Updated on November 1, 2023
At HOOLOOVOO, we take data seriously. Given that, like other websites, our website collects your personal information too and we understand that you need to know in what manner it is being done. Therefore, please continue reading to learn about our privacy rules and do not hesitate to contact us for any additional clarification that you may require.
This is our Privacy and Cookie Notice, and we update it regularly to meet legal requirements primarily established by the Law on Personal Data Protection (Official Gazette of the Republic of Serbia no. 87/2018) (“the Law”) or to enhance our system of personal data protection. Upon each amendment, the date of entry into force of the new Policy will be clearly indicated. Amendments enter into effect on the date shown above. We will never use or share your personal information retroactively.
1. Who is responsible for the processing of your personal data?
The controller responsible for handling your personal data is:
2. What personal data do we process and how?
We collect your personal information directly from you and when you disclose it (for example, when you address us or when visiting our website).
As regards the cookies that our website uses, please read section 2.2 below.
2.1. Data about subjects that address us
Depending on the capacity and reason for which you addressed us, we may process data regarding your name, surname and e-mail address (as those are the elements of the contact form on our website), as well as other data included in your message (if any).
In this case, we process your data either because processing is necessary for undertaking certain activities at your request (prior to conclusion of the agreement) or on the basis of our legitimate interest (to respond to your inquiries).
You are not obliged to provide us with your data for such purposes; however, in that case we will not be able to respond to your inquiry.
The data we process for these purposes shall be kept as long as necessary for the purpose for which we process them, but no longer than six months after the last communication. However, we may store your information longer than stated above if it is necessary to fulfill legal obligations or to protect our legal rights (for example in a legal dispute).
Accordingly, in order to prove our compliance with data protection requirements, i.e., that we informed you on all relevant aspects of personal data processing (as prescribed by Article 23 of the Law), data regarding your name and surname, if collected through our contact form, shall be kept for two years since the last communication.
2.2. Use of Cookies
We use cookies (simple text files kept on your web browser or device, which can access the data you keep on your devices and collect the data on your online activities), as it allows us to optimize and personalize your experience on our website and analyze how our website is used.
Along with cookies, we also use other technologies to store and read information on your device (computer, tablet or mobile phone), such as JavaScript and Google Analytics (which we will also call “cookies”, to make it easier).
Read on to learn about the categories of cookies that we use.
a) Necessary Cookies or Technical Cookies
We need these for our website to work. They enable easy navigation through our website and register your privacy settings. Without technical cookies, our website would not function, so they are always set and we do not require your consent to use them. These do not process any personal information.
b) Preference cookies
With your consent, we place preference cookies on your device. For example, we remember which language you prefer and we can make your interaction with our website more user-friendly.
We base the placement of preference cookies and the processing of data collected on your consent.
c) Analytical cookies
With your consent, we also place analytical cookies on your device. They help us collect information about your computer, internet and system administration. These cookies also collect aggregated information on how you use our website, time spent, pages visited, geolocation, etc. This does not allow us to identify you or draw conclusions about you.
This information allows us to estimate our audience size and usage patterns, store information about your preferences and recognize you when you return to our website. We base the placement of analytical cookies and the processing of data collected through these cookies on your consent.
Managing cookies
Once you opt in, you can opt out/withdraw your consent at any time by clicking on the “cookie settings” link that is shown at the bottom of our website and change your settings. Withdrawal of consent does not affect processing of your data that took place prior to the withdrawal.
3. Who do we share your personal data with and where do we keep them?
We are all committed to keeping your data safe and secure, so we do not share your personal information, except with analytics partners. For example, we may share identifiers, internet and network activity information and other information about how you interact with our websites or mobile applications. These third parties may use your personal data collected through cookies for targeted advertising, marketing and campaign management purposes. Our relations with our partners in terms of data protection are regulated by agreements.
We primarily use your data on the territory of the Republic of Serbia. However, given that our website is hosted in Germany, the data collected through it are being transferred to the said country, which transfer is done on the basis of an appropriate level of protection in terms of the Law, considering that the said country is a signatory to the Convention of the Council of Europe on the Protection of Persons in Relation to the Automatic Processing of Personal Data, i.e., that it is covered by the Decision of the Government of the Republic of Serbia on the List of Countries, Parts of Their Territories or One or More Sectors of Certain Activities in Those Countries and International Organizations in Which it is Considered that an Adequate Level of Protection of Personal Data is Ensured (Official Gazette of the Republic of Serbia no. 55/2019) (“RS Adequacy Decision”).
In addition, please note that, due to the use of Google Analytics, a web analytics service of the US-based company Google LLC, the data collected through the said service are being transferred to the United States of America, also based on the appropriate level of protection in terms of the Law, i.e., considering that the said country is also included in the RS Adequacy Decision. However, please note that this transfer is limited to the mechanism for personal data transfer between the EU and the USA, which entered into force on July 10, 2023. To learn more about this mechanism and the privacy policy applied by Google LLC, please visit this link.
In the event that you have a place of residence or stay outside the territory of the Republic of Serbia, i.e., in any other country, when addressing us, your personal information is transferred to the Republic of Serbia, whereby the legal basis for this transfer is your consent.
4. How do we keep your personal data safe?
We take technical, organizational and personnel measures to protect your personal data against destruction, loss, alteration, unauthorized disclosure or access.
Examples of technical measures are encryption of your personal data and regular destruction of logs. An example of other measures is that only our authorized employees are allowed to have access to your data. These employees only have access to your personal data to the extent necessary to perform their duties and are required to treat your personal data information confidential.
5. Your rights related to personal data
You have a number of privacy rights.
Namely, you are entitled to:
Our website is not directed at children, nor do we have actual knowledge that we sell or share the personal information of children. If you have knowledge that a child has submitted personal information to us, we request that you contact us via one of the methods listed above so that we may delete the information.
How to exercise your rights?
You can send your request via the contact form on our website. Depending on the type of request, we may request additional information needed to process your request.
You may use an authorized proxy to submit a request on your behalf. If you choose to use an authorized proxy, make sure that you supply your proxy with written permission to act on your behalf. We will ask your proxy to provide us with proof of such authorization before we process your request. We will respond to your request within the timeframe required by applicable laws.
6. Who to contact?
If you have questions about our Privacy and Cookie Policy or practices, please feel free to get in touch.
You can contact us at: kancelarija@hooloovoo.rs
