Privacy Policy

In order to ensure the protection of personal data, we take care of the security of your personal data. This Privacy Policy transparently and comprehensively informs you about the collection, use, nature, and scope of processing your personal data by ICT Hub d.o.o. Belgrade, Kralja Milana Street No. 10, Registration Number: 20388307, when we process your personal data as the data controller (hereinafter referred to as “ICT HUB” and/or “we,” “our,” “us,” “ours,” “our,” “our,” “ours,” and all other personal and possessive pronouns that refer to ICT HUB, i.e., SME HUB).

This Privacy Policy provides information about all data we collect about you, especially the data we collect when you access our website www.smehub.rs.

Personal data includes any information related to a natural person whose identity is determined or determinable, directly or indirectly, in particular by an identifier such as name or identification number, location data, an online identifier, or one or more factors specific to their physical, physiological, genetic, mental, economic, cultural, or social identity (hereinafter “PD”).

The legal framework for the regulation of personal data protection is the Law on Personal Data Protection (“Official Gazette of the Republic of Serbia,” No. 87/2018) (hereinafter the “Law”). PoL within ICT Hub d.o.o. is protected based on the Regulation on the Protection of Personal Data of ICT Hub dated March 15, 2022.

If our website contains links to other websites, we inform you that we are neither aware of nor responsible for the ways in which the entities managing those websites collect and process personal data, and therefore, we cannot be held responsible for the protection of your privacy on those websites.

Methods of collecting PD and legal basis for PD collection

All information we collect is obtained directly from you when you access the SME HUB website, for example, when you:

Fill out or use any forms on the website (e.g., “Contact,” application for “Become a Supplier”)
or when you provide us with other information in this or a similar manner.

All your personal information is treated as confidential, and ICT Hub/SME HUB stores it in an appropriate manner.

In accordance with the applicable legislation governing PoL protection, we may process your PoL based on the following legal grounds:

When processing your personal data is necessary for the performance of legal agreements you enter into with ICT Hub or SME HUB.
When processing your personal data is necessary to fulfill certain legal obligations.
When we have a legitimate interest in processing your data, except when your interests or fundamental rights and freedoms outweigh those interests.
When you have given us consent to process your personal data for a specific purpose, and you have the right to withdraw this consent at any time.

It is mandatory to provide only those PD that we collect to fulfill certain legal obligations.

Disclosure of PD based on all other legal grounds is voluntary, but we would like to inform you that if you choose not to disclose this data to us, in certain situations, we may not be able to proceed with potential legal transactions in which you would be involved.

Please note that all the mentioned legal grounds apply depending on the purpose for which we collect your data, and we will inform you about this in each specific case.

Data collected

ICT Hub/SME HUB collects several categories of personal data, depending on the specific user’s request.

When contacting ICT Hub/SME HUB – various types of inquiries (via email, phone, contact form, or through social media).

Depending on the way you contacted us and the type of inquiry, we may collect your data such as name, surname, phone number, email address, and other information related to your inquiry.

Processing purpose:

Applying for “Become a Supplier” to enter the selection process for small and medium-sized enterprises to participate in the SME HUB program.
Sending inquiries for collaboration or contacting through the contact form for potential cooperation.

Legal basis for processing: Consent of the data subject.

Data retention period: During the provision of services for which personal data is processed, and after that period, as long as there are legal obligations for the data controller, but no later than the withdrawal of consent or the exercise of the right to delete personal data.

Protection measures:

Personal data is stored in a database with restricted access, and passwords for accessing these databases are regularly updated. Individuals who access these databases have a specific obligation to keep business secrets, including personal data, and all personnel with access to such personal data have undergone training in data protection.

Transfer of data to another country or international organization: ICT Hub/SME HUB does not transfer personal data to other countries or international organizations.

Website visit:

With your consent, we track your behavior as a user of our website www.smehub.rs, which includes the following:

Domain and IP address,
Type of browser and operating system used to access our site,
Time of access and duration of the visit,
Pages visited.

If you have linked to our portal from another website, we collect the address of that website. Additionally, we process your data when you visit our website, use our applications, and other platforms. During this process, various data is exchanged between your device and our server, which may include personal data. The data collected in this manner is used, among other things, to optimize our website or display advertisements in your device’s browser and for statistical analyses of our pages’ usage to improve the quality of our service.

When you visit our website, your device’s browser automatically and without your action sends the following information to our website’s server:

IP address of the device from which the query was sent and which has access to the internet.
Date and time of access.
Name and URL of the downloaded file.
The website/application from which access was made (referrer URL).
Browser you are using and, if necessary, the computer’s operating system that supports the internet, as well as your provider’s name.

The mentioned data is temporarily stored by the server in a log file for the following purposes:

Ensuring the establishment of an uninterrupted connection.
Ensuring comfortable use of our website/application.
Evaluating the security and stability of the system.

The legal basis for processing the IP address is the consent of the data subject. The consent is obtained through a notice regarding the use of “cookies.” During each visit to the website, you will have the option to refuse consent, in which case your personal data will not be processed, but this may restrict your access to the website. We do not transfer this data to third parties. The data is stored temporarily and automatically deleted afterward.

OTHER FORM OF PROCESSING

Use of Cookies

HTTP cookies (hereinafter referred to as “cookies”) are pieces of information collected based on the user’s access point – IP address, used by ICT Hub/SME HUB to customize the content of services or information society services (hereinafter referred to as “services”) according to access points, i.e., IP addresses.

“Cookies” are text files stored on the user’s computer when accessing the service through the IP address or access point. After accepting “cookies” when accessing the service, they are used to customize the content offered by such a service.

A user who does not wish to use “cookies” can prevent this during access to the service. In that case, certain contents of the service may be unavailable or partially accessible.

The cookies we use: (Unfortunately, the specific list of cookies you use is not provided in the text.)

Necessary Cookies

Necessary cookies help make the website functional by enabling basic features such as navigation and access to secure areas of the website. Without these cookies, the website may not function properly.

Performance cookies

Performance cookies allow us to track visits to our website to measure and improve performance. They help us identify the most and least visited pages and track how visitors navigate our website. All information collected by these cookies is aggregated and, therefore, anonymous.

Preference Cookies

Preference cookies enable the website to remember information that changes the way the website behaves or looks, such as language or geographical settings of the user.

Marketing Cookies

Marketing cookies are used to track visitors on the website. They are used to display relevant and tailored advertising content to individual users, providing greater value to external advertisers and publishers.

There are different types of cookies:

Session cookies are temporarily stored on your computer when you visit our website and are deleted as soon as you close your browser.
Persistent cookies remain on your computer until you remove them or until they expire after a predetermined retention period.
First-party cookies are set by SME HUB on your computer when you browse our website.
Third-party cookies are cookies placed on the SME HUB website by partner advertising sites and are used to collect information for advertising purposes and personalized content delivery, as well as web statistics. These cookies provide insights into your interests while browsing the SME HUB website and can be blocked. They do not directly store personal data but work by uniquely identifying your browser and device.

Google Analytics

For the purpose of customizing our website, we use Google Analytics, a web analytics service provided by Google Inc. Besides the cookies mentioned above, we also use Google tools such as Google Analytics, Google Tag Manager, and Google Ads for marketing conversion tracking. Google Analytics is a web analytics service provided by Google used to track and report website traffic. Google uses the collected data to track and monitor the usage of our website.

In this context, pseudonymized user profiles are created and cookies are used. The cookies generate the following information about your usage of this website:

Browser type/version
Operating system used
Referrer URL (the previously visited website)
Host name of the accessing computer (IP address)
Time of the server request

This data is not linked to any specific individual and is used solely for statistical analysis and website optimization. By using this website, you consent to the processing of data by Google as described above. If you wish to opt-out of Google Analytics tracking, you can use the Google Analytics Opt-out Browser Add-on, which is available for most popular browsers.

Rights of data subjects

When personal data is collected from you, ICT Hub will provide you with the following information at any time:

Identity and contact details of the data controller and its representative if designated.
Contact details of the data protection officer, if appointed.
Purpose and legal basis for processing.
The existence of the data controller’s or a third party’s legitimate interest, if the processing is based on necessary processing for the purpose of legitimate interests pursued by the data controller or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, especially if the data subject is a child.
The recipient or categories of recipients of the personal data, if any.
The retention period of the personal data or, if not possible, the criteria used to determine that period.

As a data subject, you have the right to:

Request access, correction, or erasure of personal data, or restriction of processing, the right to object to processing, and the right to data portability.
Withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal, if the processing is based on consent.
Lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection.
Obtain information on whether providing personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as the consequences of not providing such data.
Receive information about the existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
For the exercise of your rights and for additional questions regarding the processing of personal data, you can use the following email address: info@smehub.rs.

This Privacy Policy comes into force on April 15, 2022.

The Privacy Policy is written in Serbian and English, and in case of any discrepancies in the interpretation of its provisions, the Serbian version shall prevail.

ICT Hub reserves the right to make changes and amendments to this Privacy Policy. All changes and amendments will be published at the following hyperlink https://smehub.rs/privacypolicy.