projects, or on social media profiles, as well as personal data arising from our communication or business cooperation, including your identification data (full name) and communication data (contact phone number and email address). We process your data in accordance with the defined purpose, to respond to your inquiry, present our offer in more detail, and provide any requested information. The legal basis for processing this data is Article 12, Paragraph 1, Point 6) of the Personal Data Protection Law (legitimate interest). Our legitimate interest in processing these data arises from the need to respond to your questions, resolve existing issues when necessary, and ensure your satisfaction as a user of our services and website. If you participate in one of our surveys, participation is voluntary. In anonymous surveys, we do not store data that would allow us to identify the participant. We only store the date and time of your participation. Any personal data you provide through the survey is considered voluntarily provided, and we store it in accordance with the provisions of the Law. If you have given consent for conducting the survey, the legal basis for data processing is your consent in accordance with Article 12, Paragraph 1, Point 1) of the Personal Data Protection Law. In such cases, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the legality of processing that occurred prior to the withdrawal.
4. Personal Data of Social Media Users – On the Company’s social media pages, we process data for the purpose of informing individuals about the business-residential complex, real estate for sale, services we offer, promotions, important news, and updates in the company, all to interact with visitors on social media and respond to their questions, compliments, and criticisms. The legal basis for processing your data is Article 12, Paragraph 1, Point 6) of the Law (legitimate interest). We have limited influence over the data processing by social media platform operators (e.g., member administration and information sharing). Where possible, we take measures to ensure the platform operator complies with data protection standards. However, we cannot influence data processing by the platform operator nor know exactly what data they process. The platform operator is solely responsible for any issues related to your user profile data, to which we, as a company, do not have access. For more information on data processing by platform operators, you can refer to their data protection policies. Data you enter on our social media pages, such as comments, videos, images, likes, public posts, etc., are published by the platform operator, and we do not process them for any purpose other than what is intended. We reserve the right to delete unlawful or inappropriate content when necessary. We process your data to communicate with you. We may share your content on our page if it serves the platform’s functions.

ACCESS TO YOUR DATA

We consider your personal data to be a business secret and protect it in accordance with applicable legal regulations and best practices. Within our company, access to the data you have provided is granted only to organizational units or employees who need it to fulfill the purpose for which the personal data was collected. We will process your personal data ourselves, while third parties may have access to and process your personal data only in the situations described below: 

• Our trusted partners or legal entities with whom we do business and who assist us in our regular operations. These may include entities that develop and maintain IT solutions and platforms, servers, as well as entities that provide services on our behalf, such as for marketing purposes. In this case, those legal entities process your personal data exclusively for our purposes. These service providers are obligated, under the contracts signed, to use the data entrusted to them exclusively in accordance with our instructions and strictly for the purpose we have specified, with the obligation to adequately protect your data and keep it confidential. 
• Entities with whom we cooperate when we assess it is necessary for the protection of our legitimate interests, such as tax advisors, accountants, insurance companies, lawyers, and other consultants. In this case, these entities process your personal data exclusively for our purposes. 
• Competent authorities conducting supervision over the legality of business operations and actions, as well as other legal entities when necessary to fulfill a legal obligation of ours, such as auditors. In this case, those legal entities process your personal data for the purpose assigned to them by law. 
• Other parties involved in business transactions such as the sale of the company or part of the company, reorganization, mergers, joint investments, or any other type of disposal of our company or assets. Also, there may be a need to forward part of your inquiries to contractual partners (e.g., suppliers, architects, or contractors for inquiries related to specific products/materials, etc.) for the purpose of processing your inquiry. However, in such cases, the inquiry will be anonymized beforehand, so that third parties cannot associate it with you. If in any particular case forwarding your personal data is necessary, we will inform you in advance and seek your consent. Third parties are limited in their ability to use your personal data for any other purpose except as stated, and they are obligated to protect and process your personal data in accordance with legal, regulatory, and contractual obligations. All legal entities with whom we cooperate are carefully selected and, when required by law, they are contractually bound to keep personal data confidential in accordance with Article 45 of the Personal Data Protection Law.

TRANSFER OF YOUR PERSONAL DATA TO OTHER COUNTRIES

In certain cases, we may share or transfer your personal data to other countries in accordance with the law. When we do so, we transfer your data to servers located in the EU or in a country that provides an adequate level of protection in accordance with the legislation of the Republic of Serbia. Access will only be allowed to a limited number of people, i.e., authorized persons, exclusively for maintaining the functionality of the server.

HOW WE PROTECT YOUR PERSONAL DATA

Some of the protective measures we implement include the following: 

• Application of modern protection methods and access control to data sources containing personal data. 
• Limiting access to sensitive data and restricting user accounts that can access specific data, introducing role systems and authorizations to ensure that only certain employees who need access to the data for performing their job tasks can view and process the relevant data. 
• Continuous monitoring of all resources (physical spaces where your data is stored) used for processing personal data. 

The purpose of implementing these measures is to prevent the risk of destruction, loss, alteration, unauthorized disclosure, or access to your personal data. We also require third parties who have access to and process your personal data to apply appropriate protective measures. All personal data is stored on our server in the Republic of Serbia. Please note that the aforementioned protective measures do not apply to information or data you choose to share publicly via social media or messaging apps.

RETENTION PERIOD FOR YOUR PERSONAL DATA

Personal data is stored for as long as necessary to fulfill the purpose for which it was collected. If you have entered into a contract with us, we store data for as long as the rights and obligations arising from the contract exist, and thereafter for as long as required by applicable regulations. We retain your personal data even after the termination of the contractual relationship if your personal data is needed for the establishment, exercise, or defense of legal claims or compliance with applicable laws. To the extent possible, we will limit the processing of your personal data to these limited purposes after the termination of the contractual relationship. Once the purpose is fulfilled, or the legally prescribed retention period for personal data expires, personal data will be permanently deleted.

YOUR RIGHTS

If you decide to exercise any of the rights listed below, we have the right to verify your identity, all in the interest of protecting personal data. You may exercise your rights free of charge. Exceptionally, if your request is clearly unfounded or excessive (e.g., you are requesting personal data that you already possess), and especially if the same request is repeated frequently, we have the right to charge necessary costs for processing your request or refuse to act on your request. Please send any questions or requests related to your rights in writing to the address specified in the section Data Controller. We will respond to your request immediately, and no later than within one month, unless exceptional complexity requires an extension of the specified deadline. To protect you as the data subject, it is necessary for you to appropriately identify yourself as the submitter of the request to guarantee that the personal data is being provided to its rightful owner. 

1. Access to Your Personal Data – You have the right to request information on whether we process your personal data, access to that data, and information on processing in accordance with Article 26 of the Law. 
2. Correction of Inaccurate Data, Supplements, Deletion, and Restriction of Data Use – You have the right to request the correction of inaccurate personal data, as well as the right to supplement, delete, or restrict the use of your personal data. 
3. Data Portability – You have the right to download and request the transfer of your personal data. 
4. Right to Withdraw Consent and the Right to Be Forgotten – You have the right to withdraw your consent for the processing of personal data, as well as to request the permanent deletion of your personal data that we have processed based on your consent. 
5. Objection to Processing or Handling of Your Personal Data – You have the right to object to the processing of your personal data, as well as in general to how we handle your personal data. You may send your request via email to the address provided in the Data Controller section, where you specify “Objection to Processing” in the subject line and explain the reason for your objection and your request in the body of the message. 
6. Right to File a Complaint with the Commissioner for Information of Public Importance and Personal Data Protection – You have the right to file a complaint with the competent authority for personal data protection – the Commissioner for Information of Public Importance and Personal Data Protection (https://www.poverenik.rs/).

CHANGES TO THE PRIVACY POLICY

The Company reserves the right to change these privacy policies at any time. Any changes become effective after they are published on the Company’s website or through another appropriate method. Therefore, we recommend that you regularly check the section related to the Privacy Policy to keep up with the latest information. 

Belgrade, March 17, 2023