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Privacy Policy
Date of publication: August 25, 2022

This Privacy Policy (“Policy”) covers the personal information that Data Driven Lab doo Beograd, company Registration number 21771902, with registered office at: Milutina Milankovića 1i, Belgrade, Serbia 11070 (hereinafter “We”, "Us”, “Our”, “DDL”) its subsidiaries and affiliates located worldwide within the DDL family of companies (“Affiliates”) collect through https://ddl.com/ (“Site”), applications, products, and services owned or controlled by DDL or Websites that post a link to this Policy.
By using the Site, you consent to the processing of Personal Data in accordance with the Policy. Refrain from using the Site if you do not agree with the terms of this Policy.
The protection of the security and privacy of your personal information is important to us and to the way we conduct our business in compliance with the laws on privacy, data protection, and data security.
The purpose of this policy is to outline what information the DDL may collect, how it uses and safeguards that information, and with whom it may share it.


1. WHO WE ARE
Data Driven Lab doo Beograd is the data controller and is responsible for your Personal Data.
Postal address: Milutina Milankovića 1i, Belgrade, Serbia 11070
Email address: support@ddl.com

2. PERSONAL INFORMATION
3.1. Information we collect
(1) We will collect the following personally identifiable information (“Personal Data”):
  1. full name (patronymic name if applicable);
  2. date of birth;
  3. mailing and billing address;
  4. phone number;
  5. country of residence;;
  6. log-in credentials;
  7. and any other information provided by sending your CV to Us, such as education information, professional expertise, and experience, including your title, company name, industry, technical specialty, trade and/or organization(s)/associations(s) to which you belong.

(2) We will process your Personal Data legally and fairly and not use it outside the purposes of which we have informed you, including selling it individually or in the aggregate for commercial use.

(3) We retain Personal Data in an identifiable format for the least amount of time necessary to fulfill our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and is not directly prohibited by the applicable law. We may take steps to mask Personal Data and other Data, but we reserve our right to retain and access the data for as long as required to comply with applicable laws. We will continue to use and disclose such Personal Data in accordance with this Policy.

(4) We also collect, use, and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data could be derived from your Personal Data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific software feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Policy.

(5) We do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, data about your health data).

(6) DDL and certain third parties that advertise or provide other services on the Site may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Site when you use the Site or certain Site services or click on advertisements on the Site.

(7) DDL and its partners and service providers may collect and analyze the information about the devices that are used to access the Site. This information may include (a) IP addresses, geo-location information, unique device identifiers, and other information about your mobile phone or another mobile device(s), browser types, browser language, operating system, the state or country from which you accessed the Site; and (b) information related to the ways in which you interact with the Site, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Site, the frequency of your use of the Site, error logs, and other similar information.

(8) As explained further below, this information is collected passively through the use of certain electronic technologies, such as cookies, web beacons, pixels, clear GIFs, and similar technologies., DDL may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information. As we adopt additional technologies, we may also gather additional information through other methods.

(9) Browser Cookies: We and certain third-party advertising partners may use “cookies.” Cookies are small pieces of information that are stored by your browser on your device. These cookies may be used: (a) to improve or enhance your experience using the Site; (b) to deliver content, including advertising, specific to your interests; and (c) for other purposes, such as security and administrative functions. For example, cookies are used to store your preferences for certain types of information so that you do not have to input those preferences every time you use the Site. Most web browsers automatically accept cookies, though different browsers may address cookies differently. Your browser may enable you to set your device to accept all cookies, notify you when a cookie is issued, or not receive cookies at any time. If you set your browser to not accept cookies, it may result in certain personalized services or other features not being provided to you when you use that device.

(10) Web Beacons, Pixels and Clear GIFs: We and our advertising partners may use web beacons, pixels, and clear GIFs. These electronic technologies are transparent image files that, if used, allow us and our advertising partners to track Site usage information, such as the number of times a given web page has been viewed and whether and when you have opened a HTML email, how many times the email was forwarded and which links in the email were clicked. Unlike cookies, these technologies do not place files on your device. We and our advertising partners use information collected through Web beacons, pixels, and clear GIFs to improve and enhance our Site and measure the effectiveness of these communications with you. These technologies may be used in association with cookies to understand how visitors interact with the Site or advertisements made by our advertising partners.


3.2. How we acquire your data
(1) Information may come from:
  • directly from you (from our communication and/or forms that you filled in);
  • from cookies stored in your browser by our Website;
  • IP-address;
  • from other sources including third parties and publicly available sources.

3.3 Purposes
We collect Personal Data for the following purposes:
(1) to administer Site, and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;
(2) respond to your requests, for example, to contact you about a question you submitted to our user service team;
(3) to provide products, services, or information to Users;
(4) protect our rights and interests as well as the rights and interests of our users and any other person;
(5) сarry out any actions for which we have received your consent;
(6) perform research and analysis about your use of, or interest in, our products, services, or content, or products, services, or content offered by others;
(7) to comply with applicable legal or regulatory obligations, including complying with requests from law enforcement or other governmental authorities, or in legal proceedings;
(8) fulfill our contractual obligations;
9) вcommunicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the Site, and for marketing and promotional purposes;
(10) to customize the advertising and content you see on the Site;
(11) to tailor the Site or other service we provide to you relating to your needs and interests; and to create anonymous statistical data;
(12) to administer sweepstakes and contests;
(13) interact with you regarding your application for employment with us;
(14) prevent and investigate fraudulent or other criminal activity.

The legal bases for using your information as set out in this Policy are as follows:

(1) Where use of your information is necessary to perform our obligations under a contract with you or in order to take steps at your request subject prior to entering into a contract; (for example, to comply with: our website user agreement, which you accept by browsing the websites/registering; and/or our contract to provide our Site to you); or

(2) Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our website and applications; operate our business and our Site and its services; make and receive payments; customer service; marketing; analyze and improve our business; comply with legal requirements and defend our legal rights; prevent fraud).

(3) Where required by law, and in some other cases, we handle your information on the basis of consent.

3.4 Children
We do not knowingly collect or solicit Personal Information from anyone under the age of 13. If you are under 13, please do not attempt to use the Site or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under the age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us their Personal Information, please contact us.


4. DISCLOSURE OF INFORMATION

4.1 To whom we disclose information
(1) Your Personal Information may be disclosed to:
(2) In general, we require that any third-party service provider that we share any Personal Information with undertakes to respect any individual’s right to privacy and comply with the Data Protection Principles.


4.2. Third Party Sites
The Site provides hyperlinks, which are highlighted words or pictures within a hypertext document, including advertisements that, when clicked, take you to another place within the document, to another document altogether, to another application not controlled by DDL, or to other Web sites not controlled by DDL. These hyperlinked Web sites may contain privacy provisions that are different from those provided herein. DDL is not responsible for the content or collection, use, or disclosure of information collected through these Web sites, and DDL expressly disclaims any and all liabilities related to such collection, use, or disclosure. We urge you to read the privacy and security policies of these third parties.

Marketing mailings

(1) If you provide us with your email address and agree to this Privacy Policy, we and our partners may send you emails regarding the products we offer. You can choose to opt out of receiving email from us at any time. If you wish to opt out with respect to more than one email address, you must provide a separate request for each email address. Every email sent from us will include appropriate unsubscribe instructions. To opt out of all email marketing messages from us, you should follow the instructions provided with each email.

(2) If you provide us with your telephone number and agree to this Privacy Policy, we and our partners may send you texts regarding the products we offer. You can choose to opt out of receiving texts from us at any time by emailing us.

4.3. International transfers

(1) We operate all over the world, and therefore we may transfer your data to our counterparties (partners, affiliates etc.) in different countries, including those which are located outside the country in which you are based. We do all our efforts, including those imposed on us by applicable law, to ensure an adequate level of personal data protection in each case, HOWEVER, we would like you to consider that the countries to which we transfer your data may not have the same data protection laws as your jurisdiction.

(2) Where we transfer, store, and process your Personal Information outside of the country in which you are based we will ensure that the appropriate safeguards are in place to ensure an adequate level of protection. Further details regarding the relevant safeguards can be obtained from us upon request.


Information for users in the European Economic Area (“EEA”) or in the United Kingdom (“UK”):

Operating globally, DDL may transfer Personal Information from the EEA or the UK to the United States and other countries, including Personal Information we receive from individuals residing in the EEA or the UK who visit our Sites and/or who may interact with us. Please note that the term Personal Information used in this Notice is equivalent to the term “personal data” under applicable European and UK data protection laws for individuals located in the EEA or the UK.
When DDL engages in such transfers of Personal Information, it relies on:
Adequacy Decisions, as adopted by:

  • European Commission, based on Article 45 of Regulation (EU) 2016/679 (GDPR);
  • UK Secretary of State, based on Article 45 of the UK GDPR and Section 17A of the Data Protection Act 2018; or
  • Standard Contractual Clauses.

5. YOUR LEGAL RIGHTS

In accordance with applicable law, you may have the right to:
(1 ) Access Personal Data about you;
(2) Request correction of your Personal Data where it is inaccurate, incomplete, or outdated;
(3) Request deletion, anonymization or blocking of your Personal Data;
(4) Request restriction of or object to our processing of your Personal Data;
(5) Withdraw your consent to our processing of your Personal Data;
(6) Request data portability and receive an electronic copy of Personal Data that you have provided to us;;
(7) Be informed about third parties with which your Personal Data has been shared;
(8) Request the review of decisions taken exclusively based on automated processing if that could affect data subject rights.

6. SECURITY

6.1. Retention of records

(1) We may be requested to retain and use your Personal Information to meet our legal obligations for data security purposes and as we believe to be fit and necessary or appropriate in order to either but not limited to comply with our requirements under applicable laws and regulations, to respond to requests from courts and/or other public and governmental authorities, for monitoring purposes through compliance and anti-money laundering processes.

(2) We will not keep your information for any longer than the time required. In many cases, information must be kept for considerable periods of time. Retention periods will be decided, considering the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.


6.2. Security measures

(1) DDL takes precautions to ensure the security of your personal information and strives to keep it accurate.

(2) We act with care to protect the user’s personal information from loss, destruction, falsification, manipulation, and unauthorized access or unauthorized disclosure and have developed and will maintain security procedures to safeguard Personal Information against loss, theft, copying, and unauthorized disclosure, use or modification.

(3) Access to Personal Information is limited to the DDL employees and authorized service providers who require to receive it in order to perform their work.

(4) While we will use all reasonable efforts to safeguard the user’s information, the user acknowledges that the use of the internet is not entirely secure and therefore, we cannot provide any guarantee concerning the security or integrity of any personal data transferred from the user, or to the user through the use of the internet.


7. GENERAL

7.1. Changes to the Privacy Policy

This Policy and the documents referred to in this Policy govern the entire relationship between the parties with respect to its subject matter. We shall have the right, at any time and at our sole discretion, to unilaterally modify or amend this Policy and the documents referred to in this Policy by posting such modified or amended text on the pages of the Site. The date of the latest version of the Policy is displayed at the top of this page. If we make material changes to this Policy and if We have your email address available, We will notify you of such changes at that address. We recommend that You check this Policy periodically for updates or changes. Any changes or amendments will be effective at the time the text is posted on the Site or/and when notice is sent to your email address. By continuing to use the Site and/or submitting information to us, you agree to be bound by the modified terms of this Policy.

7.2. Compliance with applicable legislation

We are committed to complying with applicable privacy and data protection laws and regulations designed to protect your personal information, including, but not limited to the Law on Protection of Personal Data 2018 and other applicable current or future regional and state privacy and data protection laws and regulations worldwide as they become effective.

7.3. Questions, problems, or complaints

Contact us support@ddl.com, if you have any questions, problems, or complaints regarding this Policy.
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