1. INTRODUCTION
The privacy policy applies to the business of the company Comemorial doo Novi Sad, Narodnog fronta 10 (“operator”) in order to provide the service of keeping memories of important and beloved persons. All packages contain a memorial page with information about the deceased and the geo location of the grave site and a generated QR (Quick Response) for access to the memorial page which, depending on the package, is ordered from the operator or can be printed. Some packages also include the option to associate certain multimedia content with a memorial page. The Privacy Policy describes how we handle the personal data we collect when providing our services (“personal data”).
The collected data is protected from abuse, loss or unauthorized use, it cannot be disclosed, except when such an obligation is provided by law or on the basis of a court order.
The operator does not perform automated data processing, ie does not make decisions based on automated data processing.
The rules of this Privacy Policy apply to all sales collected and processed by the operator, which are provided for in section 2.
2.WHAT DATA DO WE COLLECT?
We collect personal data in order to provide our services. The legal basis for the collection and processing of personal data is the consent of the subject, ie the person who submits the data to the operator in accordance with this section. The data subject has the right to revoke consent at any time. Revocation of consent does not affect the validity of processing carried out on the basis of consent prior to revocation. If you choose not to provide us with the data we request from you, we will not be able to provide you with the services you request. Providing personal data is necessary in order to provide you with our services.
The data we collect are as follows: personal data of the user (“user”), personal data of the deceased person given by the user and personal data of the visitor of the site or page (“visitor”).
Personal data of the user are data that the user submits during the registration and opening of the user account, as follows: name and surname, address and country of residence and email address. All listed data is only available to the operator.
Personal data on the deceased person given by the user are: name and surname, date of birth, date of death and multimedia content. In addition to the above data, the user has the opportunity to enter text in the free fields with the data of their choice. All the above data may be available to the public after the publication of the memorial page.
The visitor’s personal data is the data that the visitor submits when typing a memory or a statement of condolence on the page created through the user’s account. Visitor’s data are: name and surname and e–mail address. In addition to the above data, the visitor has the opportunity to enter text in the free field with data of their choice. The data on the name and surname of the visitor and his message can be available to the public if the user of the account decides to post them, while the data on the e–mail address of the visitor are available only to the user and the operator.
The user bears full material and criminal liability for all actions that occur as a result of entering data through the user account, and this refers to personal data of the user, personal data of the deceased, data entered in the free field and multimedia content. If the content that he posts on the created page via the user account represents a copyright infringement, the user is considered fully responsible for the stated infringement.
The visitor bears full material and criminal liability for all actions that occur as a result of entering data on the page created through the user account, and this refers to the data he enters in the free field and the data he submits about himself as a visitor.
You may use some services without providing any personal information (for example, when searching the Comemorial site as an unofficial visitor).
The operator does not collect data on persons under the age of 21. People under the age of 21 cannot create a user account. The operator will make reasonable efforts to verify that the user is older than 21, but has no responsibility if the user has used false data. The user bears full material and criminal liability for entering data and for all actions that occur as a result of entering data on the deceased person under the age of 21 and for posting data on the visitor under the age of 21.
All collected data is stored permanently. The operator database is located in the Republic of Germany. By accepting this privacy policy, you agree that the data in the database may be transferred outside the borders of the Republic of Germany to any other country listed in article 64 paragraph 7 of the Law on Personal Data Protection of the Republic of Serbia.
Cookies policy. There is a use of cookies on our site, and for this reason we have a special act called the Cookies Policy.
The user can also open a user account via his Facebook or Google account. In that case, the operator does not have access to the data from the user’s Facebook or Google account in any way. Also, the operater is not responsible for any form of abuse of user data, ie submitted by the user, which is committed by any person (the user or a third party) through a Facebook account or this social network.
3. HOW DO WE USE YOUR DATA?
We use data we collect about you to provide the services refered in Chapter 1. The operator is not responsible for any abuse of data by third parties.
We may use your data to send you promotional materials or other information that we think may be of interest to you.
We may share your data with third parties when such an obligation is required by law. This refers to situations when we reasonably believe that sharing your data is necessary for the purpose of:
-performance or protection of the rights, privacy, security or property of the company and our employees;
-protection of privacy and security of users;
-protection against fraud or for risk management purposes;
-acting in accordance with the law or judicial or administrative proceedings in any
country; or
-acting in accornace with the orders of authorities.
4. HOW DO WE PROTECT YOUR DATA?
We use reasonable measures to protect your personal data from loss, theft and unauthorized use, disclosure or modifications.
We take reasonable steps to prevent unauthorized access to our online and computer systems by using measures such as firewalls, data encryption, antivirus programs, and restricted password access.
We train our employees to handle your data in accordance with the Privacy Policy and applicable laws.
However, the Internet is a risky area of information flow, so we cannot guarantee that your data cannot be hacked and abused by third parties. The operator is not responsible for these abuses.
5. HOW CAN YOU ACCESS YOUR DATA?
If you want to access, view, correct or update your personal data, and there is no system possibility to do it yourself through the site, you can contact us. When contacting us, provide your name and contact information (including your email address and address) and clearly state what data you wish to access, review, correct or update. We will act on your request as soon as reasonably possible. If we reject your request, we will give you an explanation why your request was denied.
Any person from whom personal data are collected and a person whose data are collected listed in Chapter 2 (“persons whom data refer to”), in accordance with the applicable regulations, shall have rights set forth below. In addition to the stated rights, the subject of data processing has other rights that are guaranteed by the applicable regulations.
The right to be informed
Person whom data refers to has the right to information and access to his data which is stored and processed by the operator.
The right to correct inaccurate personal data and to complement data
Person whom data refers to has the right to correct inaccurate data and to complement the data stored and processed by the operator.
The right to delete personal data
Person whom data refers to has the right to request the deletion of personal data that the operator keeps and processes about him, if the conditions in accordance with law are met.
The right to restrict processing
Person whom data refers to, has the right to request a restriction on the processing of all personal data that the operator keeps and processes about him, if the conditions in accordance with law are met.
The right to report related to the correction or deletion of personal data or the restriction of processing
The operator is obliged to inform the person whom data refers to about the measures taken regarding his request for correction, deletion or restriction of personal data processing.
The right to object
Person whom data refers to has the right to object to the operator in the event that his / her personal data is handled contrary to this Privacy Policy and applicable regulations.
The operator is released from any responsibility in terms of collected data and content in accordance with Chapter 2, and full material and criminal liability is borne by the persons who provided the operator with these data, primarily the responsible user and visitor, but also all third parties who illegaly entered the data. This applies to all personal data listed in Chapter 2, as well as to textual content in free fields and to multimedia content.
6. OTHER IMPORTANT INFORMATION
The operator has the right to change the Privacy Policy at any time. The date at the very end of the Privacy Policy is the date of the last update. All changes to the Privacy Policy become effective on the day of online publication.
If you share your data with social network service providers (including posting data through this service), these data may not be removed even after you close your account. If you close your account, the data about your account may be available to third parties for a certain period of time due to the way the data is stored on the
Internet.
If you provide us with any sensitive data, such as data about your racial or ethnic origin, religious or other beliefs, health condition, criminal record or trade union membership, you will be deemed to have given us the approvel to collect and manage this data in accordance with the Privacy Policy.
If you believe that we have violated data protection regulations, you can contact us to file complaints. When contacting, provide your name and contact information (including your email address and address) and clearly describe the allegations of your complaint. We will be forced to share your data with others who can help us
respond to your complaints. We will contact you within 7 days to inform you of the next steps in dealing with your complaint and to provide us with any additional information we need to review your complaint.
We will notify you of our decision as soon as reasonably possible and in any event within 30 days. If you are not satisfied with our answer, you can send your complaint to the Commissioner for Information of Public Importance and Personal Data Protection in the Republic of Serbia ( in serbian: Poverenik za informacije od javnog značaja i zaštitu podataka o ličnosti u Republici Srbiji), Bulevar Kralja Aleksandra 15, Beograd 11120, Srbija (https://www.poverenik.rs/en/).
7. HOW CAN YOU CONTACT US?
In order to fulfill any request pursuant to the Privacy Policy, and for any other reason, you may contact us at [email protected] .
Comemorial doo Novi Sad
Narodnog fronta 10
21000 Novi Sad
Last update: 16.09.2021