Version: 2
Valid from: 30 January 2020
We at PR Legal highly respect Your privacy and we understand that You need to know who uses Your personal data and in what manner. This Privacy policy has been drafted in accordance with the Law on Personal Data Protection (Official Gazette of the Republic of Serbia no. 87/2018, hereinafter: LPDP) and best practice in this field, for the purpose of helping You understand how we handle Your data and what Your related rights are.
We process personal data lawfully, fairly and transparently with regard to the subjects of data, and we only collect them for the purposes that are specified, explicit, justified and lawful. The data are suitable, significant and limited to what is necessary for the purpose of processing and, as to our best knowledge, they are accurate and updated to the greatest extent. We keep the data in the form that only enables identification of persons in the period necessary for realising the purpose of processing and as required by the law; in that period we ensure relevant personal data protection, including protection against unauthorised and unlawful processing, accidental loss, destruction or damage by application of relevant technical, organisational and HR measures. We are committed to preservation of Your privacy and we shall be liable, under the law, for handling Your data.
Please read this Policy carefully and do not hesitate to contact us for any additional clarification that You may require.
1. JOINT CONTROLLERS
This chapter contains the information on identities and contact data of controllers i.e. persons responsible for handling Your data.
Attorneys Milan Petrović and Ivana Ružičić, partners at PR Legal (“Named partners“), jointly define the purpose and manner of personal data processing, wherefore they are considered joint controllers in terms of LPDP.
| Attorney Milan Petrović | Attorney Ivana Ružičič | |
| Seat: | Belgrade | Belgrade |
| Address: | Studentski trg 10/4 | Studentski trg 10/4 |
| Company reg. no.: | 56113665 | 57307862 |
| Tax ID: | 104135210 | 107096879 |
| Phone: | +381 11 420 80 20 | +381 11 420 80 21 |
| Mobile phone: | +381 63 86 20 634 | +381 64 24 35 590 |
| E-mail: | milan.petrovic@prlegal.rs | ivana.ruzicic@prlegal.rs |
The Named partners are jointly and severally liable for compliance with the provisions stipulated by the LPDP, notably the provisions on realisation of rights of persons that the data refer to and obligations regarding the information of these persons.
As agreed between the Named partners, the nominated contact point for the persons that the data refer to is attorney Ivana Ružičić.
In any event, the persons that the data refer to may realise their rights stipulated in the LPDP individually and with each of the Named partners as joint controllers.
2. THE MANNER OF DATA COLLECTION
This chapter contains the information on the manner in which we collect Your data and from whom.
We collect Your data directly from You and when You disclose them. For example, when You address us for legal services or when You apply for a post in our office. The data may be disclosed orally or delivered in writing or in e-form.
We may also collect Your data from the public databases when this is necessary for provision of legal service that You hired us to provide.
3. COLLECTED DATA, PURPOSE AND LEGAL BASIS OF PROCESSING, VOLUNTARY / MANDATORY NATURE OF DATA DISCLOSING; STORAGE PERIOD
This chapter contains the information on data that we process, the reasons why we need Your data and how we use them; what are the bases for our authorisation to process Your data; are You obliged to disclose Your data to us and what are the possible consequences if You deny to do so; the storage period for Your data and how we handle them upon the expiry of such term.
The data that we collect and process vary depending on the category of data subjects:
a. Clients
The data we collect about clients can be rather versatile. These are primarily contact information (name, surname, address, e-mail, telephone number) and the data we need for the provision of legal service that we were hired for (e.g. information about Your employment, Your property or Your activities). Sometimes, these can include special types of personal data (such as, for instance, membership in syndicates or Your health state), which we process exclusively for the purpose of provision of legal service that we were hired for and when necessary due to the nature of the service.
The legal basis of processing in such cases is realisation of legal service contract concluded with the data subject or undertaking of the activities, at the request of the data subject, prior to contract conclusion.
In some cases, the processing may be required in order to meet our legal obligations (e.g. those arising from the application of the Law on the Prevention of Money Laundering and Terrorism Financing).
We process Your data exclusively on voluntary basis. This means that Your are not obliged to provide us with Your data, but please note that in such case we may not be able to provide our service, entirely or partly.
The data and documentation about clients are kept in accordance with the Rulebook of the Serbian Bar Association on keeping of archival material in law offices and bar association. This means that, for instance, final decisions, real estate purchase agreements or documents and photographs that clients provide to us as evidence, shall be kept permanently, whereas communication and other documentation and data of less importance shall be kept during our engagement and two years after its completion.
In case of our corporate clients, we process the data of contact points within the client’s organisation, notably the contact information (name, surname, title, telephone number, e-mail, place of work). The legal basis of processing in this case is our legitimate interest to establish and maintain business relationship with our client. There is no obligation for You to provide us with Your information for this purpose, however in this case we would not be able to establish or maintain the business relation with the organisation that You work for. These data would be kept during our engagement.
b. Recipients of Legal PRess Newsleter
Legal PRess is electronic bulletin of our office where we publish the articles written by our lawyers on legislative novelties in the Republic of Serbia. These writings are of strictly informative nature and they do not contain legal advice. The bulletin is intended for our clients, our business contacts and the persons who registered to our mailing list.
For the purpose of newsletter sending, the data that we process include name, surname and e-mail address.
The legal basis of processing is our legitimate interest to notify our clients and business contact on legislative novelties in the Republic of Serbia, and consent of the persons who registered into our mailing list but are not our clients or business contacts.
Any recipient of our newsletter has a simple option to unregister from our contact list in e-form and thus stop receiving the bulletins in the future.
You are not obliged to provide us with Your data for this purpose, however we will not be able to send Your our newsletter and inform You about the legislative novelties in the Republic of Serbia.
The data that we process for this purpose shall be kept throughout our engagement or until a person’s unregistration from the mailing list.
c. Visitors of prlegal.rs
The Internet presentation of our office is located at www.prlegal.rs (“Website”). When You visit the Website, we do not automatically collect Your data (for more information, read the chapter on Cookies), but it is possible for You to submit us Your data through contact form on the Website or by phone, e-mail or regular mail, based on the information available to You on the Website.
In such cases, You provide us with Your contact information (name, surname, e-mail) and sometimes with information relating to the matter that You address us for.
We process Your data because processing is necessary for undertaking the activities, at the request of the person that the data refer to, prior to conclusion of the agreement and sometimes on basis of our legitimate interest to respond to Your enquiries.
You are not obliged to provide us with Your data for such purposes, but in that case we will not be able to respond to Your enquiry.
The data we process for these purposes shall be kept throughout our engagement and no later than six months after the last communication.
d. Our staff
Alike other employers, our office collects and processes the employees’ data in line with the Labour Law, Law on records in the field of labour and other regulations. We need these information in order to meet certain legal obligations relating to start and termination of employment, as well as to realising the rights and obligations arising from employment (e.g. application for mandatory social insurance, payment of salaries and other allowances relating to employment, payment of income tax and related contributions etc.).
The data we process are almost entirely defined by regulations in force. They include, for instance, contact information of the employee, information on professional qualifications and previous working experience, salary, business trips, leaves etc. Legal basis for this processing is fulfilment of our legal obligations or in certain cases the enforcement of employment contract concluded with the data subject. Provision of certain data is a necessary precondition for conclusion of employment contract. If You do not provide us with these data we will not be able to conclude an agreement with You and to exercise our obligations based on Your employment. We shall keep these data permanently, considering that the storage period is prescribed by the law.
In addition, we display or we may display staff photos on our Website in order to present our office team. The legal basis for processing in this case is personal consent. You are not obliged to allow us to use Your photos for the stated purpose, in which case we will not be able to present You as part of our team on our Website. Your photos will be kept throughout Your employment.
e. In-house and external collaborators
Our office cooperates with many persons relating to provision of high quality services in a number of fields. These persons are primarily in-house collaborators or those in an of counsel capacity, notably legal experts and advisors in other fields whose expertise supplements the services provided by our office.
The data that we process in this case are primarily contact information, data on qualifications and expertise, data on the agreed and paid fees etc. Legal basis for processing of these data is fulfilment of the agreement concluded with the data subject. You are not obliged to provide us with Your data for such purposes, but in that case we will not be able to conclude an agreement with You nor to exercise it.
We display or we may display the photos of our collaborators on our Website in order to present our office team. The legal basis for processing in this case is personal consent. You are not obliged to allow us to use Your photos for the stated purpose, in which case we will not be able to present You as part of our team on our website.
Data on our collaborators will be kept during their assignment, unless we are legally bound to keep them longer (e.g. financial data).
f. Job applicants
We process the data of persons who apply for job in our office, for starting employment or other form of cooperation. These data imply those contained in applicant’s CV (contact information, professional qualifications, previous working experience etc.). Legal basis of processing is undertaking of activities for candidate selection, upon request of the data subject, prior to conclusion of agreement. There is no obligation to submit these data, but if You do not provide them we will not be able to process Your application and consider it during candidate selection.
Data about the candidates shall be kept during the selection procedure and six months after its completion i.e. after the moment of application receipt if there was no selection procedure.
After the expiry of the storage period, we remove the data from our systems, return the files to the clients (if applicable) and/or destroy them in a safe manner, depending on their form (paper or electronic).
4. COOKIES AND THIRD PARTIES
This chapter contains the information about cookies, on whether and how we use them, what happens if You share some content from our Website on social networks or if You click on links available on our website.
Cookies are simple text files kept on user’s web browser or device. Cookies can access the data You keep on Your devices and collect the data on Your online activities.
Our office does not use cookies on our website for marketing purposes. As it is made on WordPress platform, our Website contains WordPress cookies that enable technical operation of the website (for more information, click here). In addition, we use Google cookies such as Tag Manager for analytical purposes and Google Maps that enables the display of our office location in Contacts on our website.
Web browser used for access to our website contains the options that enable You to turn off some or all cookies, in which case certain elements on our Website may not work properly.
Our website contains fields with links to our office profiles on Facebook and LinkedIn. These fields use parts of the code coming directly from Facebook and LinkedIn and which feed cookies to your web browser. You are therefore suggested to read privacy notices of these companies (which may be updated from time to time) in order to understand the way they process Your data using cookies. Please note that the seats of Facebook and LinkedIn are in the United States.
Texts on our Website may contain links to other Internet presentations (e.g. different institutions, state authorities or civil society organisations). If You visit some of these presentations via links on our website, please note that we will not be liable for processing of Your data that may be done through these websites (including cookies that may be fed by these websites to Your web browser or device) and we advise that You get informed on such processing through privacy notices on these websites and/or to adjust the parameters on Your web browser so as to prevent the feeding of cookies and following Your activities.
5. RECIPIENTS OF PERSONAL DATA
This chapter contains the information as to who we share Your data with and why.
We share Your personal data only when necessary and only with the persons that they are necessary for. We are doing this in order to realise the service that we were hired for, to comply with our legal obligations or to respond to Your enquiries. The persons in question usually imply our staff, collaborators, consultants or providers of certain services (e.g. bookkeeping agency) or relevant state authorities. We have properly regulated our relations with these persons as regards the protection of personal data, and they are required to use such data exclusively in accordance with this Privacy policy.
6. TRANSFER OF DATA TO OTHER STATES
This chapter contains the information as to whether and when we transfer Your data from the Republic of Serbia, and the way we ensure that Your data are handled lawfully and safely.
We process and use Your data primarily in the territory of the Republic of Serbia. All our documentation in paper form, as well as servers where e-documents are stored, are located in the Republic of Serbia.
When necessary and exclusively at Your request, we may transfer Your data to our partner law offices abroad, if that is necessary for provision of legal service that You requested and which is within the jurisdiction outside the Republic of Serbia. This will particularly imply the states with appropriate level of personal data protection within the meaning of LPDP. When the required conditions have been met, we may also perform transfer on basis of the standard contractual clauses prepared by the Commissioner for the protection of information of public importance and personal data protection of the Republic of Serbia.
7. YOUR RIGHTS WITH REGARD TO DATA PROCESSING
This chapter contains the information about Your rights relating to the processing of Your personal data, as well as contact point that You need to address in order to exercise these rights.
It is important for us that You are aware of Your rights relating to personal data processing that are guaranteed by the law and which are exercised under the prescribed terms.
If You would like to exercise these rights or if You have any question regarding our processing of Your personal data, You may contact us in the following manner:
| Mailing address: | Telephone number: | E-mail address: |
| PR Legal Studentski trg 10/4 11158 Belgrade PAK 105103 Serbia |
+381 11 420 80 20 +381 11 420 80 21 |
dataprotection@prlegal.rs |
Your rights with regard to processing of Your personal data:
Right to access – You are entitled to require the information as to whether we process your personal data, as well as to access such data. At your request, we shall provide you with a copy of your data that we process.
Right to correcting and supplementing – You have the right to correct inaccurate data that refer to you without unnecessary delay, and to supplement the incomplete data, including the issuance of additional statement.
Right to deletion of data – You have the right to require the deletion of your data, notably:
(a) If the data are no longer necessary for realising the purpose of their collection or other processing;
(b) If you withdrew the consent for processing, and there is no other legal basis for processing;
(c) If you filed a complaint against processing in accordance with law.
Right to restrict processing – You have the right to restrict the processing of your data if one of the following conditions has been met:
(a) If you deny the accuracy of data, within a deadline that enables us to verify the accuracy of personal data;
(b) If the processing is unlawful and you oppose the deletion of personal data and request the restriction of use instead of data deletion;
(c) If we no longer need personal data for achieving the purpose of processing, but you required them for the purpose of submission, exercising or defending the legal request;
(d) If you filed a complaint against processing done on basis of legitimate interest of the handler, and the estimation is ongoing with regard to prevailing of legal basis for processing by us against your interests.
Right to objection – If you deem that it is justified with regard to the special situation you are in, you have the right at any time to object to the processing of your personal data which is done on basis of legitimate interest of the handler, including the profiling based on such provisions.
Right to transferability of data – You have the right to receive your personal data provided to us in a structured, commonly used and machine-readable format and transfer such data to another handler without any interference, providing that the processing is based on consent or contract and is carried out by automated means. Also, you have the right for these data to be indirectly transferred to another handler if this is technically feasible.
Right to withdraw consent – If processing is done on basis of your consent, you have the right to withdraw consent at any time, whereas the withdrawal of consent shall not affect the admissibility of processing based on the consent prior to withdrawal.
Right to file complaint – You have the right to file complaint regarding the processing of your personal data to the responsible authority in the Republic of Serbia. Their contact information are as follows:
Commissioner for information of public importance and personal data protection
| Address: | Bulevar kralja Aleksandra 15, 11120 Belgrade, Serbia |
| Email: | office@poverenik.rs |
| Telephone: Serbia | +381 11 3408 900 |
8. PROTECTIVE MEASURES
This chapter contains the information about the measures we take in order to preserve the confidentiality of Your data, as well as measures that we will undertake in case the safety of Your data is compromised.
The safety of Your data is very important to us. As lawyers, we are particularly responsible for safety and confidentiality of the data disclosed by our clients or those that we found out during our engagement (“lawyer’s confidentiality obligation”).
We undertake the measure of physical, technical and electronic protection in order to prevent any accidental or unlawful destruction, loss, modification, unauthorised disclosure or access to personal data. These measures are applied both to the persons outside our office and to those inside. With regard to our employees and collaborators, the access to Your data is restricted to those whose duties require such access and who are instructed on data protection rules.
Unfortunately, no safety system is break-free, hence we cannot guarantee that safety of the system that we directly control will never be jeopardised. In case of infringement of any personal data, we shall take all possible measures and notify the responsible authorities according to the regulations, as well as individuals concerned, if possible.
9. APPLICABLE VERSION
This Policy has been in force since 21 August 2019. We may amend and/or supplement it from time to time in order to meet legal requirements 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.
