Privacy Policy

This Policy aims to clearly and understandably explain which personal data we collect, for what purpose, how we protect it, and how you can exercise your rights when you visit the website www.coming.rs (“Website”) and contact us with an inquiry through the Website, when you attend events we organize, as well as in other situations when you do business with us. This Policy applies to the personal data of natural persons whose identity is determined or identifiable, and does not apply to anonymized data, i.e. data on the basis of which identity cannot be directly or indirectly determined. For example, personal data include first and last name, email address, contact phone number, and other data you provide to us through the contact form on the Website. This Policy does not apply to content provided by another company, if the Website contains links that lead to such content or websites.

Data Controller / Data Processor

The data controller is the company Coming – Computer Engineering d.o.o. Belgrade, with its registered office at Toše Jovanovića 7, 11030 Belgrade (“Coming”). As the data controller, Coming determines the purpose and means of processing personal data. If you have any questions regarding the personal data we process, you may contact us via the email address dpo@coming.rs.

Within the scope of the services we provide, in certain situations we act as a data processor. This means that we process the data of companies that are users of our services exclusively on their behalf and in accordance with their instructions. In such situations, the privacy policies of our clients, as data controllers, apply to the personal data of natural persons whose data are processed.

Coming has undertaken appropriate organizational, technical, and personnel measures to ensure the security and integrity of data.

Which Personal Data Do We Process?

Depending on the type of relationship, we process several categories of personal data.

If you contacted us via the contact form on the Website, in order to process your inquiry as accurately as possible and respond to it, we will collect your first and last name, email address, contact phone number, the name of the company you work for, as well as your position in the company. The same data will be collected if you register to participate in an event we organize, for the purpose of preparing accreditations, sending materials, and similar activities.

For the purpose of informing the public about events we organize, visitors and the atmosphere at the event may be photographed. We have a legitimate interest in publishing photographs from our public events on Coming’s social media profiles or the Website. At any time, you may request that we remove your published photograph from social media or the Website by contacting us at dpo@coming.rs, after which we will do so if the legal requirements are met.

If, during registration for an event we organize, you indicated that you wish to receive notifications and news about our business, you may withdraw your consent by clicking the “Unsubscribe” link/button.

If you visit our premises, for security reasons and based on legitimate interest, we will collect your first and last name and ID card number.

During the recruitment and employment process, we collect candidates’ CVs. If you are not selected for the position, we will cease processing your data, unless we believe that you may be suitable for a position in the future, in which case we will retain your data based on legitimate interest.

For the purpose of establishing and carrying out business cooperation, we process a minimum amount of data – first and last name, contact details, and the position of employees in companies with which we cooperate. Based on legitimate interest, we may retain employee data even after the termination of business cooperation with the employer, in order to occasionally send notifications about our activities and offers. In such cases, you may always request that we stop such processing by clicking the unsubscribe link/button, after which we will no longer process your data.

Coming does not process special categories of personal data. Exceptionally, Coming may process such data only in cases expressly provided for by law.

Purpose of Processing and Legal Basis

If you contact us with an inquiry for an offer, as well as in other cases of potential business cooperation, we process data on the basis of entering into or performing a contract, which is also the legal basis for processing data of persons employed by users of our services or other business partners. If we continue to retain contact data after the termination of cooperation in order to occasionally send notifications about our business and offers, we do so based on legitimate interest. We also retain the CVs of job applicants, based on legitimate interest, if we believe the person could be engaged in the future. Photographs taken at events we organize are processed on the basis of legitimate interest. For security purposes, we keep records of visitors to our premises, also based on legitimate interest. If we process your data based on consent, you may withdraw your consent at any time.

If our business requires new purposes or methods of processing personal data, we will amend this Policy and request consent from the data subjects, if required in accordance with applicable regulations.

With Whom Do We Share Your Data?

We share the data we process only if it is necessary for the provision of our services, i.e. if it is necessary to achieve the purpose for which the data are processed. In such cases, it is ensured that the processing of personal data by our partners, as processors, sub-processors, or joint controllers, is regulated by an appropriate agreement that ensures data processing in accordance with the law.

Transfer of Personal Data

We do not transfer personal data outside the territory of the Republic of Serbia.

Protection of Data Integrity

We have implemented appropriate technical, organizational, and personnel measures (for example, access control, segregation of duties, and access to data in accordance with assigned duties) to protect personal data from unauthorized processing, loss, destruction, or damage. We operate in accordance with the ISO 27001 standard, which is an international standard for information security.

Data Retention Period

Personal data are retained only for as long as necessary to achieve the purpose of processing, unless applicable regulations prescribe a longer or shorter retention period for a specific purpose, or in other cases expressly provided for by law. After the expiration of retention periods, data are deleted or anonymized. Retention periods are prescribed by a separate internal regulation.

Your Rights Regarding Personal Data

You have the following rights regarding the processing of your personal data:

You have the right to access your personal data, as well as the right to receive a copy of the personal data we process, if you request it. You have the right to rectification and completion if you believe that the data we process are inaccurate or incomplete. If you wish to restrict processing, request deletion of data, or request that we stop processing, you may submit an appropriate request to us in accordance with the law. If your data are processed based on consent, you may withdraw consent at any time. Upon request, you may receive your data from us in a structured, commonly used, and machine-readable format, and you may transfer the data to another controller. If you wish, you may at any time object to the processing of your data based on legitimate interest, and we will cease such processing if the legal conditions are met. You have the right to object at any time to the processing of your personal data for the purposes of direct marketing, including profiling. If you do not wish to receive email messages related to our offers and activities, you may unsubscribe by clicking the unsubscribe link/button. In the case of automated processing of personal data, you have the right to human intervention, to express your point of view on a decision made solely on the basis of automated processing, or to contest such a decision, in accordance with the law. You may exercise your rights by sending an email to dpo@coming.rs.

Filing a Complaint with the Commissioner for Information of Public Importance and Personal Data Protection

The competent authority for personal data protection in the Republic of Serbia is the Commissioner for Information of Public Importance and Personal Data Protection (“Commissioner”). You have the right to file a complaint with the Commissioner if you believe that the processing of personal data is contrary to applicable regulations. You may contact the Commissioner at the address Bulevar kralja Aleksandra 15, 11000 Belgrade, Republic of Serbia, by sending an email to office@poverenik.rs, or by phone at +381 11 3408 900.

Amendments to the Privacy Policy

All amendments to this Policy will be published on the Website.