Privacy Policy of Sinneo
1) Introduction. Joint SINNEO by this Privacy Policy defines which types of personal data it collects and processes during the browsing of the SINNEO's websites and, as well as the manner of handling and processing the personal data of persons subscribed for reception of information by SINNEO via page or via other pages of website based on address

2) Definitions. Certain terms used in this Privacy Policy have following meaning:
– „personal data" means any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
– „data subject" signifies an individual whose personal data are being processed;
– „processor" represents an individual or a legal person, or public authority which processes personal data on behalf of the controller;
– „processing of personal data" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (hereinafter: processing);
– „cookies" are text files stored locally in the user's browser, exchanged between the website and user's device as a short-term memory of user's activity on the website.

3) Information about Joint Controllers and contact person.
In relation to this Privacy Policy, as well as in accordance with provisions of the Act on personal data protection SINNEO, is considered as Controller of personal data of visitors of web pages of SINNEO.
The Data subjects may submit request for exercising their rights guaranteed by Act on personal data protection and other applicable regulations regarding data protection to Andrei Ilinskii, as a contact person for the data subjects, via email

4) What kind of personal data we collect. SINNEO collect email address as a personal data, which within itself can contain name and surname as personal data, depending on the manner on which email address is generated.

5) Legal grounds for collecting and processing personal data. Legal ground for collecting and processing of personal data is consent of data subjects, pursuant to Article 12 of the Act on personal data protection.

6) Purpose for collecting and processing personal data. Personal data is collected so we can enable usage of our website. Except in abovementioned purposes, we can process collected personal data, i.e., use them exclusively in situations and within a scope defined by the Act on personal data protection.

7)Visitors of our internet pages have the possibility to subscribe for receiving information (consultation) from SINNEO by submitting their email to us. In that case, SINNEO collects email address of such visitors which may contain name and surname as a personal data. Mentioned personal data are used only for the purpose of communication with persons subscribed for receiving information from SINNEO

8) Protection measures. SINNEO applies advanced technologies for the purpose of protection of your personal data. Your personal data is stored in a password secured data bases to which access is granted exclusively to specially authorized persons. Devices from which your personal data can be accessed are stored in a physically secured rooms with appropriate protection measures. Rs Consulting your personal data is used and processed exclusively by specially authorized members of SINNEO.
All processors of personal data with whom we cooperate are also obliged to apply all prescribed protective measures in accordance with signed contracts with controller and/or applicable regulations.
Although we put effort to protect your personal data, we cannot unconditionally guarantee safety of personal data that you deliver to us, so you are doing that at your own risk.

9) Personal data collected through consent of the data subjects are stored until consent is recalled. Personal data for which legal grounds for collection and processing is not consent of data subjects we store in periods prescribed by applicable regulations.

10) Data processors. SINNEO may, based on an agreement, hire third persons for processing personal data collected in accordance with this Privacy Policy. In that case, processor can only be a person that fully guarantees application of appropriate technical, organizational and measures regarding its personnel in a way that secures that processing is done in accordance with provisions of the Act and other applicable regulations and that it secures protection of rights of data subjects. This shall, for e.g., be the case when we hire IT company for provision of services, lease a server of organize automated sending of emails. Certain personal data, depending on the processor, i.e., location of the server on which we store personal data, can be stored outside of Republic of Serbia, but only within countries members of Council of Europe Convention for the Protection of Individuals with Regard to Automatic Processing of Personal Data, i.e., in countries or part of their territory for which EU has determined that they secure appropriate protection level.

11) Rights of Data subjects. Right of access. The data subject shall have the right to obtain from SINNEO confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipient to whom the personal data have been or will be disclosed; the envisaged period for which the personal data will be stored or the criteria used to determine that period; the right to request rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; the right to submit a complaint to the Commissioner; where the personal data are not collected from the data subject, any available information as to their source; and the existence of automated decision-making.

Right of rectification and completion. The data subject shall have the right to obtain without undue delay the rectification of inaccurate personal data concerning him or her. Considering the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to erasure of personal data. The data subject shall have the right to request erasing of personal data concerning him or her, if the requirements from Article 30 of the Act are fulfilled.

Right to restriction of processing. The data subject shall have the right to obtain restriction of processing of his/her personal data, if one of the requirements under Article 31 of the Act has been fulfilled.

The right to objection. The data subject shall have the right to object, at any time, to processing of his/her personal data, on grounds relating to his/her situation via email

The right to transfer personal data. The data subject has the right to receive the personal data concerning him or her, which he or she has provided to the SINNEO, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from SINNEO, if the requirements from Article 36 of the Act have been cumulatively fulfilled.
SINNEO shall, free of charge, provide information regarding the exercise of rights under Act on personal data protection relating to this Privacy Policy. Where the data subject's requests are manifestly unfounded or excessive, in particular because of their repetitive character, SINNEO can:
– charge a reasonable fee based on administrative costs, i.e. acting on the request;
– refuse to act on the request.

Automated decision-making and profiling. SINNEO does not exercise automated decision-making and profiling on its internet pages and while sending information to persons subscribed for its reception through our internet pages.

12) Cookie Policy. SINNEO on its internet pages uses cookies. Their purpose is to enable all functionalities of our internet pages, as well as to give our visitors better user experience.
During your first visit to our internet pages, we shall inform you that while using our pages you agree to use of cookies. You can, at any time, recall your consent for using of cookies.
Also, we have limited using of cookies to a minimum and on our web pages following categories of cookies are being used:
– Necessary cookies that enable proper functioning of our internet pages;
– Statistical cookies that help us to understand the manner on which you use our website and how to improve its functionalities to provide our visitors with better user experience (such as Google Analytics).
You can delete cookies from your device or disable their usage through your browser. Precise information on how to delete cookies you can find within your browser, as they depend on the type of browser you use.
On our web pages there are links to other web pages, as well as to LinkedIn as a social network. While visiting such web pages, please keep in mind that their Privacy Policy shall apply on such visit.

13) Contact info. If you have any questions or requests relating to processing of your personal data that you have made available to us, you can contact us via:
– email:

14) Commissioner for information of public importance and personal data protection. If you consider that we have breached your right to personal data protection, you can submit a complaint to the Commissioner via:
– email:

You can find more detailed information on the manner how to exercise right to personal data protection on the Commissioners' website
Also, if you consider that we have breached your rights to personal data protection, you can protect them in a court proceeding in accordance with the Act on personal data protection.

15) Entering into force of this Privacy Policy and its subsequent changes. This Privacy Policy enters into force on the day of its publication on our internet pages, having in mind the necessity that your rights are properly protected from the moment when our website starts functioning.
All potential changes and amendments to this Privacy Policy shall be published on our web pages before they enter into force, in order for you to be able to timely acquaint with its provisions.
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