PRIVACY POLICY NOTICE

SOG / Samardžić, Oreški & Grbović a.o.d., with its registered seat at 15, Kapetan Mišina Street, Belgrade, Serbia, registration number: 57330821 (hereinafter referred to as “SOG or We”), respects and protects the privacy of every person whose private data it collects. Collection and safekeeping of data are conducted in accordance with the Personal Data Protection Act of the Republic of Serbia (“Office Gazette of RoS”, no. 87/2018) (hereinafter referred to as the “Law”), as well as with General Data Protection Regulation of EU 2016/679 (hereinafter referred to as the “GDPR”) when collection and processing of Personal data are directed towards citizens of the European Union.

SOG values you as our clients and recognizes that privacy is important to you.

In order to protect the privacy of every person whose private data it collects, SOG rendered its Privacy policy. Such Privacy policy defines which personal data we collect, for which purpose we use them, how we protect them, and what your rights are. Namely, we have developed this Privacy policy to explain our practices regarding the personal information we collect from you or about you on this site, through written or verbal communication with us, when you visit our business premises, or from other sources.

In any case, feel free to contact our employee in charge of protection of personal data via the following e-mail dataprotection@sog.rs.

General provisions and Personal data processed by SOG

Personal data” means any information relating to an identified or identifiable natural person (“Data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing” means any operation or set of operations which is performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Sensitive data“ means data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

We do not collect your Sensitive data, unless you make it available to us voluntarily for the purpose of providing you legal services or if we are required to do so by applicable regulations.

Personal data of children” refers to persons under 18 years.

We do not collect the Personal data of children. As a parent or legal guardian, do not allow your children to make their Personal data available without your permission.

Your Personal data which SOG collects and process include:

  • Name and surname;
  • Personal identification number;
  • Occupation;
  • Citizenship;
  • Name of the Employer;
  • Workplace;
  • Education;
  • E-mail address;
  • Phone number;
  • Mobile phone number;
  • Bank account number;
  • Address of residence (street name and number, area code and city);
  • KYC information provided by a client or collected as part of our business acceptance processes

How We Collect Personal Data

We collect Personal data in a variety of ways.

a)   While providing you a legal service

We collect information such as name and surname, personal identification number, citizenship, name of the employer, education, e-mail address, phone number, mobile phone number and address of residence from you necessary in the course of providing you legal services and responding to inquiries.

If you do not provide us with the required Personal data, we may not be able to conclude and execute an agreement on legal services, or we will not be able to respond to your request.

The purpose for which we process the above Personal data is the conclusion and execution of the agreement on legal services and compliance with legal requirements and other statutory legal regulations.

Such Personal data are stored in our database permanently.

b)   While visiting our business premises

During your visit to our business premises, we collect information such as name and surname, mobile phone number, phone number, address of residence, and email address, in order to inform you promptly about offers for our services, as well as changes in legislation that we believe they can be important to you or affect your business or life sphere.

The purpose for which we process the above Personal data is the protection of your interest and providing you offers for our services.

Such Personal data are stored in our database until you withdraw your consent.

c)   While visiting our web site   www.sog.rs

During your visit to our website, Personal data are collected through cookies and IP addresses. You can find more information about our cookies policy on the following link    https://sog.rs/cookies-policy/.

d)   From Third-parties

In some events you may provide to us Personal data of some other natural person in which case, we shall deem that you have all necessary authorizations from such person to share his/her personal data to us.

If you are an individual whose personal information is processed by us as a result of providing our services to others (including individual clients and corporate clients) we will process a variety of different personal information depending on the services provided.

This may include personal information relating, without limitation, to any of our corporate clients or prospective clients’ officers or personnel, any opponent or vendor, or purchaser personal information including personal information relating to their legal advisors, other advisors, or personnel as relevant or similar.

For example, in the event of complying all employment agreements of the company, we shall process data of all employees of such company, such as name, surname, residence address, work post, educations, and other.

We might also need to process personal information in relation to other third parties instructed either by our clients or other persons or companies involved with us providing the services to our client (for instance other law firms, experts, etc.).

Purpose of the collection

  • to perform a contract, such as engaging with an individual to provide legal or other services,
  • establishment, exercise, or defense of legal claims or proceedings,
  • complying with legal and regulatory obligations,
  • performing our regular business activities, and
  • legitimate interest such as ensuring network and IT security.

By providing us with Personal data, you agree that SOG may use them for the needs of our regular business activities and fulfillment of our obligations regarding the agreement on legal services, including submission of offers for our services, market research, and customer satisfaction, as well as statistical analysis.

By giving to us your Personal data, you consent that they can be processed by us in accordance with the provisions of Law, GDPR, and other regulations, as well as that we can share them with associates and attorneys who work with us together to provide you legal or other services, as well as for performing our other business activities.

SOG will not make your Personal Data available to third parties, except in the cases specified in this Notice.

Legal basis for collections of Personal data

  • Consent

Your Personal data obtained based on your consent will be processed and stored as long as your consent exists, i.e. until the eventual withdrawal of your consent. If you have given us consent in relation to particular processing or activities, you can withdraw your consent at any time by contacting us on dataprotection@sog.rs.

Withdrawal of consent does not affect the admissibility of processing Personal data performed based on your consent before the withdrawal.

  • Performing an agreement on legal services

We collect Personal data that are necessary for us to conclude and execute agreements with you and fulfill pre-contractual obligations. If you do not provide us with the necessary Personal data, we will not be able to process your request or conclude an agreement with you.

  • Legitimate interest

We process Personal Data for the purpose of safeguarding the legitimate interests and legitimate interests of third parties. The legitimate interests of SOG in particular include: maintaining the functionality and security of the network and IT systems.

  • Complying with legal and regulatory obligations

We collect and process your Personal data to the extent necessary for the fulfillment of our legal and regulatory obligations, i.e. obligations defined by various laws.

Period of data safekeeping

We are obliged to keep safe the data collected on the basis of complying with legal and regulatory obligations for as long as requested by certain law or other statutory legal regulations.

Data collected by us based on contractual relations will be kept only as long as necessary for the purpose of fulfillment of the contract i.e. for the providing of service.

Other data collected by us based on explicit consent will be kept until the consent is withdrawn.

Rights of Data subject

Regardless of the basis of data collection, you can ask at any time, free of charge, for:

  • information on whether we process your data and access to that data,
  • rectification or deletion of your data, the right to restrict processing and the right to object to processing,
  • to file a complaint to the Commissioner for Information of Public Importance and Personal Data Protection,
  • to have your incorrect Personal data corrected without needless delay. Depending on the purpose of the processing, the Data subject has the right to supplement his/her incomplete personal data, which includes giving an additional statement,
  • request for deletion of your Personal data collected by us,
  • limitation on the processing of your Personal data, if one of the following conditions is met:

1) the accuracy of the Personal data is contested by the Data subject, for a period enabling us to verify the accuracy of the personal data;

2) the processing is unlawful and the Data subject opposes the erasure of the personal data and requests the restriction of their use instead;

3) we no longer need Personal data for the purposes of the processing, but they are required by the Data subject for the establishment, exercise, or defense of legal claims;

4) the Data subject has objected to processing pursuant to Article 37 para 1 of the Law pending the verification whether the legitimate grounds of the controller override those of the data subject.

We shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance Law to each recipient to whom the personal data have been disclosed unless this proves impossible or involves disproportionate effort. We shall inform the Data subject about those recipients if the Data subject requests it.

The Data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, in accordance with the Law.

The data subject has the right to object the processing of his/her Personal data in accordance with the Law, on the ground relating to his or her particular situation.

The Data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

Procedure in the event of Privacy Policy violation

In the event of Personal data violation that probably will cause a high risk for the rights of individuals, we will inform Data subject on personal data violation without the necessary delay.

In the event of personal data violation that probably will cause high risk for rights of Data subject, we will inform Commissioner for Information of Public Importance and Personal Data Protection on the violation of personal data, without necessary delay and, if possible, within 72 hours of learning about that violation. Notification delivered to competent authority holds all the information in accordance with the Law.

Transfer of Personal data to other countries

SOG does not transfer your Personal data to other countries.

Links to Third-party Websites and Services

Our site may contain links to third parties’ websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information on and use third-party sites, the privacy policy and terms of service on those sites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting personal information

By clicking on the Facebook, Twitter, Instagram, or Youtube button on our site, you accept the possibility that data on your visit to our site, may be processed by such social networks if you have an account on them. In order to avoid this situation, we advise you to log out of your user accounts from these social networks beforehand, and only then, by clicking on the link on our website, visit our page on one of the listed social networks.

Confidentiality and transparency

Your Personal data will be treated as confidential information and we will take appropriate measures to protect them in accordance with the Law. They will be accessible only to persons who given the job description should be aware of your Personal data and only to the extent necessary to perform their duties.

This Privacy Policy is available on the website www.sog.rs as well as in the business premises of the SOG.

If we decide to change our Privacy Policy, the changes will be posted on the website  www.sog.rs and in our business premises.

If you have any questions or requests regarding the processing of your personal data, please contact us at:

Phone: +381 11 3282 667
E-mail: dataprotection@sog.rs