SVILUPPO DOO BEOGRAD (NOVI BEOGRAD), with its registered office at Gramšijeva 2, 11070 Belgrade, Republic of Serbia, company number 21950106, VAT ID 113961001 (“SVILUPPO”, “we” or the “Controller”), respects the privacy of visitors to its websites and processes personal data in line with the Personal Data Protection Act of the Republic of Serbia (“Official Gazette of the RS”, no. 87/2018 – the “Act”), as well as, where applicable, Regulation (EU) 2016/679 (“GDPR”) and other applicable regulations.
Through this Privacy Notice (the “Notice”) we explain what data we collect through our websites, for what purposes we use it, on what legal basis, how long we keep it, who we may disclose it to and what rights data subjects have.
1. Which websites this Notice applies to
This Notice applies to SVILUPPO’s websites available through the following domains:
- redapp.rs
- uvedired.rs
- redapp.hr
- uvedired.me
- redapp.bg
- vavedired.bg
These domains are localised versions of the same website and may differ in language, market or available content.
The Notice applies primarily to representatives of companies and other organisations who visit our websites, submit a business enquiry, express interest in our products and services or book a meeting with SVILUPPO representatives.
2. Controller of personal data
The controller of personal data is:
SVILUPPO DOO BEOGRAD (NOVI BEOGRAD)
Gramšijeva 2
11070 Belgrade, Republic of Serbia
VAT ID: 113961001
Company number: 21950106
For questions about privacy and the exercise of rights relating to personal data you can reach us by email:
3. What data we collect
3.1. Data you provide to us directly
When you fill in a contact form on the website, express interest in our products or services or book a meeting, we may collect:
- your first and last name;
- your business email address;
- your phone number;
- the company name;
- the approximate number of employees in the company;
- the approximate number of company locations;
- the information you enter in the “What would you like to bring into rêd?” field or another free-text field;
- data about the meeting slot you selected;
- data needed to create and deliver the meeting invitation;
- data from further communication with our representatives.
Please do not send us, through free-text fields, data that is not needed for your business enquiry, and in particular special categories of personal data.
3.2. Website usage data
While the website is being used, certain technical and usage data may be processed, including, depending on your cookie choices:
- the IP address;
- device and browser data;
- approximate location derived from the IP address;
- the date and time of access;
- the pages visited and the actions performed;
- the source you accessed the site from;
- cookie identifiers and other online identifiers;
- data about interaction with ads or marketing campaigns;
- data about consent given or refused for the use of cookies.
More information about these technologies is available in our Cookie notice.
3.3. Data from publicly available sources
As part of the B2B sales process we may supplement information about a prospective business customer with data from publicly available sources.
Such sources may include public registers, the company’s website, publicly available business databases, professional networks and other legitimately available sources.
The data may relate, among other things, to:
- the company’s line of business;
- the size and organisation of the company;
- the number or type of business locations;
- the market the company operates in;
- the publicly available business or professional role of the contact person;
- other publicly available facts relevant to assessing the possibility of business cooperation.
Through this processing we do not seek to collect information relating to the private life of the contact person, nor special categories of personal data.
4. The purposes we process data for
We may process personal data for the following purposes:
4.1. Responding to business enquiries
We use the data to:
- receive and process your enquiry;
- understand your company’s needs;
- answer questions;
- present relevant products or services;
- contact you regarding the interest you expressed.
The legal basis for this processing is our legitimate interest in responding to a business enquiry a person has voluntarily sent us and in developing business relationships with prospective customers, or, where applicable, taking steps at the person’s request prior to entering into a contract.
4.2. Booking and holding meetings
We process the data in order to enable slot selection, create a calendar event, send an invitation, prepare and hold the meeting and communicate afterwards about it.
The selection of an available slot and the booking of the meeting are technically handled through a backend integration with Microsoft services using the Microsoft Graph API. In that process Microsoft receives only the data needed to check availability, reserve the slot, create the calendar event and send the invitation.
4.3. Recording prospective business customers in the CRM system
We may record the data in our CRM system in order to:
- track the business enquiry;
- record communication;
- organise the work of the BizDev and sales team;
- plan the next steps;
- internally track the sales process;
- prevent duplicated communication.
The legal basis is SVILUPPO’s legitimate interest in organising and improving its B2B sales process.
4.4. Sales follow-up
Our representatives may contact you afterwards regarding a specific enquiry, meeting or interest you expressed.
Submitting a business enquiry does not automatically add you to a newsletter or to a general list for promotional messages unrelated to your specific interest.
If we introduce such marketing communications in the future, we will ensure an appropriate legal basis for them and an easy way to stop receiving them.
4.5. Internal analytics and improving the sales process
We may use the data for internal analysis, including analysis of:
- the number and quality of business enquiries;
- the sales funnel;
- the sources enquiries come from;
- the characteristics of companies interested in our services;
- the effectiveness of the sales process;
- the needs of different groups of prospective customers.
Where possible, for statistical and aggregated analysis we use data that does not require the direct identification of a specific person.
4.6. Website security
We may process technical data in order to:
- protect the website and its forms from abuse;
- prevent automated and malicious requests;
- protect infrastructure and data;
- detect and resolve technical and security issues.
For this purpose we may use, among other things, security services from Cloudflare, including Cloudflare Turnstile.
4.7. Website analytics and advertising
If you have given the relevant consent through our consent management system, we may use analytics and marketing technologies in order to:
- measure website traffic and usage;
- understand the performance of content and campaigns;
- measure conversions;
- optimise advertising;
- build audiences and run remarketing;
- show more relevant ads.
This processing is based on your consent, where such consent is required under applicable regulations.
You can withdraw consent at any time through the cookie settings.
5. Profiling and automated processing
SVILUPPO may use automated processing, filtering, segmentation or scoring of prospective business customers in order to organise the B2B sales process more efficiently.
Such processing may take into account, among other things:
- data submitted through the lead form;
- the size of the company;
- the number of locations;
- the line of business;
- the market;
- publicly available data about the company;
- other business-relevant and publicly available facts.
The purpose of this processing is, among other things, to prioritise sales follow-up, assess how relevant our products are to a specific company, route the enquiry to the appropriate team member and analyse sales opportunities internally.
This profiling is not used to make decisions based solely on automated processing that would produce legal effects concerning the contact person or would similarly significantly affect them.
Final decisions about a business contact and potential cooperation may be subject to human assessment by our representatives.
6. Who we may disclose data to
To the extent necessary for the purposes described above, the data may be available to:
- SVILUPPO employees and engaged persons who need the data to perform their work;
- providers of CRM and other business information systems;
- providers of email, calendar and meeting scheduling services;
- providers of CMS, hosting, cloud and infrastructure services;
- providers of website protection and abuse prevention services;
- providers of analytics and digital advertising services, where you have given the required consent for such processing;
- providers of communication and customer service tools;
- our legal, accounting, audit and other professional advisers, where necessary;
- state authorities and other parties where there is a legal obligation or an appropriate legal basis for disclosing the data.
Where a third party processes data on our behalf as a processor, we seek to govern that relationship with an appropriate contract and require the application of appropriate technical and organisational safeguards.
7. International data transfers
Some providers of the technology, cloud, communication, analytics or marketing services we use operate internationally, which means that in some cases data may be processed outside the Republic of Serbia or the country in which the data subject is located.
We transfer data in line with applicable data protection regulations.
Where data is transferred to a country, part of a territory, sector or international organisation that has been found to ensure an adequate level of protection, the transfer may be carried out on the basis of that status.
Where an adequate level of protection has not been established, a transfer may be carried out only where another appropriate legal mechanism and safeguards provided for by applicable regulations are in place, such as appropriate standard contractual clauses or other permitted safeguards.
8. Data retention period
Data collected in connection with a business enquiry or potential business cooperation is generally kept for up to five years from collection.
Data may be deleted earlier when it is no longer needed for the purpose it was collected for, when there is a justified request for deletion or when there is no longer an appropriate legal basis for further processing.
If a prospective business customer becomes a customer of our services, the relevant data may be further processed within the business and contractual relationship and kept according to the retention periods that apply to that relationship.
Certain data may be kept longer where necessary to comply with legal obligations, to establish, exercise or defend legal claims, or to protect our rights and interests.
Data about cookies and similar technologies is kept for the periods stated in our consent management system.
9. Data security
SVILUPPO applies appropriate technical and organisational measures aimed at protecting data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure, access or other unlawful processing.
We limit access to data according to business need and apply safeguards we consider appropriate to the nature, scope, context and purpose of the processing and to the risks to the rights and freedoms of natural persons.
10. Your rights
Depending on the circumstances of the processing and applicable regulations, you have the right to request from us:
- information about whether we process your data;
- access to your data;
- rectification of inaccurate data and completion of incomplete data;
- erasure of data where the statutory conditions are met;
- restriction of processing;
- data portability, where the statutory conditions are met;
- to object to processing based on legitimate interest;
- to withdraw consent previously given, where processing is based on consent.
Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.
Where you object to processing based on legitimate interest, we will stop such processing unless there are legal grounds for continuing it that override your interests, rights and freedoms, or the processing is necessary to bring, exercise or defend a legal claim.
You can send requests relating to the exercise of your rights to:
Before acting on a request we may ask for additional information reasonably needed to verify the identity of the person making it.
11. Right to lodge a complaint
If you believe your data is being processed contrary to the regulations, you have the right to lodge a complaint with:
the Commissioner for Information of Public Importance and Personal Data Protection of the Republic of Serbia, in line with the Act.
Where the GDPR applies to the specific processing, you may also have the right to contact the competent data protection authority in an EU member state, in line with the rules of the GDPR.
Contacting a supervisory authority does not affect your right to contact SVILUPPO beforehand or in parallel in order to resolve the matter.
12. Cookies and similar technologies
SVILUPPO’s websites use cookies and other similar technologies.
Detailed information about the types of technologies we use, their purpose, their providers and how consent is managed is available in the separate Cookie notice.
13. Changes to the Notice
SVILUPPO may periodically amend or supplement this Notice in order to align it with changes to our services, technologies, business processes or applicable regulations.
The current version will be published on our websites, with the date of the last update stated.