Privacy Policy
Ing respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Each of the sections below will explain our private data processing activities as well as your related rights as a data subject, in plain English:
- Introduction
- What data we collect
- How we collect data
- How we use your personal data
- Cookies Policy
- Disclosures of your personal data
- International transfers
- Your legal rights
- Data security
- Data retention.
Introduction
This website is operated by Ingsoftware doo Niš. We are registered and located in the Republic of Serbia, City of Niš, Strahinjica bana bb. You can contact us via our contact form.
This privacy notice aims to give you information on how Ingsoftware collects and processes your personal data throughout your use of this website, and through its interactions with you.
This website is not intended for children and we do not knowingly collect data relating to children!
Ingsoftware is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).
We only process Personal Data and Communications Data for the specific purposes explained in this privacy policy, and as soon as that data is no longer needed for that purpose it is deleted. The only exception to this is where we may be required to keep certain data by law.
We have appointed a data privacy manager who is responsible for overseeing our implementation of this privacy policy. If you have any questions about it, including any requests to exercise your legal rights, please contact the data privacy manager using the contact form.
What data we collect
While using our website, we may collect the following data about you:
- Identity Data: first name, maiden name, last name, job title, place of work;
- Contact Data: email address, telephone number;
- Technical Data: IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology information about the devices you use to access our website;
- Usage Data: data about how you use our website (ie. time of visit, pages opened, time spent on the website, etc.);
- Marketing and Communications Data: your preferences for receiving marketing information from us.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Also, we do not collect any information about criminal convictions and offenses.
How we collect data
We use two different methods of data collecting.
Firstly, through direct interactions with our website you may give us your Identity and Contact data by filling in forms or by corresponding with us by post, phone, email or other channels. This includes personal data you provide when you: send us a message using contact form; request access to specific content; complete our questionnaires; give us any kind of feedback; etc.
Also, when you visit our website, third party tools embedded in our website collect different data related to your visit. In this way, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies.
How we use your personal data
We will only use your personal data when the law allows us to. To be more precise, we will use your personal data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, and where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent for marketing communications at any time by contacting us.
Below you can see a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate, and we have identified the purpose of data collecting, where your consent is the legal base for data collection.
Purpose/Activity | Type Of Data | Legal Basis For Processing | Basis of Legitimate Interest And Purpose Of Data Collecting | Period Of Retention |
|---|---|---|---|---|
To manage our relationship with you. | - Identity - Contact | Necessary for our legitimate interests, or for the execution of a contract with you, or to prepare such a contract or provide you information about our services. | To keep our records updated, or to execute a contract with you or prepare a cooperation proposal. | -- |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | - Identity - Contact - Technical | Necessary for our legitimate interests. | Needed for running our business, provision of administration and IT services, network security, to prevent fraud. | -- |
To deliver relevant website content and advertisements to you and measure the effectiveness of the advertising we serve on the internet. | - Identity - Contact - Technical - Usage - Marketing and Communications | Your consent. | To see how visitors use our website, to grow our business, and to inform our marketing strategy. | -- |
To improve our website, services, marketing activities, customer relationships and experiences. | - Technical - Usage | Your consent. | To define types of customers for our services, to keep our website updated and relevant, to improve our business, and to inform our marketing strategy. | -- |
To make recommendations to you about goods or services that may be of interest to you. | - Identity - Contact - Technical - Usage - Marketing and Communications | Your consent. | To develop our services and grow our business. | -- |
We may use your Identity, Contact, Technical, Usage, and Marketing and Communications Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing communications. You can ask us or third parties to stop sending you marketing messages at any time, by using an unsubscribe form, or by contacting us.
Cookies policy
Cookies are small text files containing a string of characters that can be placed on your computer or mobile device that uniquely identify your browser or device. In more detail, a cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser.
What kind of cookies do we use
We use cookies to improve the browsing experience of our website, to analyze website traffic, to understand where our visitors are coming from, and to show you personalized content and targeted ads
Necessary cookies - These cookies are essential to provide you with services available through our website and to enable you to use certain features of our website. Without these cookies, we cannot provide you certain services on our website.
Functionality cookies - These cookies are used to provide you with a more personalized experience on our website and to remember choices you make when you use our website. For example, we may use functionality cookies to remember your language preferences or remember your login details.
Tracking and performance cookies - These cookies are used to collect information to analyze the traffic to our website and how visitors are using our website. For example, these cookies may track things such as how long you spend on the website or the pages you visit which helps us understand how we can improve our website site for you. The information collected through these tracking and performance cookies do not identify any individual visitor. For collecting these kinds of cookies, we are using third party services (ie. Google Analytics, Matomo, Microsoft Clarity, and similar).
Targeting and advertising cookies - These cookies are used to show advertising that is likely to be of interest to you based on your browsing habits. These cookies, as served by our content and/or advertising providers, may combine information they collected from our website with other information they have independently collected relating to your web browser's activities across their network of websites. If you choose to remove or disable these targeting or advertising cookies, you will still see ads on the internet but they may not be as relevant to you. For collecting these kinds of cookies, we are using third party services (ie. Facebook Pixel, Google Ads tag, LinkedIn Insight tag, and similar).
How long will cookies stay on my device?
The length of time a cookie will stay on your computer or mobile device depends on whether it is a persistent or a session cookie.
Session cookies will expire at the end of the user session, when the web browser or tab with our website is closed.
Persistent cookies will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date.
Cookie consent and preferences
When you visit our website for the first time, we ask you for consent regarding collecting cookies, but at any time, you have the option to change cookies preferences (ie. you can give your consent for just certain types of cookies).
For the basic website analytics we are using a tool called Matomo without pushing cookies to your device and without collecting your personal information (your IP address is anonymized).
Also your web browser may allow you to change your cookie preferences, including the option to delete and/or disable cookies. Please consult the help section of your web browser to understand your options, but please note that if you choose to disable the cookies, some features of our website or services may not operate as intended.
Disclosure of you personal data
We may have to share your personal data with the third parties, which services are embedded in our website.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers
Some of the third party tools we are using are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we try to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy decisions.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Standard contractual clauses.
- Where we use providers based in the US, we may transfer data to them if they are a part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see Privacy Shield.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out below, please contact us.
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we have about you and to check that we are lawfully processing it.
Request correction of the personal data that we have about you. This enables you to have any incomplete or inaccurate data we have about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which you will be notified about, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold on to the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data according to our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so
Data retention
We will only retain your personal data for as long as it is necessary to fulfill the purposes we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data. See Request erasure in the section above for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.