THE PRIVACY STATEMENT OF THE LOCKER ROOM SYSTEM 

*PROPERTY OF OCTA D.O.O. BEOGRAD

 

Octa D.O.O. Beograd is committed to the guarantee of privacy and data protection. By means of this privacy statement (hereinafter referred to as the "Privacy Statement"), Octa D.O.O. wishes to inform the participant in detail about the processing of his/her personal data and associated rights when using the Locker Room System platform.  We encourage you to read this privacy statement carefully.

 

By using the Locker Room System platform, Octa D.O.O. will have access to your personal data, which will be processed with respect for the privacy of the participant and with compliance to the law of 8 December 1992 on the protection of privacy with respect to the processing of personal data, that was replaced on 25 May 2018 by the (European) General Data Protection Regulation (also known as the GDPR).

If you wish to receive more information concerning privacy and data protection, please visit the website of the Commission for the Protection of Privacy (also referred to as the Privacy Commission).

 

Whenever we modify this Privacy Statement, you will be informed. If applicable users will be asked to accept the new and therefore most recent version of this Privacy Statement.

Octa D.O.O. is committed to protecting your privacy and personal data. If you have any questions about this Privacy Policy, please contact us at any time at office@octasolutions.biz

 

This Privacy Statement was last reviewed on 11 December 2020.

 

 

1. TO WHOM DOES THIS STATEMENT APPLY?

This Privacy Statement applies to all of our potential/present/previous participants and users of the Locker Room System platform.

 

2. CONTACT DETAILS FOR OCTA D.O.O. BEOGRAD

OCTA D.O.O. BEOGRAD
Address: Jurija Gagarina 31V Apt 1
Belgrade, Serbia 11070
Phone: +381 66 41 44 22
Contact: office.octasolutions.biz

 

3. WHAT MEANS

 

3.1 Processing of personal data

By 'processing' we mean any operation or set of operations performed on personal data (whether or not by automatic means, such as collection, recording, organisation, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, as well as the blocking, erasure or destruction of personal data). By 'personal data' we mean all information about an identified or identifiable natural person.

 

3.2 A processor

A processor is the natural or legal person, de facto association or public administration who processes personal data on behalf of the controller, with the exception of persons who are authorised to process the data under the direct authority of the controller.

 

3.3 A controller

A controller (person in charge of processing) is any natural or legal person, de facto association or public administration who alone or jointly with others determines the objectives and legal and technical means for the processing of personal data.

 

3.4 A user

A user is an individual who uses the Locker Room System platform and has an active account.

 

4. WHO IS RESPONSIBLE FOR PROCESSING? 

OCTA D.O.O. BEOGRAD as a processor

OCTA D.O.O. BEOGRAD is considered to be a processor of personal data in so far as it processes personal data on behalf of its customers, in which case these customers act as data controllers.

OCTA D.O.O. BEOGRAD as the data controller

OCTA D.O.O. BEOGRAD is considered controller and responsible for processing when it determines the purpose and means for the processing of personal data.

The Locker Room System platform offers a wide range of possibilities for the customer/participants to process personal data. If the user copies your personal details from the Locker Room System platform on his own initiative and processes them via another medium, the customer will be responsible for processing.

A participant who wishes to exercise his rights as a data subject must always contact the controller.

 

5. WHO IS A DATA PROTECTION OFFICER?

OCTA D.O.O. BEOGRAD has appointed a Data Protection Officer who is responsible for supervising and monitoring OCTA D.O.O. BEOGRAD 's privacy and data protection policy with respect to the processing of personal data. You can contact the Data Protection Officer on office@octasolutions.biz for all of your questions concerning privacy and data protection, regarding the processing of your personal data and the exercise of your rights.

 

6. WHAT PERSONAL DATA IS PROCESSED BY OCTA D.O.O. BEOGRAD WHEN OFFERING THE LOCKER ROOM SYSTEM PLATFORM?

The personal data processed by OCTA D.O.O. BEOGRAD is the data you provide to us when you use our platform, whether or not at the request of our customer (e.g. by answering questionnaires).

 

1.1 For the Locker Room System user

Organising the platform in function of the development of professionals.

OCTA D.O.O. BEOGRAD processes the personal and electronic identification data of the Locker Room System users in function of the ability to organize improvements based on the legitimate interest of OCTA D.O.O. BEOGRAD.

OCTA D.O.O. BEOGRAD processes images and additional personal identification data from the Locker Room System user in function of creating a Locker Room System account and based on your permission.

OCTA D.O.O. BEOGRAD processes personal identification data of the Locker Room System user in the context of the customer relationship in order to keep them informed of other products and services and allows Locker Room System users to unsubscribe at any time, based on the legitimate interest of OCTA D.O.O. BEOGRAD.

 

1.2 Benchmarking

OCTA D.O.O. BEOGRAD uses the results of the many participants to situate an individual participant between other participants, which act as a reference group.  In this context, OCTA D.O.O. BEOGRAD anonymises or aggregates the personal data of former participants in order to identify possible reference groups.

OCTA D.O.O. BEOGRAD only processes sensitive personal data if the participant has given his explicit consent prior to processing.  In order for explicit consent to apply, content must be obtained in a free, specific, informed manner and by an unambiguous active act. If required, OCTA D.O.O. BEOGRAD will ask you specifically for the use of this information.

As a participant, you have the right to withdraw your consent at any time. 

 

7. GOOGLE ANALYTICS

Google Analytics is a web analytics service provided by Google Inc. ("Google"). OCTA D.O.O. BEOGRAD uses Google Analytics within the website and the Locker Room System platform. OCTA D.O.O. BEOGRAD does not transfer any personal data to Google. By analysing this information, based on legitimate interest, OCTA D.O.O. BEOGRAD learns how the website and platform are used and OCTA D.O.O. BEOGRAD can improve it.

Google Analytics Information: Privacy Policy - Unsubscribe

 

8. WHO RECIEVES MY PERSONAL DATA?

When a participant uses the Locker Room System platform, OCTA D.O.O. BEOGRAD collects personal data.  Only if this processing is carried out on behalf of a customer (as controller) will this customer also receive the personal data of the participant.

Your personal data will not be passed on to other external parties without prior consent, unless OCTA D.O.O. BEOGRAD is obliged to do so on the basis of a statutory provision or a court order. Your personal data will not be passed on to the partners of OCTA D.O.O. BEOGRAD.

 

9. IS ANONYMOUS DATA USED FOR REPORTING PURPOSES?

We may use anonymous data for commercial purposes or for external reporting. Anonymous data are personal data that are rendered anonymous to such an extent that they no longer relate to an identified or identifiable person, or the data is displayed anonymously so that the individual is not, or is no longer, recognisable.

 

10. HOW LONG WILL MY DATA BE STORED?

OCTA D.O.O. BEOGRAD will only retain your personal information for the minimum period necessary to fulfil the purposes set out in this Privacy Statement, except in the case of dispute resolution or if a longer retention period is required by law. Non-personal information may be retained without restriction for statistical purposes.

 

11. DATA SECURITY AND RETENTION

OCTA D.O.O. BEOGRAD acknowledges that the security of personal data is part of data protection. OCTA D.O.O. BEOGRAD therefore takes appropriate technical and organisational measures to protect your personal data against unauthorised processing or unauthorised access in order to prevent misuse.

OCTA D.O.O. BEOGRAD follows the applicable data protection laws and regulations to ensure adequate safeguards.

 

12. COOKIES

Cookies are text files that can be placed on your computer in order to collect standard internet logging information and behavioural information. This information is used to track the visitor behaviour of the Locker Room System platform and to compile statistical reports on the Locker Room System platform.

 

13. WHAT ARE MY RIGHTS AND HOW CAN I EXCERCISE THEM?

A participant who wishes to exercise his rights as a data subject must always contact the controller.  

 

1.1 How can I exercise my rights as a data controller at OCTA D.O.O. BEOGRAD?

You can exercise your rights by sending an e-mail to office@octasolutions.biz

In order to prevent any unauthorised disclosure of your personal data, it is mandatory to send the request stating the e-mail address linked to your Locker Room System account. In addition, we ask you to state when you last participated in an assessment within the Locker Room System platform, as well as for which client.

OCTA D.O.O. BEOGRAD has one month to reply to your request. This period starts when OCTA D.O.O. BEOGRAD has received your application and has all the information required to satisfy it.

OCTA D.O.O. BEOGRAD will provide the requested information free of charge. Where requests are unfounded or excessive, in particular because of their repetitive nature, OCTA D.O.O. BEOGRAD may charge a reasonable fee or OCTA D.O.O. BEOGRAD may refuse the request.

If for any reason you believe that OCTA D.O.O. BEOGRAD has not dealt with your application correctly, you can contact the data protection officer of OCTA D.O.O. BEOGRAD at office@octasolutions.biz who will work with you to resolve any issues.

For the sake of completeness, we inform you that if OCTA D.O.O. BEOGRAD does not respond to your request, if it refuses or if the response does not meet your expectations, you are entitled to lodge a complaint with the Commission for the Protection of Privacy (Privacy Committee), Drukpressstraat 35 in 1000 Brussels or commission@privacycommission.be.

 

1.2 What rights can I exercise?

Right of access: You can ask us which personal data we process from you, what we process it for, which categories of personal data we process, with which categories of third parties we share your personal data, what the origin of the data processed is.

Right of rectification: It is currently possible for each participant to improve their account details whenever an assessment is started via the Locker Room System platform. In order to keep your data up to date, please make any changes yourself or contact us.

Right to erase data: You can ask us to erase your account. As a result, it is no longer possible to use the Locker Room System platform. After the request, OCTA D.O.O. BEOGRAD will suspend your account for 30 days in order to give you the necessary reflection period. After that, the account will be anonymised. 

Right to limitation of processing: in the cases defined in European privacy legislation. Where processing within the Locker Room System platform is restricted, your personal data (except for storage) will only be processed with your consent or for the creation, exercise or defence of any legal claim or for the protection of the rights of any other natural or legal person or for reasons of public interest. After obtaining this processing restriction, you will always be notified by OCTA D.O.O. BEOGRAD before the processing restriction is lifted.

Right to withdraw consent: If the processing of personal data is based on basic consent, you as a participant have the right to withdraw this consent at any time.

Right of objection: You have the right to object to the processing of your personal data only if the processing is based on a general interest or a legitimate interest.

 

14. IS MY DATA USED FOR AUTOMATIC DECISION MAKING?

There is no automatic decision-making, including profiling, within the Locker Room System platform.