Privacy Policy

In this document we will explain the privacy practices and personal data protection issues in relation to the IT services we provide to our clients, which includes (but is not limited to) our software search platform “Athena XAI” (which may include “Omnispect Search” and/or “Category Navigation” and/or “Visual Search” and/or “Product Recommender” and/or “Analytics” and/or “AI-BI” and/or any other product from the Athena XAI platform yet to come), as well as in relation to other aspects of our business, as implemented by Syncit Group d.o.o. Beograd-Novi Beograd, Bulevar Mihaila Pupina 115b, 11070 Novi Beograd (“Syncit Group” or “we”).

Syncit Group makes sure that the processing of personal data carried out by Syncit Group (including via Athena XAI) is fully compliant with the best legal standards, especially those contained in the General Data Protection Regulation (GDPR). As a Serbian company, Syncit Group is also acting in accordance with the Serbian Personal Data Protection Act (PDPA). All terms in this policy shall be interpreted as in the GDPR.

Which data do we process?

Syncit Group collects and processes personal data in the capacity of the controller or the processor, as applicable, depending on the purpose for which personal data are collected and used, as follows:

1. In the situation where the personal data of the client’s website and mobile application visitors and users (as applicable) are processed as part of our service (which includes Athena XAI usage operations), Syncit Group has the position of a data processor. Processing of any online identifiers (e.g. cookie identifiers) of website visitors and other users is limited to what is strictly necessary for purposes of provision of services to our clients, including (if applicable) conducting Athena XAI. Personal data collected from a client’s website or mobile application visitor or user will not be used for any other purpose except for the provision of services to the client, including (if applicable) the provision of Athena XAI service to that particular Syncit Group client. 
2. In the situation when personal data are collected by Syncit Group from a client, business partner or supplier in order to enter into a contractual relationship with that client, business partner or supplier, or to perform a contract entered into with them, Syncit Group has the position of a data controller. Personal data collected in the context of Syncit Group’s relationship with its clients, business partners or suppliers are processed solely for the purpose of the optimal fulfillment of the contracts entered into with the client, business partner or supplier, based on our legitimate interest, and are kept to a minimum required for this purpose (name, position, contact details, etc.). These data are deleted after the expiry of the relevant statute of limitation periods.
   
   Syncit Group also acts as a data controller regarding the personal data collected through its websites and mobile applications (contact and application forms, chatbots, etc.). Depending on the concrete contact or application form, we might collect different types of data (name, last name, email address, position, data contained in a CV, text entered into the contact or application form, etc.).
   
   We collect such personal data in order to answer your inquiries and applications, for the purpose of potentially entering into a contractual relationship with you. We retain this data for as long as required to answer your inquiries and applications or to complete the negotiations on our potential relationship.

What are your rights if you are a visitor or user of a website or a mobile application (as applicable) of our client that is using Athena XAI, or on behalf of which we process personal data?

In this situation, our client is the controller of your data, so you can contact the respective client for any matters regarding the processing of your personal data.

What are your rights if we are the data controller?

As a person who is related to our client, business partner or supplier, or whose personal data we collect through our website or mobile application, you have the right to submit the following requests with regard to your personal data:

• Right of access to your personal data (Art. 15 GDPR and Art. 26 PDPA);
• Right to rectification of inaccurate data (Art. 16 GDPR and Art. 29 PDPA);
• Right to erasure of personal data (Art. 17 GDPR and Art. 30 PDPA);
• Right to restriction of processing of personal data (Art. 18 GDPR and Art. 31 PDPA);
• Right to data portability (Art. 20 GDPR and Art. 36 PDPA);
• Right of objection (Art. 21 GDPR and Art. 37 PDPA).

These rights might be restricted or denied depending on the rules set out in the applicable laws, including GDPR and PDPA.

Under the conditions set out in the applicable law, you also have the right to lodge a complaint with a data protection supervisory authority:

Commissioner for Information of Public Importance and Personal Data Protection
15, Bulevar kralja Aleksandra str, Belgrade 11120
Tel: +381 11 3408 900
Fax: +381 11 3343 379
Email: о[email protected]

Where do we transfer data?

Clients’ data are stored in the EU and the United States of America, depending on the instructions by our clients.

For our contract management and communication purposes, we use Google Workplace services and servers, as well as local servers and computers in the Republic of Serbia. Our chatbot is powered by Meta (Facebook), which means that the data you submit through it may be transferred across the globe, in accordance with their data privacy policies and practices.

Any personal data we process are accessed by our staff in the Republic of Serbia, regardless of whether we are a controller or processor. Any personal data transfer from the EU to the Republic of Serbia (and onward transfers to our subprocessors, if applicable) shall be governed by the Standard Contractual Clauses used in the EU.

With whom do we share personal data?

We don’t sell, share, or lend any personal data. This is the case with both clients’ data and the data of visitors and users of clients’ websites and mobile applications, as well as the data of persons who contact us through our websites or mobile applications.

We might, however, use another processor in order to provide our services.

If you are using our chatbot, please be aware that the data submitted through it is shared with Meta (Facebook) and consult their data privacy policies and practices.

How can I contact Syncit Group?

For all information regarding our processing of personal data, you can write to: [email protected]

LAST UPDATED: 23/11/2022