I INTRODUCTION
Enuma Elish doo (hereinafter referred to as “Enuma”) is the controller of personal data and it processes the personal data in accordance with Law on personal data protection („Official Gazette RS“, no. 079/08 from 23.12.2008, 070/09 from 21.10.2009, 044/12 from 09.08.2012, 022/17 from 03.04.2017), (hereinafter referred to as “the Law”).
Enuma processes personal data in a legal, transparent and fair manner.
Enuma is carrying out only necessary data processing, and in order to implement the contract concluded with the data subject (eg clients, potential clients, hired associates, etc.), when the processing is required by the relevant legislation and represents a legal obligation of Enuma as a controller, when processing is necessary to achieve the legitimate interest of Enuma but only in cases where that interest prevails over the interest of the data subject, as well as processing performed on the basis of explicit and freely given consent of the person to which the data relate.
Enuma processes personal data for purposes that are specifically determined, explicit, justified and lawful. Personal data may no longer be processed in a manner inconsistent with those purposes.
In obtaining personal data, Enuma adheres to the principle of a minimum amount of data, so only those personal data that are necessary to fulfill the purpose for which they are processed are collected from the data subjects. In case additional personal data are necessary, they are obtained with the consent of the data subject.
Enuma ensures the accuracy of personal data by applying technical and organizational measures and periodically updating the data.
The deadlines for data retention are determined in Enuma’s internal acts in such a way that the data are retained for the period necessary to achieve the purpose of processing and is in accordance with legal requirements.
Enuma respects the principle of integrity and confidentiality of personal data. Enuma has implemented technical and organizational measures for the protection of personal data, following legal provisions, good business practice and internationally recognized standards.
Enuma may hire a processor for the processing of personal data on the basis of a contract which, among other things, regulates the duties of the processor with regard to the protection of personal data.
II SCOPE
This Privacy Notice applies to all personal data of Enuma’s Client that Enuma processes or determines the purpose and manner of processing, as well as to other persons listed in this item.
The Privacy Notice applies to all services and products of Enuma that include the processing of personal data. If the basis for processing is consent, the last expression of the will of the data subject, by which that person gives consent for the processing of personal data, applies to all services and products of Enuma used by that person.
The Privacy Notice is primarily intended and refers to:
1. Natural persons who submit a request or use the services and products of Enuma (Clients):
2. Natural persons interested in using the services and products of Enuma (Potential Clients),
3. Other natural persons whose data Enuma obtains during its operations in accordance with applicable legal regulations.
The Privacy Notice does not apply to anonymized data, i.e. to data on the basis of which the identity of a person is not directly or indirectly identifiable. Anonymized data is data that has been changed in such a way that it cannot be linked to a specific natural person and therefore, in accordance with the applicable regulations, it is not considered personal data.
Enuma processes personal data for different purposes, and the means of collection, the legal basis for processing, use, disclosure, and retention periods may differ depending on the purpose.
III HOW AND WHAT TYPES OF PERSONAL DATA DO WE COLLECT
Enuma collects personal data in the following ways:
1. Directly from the Client or Potential Clients, by direct delivery by the Client and / or Potential Client (such as when submitting a request for service at points of sale, during communication of the Client / Potential Client with the Contact Center or through the website and social networks, when filing an objection and the like).
2. Automatically when using Enuma’s products and services, if it is necessary for the Client / Potential Client to enter their data in order to use the appropriate product and/or service of Enuma.
3. From publicly available sources such as, for example, data from publicly available services.
A precondition for any collection of personal data is the existence of an appropriate legal basis in accordance with the Law.
Enuma collects and processes following data:
· Data on visits to our portals and mobile apps and information provided by Clients and / or Potential Clients by filling in the appropriate forms on our website, including but not limited to: name, surname, address, mobile phone number, landline number and email address;
· Personal and financial data provided by our Clients and / or Potential Clients necessary for approval and/or purchase of products and services of Enuma or a third-party which uses Enuma’s digital sales services
· Mobile Device specific data
o Geo-Location Information - we may request access or permission to and track location-based information from your mobile device, either continuously or while you are using the mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
o Mobile Device Access - we may request access or permission to certain features from your mobile device, including your mobile device’s storage. If you wish to change our access or permissions, you may do so in your device’s settings
o Push Notifications - we may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
· Information contained in the records on communications and correspondence in situations of establishing contact by the Client, Potential Clients and other natural persons, including recordings of conversations with the Contact Center, written or electronic communication;
· Data of Clients, Potential Clients and / or other natural persons from surveys used for research purposes, if the persons wish to be surveyed;
· Information that Enuma collects and processes for the purposes of direct marketing and profiling, based on the freely given consent of the data subject;
Other personal data for which there is a legal basis for their processing in accordance with the law.
IV FOR WHICH PURPOSES DO WE USE THE COLLECTED PERSONAL DATA
Enuma processes the personal data of the data subject only when such processing is lawful. Processing is legal in the following cases:
1. Processing is necessary for the execution of the contract concluded with the data subject or in order to take action at the request of the data subject prior to the conclusion of the contract.
2. Processing is necessary in order to comply with the applicable legal regulations according to which Enuma is obliged to act, especially those that regulate banking operations and the implementation of payment operations services, as well as European legislation, primarily the obligation to report, check clients (prevent money laundering) and risk management. Based on a written request based on applicable legal regulations, Enuma is obliged to provide access to certain personal data of the Client/data subject to the competent state bodies (eg courts, police, etc.) in certain situations.
3. Processing is necessary in order to achieve the legitimate, law-based interests of Enuma or a third party, except when those interests are stronger than the interests or fundamental rights and freedoms of data subjects that require protection of personal data, especially if the data subject relations are minors.
4. The data subject has given consent for the processing of his / her personal data for one or more specially specified purposes, whereby that consent must be provable and voluntary, written in easy-to-understand language and the data subject has the right to withdraw his consent at any time.
5. Processing is necessary for the vital interests of the data subject or another natural person.
6. Processing is necessary for the purpose of performing activities in the public interest or exercising the legally prescribed powers of Enuma.
V AUTOMATED PROCESSING
Decision-making based on automated data processing, including profiling, is carried out in accordance with:
1. applicable laws;
2. fulfillment of contractual obligations;
3. with the explicit consent of the data subject;
4. the legitimate interests of Enuma.
In accordance with the Law, Enuma enables data subjects to exercise the right to object to automated processing, including profiling. The complaint can be filed either in relation to the initial or further processing, at any time and free of charge.
VI WHO HAS ACCESS TO YOUR PERSONAL INFORMATION AND TO WHOM CAN IT BE PASSED ON?
Only employees of Enuma, as well as hired associates have access to personal data in accordance with the tasks they perform on the basis of appropriate authorizations determined by Enuma and only to the extent necessary, with the obligation to act in accordance with Enuma’s regulation which relates to personal data protection.
Personal data are available to third parties outside Enuma only in the following cases:
1. If there is a legal obligation or explicit authority under the law (eg a court request);
2. If a third party or subcontractor (processor) is engaged to perform certain tasks, whereby that processor acts exclusively in accordance with the order of Enuma, and Enuma ensures all data protection measures as if it performs these tasks independently;
3. Affiliated companies of Enuma provided that there is a legal basis for such transfer or access (consent of the person or legitimate, law-based interest);
4. If the data need to be forwarded for the purpose of performing the contract;
5. Other persons outside Enuma for whom there is the explicit consent of the data subject.
Enuma processes your personal data in Montenegro or in other countries or international organizations in accordance with the Law on Personal Data Protection.
VII HOW DO WE PROTECT YOUR PERSONAL DATA?
Personal data are treated as a business secret of Enuma and are accordingly classified as confidential. In accordance with their classification, adequate protection measures are applied to them, which protect this data from injury, unauthorized access, accidental loss, destruction, damage, and any other security threat. For these purposes, technical and organizational measures are applied, such as control of access rights, establishment and implementation of information security policy and other related internal acts, establishment of segregation of duties, establishment and enforcement of confidentiality and compliance with the law of all third parties entitled to access personal data in Enuma’s information system, application of methods for monitoring access and activities in information systems, as well as application of software solutions for the protection of information resources.
In the event of a breach of personal data that results or may result in accidental or intentional destruction, loss, alteration or unauthorized disclosure of personal data during their processing, which may pose a high risk to the rights and freedoms of data subjects, Enuma shall immediately upon learning of such violation, without undue delay, notify the Agency for Personal Data Protection and Free Access to Information and the data subject in a clear and understandable manner with a description of possible consequences and a description of measures taken. In the event of a breach of personal data, Enuma shall immediately take appropriate measures to prevent further damage to the rights and freedoms of the data subject and to reduce the consequences of that breach.
VIII WHAT RIGHTS DO YOU HAVE IN RELATION TO YOUR PERSONAL DATA THAT WE PROCESS?
Clients, Potential Clients and other persons to whom personal data relate may exercise the following rights:
1. The right to access personal data – the applicant for the exercise of this right has the right to obtain information on the existence of processing of personal data relating to him, the purpose of processing, the type of personal data being processed, recipients or categories of recipients personal data are disclosed or may be disclosed, on retention periods, on the existence of the right to request correction or deletion of personal data, ie the right to limit the processing of such data, on the existence of the right to file a complaint.
2. The right to correction of personal data – the right to request the correction of inaccurate personal data, as well as the right to supplement incomplete data.
3. The right to restrict the processing of personal data in the cases when the accuracy of personal data is disputed, Enuma will temporarily limit the processing for a period sufficient to verify the accuracy of personal data and when there is no legal basis for the processing of personal data, and the data subject opposes the deletion of data in order to submit the realization or defense of legal claims.
4. The right to object refers to the right of a person to submit at any time an objection to Enuma on the legality of the processing of his / her personal data established on the basis of the appropriate legal grounds for processing.
5. The right to erasure (“right to be forgotten”) may be exercised in cases when the personal data have been processed illegally or there is no legal basis for the processing.
6. The right of a person to data portability means the right of a person who has submitted his personal data to Enuma in a structured, commonly used and electronically legible format, received by Enuma, as well as the right to transfer such data from Enuma to another controller. consent, is performed on the basis of a contract or in accordance with the Law on Personal Data Protection, and if the processing is performed automatically.
7. The right to revoke consent may be exercised in anytime. The consent for the processing personal data given by the data subject is voluntary and may be withdrawn at any time.
IX HOW CAN YOU EXCERCISE YOUR RIGHTS
You can exercise your rights regarding the personal data that Enuma processes. All additional questions related to the processing of your personal data, as well as questions related to the exercise of your rights, you can send to:
E-mail: info@enuma.me
X FILING A COMPLAINT TO THE SUPERVISORY BODY
The supervisory body for the protection of personal data in Montenegro is the the Agency for Personal Data Protection and Free Access to Information (https://www.azlp.me/me/kontakt)
The person to whom the personal data refer has the right to file a complaint to the Agency if he / she considers that the processing of his / her personal data by Enuma is contrary to the provisions of the Law.
The data subject has the right to judicial protection if he considers that, contrary to the Law, the controller or processor has violated the right prescribed by the Law by processing his personal data.
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