In accordance with Article 23 of the Law on Personal Data Protection (“Official Gazette of the Republic of Serbia”, no. 87/2018, hereinafter referred to as the “Law”) and the General Data Protection Regulation no. 2016/679 (hereinafter: “GDPR”), the Data Controller, CODIFYING doo Belgrade, Tetovska no. 42/14, registration number: 21875210, issues the following Notice on the processing of personal data under the name:

 

PRIVACY POLICY

 

The purpose of this Privacy Policy has been compiled to assist you to understand how IBDComfort application collect, use and disclose your personal  information as the Data Controller to ensure the realization and protection of the right to privacy of individuals registered on the application (hereinafter: “users”) and to inform them about their rights regarding the processing of personal data.

 

1. Data Controller

 

The Data Controller is CODIFYING doo Belgrade, Tetovska no. 42/14, registration number: 21875210 (hereinafter: “Data Controller,” “IBDComfort,” or “We”).

By accessing, browsing, or otherwise using the application made by IBDComfort, you acknowledge and consent to the collection and use of information as set forth in this notice of Privacy Policy. Please read this Privacy Policy carefully. Your use of this application constitutes your consent to this Privacy Policy. Do not use the application if you are unwilling or unable to consent to this Privacy Policy.

 

2. Personal data that We process

 

IBDComfort processes the following personal data:

  • First name and Last name
  • Date of Birth
  • Email address
  • Health-related information

 

3. Purpose and legal basis for data processing

 

Your personal data is processed solely to enable the use of the application and the functionalities and features it offers. Health-related data is used exclusively to personalize application features. Data is entered during user registration.

The processing of your data is based on your consent, provided at the time of registration in the application. Our application will process the personal data you provide only with your consent, otherwise the application will not process your data.

 

4. Transfer of personal data to another country and sharing with Third Parties

 

We use trusted third-party providers to host and process your data securely. Our app’s landing page is hosted on Hetzner Cloud, with servers located in Germany or other EU regions, and the app’s API and database are hosted on Amazon Web Services (AWS), which may involve servers located outside your country of residence.

By using our services, you acknowledge and agree that your data may be transferred to, processed, and stored on servers located in different countries, including countries that may not have the same data protection laws as your country of residence.

Your personal data will not be shared with third parties unless we are legally obligated to do so (e.g., in accordance with a judicial investigation, court order, or legal proceeding).

Our application does not use any form of cookies, although marketing or Google Analytics cookies may potentially be placed on the website www.ibdcomfort.com , which we will not directly set.

In general, we do not and will not share your personal identifiable information except as set forth in this Privacy Policy. We do not sell, transfer, and/or share your personally identifiable information with third parties for their own marketing purposes.

 

5. Data retention period and criteria for its determination

 

Data will be retained as long as you use the application. Upon withdrawal of your consent or account deletion, your data will be permanently deleted.

 

6. Rights of individuals whose data is processed

 

  • Right to information, access, and copy: You have the right to be informed about whether the Data Controller processes your personal data. If the Data Controller holds your data, they will be obligated to grant you access and provide a copy of it upon request.
  • Post-access rights: After accessing or receiving a copy of your data, you may request correction, supplementation, updating, deletion, or the cessation or temporary suspension of processing.
  • Right to data portability: You may request that the Data Controller transfers your personal data to another controller, if technically feasible, in a structured, machine-readable format.
  • Right to withdraw consent: You have the right to withdraw your consent at any time, after which the Data Controller must cease data processing.
  • Right to object: You may object to the processing of your personal data if you believe it is not in accordance with data protection laws. The Data Controller must cease processing unless it can demonstrate legal grounds that override your interests, rights, and freedoms.

Requests should be sent via email to [email protected] .

The IBDComfort application is not intended for use by persons under the age of 18 and the app features or content comply with the restrictions and regulations for minors regarding Children’s Online Privacy Protection Act in the USA and GDPR in European Union and rest of the Europe.

The Data Controller will respond to any request as quickly as possible not later than 30 days from receipt, in accordance with Article 21 of the Law and Article 12 of the GDPR for European Users.

Individuals may file a complaint regarding the processing of their personal data with the Commissioner for Information of Public Importance and Personal Data Protection.

 

7. Technical and Organizational Measures for Personal Data Protection

 

The Data Controller has implemented technical and organizational measures to ensure the security and integrity of personal data, protecting it from unauthorized access, malicious acts, loss, or disclosure to unauthorized third parties.

By accepting this Privacy Policy, you acknowledge and agree that your personal data will be processed by the Data Controller and accessed by employees and contractors of the Data Controller.

Individuals accessing personal data are obligated to keep it confidential and secure and are required to use the data only for the aforementioned purposes.

 

8. Links to Other Websites

 

The application may contain links to websites not owned or controlled by IBDComfort. We are not responsible for the Privacy Policies of these websites.

We do recommend reading the Privacy Policy of every website that collects personal data.

 

9. Access to Personal Information

 

If your personal information changes, you can correct or update it by making changes in the “User Account” section.

 

10. Security

 

We are committed to the protection of your personal information and in that manner we use industry-standard methods to protect your personal data during transmission and storage.

However, no method of data transmission over the Internet or electronic storage is 100% secure. Despite employing industry-accepted standards to protect your data, we cannot guarantee absolute security.

 

11. Business Changes

 

If IBDComfort undergoes a business change, such as a merger, acquisition, or sale of a significant portion of its assets, your personal data will likely be part of the transferred assets.

You will be notified of any major changes in the ownership or control of your personal data via email or an urgent notice on our website 30 days before the change.

 

12. Amendments to the Privacy Policy

 

We reserve the right to update this Privacy Policy occasionally. All changes will be published within the application, and significant changes will be communicated via email.

 

13. Contact Us

 

If you have any questions or suggestions regarding our Privacy Policy, you can email us at [email protected].

 

In Belgrade, December 9th 2024