On the basis of the Personal Data Protection Act („Official Gazette of RS“, no. 97/2008, 104/2009 – other laws, 68/2012 – US decision and 107/2012), the director of the company Net Logist doo, on 31.07. in 2012 year brings the following:
REGULATION ON PROTECTION OF PERSONAL DATA
Article 1.
Net Logist doo, MB 20645385, PIB 106616720, processes the necessary Data of users and those Persons who have given their consent for processing, for a clearly defined purpose and in a manner permitted by law, so that the Persons to whom the data refer are not specified or determinable even after the purpose of processing has been achieved, in proportion to the purpose of processing and using the Services.
The data processed must be completely true and based on a reliable source of information and personal documents, i.e. sources that are not out of date
Article 2.
Before collecting data, Net Logist doo informs the following persons: Physical and Legal persons, to whom the data refer:
- The person responsible for data collection in front of Net Logist doo is the legal representative and director of the company: Dušan Supurović.
- The purpose of collecting and processing data enables the smooth functioning of the digital service, managing the process of ordering products and services, digital content, marketing actions, conducting online financial transactions, organizing loyalty programs and campaigns, as well as providing the aforementioned services via the Internet, related to the user’s geo-location on The e-pharmacy portal , which is owned by Net Logist doo.
- Collected Data is used in a way that enables clear identification of the Person who, by carrying out the sale or transfer, realizes the right to order products and services from the offer, and in accordance with good business practices, keeping business secrets and the Law.
- The personnel who use the submitted Data are individuals employed by Net Logist doo, who have the authority to use the Data and access the Data bases, as well as all the State bodies of the Republic of Serbia that exercise the right to use the Data based on the law and/or court decision.
- The provision of personal data is voluntary, and the User who does not wish to use the specified products and services through the digital internet service and the Portal is not obliged to register and leave any Data, but that leaving data is mandatory in terms of the Law on Obligations and According to the Law on Consumer Protection for the purpose of making a purchase.
- A person who has given his consent to the collection and processing of data can, at any time and without explanation, withdraw his consent, which as a legal consequence produces the termination of the account of the Registered User’s account, termination of membership, termination of receiving e-mail notifications, as well as the termination of any further collection of data from persons who have withdrawn their consent.
- In case of unauthorized processing, Persons have the right to the protection of personal data, as well as other rights that belong to them according to the Law.
Article 3.
The data collected from individuals and legal entities for the purposes indicated above are:
- for Individuals: Name and Surname, address, email address and mobile phone number,
- for Legal Entities: Name of the legal entity, TIN, National Identification Number, seat address, as well as the Name and Surname of the person authorized to use the services on behalf of the Legal Entity, email address and mobile phone number.
Net Logist doo exclusively requires this data for the purposes of implementing business activities in the sales and processing of Non-Orders, as well as the delivery of products and services in the country and abroad.
Article 4.
Registration of a new user for natural and legal persons is enabled but not necessary, both for domestic and foreign persons. Ordering products and services can be done without registration.
Article 5.
Net Logist doo keeps all collected Data of Natural and Legal Persons as its own business secret.
Article 6.
Net Logist doo does not process personal data except for the purpose of processing the ordered Service and organizing the loyalty program.
Article 7.
All general business acts of the company Net Logist doo are in accordance with this Rulebook.
If any general act of Net Logist doo is not in accordance with this Rulebook regarding the protection of personal data, the provisions of this Rulebook shall apply.
Article 8.
This Rulebook enters into force on the day of its adoption and is published on the e-apoteka
PROTECTION OF CONFIDENTIAL INFORMATION ABOUT FINANCIAL TRANSACTIONS
When entering payment card data, confidential information is transmitted via the public Internet network in a protected (encrypted) form using the SSL protocol and the PKI system, as currently the most modern cryptographic technologies.
The payment card data is not available to the Net Logist doo business system for a single moment.
TERMS AND CONCEPTS – Explanation
Definitions:
„Person – Persons“ – refers to all Natural and Legal persons who share personal data with Net Logist doo.
„Portal“ – refers to the web shop https://www.e-apoteka.com
„User“ – refers to any person who accesses the Portal.
„Registered user“ – refers to persons who have a registered and validated account on the Portal.
„Guest“ – refers to a user who stays on the Portal without registering an account and can ask questions to the Support service.
„General terms of business“ – refers to the terms of business that form an integral part of the business policy of Net Logist doo and the Contracts with business-related legal entities, for the purpose of performing Services, which are the subject of business and which are available in the offer on the Portal.
„Data“ – refers to personal data, i.e. data related to a Natural Person, and a Natural Person within a Legal Entity, whose identity is determined or determinable, directly or indirectly based on the submitted data.
„Commissioner“ – refers to the Commissioner for Information of Public Importance and Protection of Personal Data, Bulevar kralja Aleksandra 15, 11000 Belgrade, e-mail: .
„Cookie Policy“ – refers to special rules on the collection of individual personal data on the Portal through the so-called „cookies“, which form an integral part of the Privacy Policy.
‘Consent’ – means your unequivocal consent to the processing of personal data. A person who has reached the age of 15 can independently give consent to the processing of personal data in the use of information society services. Consent is only one of the legal bases for data processing, so data can be processed on another basis as well.
„Products and Services“ – refers to the initiation of an Order, i.e. our mediation in the sale of products and services offered on the online portal under the trade name: e-apoteka
To whom does the Rulebook apply?
Net Logist doo takes care of the privacy and safety of minors on the Internet. The e-pharmacy portal is intended for the general public, but is not intended for persons under the age of 15. Persons under the age of 15 may not disclose their personal data to us. If you believe that we have collected data on persons under the age of 15, please inform us without delay at the email address: .
How and when personal data is collected
Data is primarily collected when user registration is performed, or when ordering products and services without registration, or when you contact us for support with additional questions, or when you send an email or send a question via the official Viber or WhatsApp registered number +381 652 381 652.
PLEASE NOTE
Data on the Registered User, that is, on the Name and Surname of the person who places the order, as well as the email address and mobile phone number, are exclusively collected in the sense of determining the real person as the person who orders products and services, and in the sense of positive legal norms and the execution of the order and delivery of the shipment.
All submitted Data are kept strictly confidential, and each method of data collection has its own purpose and legal basis based on the Law.
Help Desk and User Questions
In certain situations, you may need to contact our Support Service via the Portal’s contact form, or email, or the official Viber or WhatsApp registered number (for example, for short instructions, the need for additional information, etc.).
In such situations, we will need your data so that we can provide you with help, that is, so that we can solve the issue for which you contacted us.
Data collected are: first and last name, phone number, email, or data related to the question for which you contacted us, and for which you yourself decided to provide us.
Processing is necessary in order to comply with legal obligations, that is, to provide assistance to Users. The processing is also carried out on the basis of legitimate interest, because we use the data to provide you with information that you request from us or that may be of help to you regarding requests or questions that you have sent to the Support Service.
Newsletter
We only collect data and use it for marketing purposes based on your prior express consent. We will always inform you separately about this and emphasize that you can withdraw your consent at any time.
Data for the Newsletter is collected based on your consent, which you provide to us when signing up for the Newsletter.
In the event that you initially agreed, you can withdraw this consent at any time, provided that this will not affect the legality of the processing that was carried out while the consent existed.
Informing about changes to the General Business Terms and Privacy Policy
If we have information about your e-mail or mobile phone, collected for the purpose of achieving one of the aforementioned purposes, we can send you a notification about changes to the General Terms and Conditions or the Privacy Policy.
The data used is e-mail or your mobile phone number via Viber or WhatsApp applications.
We provide information in order to realize our legitimate interest, but also the interests of the users themselves, and in order to ensure transparency in relation to the Users, and so that the Users can consider whether the changes have an impact on them.
If we do not have your data for the stated purpose, we will not inform you directly about the change in these acts, and you will be able to see the change notification on the Portal.
Where and how your data is stored
Adequate technical and organizational measures have been implemented on the modern online platform, all to protect your data from unauthorized or illegal processing, as well as from accidental or illegal loss, alteration, or access to your personal data.
However, please keep in mind that we cannot completely eliminate all risks related to the storage of your data, because they are used for the purpose of processing the Services, and as such are available and visible in certain business segments, parts of the postal services, in the domestic and international system for the distribution of shipments.
On the trend of digitalization of all personal data processed in the process of ordering products and services, we store all data on the servers of our providers and providers of our partners in the process of processing your order.
Access to places where personal data is stored is restricted with access security control functions. Only personnel authorized to access data can access secured data zones. Our staff who have access to this data are trained and qualified to understand the importance of personal data, as well as to apply internal processes for their protection, and are bound by the obligation of confidentiality.
Do we share your data with third parties?
Protection of personal data and personal privacy is very important, therefore we will never share your data with third parties for purposes not described in this Rulebook.
In terms of the processing and execution of order services, your data is provided only to third parties, who provide us with services and who have the status of our partners. These include service providers that maintain our IT systems, that we hire for marketing or advertising purposes, that we hire for payment processing, legal services or to provide other services that we provide in domestic and international transportation.
In the case of paying for services with payment cards through our Portal, your personal data is transmitted encrypted via the electronic payment institution PayPal for users outside the Republic of Serbia, which is necessary for the execution of financial transactions via PayPal.
Third party service providers are, according to the contracts we sign, obliged to use the data entrusted to them exclusively in accordance with our instructions, and strictly for the purpose stated.
When choosing a partner, positive business criteria were used, among which positive norms and procedures for preserving the confidentiality of personal data are one of the most important.
In cases of using ordered products and services, your data may be available outside the territory of the Republic of Serbia, as well as on servers located in other countries. The servers we use meet the level of protection provided by the EU General Regulation on the Protection of Personal Data (GDPR), and the level of personal data protection is (at least) equal to the level of protection within the Republic of Serbia.
How long are personal data kept?
Personal data collected for the purpose of performing the Services will be processed as long as the business relationship with the data subjects lasts, except in cases where we are obliged to keep the data and after the end of the business cooperation with the data subjects, based on the law, the consent of the Data Subject or legitimate interest (eg in the event of a dispute with the Data Subject).
Data collected only for the provision of Services and monetary transactions, or the provision of other services, are stored for another 18 months from the date of the last transaction (for example: delivery, complaint, etc.) or from the expiration of the legal deadline for complaints, whichever of those dates is later.
Personal data that is processed solely on the basis of the consent of the Person to whom this data refers, is processed only in accordance with the purpose for which it was collected, that is, until the consent is withdrawn by the Person to whom the data refers.
We keep the data you provide us when signing up for the Newsletter until you unsubscribe. At any moment, the so-called unsubscribe from the Newsletter, in accordance with the instructions that arrive in each email in which the Newsletter is sent .
If judicial, administrative or extrajudicial proceedings have been initiated, personal data may be stored until the end of such proceedings.
Particularly strict processes have been implemented for the deletion of personal data, which ensure respect for privacy (shredding of documents in paper form, processes for disposal of waste containing confidential information, as well as reliable deletion of data in electronic form).
Rights of the Registered User
As Persons whose personal data are processed, there are rights guaranteed by law in relation to the Data of the Registered User. The rights are as follows:
Right of access
You have the right to send us a request for information about whether we are processing your personal data. If data is processed, you have the right to request a copy of some or all personal data at any time.
We try to provide the requested information as soon as possible, and no later than within 30 days from the date of receipt of the request. When finding or obtaining information is particularly complex or justifiably requires a long time, this period can be extended by another 60 days. However, this only applies to exceptional circumstances and during the process we regularly inform you of any delay or reasons for the delay.
Right to rectification
All Data we process is reviewed and verified as accurate whenever possible and updated regularly. If you believe that the Data is incorrect or there is a change in it, you have the right to ask us to correct your Data
Right to be forgotten (deletion of data)
You have the right to request the deletion of your personal data, except in the case where there is a legal obligation to store such data or there is a legal basis for refusing a request for data deletion.
(for example: submitting, exercising or defending a legal claim).
Right to restriction of processing You have the right to restrict access to Your Data to us and/or third parties, on certain processes, or completely, in certain situations. This right is available to you in the event that you dispute the accuracy of the Data for the duration of the period that allows us to check the accuracy, you consider that we no longer need the Data for the purpose of processing, or you have filed a complaint with the competent authority, and for the duration of the assessment procedure of the overriding legitimate interest .
The right to data portability
You have the right to request the transfer of Data to another controller if the processing is based on your consent.
Right to withdraw consent
If data processing is based on your consent, you can withdraw consent at any time.
You can withdraw your consent by sending an email to:
Withdrawal of consent will not affect the legality of Data processing based on the consent given, before its withdrawal.
Navedeni način komunikacije mora omogućiti našem osoblju Vašu adekvatnu identifikaciju.
Contact for exercising rights
For all questions, requests and information regarding the processing of Data and the exercise of rights protection in this area, please contact us at the e-mail address:
The mentioned method of communication must enable our staff to adequately identify you.
In case you believe that your Data is being processed illegally, you can file a complaint:
To the Commissioner for Information of Public Importance and Personal Data Protection , Bulevar Kralja Aleksandra 15, 11000 Belgrade, Serbia, email: or to phone number +381 11 3408 900
Also, if for any reason we are unable to comply with your request, we always provide you with a written explanation and inform you that you have the right to file a complaint with the Commissioner from the previous paragraph.
Sincerely yours
e-apoteka team
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