PRIVACY POLICY

SGC DIGITAL BITE INDUSTRIES LTD with its registered seat at the address: Neda Center, 1st floor, Office 1B, 9 Spyrou Kyprianou Avenue, 3070 Limassol, Cyprus, VAT Number CY10370240A (hereinafter: “We”), respects and protects the privacy of each person (natural persons – customers, potential customers) or another person – hereinafter collectively referred to as: “Person or You”) whose personal data it collects (hereinafter: “Personal Data“).

Collection and storage of personal data are carried out in accordance with the Act on Personal Data Protection (“Official Gazette of the Republic of Serbia” No. 87/2018) (hereinafter: the “Act“) as well as with the EU General Data Protection Regulation (EU 2016/679) (hereinafter: “GDPR“), where applicable (in the case of processing Personal Data of Persons who are residents of a Member State of the European Union, We will also apply the provisions of the GDPR, to the extent applicable).

We appreciate you as our visitor and client and recognize that privacy is important to you.

To protect the privacy of any person whose Personal Data We collect, We have published our Privacy Policy. The Privacy Policy defines what Personal Data We collect, for what purpose We use it, how We protect it and what are your rights regarding the processing of Personal Data. Namely, We have developed this Privacy Policy to show You our practice regarding the collection and processing of Personal Data that We collect from You or about You at this web address: https://themestreet.net, through written or oral communication, when You conclude a contract for provision of services, or from some other source.

In any case, feel free to contact us at the email address: [email protected]

General conditions

Scope of application

This Privacy Policy applies to any processing of Personal Data by us.

“Personal Data” is any data relating to a natural person whose identity is determined or identifiable, directly or indirectly, in particular based on an identity mark, such as name and identification number, location data, identifiers in electronic communications networks or one, that is, more features of his physical, physiological, genetic, mental, economic, cultural and social identity;

“Data subject” means a natural person whose personal data are processed;

“Data processing” is any action or set of actions that are performed automatically or non-automatically with personal data or their sets, such as collecting, recording, sorting, grouping, structuring, storing, matching or changing, detecting, inspecting, using, disclosure by transmission or delivery, duplication, dissemination or otherwise making available, comparing, restricting, deleting or destroying;

“Sensitive data” refers to data revealing racial or ethnic origin, political opinion, religious or philosophical beliefs, or trade union membership, as well as the processing of genetic data, biometric data for the purpose of unique identification, health data or sexual data. the life or sexual orientation of the individual;

We do not collect your sensitive data unless you make it available to us voluntarily.

“Personal Data of children” refers to persons under the age of 15.

We do not collect the Personal Data of children. As a parent or legal guardian, do not allow your children to make their Personal data available without your permission.

If you send us Personal Data about other individuals (e.g., provide the email address / residence address of another person or the information of the person you wish to process with our service), We will consider that you have the authority to do so and that You have allowed us to We use that person’s information in accordance with this Privacy Policy.

Controller of the processing data and legal framework

We, as the Controller of the processing of your Personal Data, respect your privacy and undertakes to protect your Personal Data, all in accordance with this Privacy Policy.

Application of Data Protection principles

When processing Personal Data, We will at all times strive to act in accordance with the following principles of data processing:

• Personal Data must be processed lawfully, fairly and transparently regarding the person (“legality, fairness and transparency”);
• Personal Data must be collected for purposes that are specifically defined, explicit, justified and lawful and still cannot be processed in a way that is inconsistent with those purposes (“restriction on the purpose of processing”);
• Personal Data must be appropriate, relevant and limited to what is necessary regarding the purpose of processing (“data minimization”);
• Personal Data must be accurate and, if necessary, updated; taking into account the purpose of processing, all reasonable measures must be undertaken in order to ensure that incorrect Personal Data is deleted or corrected without delay (“accuracy”);
• Personal Data must be kept in a form that allows the identification of the Person only for the period necessary to achieve the purpose of processing (“storage restriction”);
• Personal Data must be processed in a way that enables appropriate protection of Personal Data, including protection against unauthorized or unlawful processing, as well as against accidental loss, destruction or damage, through the application of appropriate technical, organizational and personnel measures (“integrity and confidentiality”).

We are responsible for the application of these principles and must enable their implementation (“responsibility for action”).

How We collect personal data

Personal data is collected directly from You, as the persons whose data are processed or by other persons.

1) Direct collection of Personal Data from the Person whose data are processed

We collect Personal Data in a variety of ways:

• Access to the web address: https://themestreet.net, when You contact our employees, through the social networks Instagram and Facebook

We collect your Personal Data when You visit our website and when You contact us via email, telephone, and social networks.

The purpose of collecting Personal Data is to provide answers to various inquiries regarding our services or to establish communication with You in order to answer your inquiries or to specify your request. In that case, You consent to us collecting and processing your following Personal Data: name and surname, gender, email address and contact number. Additionally, the purpose of collecting the above Personal Data is to send notifications about offers, news, additional information, current events, events and promotions that We organize.

Providing the stated Personal Data is a necessary condition for establishing communication between You and Us. Otherwise, We will not be able to answer your inquiries or your requests regarding our services.

The stated Personal Data is stored in our database until you revoke the consent.

• Contracts for provision of services

We collect your personal data for the purposes of concluding a contract for provision of services or for the purposes of exercising the contract for provision of services, as well as for the purposes of email and telephone communication for the implementation of the contractual relationship or the establishment of a contractual relationship. The personal data that We collect and process on that occasion are: name and surname, gender, email address, contact number and address of residence.

The purpose of processing the above Personal Data is to conclude a contract for provision of services or the exercising of the contract for provision of services, as well as the realization of email communication and telephone communication for the implementation of the contractual relationship or the establishment of a contractual relationship.

Providing the above Personal Data is a necessary condition for concluding a contract for provision of services or for the purposes of execution of the contract for provision of services, which is concluded between You and us, or for the purpose of email and telephone communication between You and us. Otherwise, We will not be able to conclude or realize the concluded contract for provision of services.

The stated Personal Data is stored in our database as long as it is necessary for concluding the contract for provision of services, i.e., until all contractual obligations from the contract for provision of services are fulfilled. However, these Personal Data will be stored in our database within 5 years upon the conclusion of the contract for provision of services. Exceptionally, Personal Data collected for these purposes may be stored for a longer period of time for the period necessary to establish, execute or defend a legal claim.

• When submitting a statement on the use of the right to withdraw from the contract for provision of services

The conclusion of a contract for provision of services via the Internet is considered the conclusion of a distance contract. An integral part of the distance contract is the right of the buyer/Person to withdraw from the contract within 14 days from the day of concluding the contract without giving a reason.

In order to exercise your legal right to withdraw from the contract, you need to fill in the form on your irrevocable statement of decision to exercise the right to withdraw from the contract for the purchase of goods. By filling out the above form, which You are obliged to send to our email address: [email protected], You are revealing a number of Personal Data to us. In this regard, the Personal Data that We collect and process on that occasion are: name and surname, gender, address of residence and email address.

The purpose of processing the above-mentioned Personal Data is to exercise the right to withdraw from the contract for provision of services, in accordance with the Act on Consumer Protection. Therefore, the basis for the processing of these Personal Data for a specific purpose is the fulfilment of our legal obligations.

Providing the stated Personal Data is a necessary condition for exercising the right to withdraw from the concluded contract on the purchase of goods. Otherwise, we will not be able to enable you to exercise your legal right.

The stated Personal Data is stored in our database for as long as it is necessary for the purpose of exercising your right to withdraw from the concluded contract for the purchase of goods. Exceptionally, personal data collected for these purposes may be stored for a longer period of time for the period necessary to establish, execute or defend a legal claim.

• When submitting a complaint form

The conclusion of a contract for provision of services via the Internet is considered the conclusion of a distance contract. An integral part of the distance contract is the right of the buyer/Person to file a complaint in case of non-compliance with the provided services.

In order to exercise your legal right to complain, you need to fill out a complaint form. By filling out the above form, which You are obliged to send to our email address: [email protected], You are revealing a number of Personal Data to us. In this regard, the Personal Data that We collect and process on that occasion are: name and surname, gender, address of residence and email address.

The purpose of processing the said Personal Data is to exercise the right to file a complaint, in accordance with the Consumer Protection Act. Therefore, the basis for the processing of the said Personal Data for a specific purpose is the fulfilment of our legal obligations.

Providing the stated Personal Data is a necessary condition for exercising the right to complain. Otherwise, we will not be able to enable you to exercise your legal right.

The stated Personal Data is stored in our database for as long as it is necessary for the purpose of exercising your right to file a complaint. However, these Personal Data will be stored within two years upon the conclusion of the contract for provision of services. Exceptionally, Personal Data collected for these purposes may be stored for a longer period of time for the period necessary to establish, execute or defend a legal claim.

• By using the cookies

To learn more about cookies and how to manage them, including how to turn them off, visit the Cookie Policy section at https://themestreet.net/privacy-policy#cookie-policy

In the Cookie policy You will be informed which specific personal data We process via cookies.

2) Personal data provided by other persons

There are cases when You can provide us with the personal data of third parties, e.g., for the preparation and delivery of the promotional offer for which You consider that could be interesting to someone You know, in which case We will consider that You are authorized by that person to act in such a way and We will not bear any liability for processing Personal Data of third party.

Which Data We Collect

We collect the following personal data:

• name and surname;
• gender;
• address of residence;
• contact number;
• email address;
• other Data provided in the Cookie policy.

Purpose of collecting and processing the Personal data

The purpose of collecting the Personal Data:

• Establishing communication with You in order to answer your questions or in order to specify your request regarding our services;
• Concluding and exercising the Contract for provision of services;
• To exercise the right to withdraw;
• To exercise the right to file a complaint;
• Sending notifications about offers, newsletters, additional information, current events, events and promotions that We organize.

We may use depersonalized data for statistical purposes.

Lawful basis for processing Personal data

The lawful basis for processing personal data is:

• Your consent

Your Personal Data acquired based on your consent will be processed and stored as long as your consent exists, or until the revocation of your consent. You can revoke your consent on the acts of collecting, processing and using your data at any time by sending an electronic request to the e-mail address: [email protected]

Revocation of your consent doesn’t effect on permissibility of processing Personal data, performed before the revocation.

• Execution of the Contractual obligations

We collect your Personal data, that are necessary for us to conclude and execute contract with You and fulfil pre-contractual obligations.

Personal Data is necessary for concluding a contract for provision of services, so that We can fulfil our contractual obligations.

If You do not provide us with the necessary Personal Data, We will not be able to conclude a contract for provision of services or to fulfil all our contractual obligations.

• Fulfilment of legal obligations in accordance with the provisions of the Act on Consumer Protection

We collect your Personal Data that we need in order to exercise your legal rights (the right to withdraw from the concluded contract or the right to file a complaint), with that only, in order to fulfil our legal obligations.

The Personal Data that you disclose to us in order to exercise the mentioned rights are necessary for the fulfilment of our legal obligations.

If you do not provide us with the necessary Personal Data, We will not be able to realize the exercise of your legal rights.

Recipient and third party

We will not disclose your Personal Data to the other recipients or third parties, except in cases provided in this Privacy Policy and the General Terms and Conditions.

Period of storing the Personal Data

Personal Data that we collect for the purpose of concluding a contract for provision of services or for the realization of a contract, we will store only as much as is necessary for the purpose of fulfilling the contract or until all contractual obligations under the contract for provision of services are fulfilled. However, these Personal Data will be stored in our base within 5 years upon the conclusion of the contract. Exceptionally, Personal Data collected for these purposes may be stored for a longer period of time, and that so for the period that is necessary to establish, exercise or defend a legal claim.

Personal Data processed specifically based on your consent will be stored until the consent is revoked.

Personal Data that we collect in order to exercise your legal rights (the right to withdraw from the concluded contract for the purchase of goods or the right to file a complaint) or to fulfil our legal obligations, are stored in our database as long as it is necessary for the purpose of exercising legal rights. However, these Personal Data will be stored in our base within 2 years upon the conclusion of the contract.

Rights of Person related to the processing of the Personal Data

Besides the rights already mentioned in this Privacy Policy, as well as other rights provided by law and other regulations in accordance with the law, the Data Subject has also the following rights:

• To request information on whether We process his / her Personal Data and also to request access to such a data

In case of the mentioned request of the Person, we will provide information about the Personal Data of the Persons processed by Us or our processors, in accordance with our instructions, the purpose of processing the Personal Data, the legal basis and duration of processing, the name and address of the processor and its activities related to the processing, impact on the violation of the personal data, as well as the measures taken to eliminate them, and, in the case of data transfer, information on the legal basis of such a transfer and the receiver.

After your written request, We will provide You, no longer than 15 days from the day We received the request, with written explanation in understandable language. The written explanation shall be provided free of charge, unless the request is manifestly ill-founded or excessive, and in particular if it is repeats frequently. In that case, We can charge the necessary administrative expenses of giving a written statement and acting upon the request, or We can refuse to act upon the request.

We are obliged to provide the Data Subject, at his/her request, with a copy of the Personal Data We process. We may demand reimbursement of necessary costs for making additional copies requested by the Data Subject. If the request for a copy is submitted electronically, the information shall be provided in the commonly used electronic form, unless the Data Subject has requested for a different submission.

• To request the correction, amendment or deletion of his / her Personal Data and the right to file an objection to the processing of data

Data Subject has the right to have his/her inaccurate personal data corrected without necessary delay. Depending on the purpose of the processing, the Data Subject has the right to supplement his/her incomplete personal data, which includes giving an additional statement.

Data Subject has the right to request deletion of his/her Personal Data by us.

We are obliged to delete Personal Data without necessary delay if: 1) Personal Data are no longer necessary for the purpose for which they were collected or otherwise processed, 2) Data Subject has revoked the consent based on which the processing was performed, and there is no other legal basis for processing, 3) The person has filed an objection to the processing, 4) Personal Data has been illegally processed, 5) Personal Data must be deleted in order to fulfil legal obligations; 6) Personal Data is collected regarding the usage of information society services in terms of the Act.

• To submit the complaint to the Commissioner for Information of Public Importance and Personal Data Protection

• The right to transfer the Personal Data

Data Subject has the right to receive the Personal Data previously provided to us, in a structured, commonly used and electronically legible form and has the right to transfer this Personal Data to another controller without obstruction from us, if the following conditions are fellfield:

1. The processing is based on consent or contract;
2. The process is performed automatically.

• To limit the processing of Personal Data by us, if one of the following cases is fulfilled

1. Data Subject, denies its accuracy, within a period that allows us to verify the accuracy of Personal Data;
2. Processing is illegal, and Data Subject opposes the deletion of Personal Data and instead of requesting its deletion, it requests a restrictive use of Personal Data
3. We no longer need Personal Data to achieve the purpose of processing, but Data Subject requested it in order to submit, realize or defend a legal claim;
4. Data Subject has submitted an Objection to the processing in accordance with Article 37, paragraph 1 of the Law, and the assessment of whether the legal basis for processing by the controller outweighs the interests of the Person is in progress.

We are obliged to inform all Recipients which Personal Data has been disclosed of any correction or addition or deletion of Personal Data or restriction of their processing in accordance with the Law and GDPR unless it is not possible or it requires an excessive expenditure of time and resources. We are obliged, on its request, to inform all recipients of the person who is the subject of the Personal Data.

Data Subject has the right to receive his / her Personal Data previously provided to us in a structured, commonly used and electronically readable form and has the right to transfer this Data to another controller without interference on our part, in accordance with the Law.

If he/she considers that it is justified according to the special situation in which he finds himself, Data Subject has the right to submit us at any time an Objection to the processing of his/her personal data, in accordance with the Law.

Data Subject has the right not to be a subject of a decision made solely based on automated processing, including profiling, if that decision produces legal consequences for that person or that decision significantly affects his/her position.

Procedure in the case of breach of personal data

If breach of Personal Data may produce a high risk to the rights and freedoms of the Person, we are obliged, without unnecessarily delay, to notify a Data Subject of a breach, in accordance with the Law.

In the event of a Personal Data breach that may produce a high risk to the rights and freedoms of the Person, we are obliged to notify about it the Commissioner for Access to Information of Public Importance and Personal Data Protection without unnecessarily delay, or if it is possible within 72 hours from learning from the injury.

Transfer of personal data to other countries

The transfer of personal data to another state or international organization, without prior approval, may be made if it is determined that that other state/international organization provides an appropriate level of protection of Personal Data. In this regard, We do not transfer the Personal Data.

Link to third party websites and services

Our website may contain links to third party websites. Please consider the fact that we are not responsible for the collection, use, maintenance, sharing or disclosure of Data and information by third parties. If you disclose Personal Data on the website pages of third parties and use those sites, the Privacy Policies and Terms of use of those third parties will apply to that processing. We encourage you to read the Privacy Policies of the websites you visit before you disclose your personal information.

Data confidentiality and transparency

Your Personal Data will be treated as confidential information and we will undertake the appropriate necessary measures to protect it in accordance with the Law. They will be accessible only to persons who, given the description of the work they perform, should be acquainted with your Personal Data and only to extent necessary to perform their work.

This Privacy policy is available on the web page https://themestreet.net/privacy-policy

If we decide to change our Privacy policy, the changes will be available and published on the website page https://themestreet.net/privacy-policy

In case you have any questions or requests regarding the processing of your Personal Data, please contact us at the email address: [email protected]

Yours sincerely