Privacy Policy
Effective as of December 26, 2024
Returning Point, with the registered seat at Cara Uroša no. 18, Belgrade (Stari grad), Republic of Serbia, CIN: 28331002, TIN: 112721838 (hereinafter: Returning Point) as a data controller, collects and processes Personal data in relation to interactions on our Websites and the use of our Service.
This Privacy Policy is applicable only to the use of our Websites located at https://tackapovratka.rs/en/ (Returning Point Website) and https://kutakzaroditelje.rs/ (Kutak za Roditelje Website). The use of other Returning Point services and websites is governed by separate privacy policies and not by this Agreement.
We respect and value your privacy, so we have taken the protection of Personal data seriously. For that reason, we created this Privacy Policy – to explain to you in a transparent and understandable way how we collect, share, and use your data, as well as how you can exercise the rights you have as a Data subject.
Please note that every term that is capitalized but undefined in this Privacy Policy has the same meaning as in our Terms of Use.
The Privacy Policy applies to all individuals who access our Websites, send us inquiries via Websites, email, or social media account, and engage our Service (as defined below). However, the Privacy Policy does not apply to information from which no individual can reasonably be identified (anonymized information).
This Privacy Policy, along with our Terms of Use and Cookie Policy, constitutes an Agreement that is binding on you. Therefore, we strongly suggest you read it carefully and get informed about the processing and protection of your Personal data.
In case you have any questions regarding this Privacy Policy, please contact us at info@tackapovratka.rs.
- Definitions
- Personal data we collect
- Personal Data We Collect, Why, and on What Ground
- Data subjects under the age of 15
- Usage of your personal data
- Who do we share your personal data with?
- Data Transfers
- Data subject’s rights
- Keeping your personal data secure
- Changes to our Privacy Policy
- Get in touch
- Definitions
When we say… |
We mean…
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“Consent” |
Your explicit consent to the processing of personal data. Persons who are 15 years of age or older may give free consent to the processing of their Personal data.
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“Cookies” |
Small pieces of code stored on your device (computer or mobile device). This information is used to provide you with certain functions, track your use of the Websites, and compile statistical reports on the website activity. Mention of Cookies also includes other similar technologies; more detailed information on what are they and how you can manage them, you can find in our Cookie Policy.
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“Data processor”
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Any natural or legal subject who processes Personal data on our behalf. We may use the services of various service providers to process your Personal data more effectively.
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“Data subject” or “you”
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Any natural person who shares their Personal data with Returning Point. |
“Data Protection Law”
| Serbian Law on Personal Data Protection adopted in November 2018, entered into effect on August 22, 2019 (harmonized with the GDPR).
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“Personal data” or “data” | Any information relating to an identified or identifiable natural person (Data subject);
Ø An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, identification number, location data, online identifier or to one or multiple factors specific to its physical, physiological, genetic, mental, economic, cultural, or social identity. Ø Data about a company or any legal entity is not considered to be personal data but acting on behalf of a legal entity may include sharing personal data.
Ø However, the information related to one-person companies may constitute Personal data when it allows the identification of a natural person. The privacy rules also apply to all personal data relating to natural persons in the course of professional activity, such as the employees of a company or organization, and business e-mail addresses like “firstname.surname@company.com”.
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“Processing”
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Any activity or set of activities performed on Personal data or sets of Personal data, whether by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
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“Service”
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Making available any content by us on our Websites. The Service does not include other services or websites that we provide. |
“Technical data” | Personal data such as Internet Protocol (IP) address, device type, unique device identification number, browser type, and broad geographic location (e.g. country or city-level location). |
“Usage data” | Information about how your device has interacted with our Websites, including the pages accessed and links clicked. |
“Websites”
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The websites owned by Returning Point, located at https://tackapovratka.rs/en/ (hereinafter: Returning Point Website) and https://kutakzaroditelje.rs/ (hereinafter: Kutak za Roditelje Website). |
- Personal data we collect
Data about you may be shared and collected directly from you or from third parties.
Under “data provided by you” we mean:
- Data collected voluntarily
We process your personal data when you contact us through our Websites, social media, email, etc. and intentionally share certain information with us through our Websites’ feature or direct correspondence. All personal information that you provide to us needs to be true, complete, and accurate, and you are obliged to notify us of any changes to such personal information.
- Data collected automatically when you access and use our Websites
Includes information such as:
- Your IP address,
- Device type,
- Unique device identification number,
- Browser-type,
- Broad geographic location (e.g. country or city-level location).
We may also collect information about how your device has interacted with our Websites, which includes the pages accessed and links clicked. Collecting this information enables us to better understand the interests of the visitors who visit our Websites, where they come from, and what content on our Websites is relevant to them.
This information is collected primarily by using cookies and similar tracking technology, as explained in more detail in our Cookie Policy.
- Personal data we collect about you from third parties
In some cases, we may obtain your personal data without you giving us such data directly. For example, we may collect information about Data subjects from LinkedIn to assess whether applicants for our events align with the profiles of our community, specifically if they are repatriates.
- Personal Data We Collect, Why, and on What Ground
3.1 Returning Point Website
DATA WE COLLECT | PURPOSE | LEGAL BASIS | RETENTION PERIOD
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Your first name, last name, email address, and other information you choose to share with us in your inquiry/ suggestion via our Returning Point Website’s Contact page, email provided on the Website, or otherwise. | To respond to your inquiries, as well as to take into account your suggestions. | Processing is necessary for the performance of the Agreement or entering into such Agreement with you. | If we do not have legal obligations or some other ground to retain your data as described in this Policy, we will delete them after 12 months from the response to your inquiry or suggestion. |
Your first name, last name, email address and LinkedIn profile. | To notify you of the MeetUp organized by Returning Point that we think would be the best fit for you. We collect information about your LinkedIn profile to assess whether you align with the profiles of our community, specifically if you are repatriate. Identifying repatriates ensures that participants can engage with like-minded individuals and maximize the value of the event. | Processing of you email address is based on your consent.
The processing of your first name, last name and LinkedIn profile is based on our legitimate interest in organizing events for our target audience, which also aligns with the legitimate interests of all attendees to participate in a community of individuals with shared experiences and goals. | We will keep you on our mailing list until you withdraw your consent. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on the consent prior to such withdrawal. You may unsubscribe from or mailing list at any time. If personal data is processed based on our legitimate interest, retention periods are determined in accordance with the purpose of data processing and the applicable statutory deadlines. |
Technical and Usage data are collected primarily by using cookies and similar tracking technology, as explained further in our Cookie Policy. | Collecting this information enables you to navigate through a website and use the different options or services that exist within it and enables us to better understand the visitors who come to our Websites, where they come from, and what content on our Website is of interest to them.
Additionally, we need to process this Personal data in order to prevent misuse and fraudulent behaviour on our Websites and thus to protect our association, but also our partners, and other Users. | Processing is: 1) necessary for the performance of the Agreement or entering into such Agreement with you (necessary cookies); 2) based on your consent (rest of the cookies); 3) based on our legitimate interest and the legitimate interest of our Users, i.e. for the safe usage and functioning of our Websites, protection of our association, but also the protection of our Users, which is essential to us. | Retention periods of data collected by using cookies and similar tracking technologies are explained in more detail in our Cookie Policy. If the processing is based on consent, data is retained until the withdrawal of your consent. You can withdraw your consent at any time at your cookie setting as explained in our Cookie Policy. The withdrawal of consent does not affect the lawfulness of the processing based on the consent prior to such withdrawal. If personal data is processed based on our legitimate interest, retention periods are determined in accordance with the applicable statutory deadlines. |
3.2 Kutak za Roditelje Website
DATA WE COLLECT | PURPOSE | LEGAL BASIS | RETENTION PERIOD
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Your first name, last name, email address, phone number, country, citizenship, partner’s citizenship, optionally child’s age and other information you choose to share with us in your question via our Kutak za Roditelje Website’s questionnaire. | To respond to your questions. | Processing is necessary for the performance of the Agreement or entering into such Agreement with you. | If we do not have legal obligations or some other ground to retain your data as described in this Policy, we will delete them after 12 months from the response to your inquiry or suggestion. |
Your first name, last name, email address, and other information you choose to share with us in your inquiry/ suggestion via our Website’s Contact page, email provided on the Websites, or otherwise. | To respond to your inquiries, as well as to take into account your suggestions. | Processing is necessary for the performance of the Agreement or entering into such Agreement with you. | If we do not have legal obligations or some other ground to retain your data as described in this Policy, we will delete them after 12 months from the response to your inquiry or suggestion. |
Your first name, last name, email address, optionally phone number and other information you choose to share with us in your suggestion via our Website’s form. | To take into account your suggestion for a place to spend quality time with children in Serbia. | Processing is based on your consent. | We will keep your information until you withdraw your consent, but not longer than 12 months from the receipt of your suggestion. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on the consent prior to such withdrawal. |
Technical and Usage data are collected primarily by using cookies and similar tracking technology, as explained further in our Cookie Policy. | Collecting this information enables you to navigate through a website and use the different options or services that exist within it and enables us to better understand the visitors who come to our Websites, where they come from, and what content on our Website is of interest to them.
Additionally, we need to process this Personal data in order to prevent misuse and fraudulent behaviour on our Websites and thus to protect our association, but also our partners, and other Users. | Processing is: 1) necessary for the performance of the Agreement or entering into such Agreement with you (necessary cookies); 2) based on your consent (rest of the cookies); 3) based on our legitimate interest and the legitimate interest of our Users, i.e. for the safe usage and functioning of our Websites, protection of our association, but also the protection of our Users, which is essential to us. | Retention periods of data collected by using cookies and similar tracking technologies are explained in more detail in our Cookie Policy. If the processing is based on consent, data is retained until the withdrawal of your consent. You can withdraw your consent at any time at your cookie setting as explained in our Cookie Policy. The withdrawal of consent does not affect the lawfulness of the processing based on the consent prior to such withdrawal. If personal data is processed based on our legitimate interest, retention periods are determined in accordance with the applicable statutory deadlines. |
We do not process data outside the specified purposes, and, especially, we do not:
- Sell any kind of personal data,
- Disclose this information to other marketers,
- Provide your personal information to any third party individual, government agency, or company at any time unless strictly compelled to do so by law or in accordance with section 6 of Privacy Policy.
- Data subjects under the age of 15
Our Websites are not intended for minors, and we do not knowingly collect data relating to a person younger than 15. If you are under the age of 15, please do not provide any personal information about yourself to us. If we detect that we have collected personal information from a person under the age of 15, such information will be deleted promptly. If you believe we have collected personal information regarding a child under the age of 15, please contact us at info@tackapovratka.rs.
- Usage of your personal data
None of your personal data will be used by Returning Point, unless we have your consent or if some other legally valid reason applies. Your personal data will be used only for the purposes we collected it for, and only when we have a reasonable and lawful basis to do so.
In order to achieve the highest level of personal data security, our staff is legally bound by the professional secret. Furthermore, we use adequate legal, technical, and organizational measures to prevent any disclosed information is revealed outside the legal purpose for which it was collected.
- Who do we share your personal data with?
To be able to perform some processing activities, we may require additional support from external processors. In such situations, Returning Point uses information audits to identify, categorize, and make records of all personal data that is processed outside of Returning Point – that way, all the information, processing activity, processor, and legal basis are recorded, reviewed, and easily accessible.
Such external processing may include (but is not limited to):
- Legal Services,
- Human Resources,
- Marketing Services.
We may occasionally share personal data with IT service providers located in Serbia to ensure the proper functioning, maintenance, and security of our IT systems.
We may be legally required to share certain information, including your personal data, with e.g. public authorities or governmental bodies; in such cases, we will not require your further consent in order to share your personal data in such circumstances.
This is the list of processors with whom we share your personal data:
PROCESSOR | ROLE | SEAT |
UNITED INTERNET DOO BEOGRAD | Data storage / Hosting providers | Serbia |
Google Inc. | Analytics | United States of America |
Social Networks
Returning Point collects and processes Personal data through user interactions on social networks such as Facebook, LinkedIn, Instagram, and YouTube. Returning Point or responsible individuals appointed by Returning Point have access to messages and/or posts on these social networks. However, personal data collected through these interactions, especially those in messages directed to Returning Point, are not stored in other locations or processed further, except for purposes outlined in this privacy policy.
Returning Point uses its business profiles on services like Facebook, LinkedIn, Instagram, and YouTube. You can review their privacy policies or privacy statements, as well as how they use your personal data, through the links provided below.
Returning Point cannot influence the privacy policies of social network service providers, which act as independent data controllers. If you have questions regarding data collection and processing by Facebook, YouTube, LinkedIn, and/or Instagram, or if you wish to exercise any of your rights under the Data Protection Law, please contact:
Company | Contact Information | Details |
Facebook | Whenever an individual is logged into Facebook and accesses the Website simultaneously, Facebook will receive information about this via the Facebook component, regardless of whether the individual clicks on the Facebook component. If an individual does not wish to transmit such information, they can prevent this by logging out of their Facebook account before accessing the Website. | |
YouTube | YouTube or Google will receive information through the YouTube component that an individual has visited the Website if they were logged into YouTube during the visit, regardless of whether they clicked on a YouTube video. If you wish to prevent such data transfer, you can log out of your YouTube account before opening the Website. | |
Instagram | The same terms apply as for Facebook for users logged into their Instagram accounts. | |
(LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland) | When an individual is logged into LinkedIn and accesses the Website simultaneously, LinkedIn will receive information through the LinkedIn component, regardless of whether the individual clicks on the LinkedIn component. If you wish to prevent this information from being transmitted, you can log out of your LinkedIn account before accessing the Website. |
- Data Transfers
We may transfer your personal data to countries other than the one you reside in. In these cases, we will transfer your personal data only:
- To the countries within the EEA;
- To the countries which do not form the EEA but are considered to ensure an adequate level of protection;
- To the countries which do not belong to those specified under items 1. and 2, but only by applying the appropriate safeguard measure in accordance with the Data Protection Law (for example, applying standard contractual clauses).
We use servers located in the Republic of Serbia and the EEA (Netherlands).
- Data subject’s rights
As a Data subject whose personal information we hold, you have certain rights under the Data Protection Law. This Section of our Privacy Policy should provide you with general information and an explanation of these rights.
Right to withdraw the Consent
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If you have provided your consent to the collection, processing, and transfer of your Personal data, you have the right to withdraw your consent – fully or partly.
Once we have received a notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented, unless there is another legal ground for the processing.
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Right to access
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You can send us a request for a copy of the Personal data we hold about you.
We have ensured that appropriate measures have been taken to provide such a copy in a transparent and easily accessible form, using clear and plain language.
Such information is provided in writing free of charge. It may be provided by other means when authorized by the Data subject and with prior verification as to the subject’s identity.
Information will be provided to the Data subject at the earliest convenience, but at a maximum of 30 days from the date the request was received. Where the retrieval or provision of information is particularly complex or is subject to a valid delay, the period may be extended by two further months where necessary.
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Right to rectification
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If the Personal data we have about you is incorrect, you have the right to request that we correct those data. In such a case, we will rectify the error within 30 days and inform any third party of the rectification if we have disclosed the Personal data in question to them.
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Right to be forgotten
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You have the right to request from us that your Personal data be deleted in these situations: – The personal data are no longer needed for the purpose for which they were collected; – You have withdrawn your consent (where the processing was based on consent); – You have objected to the processing and no overriding legitimate grounds are justifying us processing the personal data; – the Personal data was being unlawfully processed; or – the Personal data has to be erased for compliance with a legal obligation.
However, this right does not apply where, for example, the processing is necessary to comply with a legal obligation, or for the establishment, exercise, or defence of legal claims.
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Right to the restriction of processing
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You can exercise your right to the restriction of processing if:
– the accuracy of the Personal data is contested, – the processing is unlawful, but you do not want the data erased, – we no longer need the Personal data but you require the data for the establishment, exercise, or defence of legal claims, – you have objected to the processing, but the verification of whether the legitimate reasons of the data controller override those of the Data subject is pending. |
Right to data portability
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In case you have provided your Personal Data to us, and that data is processed using automated means, you have the right to ask us for a copy of such Personal Data, as well as to have those data transmitted to a third-party data controller. |
Right to object
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You have the right to object to using your Personal Data in case processing is based on our legitimate interest, as well as if the processing is performed with a purpose of direct marketing, which includes profiling. |
Right to Lodge a Complaint
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If you have any questions or requests regarding your personal data, please contact us at info@tackapovratka.rs, and we will respond as soon as possible, but no later than 30 days.
If you are not satisfied with our response, you can also contact the competent supervisory authority in the country where you reside or the Commissioner for Information of Public Importance and Personal Data Protection, Bulevar kralja Aleksandra 15, 11120 Belgrade, email office@poverenik.rs. |
To exercise any of these rights, please contact us at info@tackapovratka.rs.
- Keeping your personal data secure
Returning Point has implemented appropriate technical and organizational measures to protect the personal data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data.
However, please note that no method of transmission over the Internet or method of electronic storage is absolutely secure. For that reason, we cannot guarantee its 100% security or confidentiality.
- Changes to our Privacy Policy
Returning Point reserves the right to change and update this Privacy Policy periodically at its sole discretion.
If we have the possibility to inform you (via email or in a similar manner), we may send you the notice regarding the upcoming changes. In any case, a notice of each change will be published on our Websites. Therefore, please review our Privacy Policy from time to time, to make sure you are familiar with the current version.
Please note that any change shall enter into force after being published on our Websites. If you do not agree to our Privacy Policy, please stop using our Websites immediately.
- Get in touch
If you want to exercise any of the rights that you have as a data subject, or you have a question for us regarding this Privacy Policy, please contact us via our general contact email address: info@tackapovratka.rs or our general contact phone number: +381 64 400 6313.