Privacy policy

Date of last change: 18.05.2024.

This Notice on the processing of personal data (hereinafter: "Notice") describes how the company Joberty Technologies d.o.o., Veljka Dugoševića 54, 11000 Belgrade, MB: 21504769, OIB: 111575925, contact: salarypulse@joberty.com (hereinafter: "Company") collects, processes, uses and shares personal data in connection with the services we provide on the website: https://www.salarypulse.rs, platform that allows company representatives insights into IT salary benchmark in Serbia. The term "personal data" is all data related to an individual whose identity has been determined or can be determined ("the respondent"). An individual whose identity can be determined is a person who can be identified directly or indirectly, especially with the help of identifiers such as name, identification number, location data, network identifier, etc. Identification can be directly through the information itself or in a link to any other information in our possession or likely to come into such possession. Unless otherwise specified in this Notice, terms defined in the Regulation of the European Parliament and the Council of April 27, 2016 on the protection of individuals in connection with the processing of personal data and on the free movement of such data and on the repeal of Directive 95/46/EC - General data protection regulation (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679) hereinafter: „GDPR“) such as "processing/processing", "controller", "supervisory body", "consent", "legitimate interest of the controller or third parties", "anonymization", "special category of personal data" are used in the same meaning in this Notice.

1. WHO IS THE CONTROLLER?

Company acts in the capacity of data processing manager in connection with the processing of personal data of users of its services and visitors to the website: https://www.salarypulse.rs This means that Company decides on the way in which these personal data are processed and for what purposes they are processed, all in accordance with the current regulations regulating the protection of personal data (the provisions of the GDPR and the Act on the Implementation of the General Regulation on Data Protection, NN 42/ 2018).

2. WHAT TYPE OF PERSONAL DATA DO WE PROCESS AND FOR WHAT PURPOSES?

a) Processing of personal data for the purpose of user registration

We collect user personal data during user registration on the Salary Pulse platform located on the website:www.salarypulse.rs (hereinafter: “Platform“). As part of the registration process, we collect and further process your following personal data: contact data (name and surname, workplace/function in the legal entity, e-mail address and telephone) and data for accessing the user profile of the legal entity: email address and password created during registration (hereinafter: „Registration data“).

We use registration data for the purpose of your registration on the Platform, i.e. creating your user account, for the purpose of each subsequent login/access to your user account, i.e. for the purpose of enabling your use of our services on the Platform (enabling you to access IT salary benchmark of your employees and all IT industry in Serbia in general). When providing data about your employees’ salaries, you may choose and don’t have to, to identify each individual employee with an employee’s personal information (such as their Name and Surname, email and similar). We will also treat this information as Personal information even though it doesn’t have to be. We will collect it, and further process it as personal information. We also use your e-mail address, with your consent, to send you notifications about new content and functionality, additional services for users, new products and services or similar.

Also, we use your e-mail address and/or phone number when you contact our customer service with request for support, feedback or comments that you have sent to us, in order to respond to your such inquiries, requests, suggestions or comments addressed to us. As well as for sending news and notices (promotional and marketing materials), i.e. notices about new business possibilities or cooperation, when you have given us your consent for processing for this purpose.

b) Processing of personal data related to the use of the service

When you use our benchmark services for your employees, we collect and process your employee’s personal data that you might mention under Employee ID field. This field represents your identification of your employee, therefore it can be anything that helps you link provided salary information with the specific employee. It’s under your judgment to decide whether to use employee's personal information for this field such as: employee's first and last name, telephone, or email address, or not.

When you use our services, we also store text, messages, communications (such as when users contact us in some cases we will keep a record of that correspondence), or other materials submitted, produced or created and stored within the Service by you, which may include, without limitation, personal data. (hereinafter: „Data related to the use of the service“).

c) Processing of personal data related to the establishment, exercise or defense of legal claims

Additionally, we may process Registration Data and Data related to the use of the service, and for the purpose of establishing, exercising or defending legal claims. Also, in order to comply with the legal obligations of the data controller, if it is necessary to process the user's personal data in order to act in accordance with the law or a court order.

3. FURTHER PROCESSING FOR NEW PURPOSES

Also, if we intend to use your personal data for a new purpose, which is not covered by this Notice, then before starting the processing and determining the relevant purposes and conditions of the processing, we will provide you with a new notice explaining that new use. If and when necessary, we will ask for prior consent for such new processing.

4. LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

For Registration data and Data related to the use of the service by registered users that we process for the purpose of your use of our services as well as contact with our service for users, the legal basis for processing personal data is our legitimate interest in executing a contract with a legal entity in accordance with Art. 6. paragraph 1. t. (f) GDPR;

Furthermore, the legal basis for the processing of Registration Data - your e-mail address for the purpose of sending notifications about new contents and functionalities, additional services for users, new products and services or the like as well as for sending news and notifications (promotional and marketing materials), is your consent in accordance with Article 6, paragraph 1, point (a) of the GDPR;

Regarding Registration Data and Data related to the use of the service that we process for the purpose of establishing, exercising or defending legal claims, it is our legitimate interest to establish, exercise or defend various legal claims in accordance with Article 6, paragraph 1, point (f) GDPR;

5. RECIPIENTS OF PERSONAL DATA

We share your personal data obtained through your registration and use of the service with the following recipients/categories of recipients:

  • Joberty employees that have signed an NDA. By registering on the Platform and accepting Terms & Conditions and this Privacy Policy, we consider that you have given us consent for the collection and processing of your personal data and your employee’s personal data.
  • We may also disclose your personal data to data processors such as courts, administrative authorities, supervisory authorities for the protection of personal data, and our legal advisors, if this is necessary to comply with our legal obligations, establish, exercise or defend legal claims.
  • External organizations that help us operate and/or process personal data on our behalf and at our direction (e.g. our bookkeepers, IT operators and support, Data Security consultants, etc.). Service providers and/or processors and their selected staff may access your personal data and use it only on our behalf and to perform specific tasks for which they were hired, according to our instructions and after signing and NDA, and are required to keep your personal data secret and secure.

6. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

All personal data that we collect and process are stored in the Republic of Serbia and are not transferred or stored further to other third countries and/or international organizations outside the European Economic Area (hereinafter: "EEA").

If in the future it is necessary to transfer your personal data to organizations in third countries or international organizations, and these are organizations that may have different personal data protection standards than those established within the EEA and to which the decision on adequacy of the European Commission does not apply, we ensure you that we will protect your personal data through the application of appropriate protective measures, such as standard contractual clauses on data protection adopted by the European Commission and/or the competent supervisory authority. If it is allowed by law, in connection with such transfers, we can also rely on deviations for special situations provided for in Art. 49 of the GDPR, such as your express consent. We will inform you in a timely manner about such transfers to third countries or international organizations, as well as the protective measures we have taken to protect your personal data in this regard.

7. HOW LONG DO WE KEEP PERSONAL DATA

We take all reasonable steps to ensure that your personal data is kept in a form that allows the identification of the data subject only for as long as is necessary for the purposes for which the personal data is processed as set out further in this Notice. The criteria for determining the storage period are as follows:

  • Regarding the processing of personal data for the purpose of executing the contract, personal data is stored for the duration of the valid contract;
  • In relation to the processing of personal data based on the consent of the subject, personal data are stored until the consent is revoked;
  • In relation to personal data processed on the basis of the legitimate interest of the controller in the establishment, realization or defense of legal claims, personal data are stored for the duration of the contract, i.e. while we have valid consent to process your personal data, and 5 years thereafter (general statute of limitations deadline prescribed by law). If there is a dispute or the initiation of court, administrative or other similar proceedings, personal data is additionally stored for the duration of the dispute or such proceedings and 10 years after the decision is made (the statute of limitations for exercising rights from a final court decision or a decision of another state body prescribed by law). In doing so, we will limit the storage and processing of your personal data exclusively to data that is necessary for the establishment, realization or defense of legal claims;
  • In relation to personal data that we process in order to comply with our legal obligations, we store personal data within the storage periods prescribed by law.

    • After the storage or other processing of personal data is no longer necessary for the purposes specified in this Notice, we will destroy or anonymize it in such a way that it can no longer be linked to a specific natural person in any way, which means that it will cease to be personal data.

8. WHAT MEASURES DO WE TAKE TO PROTECT PERSONAL DATA

We take appropriate technical and organizational measures to protect users' personal data from unauthorized or illegal processing, by ensuring:

  • Protection of user's personal data from unauthorized access or changes.
  • Keeping the user's personal data confidential.
  • Suppliers and clients receive instructions on how to protect users' personal data.
  • An actual violation or suspicion of a violation of data security is reported in accordance with the applicable law.
  • All personal data is stored in a database located on a special server, access and handling of which requires special authorization.
  • User passwords are stored in the database in an encrypted form, which ensures the impossibility of misuse of the user's personal data, even by employees of the processing manager.

9. YOUR RIGHTS REGARDING THE PROCESSING OF YOUR PERSONAL DATA

As a data subject, you can request from us access to personal data relating to you, then correction or deletion thereof and restriction of processing relating to you. You also have the right to data portability.

Please note that in certain, legally prescribed situations, we will not be able to comply with your requests regarding the exercise of your previously mentioned rights. For example, if you ask us to delete personal data, and the processing of the same data is necessary for establishing, exercising or defending legal claims or for compliance with our legal obligations.

You have the right to object, based on your particular situation and at any time, to the processing of personal data relating to you based on a legitimate interest in accordance with Article 6, paragraph 1, point (f) of the GDPR. In the event of such an objection, we will stop processing personal data, unless we can prove that there are compelling legitimate reasons for processing that go beyond your interests, rights and freedoms or to establish, exercise or defend legal claims.

If the legal basis for the processing of certain personal data is solely your consent to the processing of personal data as stated above, you have the right to withdraw consent at any time, without this affecting the legality of the processing that was based on consent before it was withdrawn.

Your consent to the processing of your e-mail address for the purpose of sending notifications about new contents and functionalities, additional services for users, new products and services or similar, as well as for sending news and notifications (promotional and marketing materials) or notifications about new business, when you have given us your consent for processing for this purpose, you can withdraw by clicking on the link contained in each such notification expressing your wish to no longer receive notifications of this type. You can additionally withdraw your consent to the processing of your e-mail address for this purpose at any time via e-mail: salarypulse@joberty.com.

Detailed rules for exercising the rights of respondents regarding the processing and protection of their personal data are contained in the GDPR in Art. 12.-23. and 77-82.

10. OBLIGATION TO PROVIDE PERSONAL DATA

If you do not provide us with the Registration Data, you will not be able to register and/or use the related services.

11. AUTOMATED DECISION MAKING

The respondent is not subject to a decision based solely on automated data processing, including profiling.

12. CHANGES TO THIS NOTICE

If we change the way we handle your personal information in connection with the provision of the Services and your use of the Platform, we will update this Notice. We reserve the right to change our practices and this Notice at any time, so we encourage you to check the Notice frequently to be informed of any updates and changes to this Notice.

13. CONTACT INFORMATION OF THE PROCESSING MANAGER AND PROCESSING MANAGER'S REPRESENTATIVE

To ask questions or comment on this Privacy Notice and our data protection practices, or to file a complaint about our compliance with applicable regulations on personal data protection, please contact us by sending an electronic message to: salarypulse@joberty.com. We will acknowledge and investigate any complaint about the way we manage personal data (including and a complaint that we have violated your rights based on the relevant regulations on the protection of personal data).