We value your privacy and take particular care to keep your personal data secure. For this reason, this Privacy Policy aims to inform you, in a transparent and easy-to-understand way, about the collection, use, nature and scope of the processing of your personal data by MM SKI-SPORT d.o.o. Kopaonik, Maglić 402, company reg. no. 20860243, which acts as the controller of your personal data (hereinafter “MM SKI-SPORT” or “we”).
Here you will find information about all the data we collect about you in the course of various forms of cooperation, in particular the data we collect when you visit our website www.mmskisport.com, when you decide to buy our products and services online or simply book our services.
Personal data is any data that relates, or may relate, directly or indirectly to you as a natural person. As the legal basis governing data protection and the conditions for processing your personal data, we apply the Law on Personal Data Protection (Official Gazette of RS No. 87/2018, hereinafter “the Law”).
If our site contains links to other websites, please make sure you are familiar with the privacy policies on those websites and with how those parties process your data. Please note that MM SKI-SPORT has no control over the content of other websites and therefore cannot be held responsible for protecting your privacy when you visit other sites.
How we collect your personal data and on what legal basis
All the information we collect comes directly from you, when you order certain products or services or fill in a form online or at our points of sale.
All your personal information is treated as strictly confidential and is stored appropriately by MM SKI-SPORT and/or our trusted partners.
In accordance with the applicable legislation governing personal data protection, we may process your personal data on the following legal grounds:
- where processing your personal data is necessary to conclude and perform a contract you are entering into;
- where processing your personal data is necessary to comply with certain legal obligations (this applies in particular to data we keep for tax purposes);
- where we have a legitimate interest in processing your data, unless that interest is overridden by your interests or fundamental rights and freedoms;
- where you have given us your consent to process your personal data for a specific purpose, in which case you have the right to withdraw your consent at any time;
Providing personal data is mandatory only where we collect it to comply with certain legal obligations. Providing personal data on all other legal grounds is voluntary, but please note that if you withhold this data, in some situations we may not be able to provide certain services (for example, home delivery of products or sending newsletters by e-mail).
Please note that all the legal grounds listed apply depending on the purpose for which we collect your data, and we will inform you of this in each specific case. You can read more about the purpose and type of data we collect in the section “What data do we collect from you?”
What data do we collect from you
MM SKI-SPORT collects several categories of personal data, depending on the specific request of the user/customer.
Purchases/orders in the MM SKI-SPORT shop/website/app
When you make a purchase in the MM SKI-SPORT shop, via the website or the mobile app, you may, depending on the case, be asked to provide certain personal data necessary to conclude a distance sales contract, create an order or fulfil the obligations under the sales contract – delivery, payment and receipt of goods.
For purchases in MM SKI-SPORT online shops with home delivery, we need the following data:
- first name and surname;
- telephone number;
- address (town/city, street and number, postcode, flat number and floor)
When you use our online shopping services via the website or mobile app, in addition to the data above we also need your e-mail address in order to confirm the purchase and send you the order form.
If you pay online, we also collect data about the transaction in order to ensure a secure purchase.
You can shop online even if you are not registered on the MM SKI-SPORT website, i.e. as a guest.
We use data collected in this way solely to conclude and perform the distance sales contract, which includes managing and tracking orders, communicating with you and handling complaints or reminders.
To make sure the products you buy from us are delivered to the correct address, we share your data (e.g. your name and delivery address) with our external partners in order to provide the relevant services. You can find out more about our partners in the section “Who has access to your data?”
Complaints
Under the Consumer Protection Law, MM SKI-SPORT is obliged to enable customers to lodge complaints about products and services they have bought.
In that case, when you lodge a complaint as a customer, we may ask for your name and surname, telephone number, e-mail address and/or home address if goods need to be sent or a site visit is required.
We use data collected in this way solely to resolve and respond to your complaints.
Please note that under no circumstances do we collect special categories of data, such as data concerning your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, nor do we process genetic data, biometric data, data concerning health, sex life or sexual orientation.
Contacting MM SKI-SPORT – through various types of enquiry (by e-mail, telephone or social media). Depending on how you contacted us and the type of enquiry, we may collect your name, surname, telephone number, e-mail address and other information you have exchanged with us in connection with your enquiry.
Marketing purposes
Subscribing to news about current offers and promotions – newsletter. If you would like to receive our news about current offers and promotions, you can leave your e-mail address at the bottom of any page of our website at any time to receive our newsletter.
You can withdraw your consent to receive news about current offers and promotions at any time, in which case we will stop sending you promotional offers. Withdrawing consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.
Please note that if we engage external partners to send newsletters/Viber/SMS messages, your data (e-mail address and telephone number) may be transferred to them in order to provide these services. You can find out more about our partners in the section “Who has access to your data?”
Visiting the website
With your consent, we record your behaviour as a user of our website www.mmskisport.com, mobile apps and newsletters. Analysing user behaviour mainly involves data on the sections you spend time on and the links you use there. In this way we create personalised user profiles with your personal data and/or your e-mail address, so that MM SKI-SPORT can create advertising offers in the form of newsletters, on-site advertising and printed material tailored to your personal interests and thus improve our offer.
MM SKI-SPORT processes your data when you visit this website and when you use our apps and other platforms. During this, various data are exchanged between your device and our server, and these may include personal data. The data collected in this way are used, among other things, to optimise our website or to display advertisements in your device's browser.
Google Analytics
To adapt the design of our websites and keep improving them, we use Google Analytics, a web analytics service provided by Google Inc. (“Google”). In this context, pseudonymised user profiles are created and cookies are used. Cookies generate the following information about your use of this website:
- browser type/version,
- operating system used,
- referrer URL (previously visited page),
- host name of the accessing computer (IP address),
- time of the server request
The data are used to evaluate the use of our website, to compile reports on website activity and to provide other services related to website and internet use. The data are processed for market research and to adapt these websites. IP addresses are anonymised so that identification is not possible (so-called IP masking). Under no circumstances will your IP address be linked to other Google data.
For more information on data protection in connection with Google Analytics, see the Google Analytics website
Social media
Data on social media are largely processed by the operator itself, and MM SKI-SPORT has limited influence over this. More detailed information on data processing by social media platform operators and on your options for objecting can be found in their data protection policies:
- YouTube
- TikTok
We process data collected on social media to inform consumers about current promotions and offers, with the aim of interacting with and improving our relationship with followers.
Data collected on social media on the basis of consent, such as comments, videos, images and likes, are published by the operator. MM SKI-SPORT does not share these data with third parties and reserves the right to delete unlawful content, hate comments, explicit content and data constituting a criminal offence.
With the social media operator there is in part a relationship under Article 45 of the Law (joint controllership): the operator and we are jointly responsible for the web-tracking methods provided by the social media platform operator. Web tracking may take place regardless of whether you are logged in to or registered on the social media platform. As already mentioned, unfortunately we can only influence the operator's web-tracking methods to a limited extent – for example, we cannot switch them off. The legal basis for web-tracking methods is legitimate interest, consisting of optimising the social media platform and the specific fan page.
Video surveillance
MM SKI-SPORT uses video surveillance at all its retail premises for the safety of its employees and property and to detect criminal offences and other disputed situations. A notice about video surveillance is displayed at the entrance to each of our retail premises, and surveillance is used in accordance with the Law on Private Security. We keep information collected by video surveillance for a period that allows us to assist regulators and law enforcement authorities, but no longer than 3 months, after which all data are deleted automatically. This information is stored in a way that ensures appropriate protection of personal data, and access is restricted to authorised staff only.
Who has access to your data?
Protecting your personal data is extremely important to MM SKI-SPORT, which is why we make sure your personal data are not disclosed to unauthorised persons. Within our company, the data you have provided are accessible only to the departments and employees who need them to fulfil the purpose for which the personal data were collected and whose job description includes processing personal data. Besides our employees, in order to provide certain services we may disclose your data to third parties – our partners who provide services on behalf of MM SKI-SPORT (e.g. courier service, complaints service, IT partners maintaining our website/mobile app). In all these cases our relationship with external partners and the way your personal data are protected and handled are governed by contracts in accordance with the Law. We do not transfer your data outside the Republic of Serbia.
How long do we keep your data?
We keep personal data for as long as necessary to fulfil the purposes stated above, taking into account the legal obligations to retain personal data. Where data are collected to conclude and perform a contract, we keep data on completed purchases and customers for as long as required by tax regulations and the regulations governing sales contracts (e.g. data on complaints are kept for as long as required by the Consumer Protection Law). After the prescribed periods expire, or after consent is withdrawn where data are processed on that basis, all customer data will be depersonalised, deleted or destroyed.
Data on minors
MM SKI-SPORT does not knowingly process personal data of children under 16. Adults are advised to supervise minors in their care properly while they browse the internet, especially where personal data can be entered.
Security measures
To ensure the protection of personal data, MM SKI-SPORT has adopted a whole set of rules governing the processing and protection of personal data.
Various mechanisms have been implemented, such as mandatory training for all employees in handling confidential and personal data; access to personal data is permitted only to authorised persons, and strong password policies are in place. In addition, MM SKI-SPORT has appointed a data protection officer who helps protect and secure personal data and ensures compliance with the Law.
MM SKI-SPORT continuously monitors and, where necessary, improves its security measures in order to prevent unauthorised access to, loss or destruction of personal data.
What rights do you have as a data subject?
You may contact us at any time with any of the following requests:
- to give you access to your personal data, to tell you for what purposes data concerning you are used, and to let you access such personal data and know the purpose of processing, the categories of your personal data we keep, the third parties or categories of third parties with whom your personal data are shared, and the period for which we retain the data.
- to request correction of inaccurate, incorrectly entered and/or outdated data;
- to request erasure of your personal data if the processing is based on your consent or legitimate interest, or if the personal data are no longer necessary for the purpose for which they were collected;
- to request restriction of the processing of your data if you contest the accuracy of the personal data, for a period enabling the controller to verify their accuracy; if you consider the processing unlawful but do not want the data erased; if you have lodged an objection; or if you consider that MM SKI-SPORT no longer needs your data;
- to object to the way we process your data, even where there is no dispute that we process the data in accordance with the Law;
- to lodge a complaint with the Commissioner for Personal Data Protection in accordance with the Law.
For any further questions or requests regarding the processing of personal data, you can contact our Data Protection Officer, Ivanka Đorović.
Requests for access, correction and completion, erasure, restriction of processing, data portability, cessation of processing and non-application of decisions based on automated processing are submitted by the data subject to the controller. You may use this request template (in Serbian).
If, in accordance with Article 21(3) of the Law, the controller has reasonable doubts about the identity of the person submitting the request, it may ask that person to provide additional information necessary to confirm their identity, in accordance with Article 5(1)(3) of the Law.
At the data subject's request, the controller must provide a copy of the data it processes. If the request for a copy is submitted electronically, the information is provided in a commonly used electronic form, unless the data subject has requested otherwise. If the data subject requests additional copies, the controller may charge a fee covering the necessary costs.
Contact e-mail address: administracija@mmskisport.com.
Competent authority
The competent authority for personal data protection is the Commissioner for Information of Public Importance and Personal Data Protection of the Republic of Serbia, with whom you can also lodge a complaint in accordance with the law.
You can contact the authority at Bulevar kralja Aleksandra 15, 11000 Belgrade, Republic of Serbia, by e-mail at office@poverenik.rs or by phone on +381 11 3408 900.
Entry into force and amendments to the Privacy Policy
This Privacy Policy enters into force on 11 June 2020.
The Privacy Policy may be amended or supplemented depending on MM SKI-SPORT's needs and changes in its processes, changes in the legal framework, or at the request of the competent authority (the Commissioner for Information of Public Importance and Personal Data Protection). Users are advised to check regularly for amendments to the Privacy Policy on the MM SKI-SPORT website.
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