Privacy Policy
Last updated on and effective as of 25.09.2022.
Welcome to our Privacy Policy!
We are Foundation Novi Sad – European Capital of Culture, with a registered seat on the address Trg slobode 3, Novi Sad, the Republic of Serbia, CIN 28829922, TIN 109849130 (hereinafter: “Foundation” or “we”).
Our Privacy Policy is a document that reflects Foundation’s detailed approach to user privacy and shows you how we collect, share, and use your Personal Data. Also, the Privacy Policy explains how you can exercise the rights you have as a Data Subject.
As we value the privacy of all the visitors of our website, by creating this Privacy Policy we wanted to make the processing of your Personal Data clear, transparent, and understandable for you.
This Privacy Policy applies to all individuals who access our Website at https://kaleidoskopkulture.com/, or contact us – via email, or social media.
We hold a position of a data controller, which means that we determine the purpose and means for processing of Personal Data in relation to interactions on our Website and the use of our Service.
Along with our Terms of Use and Cookie Policy, this Privacy Policy is a part of the Agreement that applies to you. Therefore, please read it carefully in order to understand all the necessary information regarding the protection of your Personal Data.
Any term capitalized but undefined in this Privacy Policy shall have the meaning given to it in our Terms of Use.
In case you have any questions regarding this Privacy Policy, please contact us at privacy@kaleidoskopkulture.com.
- Defined terms
- Which Personal Data do we collect?
- Why do we collect Personal Data?
- Persons under the age of 15
- How do we use collected Personal Data?
- How long do we keep Personal Data?
- Who do we share your Personal Data with?
- Your rights
- How do we maintain the security of Personal Data?
- Changes to Privacy Policy
- Get in touch
- Defined terms
| Term | Meaning |
|
Consent |
Your explicit consent on the processing of your Personal Data. Persons who are 15 years of age or older may give free consent to the processing of their Personal Data. |
|
Cookies
|
Small pieces of data stored on your device (computer or mobile device), used to track your use of the Website and to compile statistical records on Website activity. For a more detailed explanation of the use of cookies and how you can manage them, please go to our Cookie Policy. |
|
Data Processor |
Any natural or legal subject who processes Personal Data on our behalf. We may use the services of various service providers in order to process your Personal Data more effectively. |
|
Data Subject or you
|
Any natural person who shares their Personal Data with us. |
|
Law
|
Law on Personal Data Protection
(„Official Gazette RS“, no. 87/2018) |
|
Personal Data |
Any information relating to an identified or identifiable natural person – Data Subject.
Ø An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, identification number, location data, online identifier or to one or multiple factors specific to its physical, physiological, genetic, mental, economic, cultural, or social identity. Consequently, data about a legal entity cannot be considered to be Personal Data but registering on behalf of a legal entity may include sharing Personal Data. For instance, information related to one-person companies may constitute Personal Data where it allows the identification of a natural person. These rules also apply to all Personal Data in relation to a natural person in the course of the professional activity, such as the fact of employment in the company or organization, employee’s business telephone number, or a business email address such as “firstname.surname@company.com”. This Privacy Policy does not apply to information that cannot reasonably result in the identification of an individual (anonymized information). |
|
Processing
|
Any activity or set of activities 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, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction. |
|
Service
|
Making available any content by us on the Website. Service does not include any other (if any) services provided by us without the use of the Website. |
- Which Personal Data do we collect?
We may collect and receive your Personal Data in several ways:
- voluntarily – the data you intentionally share with us, by using our Website or by getting in touch via our email addresses: info@ns2022.rs, or pr@ns2022.rs.
- automatically – the data we collect when you access our Website.
- through the use of cookies – explained in detail in our Cookie Policy.
- Data provided by you
(a) Data provided by you
Contact and additional information
In case you wish to contact us via our general contact email address info@ns2022.rs, or media contact email address pr@ns2022.rs, we may collect personal data such as your email address and related information, and the content of your message.
(b) Automatically collected data
Technical Data
When you access our Website, some information about you will be collected automatically. Such data includes your IP address, device type and unique identification number, browser, broad geographical location (e.g., country or city) and other similar technical information. This technical data also includes the information that we collect through the use of cookies and similar tracking technologies. You can read more about it in our Cookie Policy.
We measure traffic and usage trends for our Website by using analytic tools, which collect information sent by your device to our Website. For instance, we analyse the web pages you visit, add-ons you use, as well as other information that helps us improve our Website. Such analytics information is collected and used along with identical information from other users, so it cannot reasonably be used to identify any particular individual.
Data on your Usage
We collect and record data and sessions when you access and use our Website. Such information may include Personal Data.
Mobile Device Data
For the purpose of providing the best performance of our Website, as well as conducting a further improvement analysis, we collect certain data from your mobile device. Such data may refer to the type of your mobile device, identification number, date, and time stamps of Website use. Additionally, tracking technologies we use within the Website help us gather aggregate, non-personal statistical data.
- Why do we collect Personal Data?
|
Data we collect |
Purpose of collecting |
Legal ground |
|
Email address and related information, the content of the email/ your message, and other data available on your social media account (if you decide to contact us via Facebook, Instagram, or YouTube), as well as any additional data you decide to share with us. |
1. Responding to your inquiries
We collect your Personal Data in order to respond to your inquiries sent via email or social networks. |
Processing is necessary for the performance of the Agreement, entering into such an Agreement with you, as well as to respond to your questions or requests regarding the use of our Website or Services. |
|
Technical Data and Mobile Device Data. |
2. Managing, analyzing, and improving our Website and Service
Automatically collected information is used to:
· manage and operate our Website, · improve usability and performance of the Website, by keeping it updated and relevant, · analyze the use of the Website and measure the interests of visitors of our Website, · ensure that content on the Website is presented most effectively for you and your device. |
Processing of the automatically collected data is necessary for the performance of the Agreement. However, all the other data is processed on the basis of your consent. So, unless it is necessary to provide a Service or part thereof, the provision of your Personal Data is not a statutory or a contractual requirement and you may decide not to disclose any such Personal Data. When the processing is based on your consent, you can withdraw such consent at any time. However, that will not affect the lawfulness of the processing based on your consent prior to such withdrawal. |
No Personal Data are processed outside the specific purposes. We do not sell any kind of Personal Data, or disclose Personal Data to other marketers, nor do we provide your Personal Data to any third party unless we are strictly compelled to do so by law.
- Persons under the age of 15
The Website is not intended for children, and we do not knowingly collect data relating to a person under the age of 15. If you are under the age of 15, we kindly ask you to not provide any personal information about yourself to us.
In case we detect that we have collected personal information from a person under the age of 15, such information will be deleted promptly.
If you believe we have collected personal information from a person under the age of 15, please contact us at privacy@kaleidoskopkulture.com.
- How do we use collected Personal Data?
We will not use any of the collected Personal Data referring to you without your consent, or without an adequate legal basis in accordance with the section “Why do we collect Personal Data” of the Privacy Policy.
We will use your Personal Data exclusively for the purposes it is collected for, and only in cases when we have a reasonable and lawful legal ground to do so.
In order to achieve the highest level of Personal Data security, our staff members are legally bound by the professional secret. Additionally, we use different legal, technical, and organizational measures to prevent the disclosure of any relevant information beyond the legal purpose for which it is collected.
- How long do we keep Personal Data?
We keep your Personal Data solely for the time it takes to fulfil the purpose for which it is collected, i.e., for the time for which we have your consent.
When determining the period of data retention, we take into consideration domestic laws, contractual obligations, and the expectations and requirements of our Website visitors.
Once we no longer need your Personal Data, or upon your request for the deletion of such information pursuant to the law, we will securely delete or destroy the data in accordance with the applicable law and our internal policies.
- Who do we share your Personal Data with?
To conduct certain processing activities, we are sometimes required to engage some external processors. We use information audits to identify, categorize and make records of all Personal Data that is processed outside of the Foundation. That way, all the Personal Data, as well as the information on processing activities, processors, and legal grounds are recorded, reviewed, and easily accessible.
External processing includes, but is not limited to:
- IT systems and services,
- Legal services,
- Human resources,
- Direct marketing services.
The processors and sub-processors with whom we share your Personal Data are:
| PROCESSOR
|
ROLE
|
SEAT
|
|
Google, Inc. |
Analytics, tracking and advertising | USA |
| The Rocket Science Group, LLC (MailChimp) | E-mail services based on Cloud | USA |
Under the law, we may be required to share certain information, including your Personal Data, with e.g., public authorities or governmental bodies on their request. In that case, your further consent will not be required, in order to share your Personal Data in accordance with such a request.
International transfer of Personal Data
We may transfer your personal data to countries other than the one you reside in. In these cases, we will transfer your personal data only:
- To the countries within the EEA;
- To the countries which do not form the EEA but are considered to ensure an adequate level of protection;
- To the countries which do not belong to those specified under items 1. and 2, but only by applying the appropriate safeguard measure in accordance with the Law (for example, applying standard contractual clauses).
If you require further information about these protective measures, please contact us at privacy@kaleidoskopkulture.com.
We use servers located in Germany.
- Your rights
As a Data Subject whose Personal Data we process, you have the following rights:
right to be informed about the collection and usage of your Personal Data,
right to access the Personal Data we hold about you,
right to have your Personal Data corrected (rectified) if any of them is incomplete or inaccurate,
right to be forgotten, i.e., the right to ask us to delete or dispose of any of your Personal Data that we have,
right to the restriction of processing of your Personal Data,
right to data portability, in case you have provided your Personal Data to us, and that data is processed using automated means, you have the right to ask us for a copy of such Personal Data, as well as to have those data transmitted to a third-party data controller,
right to object to using your Personal Data in case processing is based on our legitimate interest, as well as if the processing is performed with a purpose of direct marketing, which includes profiling.
right to lodge a complaint, if you have any concerns or requests in relation to your Personal data, please contact us, and we will respond within 30 days.
If you are unsatisfied with how we process your data, you may also contact the competent supervisory authority – the Commissioner for information of public importance and personal data protection of the RS.
To exercise any of these rights, please contact us at privacy@kaleidoskopkulture.com.
- How do we maintain the security of Personal Data?
In order to protect the Personal Data we collect and process, we use appropriate technical and organizational measures designed to provide a level of security appropriate to the risk of processing your Personal Data.
Please have in mind that no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security or confidentiality.
If you have any questions related to security on our Website, you can reach us through privacy@kaleidoskopkulture.com.
- Changes to Privacy Policy
We reserve the right to update our Privacy Policy from time to time at our sole discretion. Any changes shall enter into force upon being published on our Website, so therefore you are cautioned to review our Privacy Policy periodically.
In case you do not agree with the changes to our Privacy Policy, please stop using our Website immediately.
- Get in touch
In case you wish to exercise any of the rights you have as a Data Subject, or you have a question regarding Privacy Policy, please contact us at privacy@kaleidoskopkulture.com
