Last updated: June 24, 2022
Types of personal data and manner of collection
We may process personal data from Users in a variety of ways, including, but not limited to, when Users visit our Site, register on the Site, and in connection with other activities, services, features or resources we make available on our Site or otherwise. Users may be asked for, as appropriate, email address (required), name (optional), website (optional), company (optional), location (optional). Further information may be required if users choose to purchase paid components of the Site, such as credit card and billing information. Site uses third party partners for credit card processing who may require and store your credit card and billing information. Such processing by third party partners might be governed by internal policies of such third party partners. We will collect personal data from Users only if they voluntarily submit such personal data to us. Users can always refuse to supply personal data, except that it may prevent them from engaging in certain Site related activities.
Web browser cookies and tracking
Semaphore processes Users personal data for the following purposes:
- To personalize User experience. We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.
- To send periodic emails. The email address Users provide for notifications, will only be used to send them information and updates pertaining to their notification settings. It may also be used to respond to their inquiries, and/or other requests or questions.
- To provide services to our customers.
- To maintain our accounts and records.
- To enhance, modify, personalise or otherwise improve our services and communications for the benefit of our customers.
- To promote our services through communications that we think will be of interest to you.
- To undertake research.
- To identify and prevent fraud.
- To enhance the security of our network and information systems.
- To understand how people interact with our websites.
- To occasionally contact you for market research purposes.
- To customise our website according to your interests.
- To determine the effectiveness of promotional campaigns and advertising.
- To process your orders.
- For statistical purposes and to improve the website and services we offer.
Legal basis for the processing of the personal data
Semaphore processes personal data of Users on the legal bases set out by applicable law. Legal basis for the particular processing differs from case to case, but it usually includes:
Performance of a contract: We use personal data to provide the Site, services or products offered by Semaphore which the User has subscribed to, and to complete, fulfil and administer the contract Users have entered into with Semaphore.
Legitimate Interest of Semaphore: We use personal data for legitimate interests of Semaphore, such as to provide you with relevant content, improve our products and services, and for administrative, security, fraud prevention and legal purposes. Users may object to the processing of your personal information for these purposes at any time..
Consent: We may use personal data with consent of the Users for exceptional purposes such as marketing, surveys, and research. Users may withdraw their consent for the specific purpose or object to the processing of their personal data at any time. Whereby, the lawfulness of any processing of your personal data performed prior to such withdrawal shall not be affected by the withdrawal.
Rights in relation to the processing of the personal data
Subject to limitations envisaged by the Serbian Law on Personal Data Protection, each User has, with respect to his/her personal data, the right to request at any moment information on the processing of his/her personal data and to access his/her personal data, as well as to request their copy, correction, supplement, update or deletion, restriction of their processing, to object to their processing (when the processing is performed on the basis of legitimate interests of Semaphore) and (where applicable) to receive or have the data transmitted to another controller in a structured, commonly used and machine-readable format. Users may exercise their rights by submitting a request to Semaphore at the email address firstname.lastname@example.org.
In the case of any unlawful processing of the personal data by Semaphore, Users have a right to the legal protection envisaged by the law, including the right to lodge a complaint to the Commissioner for Information of Public Importance and Personal Data Protection (the “Commissioner”), as well as the right to reach out to a court in order to protect his/her rights.
How we protect your information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.
Sensitive and private data exchange between the Site and its Users happens over a SSL secured communication channel and is encrypted and protected with digital signatures. We are committed to announcing any security breaches within 72 hours after we notice this kind of issue.
We take precautions to ensure the security of User’s personal data. We strive to ensure that the processing of personal data is done in accordance with international principles and best practices regarding data protection. When you enter your login information on the Site or otherwise by using Semaphore products or services, all information to and from the service is encrypted using Transport Layer Security (TLS).
If you have any questions about security applied by Semaphore, you can contact us at email@example.com.
Data storage, transfer and security
The servers on which personal data is stored are kept in a controlled environment. While we take reasonable efforts to guard your personal information, no security system is impenetrable and due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. In addition, we cannot guarantee that any incidentally-collected personal data you choose to store in our Site or our services or products are maintained at levels of protection to meet specific needs or obligations you may have relating to that data.
If the personal data of Users would be transferred out of the Republic of Serbia to one of the countries which do not ensure an adequate level of personal data protection in accordance with the Law on Personal Data Protection, Semaphore will fulfil all relevant conditions and undertake all measures necessary for the sake of ensuring adequate warranties with regard to the processing of the personal data and for the sake of ensuring an adequate level of protection, including e.g. by application of standard contractual clauses approved by the Commissioner, binding corporate rules, approvals issued by the Commissioner and similar (for more details about undertaken measures reach us on e-mail firstname.lastname@example.org or by letter to the address of Semaphore).
Sharing your personal information
We do not sell, trade, or rent Users personal data to others. We may use third party service providers to help us operate our business and the Site (such as hosting providers) or administer activities on our behalf, such as sending out newsletters or surveys. To the extent we transfer personal data to recipients located outside of Republic of Serbia, we will ensure that this is done based on the applicable laws and regulations.
You can find more information on entities engaged by Semaphore and acting as data processors in Sub-processors List document.
Third party website
Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.
Your acceptance of these terms