Privacy Policy of CloseOut FSM D.O.O.

Data Controller:

CloseOut FSM d.o.o. 

Registration number: 21931845

Golsvordijeva 2, Belgrade, Republic of Serbia 

 

This Privacy Policy (“Policy”) describes how CloseOut FSM d.o.o. Beograd (“CloseOut”, “we” or “us”) collects, stores and uses personal data, as well as how you may exercise your rights regarding those data.

At CloseOut, we respect your privacy as our existing or potential customers, and we are committed to protecting the privacy of all individuals who entrust us with their personal data.

Our Services

Personal data that we collect and process on behalf of our clients i.e. the data clients and their users entered into our “CloseOut” application constitute data we process as a data processor, based on concluded data processing agreement with clients (hereinafter: “Client Data”).

This Policy does not apply to Client Data. For more information on the use of our services and the processing of data in that capacity, please contact your organization or review their internal privacy policies.

Our clients are solely responsible for compliance with applicable data protection laws, for providing their users with adequate notice and for establishing adequate legal basis for data processing. Also, clients are responsible for addressing data subject rights requests in accordance with applicable data privacy law.  

We recommend that you carefully read this Policy to be fully informed. 

This Policy describes the personal data that we collect and process as a data controller. In this regard, we may collect the following categories of personal data relating to you:

• Identification data and business information – your name, the company you work for, your position and contact details (e-mail address, phone, etc.). 
• Inquiries – contact information and other details necessary to respond to your inquiries, to provide you with support, security notices and other technical information. 
• Promotions – contact details for organizing promotional or project related events. 
• Marketing – contact details to send promotional and marketing materials. 
• Job application – information from your CV and any other information that you provide us during the recruiting process. 
• Other – any other information that you provide to us in relation to a specific request.

All personal data that we collect are assessed through the risk assessment method in line with the ISO/IEC 27001:2022 standard implemented at CloseOut, i.e. We take all available organizational and technical measures to protect the security of this data. 

We collect personal data directly from you, during our business cooperation (including pre-contractual steps), through our website or when you request additional information about our services. 

In some situations, we may collect personal data from third party sources, including our sales partner, distributors, sponsors or via social media platforms. 

We use your personal data to provide, improve and update our services. Specifically, we collect data for the following purposes: 

• Services. To provide or invoice certain services,
• Sales and marketing. For sales calls, to send you newsletters, emails or other promotional materials,  
• Communication. To send you notifications about our services, including technical and security alerts, updates, administrative messages or to respond to your questions, comments or requests, 
• Legal and security purposes. To comply with applicable laws, 
• Consent. We may use your personal data for other purposes, if you have given us consent. 

We process your personal data based on the following legal bases: 

• Conclusion / execution of the contract. To fulfill contractual obligations under a contract with you or your company, or to take steps prior to entering into such a contract; 
• Consent. When required, we may request your consent to process data for specific purposes; 
• Compliance with legal obligations. In certain cases, the processing is necessary for us to meet our legal obligations; 
• Legitimate interest. We may rely on our legitimate interests to process your personal data provided that our legitimate interests are not overridden by your data protection interests or fundamental rights and freedoms. We may rely on our legitimate interest for purposes such as detecting or preventing illegal activities, to defend our interest before various state bodies (courts, inspections etc.). 

When collecting personal data, you may always choose not to provide us with the necessary data, except when we collect information under the law. However, in that case, please note that we may not be able to adequately establish, maintain or terminate a business relationship with you or your company, nor provide you with the required information.

We are committed to ensuring the security of your personal data. To prevent unauthorized access or disclosure, we have established appropriate physical, electronic and organizational measures. However, no security measure is perfect or impenetrable, we cannot guarantee absolute security. 

We retain personal data only for as long as necessary to fulfill the purpose for which it was collected, in line with contracts, internal policies, and/or legal obligations. 

After the purpose has been fulfilled, we will delete your personal data, unless retention is required to comply with legal obligations or to resolve potential disputes. 

Your personal data may be disclosed to third parties providing services on our behalf, such as hosting, billing and payment services or web and mobile analytics. 

We do not transfer your personal data outside the country of our registered office. If such transfer occurs, it will only be to countries that provide an adequate level of protection, in line with applicable data protection laws. If data must be transferred to countries without adequate protection, we will apply standard contractual clauses and inform you of the transfer and potential risks. You have the right to withhold consent for such transfers. 

Where required, personal data may also be provided to competent public authorities to fulfill legal obligations. 

Like most websites, we use cookies on our website. Cookies are small text files that are stored on your device when you visit our website. 

Cookies do not in any way provide access to your computer or any information about you other than the information that you choose to share with us. You can accept or reject cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies.

Our website uses “first party” cookies (cookies set by us), necessary for site functionality and “third party cookies” (cookies set by the third party providing the services), for statistical purposes (Google Analytics). 

Types of cookies we use: 

• Necessary cookies – enable basic functions like navigation and ensure the proper functioning of the site (e.g., display content in the selected language).
• Statistical cookies – help us understand how visitors use our site by collecting anonymous data (e.g., usage analysis and traffic measurement).

We also use Google Analytics (https://analytics.google.com), which sets its own cookies. The data collected, such as the number of visits and time spent on our site, is anonymized. 

You can delete accepted cookies manually at any time in your browser settings.  

Please note that if you delete or refuse to accept cookies on our website, we will not be able to remember which language you have chosen.

Our website may contain links to other websites. Once you leave our site, we have no control over other sites’ content. We are not responsible for the protection or privacy of personal data you provide while visiting such sites. Please always review the privacy policy of the website you visit. 

• Right of access – request access to or copies of your personal data;
• Right to rectification – request correction of inaccurate or incomplete personal data;
• Right to erasure – you have the right to request the erasure of your data, if it is no longer necessary, when the law requires erasure of data or when the processing of data is illegal;
• Right to restrict processing – you have the right to request a restriction on the processing of your data in situations prescribed by the applicable positive regulations concerning the protection of personal data;
• Right to data portability – you have the right to request the transfer of your data to third parties;
• Right to object – you have the right to object to the processing of your data when we rely on our legitimate interest in the processing of data, when your rights outweigh our interests;
• Right to withdraw consent – if we process your personal data on the basis of consent, you have the right to request the withdrawal of consent at any time. Withdrawal of consent shall not affect the lawfulness of the processing carried out prior to the withdrawal of consent.

We will not sell, distribute or rent your personal information to third parties unless we obtain your permission or when we are legally required to do so.

You can exercise all rights regarding your personal data by sending a request to the e-mail address: privacy@closeout.cloud.

If you believe that we do not process your personal data in accordance with the law, you can file a complaint to the Commissioner for Information of Public Importance and Personal Data Protection.

As described above, we may also process personal data that has been submitted by a customer to our services. If your personal data has been submitted to our services by or on behalf of our customer, and you wish to exercise your privacy rights, please direct your contact to the relevant customer.

We do not knowingly collect information about children under the age of 16 or about children without parental / guardian permission. If you believe that we may have any information about children under the age of 16, please contact us immediately and without hesitation, and we will take appropriate measures to investigate and resolve the situation.

If you have any questions or comments regarding this Policy, please feel free to send us an email at: privacy@closeout.cloud.

This Policy will be subject to regular revisions, and we will post any updated version on this website. Thereby, we will deem that you have read and consent to the terms of our Policy on the processing of personal data for the above purposes. If the Policy changes, we intend to take every reasonable step to ensure that all changes are posted on our website within a reasonable period.

Belgrade, November 7, 2024