1. Introductory Provisions

This Privacy Policy governs the data privacy conditions applicable to the Circular Navigator web portal available at: https://cirkularno.eko.gov.rs (hereinafter referred to as the “Portal”), including which data are collected and processed, the period for which such data are retained, information regarding the rights of data subjects, and related matters.

The Ministry of Environmental Protection of the Republic of Serbia, with its registered office in Belgrade at Nemanjina 22–26 (hereinafter referred to as the “Ministry”), is the author of the content published on this Portal and processes personal data in the capacity of data controller, in accordance with the Law on Personal Data Protection (“Official Gazette of the RS”, No. 87/2018).

As the author of the Portal content, the Ministry undertakes to protect the privacy of its visitors, to collect only the data necessary for fulfilling the purpose of the Portal, all in accordance with the Law on Personal Data Protection.

Pursuant to the Law on Personal Data Protection, “personal data” shall mean any information relating to a natural person whose identity is determined or identifiable, directly or indirectly, in particular based on an identifier such as a name and identification number, location data, identifiers in electronic communications networks, or one or more characteristics of that person’s physical, physiological, genetic, mental, economic, cultural, or social identity.

As the controller of the Portal, the Ministry shall be responsible for the collected personal data in the manner and to the extent prescribed by this Privacy Policy and the Law on Personal Data Protection.

The Ministry undertakes all necessary technical, organizational, and personnel measures to ensure that data processing is carried out in accordance with the Law on Personal Data Protection.

The Ministry implements all technical and organizational measures necessary to ensure the security and confidentiality of personal data processing.

Prior to using and accessing the content of the Portal, the visitor declares that they have read, understood, and accepted this Privacy Policy and that they consent to the collection, processing, and retention period of data as prescribed herein.

Portal visitors are advised and instructed to visit, read, and accept the Terms of Use of the Portal.

Considering that the Portal may contain links to other websites, we kindly ask you to familiarize yourself with the Privacy Policies available on such websites and the manner in which those entities process your data.

The Ministry has no control over the content of external websites that are outside its scope of authority.

The Ministry collects only the data necessary for the use of the Portal, in accordance with the law, the highest ethical and moral standards, and for the purpose of providing a quality service.

The collected data shall be retained by the competent authorities within the retention periods prescribed by law.

The application through which consent for the processing of personal data is provided has been prepared in accordance with Article 15 of the Law on Personal Data Protection.

The right to register is granted to natural persons over 18 years of age to whom the provisions of the Law on Personal Income Tax apply with regard to generated income.

In accordance with Article 82 of the Law on Personal Data Protection, every individual has the right to file a complaint with the Commissioner for Information of Public Importance and Personal Data Protection if the processing of personal data has been carried out contrary to the provisions of this Law.

All collected data shall be available to employees of the Ministry and shall not be disclosed to third parties without your approval, except where such disclosure is required by law or in judicial proceedings. Your data may also be used and disclosed to third parties for the purposes of protecting the security of our data and safeguarding the functioning of our programs, services, and technical systems, all in accordance with the Law.

All user data are treated as strictly confidential, and all employees of the Ministry are obligated to maintain the confidentiality of your data.

2. Personal Data Collected and Processed

The Ministry collects several categories of personal data, depending on the specific request of the user. All information we collect is obtained directly from the User, in the manner and for the purposes described below.

Registration of Portal Users

All information we collect is obtained from the User when registering, i.e. when completing the registration form available in the “Register” section of the Portal and/or when adding geolocation and/or address data while using the Portal for the purpose of publishing information regarding various user locations where certain materials are available.

The data required for user account registration (mandatory data) are: first and last name, email address, created password, telephone number, and geolocation (including address).

During the use of the Portal, various data are exchanged between the user’s device and the servers used by the Ministry, which may also include personal data.

The data collected in this manner are used, among other things, to ensure the uninterrupted functioning of the Portal and/or optimization of the Portal. When using the Portal, the user’s browser will automatically send the following information to the Portal server, without any additional action by the user: the IP address of the device from which the request was sent and which has internet access, date and time of access, name and URL of the downloaded file, referrer URL, and, where necessary, the browser used and the operating system of the user’s computer.

The server temporarily stores the above data in so-called log files for the purposes of ensuring uninterrupted connection establishment, efficient use of the Portal, and assessment of system security and stability.

3. Purpose of Collecting Personal Data

The collection of Users’ personal data enables connection with other users of services registered on the Portal, in order to facilitate the search for desired materials by Users and to enable access to the availability of desired materials available on the Portal.

In addition to the above, the data may also be used for conducting surveys regarding user satisfaction with the Portal, for the purpose of collecting statistical data for internal needs and preparing statistical reports for the needs of the Ministry, in accordance with its entrusted competencies.

4. Retention of Personal Data

The collected data shall be stored in accordance with the Law on Personal Data Protection, while respecting industry standards and data protection measures, and may be accessed by employees of the Ministry and persons engaged in processing data on behalf of the Ministry, for the purpose of providing the requested service and/or other purposes for which you have granted consent.

5. Data Retention Period

The Ministry shall retain data for as long as necessary to fulfill the stated purpose, in accordance with the Law on Personal Data Protection. Following the creation/registration of a user account, personal data shall be processed until the deletion of the user account or withdrawal of the granted consent. Withdrawal of consent shall not affect the lawfulness of processing carried out on the basis of consent prior to its withdrawal.

6. Rights of Portal Users

Portal users are guaranteed the following rights: the right of access (to data and information regarding the manner of their processing and use), the right to rectification of data, the right to erasure, the right to withdraw consent, the right to restriction of processing, the right to object, and the right to lodge a complaint with the competent personal data protection authority.

In the above cases, there may be a requirement to verify identity prior to responding to the relevant request.

7. Amendments to the Privacy Policy

The Privacy Policy may be amended or supplemented depending on the needs and changes in the Ministry’s processes and/or policies, changes in the legal framework, or upon request of the competent authority. We recommend that all users regularly monitor amendments and supplements to the Privacy Policy available through the Portal.