Privacy Policy

Controller

The controller of personal data is Ascalon Group d.o.o., Vojvode Putnika 34, Beograd, Registration no. 68417112, Tax ID 115503933. For any question about the processing of your data, or to exercise your rights, write to us at [EMAIL].

Who this policy covers

This policy explains how we process the personal data of website visitors, people who contact us, sellers and buyers of items of value and contact persons of our business clients, in accordance with the Serbian Law on Personal Data Protection (ZZPL).

When we build or maintain a system for a client that holds the data of the client's users, we process that data as a processor, only on the client's instructions and under a separate agreement with the client. This policy does not cover that processing.

Personal data we process

• Contact form and correspondence: full name, email address, phone number if you give it, the service you are interested in and the content of your message.
• Purchase and commission sale: full name, address, type and number of your identity document, a copy of the identity document with the data we do not need blacked out, the bank account for payment, details of the item and proof of ownership.
• Buying from our offer: full name, contact details, delivery address and payment details.
• Business clients: name, position and business contact details of contact persons.
• Website visits: the hosting provider automatically records technical data (IP address, time of access, browser type) for security and to keep the website running.

We do not process special categories of personal data (such as data on health or religious beliefs).

Purposes and legal basis

• Answering your enquiry: steps taken at your request before entering into a contract (Article 12(1)(2) ZZPL).
• Concluding and performing a purchase, commission, sale or IT services contract: performance of a contract (Article 12(1)(2)).
• Establishing the identity of the seller and the origin of the item, including keeping a copy of the identity document: our legitimate interest in preventing the sale of items of unknown or unlawful origin and in being able to prove an item's origin to the authorities (Article 12(1)(6)).
• Bookkeeping, invoicing and other legal obligations: compliance with legal obligations (Article 12(1)(3)).
• Security and proper operation of the website: legitimate interest (Article 12(1)(6)).

We do not use your data for direct marketing and we make no decisions based solely on automated processing, including profiling.

Do you have to give us your data

Sending data through the contact form is voluntary. The data needed for a purchase, commission or sale is required to conclude the contract; without it we cannot conclude it.

Retention

• Enquiries that did not lead to cooperation: up to 12 months after the last correspondence.
• Copy of the identity document and data on the item's origin: [ID COPY RETENTION, e.g. 5 years] from the date of the purchase or of taking the item on commission.
• Contracts, invoices and other accounting records: for the periods set by accounting and tax law.
• Technical data on website visits: for the short periods applied by the hosting provider.

When the period ends, the data is deleted or permanently anonymised.

Recipients and processors

We do not sell your data or pass it on for anyone else's marketing. Your data may be received only by:

• Cloudflare, Inc. (USA): website hosting and receiving contact-form messages;
• our email service provider: sending and receiving email;
• our accounting firm: bookkeeping;
• banks: payments;
• courier services: only the data needed for delivery, when we ship an item;
• the competent authorities: where the law requires it or on their lawful request.

Transfers outside Serbia

Cloudflare and our email service provider also process data outside the Republic of Serbia, including in the USA. Such transfers are made with appropriate safeguards under Article 65 ZZPL: [TRANSFER SAFEGUARD: e.g. standard contractual clauses - to be confirmed].

Data security

We apply technical and organisational safeguards: an encrypted connection (HTTPS), access to data only for staff who need it, and copies of documents kept under lock or in encrypted form.

Your rights

Under the ZZPL you have the right to:

• know whether we process your data and access it;
• have inaccurate data corrected or incomplete data completed;
• have your data erased where there is no longer a basis for processing it;
• restrict the processing;
• receive the data you gave us in a structured, machine-readable format (portability);
• object to processing based on legitimate interest.

Send your request to [EMAIL]. We answer without delay and within 30 days at the latest.

You also have the right to lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection, Bulevar kralja Aleksandra 15, 11120 Beograd, www.poverenik.rs.

Cookies

This website uses no cookies for tracking, analytics or advertising and loads no content from third-party services: fonts and all other resources are served from our own server.

Changes to this policy

We may change this policy. The current version is always on this page, with the date of the last update.