Privacy policy

All personal data will be collected, used and transferred in accordance with the Privacy Policy. By using the Website, you agree to all actions taken by us with respect to your information, as permitted in the Privacy Policy. Please read the Privacy Policy carefully and check the changes in it.

1. This Privacy Policy

User personal Data Processing Policy (hereinafter referred to as the "Policy") applies to all information that "POV 9 d.o.o. Beograd " (a legal entity incorporated on the territory of the Serbia, Registration number 1217700359601, TIN 9717104698, registered at Ljutice Bogdana 34, Belgrade 11 000, Republic of Serbia) (hereinafter — POV 9 d.o.o. Beograd ), which is the copyright holder, owner and administrator of the online website https://9pandas.gg (hereinafter referred to as the "Website") may receive from Users when they use the Website and/or contact the support service.

1.1 This Policy is a legally binding document for all Users of the Website. Each User must read this Policy before using the Website.

1.2 Any use of the Website by the User means the User's full and unconditional consent to this Policy and all the conditions for processing their personal information and the data specified therein. In case of disagreement with the terms of the Policy, the User is obliged to refrain from using the Website.

2. Definitions used for the purposes of this document:

2.1 POV 9 d.o.o. Beograd is a company (a legal entity incorporated on the territory of the Serbia, Company identification number: 21864552, Tax ID number: 113424653, registered at the address: Ljutice Bogdana 34, Belgrade 11 000, Republic of Serbia), which is the operator of personal data and independently organizes and (or) processes Users' personal data, as well as determines the purposes of processing Users' personal data, the composition of Users' personal data to be processed, actions (operations), performed with the personal data of Users in accordance with this Policy.

2.2 Website – online service https://9pandas.gg, multimedia product owned by POV 9 d.o.o. Beograd, operating as a complex object of copyright, connected by common name, formed by POV 9 d.o.o. Beograd at its own discretion, the access to which is given to the Internet Users at the following URL: https://9pandas.gg and via different consumer devices, such as: mobile devices (cellphone/tablet), personal computers (stationary/mobile) etc. post-installation of the custom software on such devices. The access to the Website is provided for the Users according to this Agreement.

2.3 User - a legally capable individual over the age of 18, who discretionary accepted this Agreement, and implementing access to the Website and Content on terms of this Agreement, or using other functionalities of the Website.

2.4 Services - activities of POV 9 d.o.o. Beograd to provide Users with access to the functionality of the Website and view Content.

2.5 Personal Data / Data — information that Users give or may give to POV 9 d.o.o. Beograd during the use of the Website in accordance with the terms of this Policy.

2.6 Data processing — any action (operation) or a set of actions (operations) performed with or without the use of automation tools with Data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deleting, destroying of data.

2.7 Other terms not defined by this Policy are subject to interpretation in accordance with the customs of business ethics and the generally accepted meaning in the relevant field of activity, as well as the provisions of the current legislation of Serbia.

2.8 All definitions of this Policy are formulated for convenience only and cannot affect the legal significance of certain provisions of the Policy.

3. General provisions

3.1 This Policy has been developed in accordance with the legal acts on the territory of the Serbia.

3.2 The User's full and unconditional consent to this Policy is a prerequisite for the User to use the Website, the User who does not agree with the terms of this Policy does not have the right to use the Website in any way.

3.3 The User agrees to the terms of this Policy from the moment the User actually starts using any functionality of the Website.

3.4 By accepting the terms of this Policy, the User gives their voluntary unconditional consent to the processing of their Data, including Personal Data.

3.5 If the User gets access to the Website using the services of third parties (for example, the services of Internet service providers, mobile operators, etc.), they must provide consent to the processing of their personal data to the above-mentioned persons. POV 9 d.o.o. Beograd is not responsible for the processing of User Data by the third parties.

3.6 This Policy may be changed unilaterally by POV 9 d.o.o. Beograd at any time, without obtaining the User's consent and without prior notice. The current version of this Policy is published by POV 9 d.o.o. Beograd on the Website page. Unless POV 9 d.o.o. Beograd explicitly states otherwise, the new version of the Policy comes into force and becomes mandatory for compliance by the User from the moment of publication.

3.7 This Policy applies only to the Website and the process of User interaction with the Website. POV 9 d.o.o. Beograd assumes no responsibility for Internet sites, online websites, third-party software, services, and products of third parties, which the User can access by clicking on links on the Website. POV 9 d.o.o. Beograd is not responsible for the information and data about the User that are requested and collected on the websites of other third parties.

4. Data

4.1 When using the Website, Users have access to and can view most of the pages of the Website without providing their Personal Data, while when contacting the Website support service, the User may be required to provide Personal Data and/or Data to a limited extent specified in this Policy, and/or in the consent to the processing of the User's Personal Data, which may be requested by POV 9 d.o.o. Beograd.

4.2 The Data includes information that Users transfers to POV 9 d.o.o. Beograd via the Website and includes both depersonalized user data and personal data of Users.

4.3 When conducting various surveys on the Website, when contacting the support service of the Website, POV 9 d.o.o. Beograd can process the following User data:

4.3.1 first and/or last name or full name of the User and/or nickname of the User;

4.3.2 email address;

4.3.4 information about subscribing to informational materials (newsletters) or materials of the Website support services;

4.3.7 information about the time and procedure for obtaining access to the Website services;

4.3.8 information about participation in Website promotions.

4.4 When the User uses the Website, POV 9 d.o.o. Beograd may process data that is automatically transmitted to POV 9 d.o.o. Beograd on the Website using software installed on the User's device, including, but not limited to:

4.4.1 IP of the User's device;

4.4.2 information contained in cookies;

4.4.3 information about the location of the User device (the User's location), the time period for accessing the Website, as well as technical information about the User device with which the Website is accessed (including the device identification number, device model, year of manufacture of the device, the software version installed on the device);

4.4.4 information about the application for the User's Device;

4.4.5 information about the User's Internet browser (or other program with which the User accesses the Website).

4.5 By using the Website, the User gives their consent to the collection, analysis and use of cookies, since the use of the Website is conditioned by the use of cookies technology by creating cookies on the user's device in order to control the use of the Website, collect non-personal information about Users, save preferences and other information on the User's device in order to save the time required to repeatedly enter the same information in the Website forms, as well as to display the content during subsequent visits of the Website. If the User does not agree with the fact that POV 9 d.o.o. Beograd uses this type of files, the User must set the settings of their Internet browser used accordingly or stop using the Website. At the same time the User is notified and aware that if the support for cookies used by the Website is disabled, this may affect the process of using the Website, including restricting it (partially or completely).

4.6 POV 9 d.o.o. Beograd may also process other User data that the User independently decides to provide when contacting the support service by phone call and/ or sending an email to the email address of the Website.

4.7 POV 9 d.o.o. Beograd collects, processes and stores only those users’ information that is, necessary for the purposes specified in this Policy.

5. Purposes of data collection and processing

5.1 Any data about the user and/or their personal information received by POV 9 d.o.o. Beograd is used exclusively for implementation and/or execution of functions and duties assigned by the legislation of the Serbia to POV 9 d.o.o. Beograd, as well as, including for the purpose of correct operation of the Website:

5.1.1 for user identification on the Website;

5.1.2 for providing Users with up-to-date information about the Website and the ability to access it;

5.1.3 for conducting statistical and other research based on depersonalized data;

5.1.4 for providing Website users with safe and convenient functionality for its use, effective display of information, providing access to Content;

5.1.5 for prevention and detection of fraud and illegal use of the Website, services;

5.1.6 for processing requests from users of POV 9 d.o.o. Beograd or the Website support service;

5.1.7 for providing users with personalized suggestions and recommendations;

5.1.8 for Website maintenance, conflict resolution;

5.1.9 for sending service, advertising and other information related to the use of the Website.

5.2 POV 9 d.o.o. Beograd tracks depersonalized statistics of visits and use by Website users as a whole, as well as separately of the Website and Applications for devices, these statistics are used by POV 9 d.o.o. Beograd to optimize the functioning of the Website and Apps for devices.

5.3 POV 9 d.o.o. Beograd may use the data to carry out informational and marketing newsletters related, among other things, to the functioning of the Website, marketing campaigns conducted, and the availability of content on the Website. Mails are sent to the email address specified by the User during registration/ authorization on the Website, and by push notifications on users' devices.

5.4 POV 9 d.o.o. Beograd has the right to entrust data processing to a third party on the basis of an agreement concluded with this person, the User expresses his consent to the exercise of this right by POV 9 d.o.o. Beograd. In particular POV 9 d.o.o. Beograd transfers User data to third parties performing processing functions when the User pays for fee-based Website services, fiscal data operators, data analytics Websites, consulting companies that are part of the same group of companies with POV 9 d.o.o. Beograd (affiliated to POV 9 d.o.o. Beograd).

5.5 POV 9 d.o.o. Beograd does not verify the accuracy of the data provided or received from the User, cannot exercise control over the legal capacity of Users. POV 9 d.o.o. Beograd assumes that the User, in all cases, when using the Website, provides reliable data about themselves, including data about their location (location of the Device), and keeps the data up to date.

6. Data processing conditions and security

6.1 When processing User data, POV 9 d.o.o. Beograd acts by the requirements of the current legislation of the Serbia.

6.2 Data processing is carried out by POV 9 d.o.o. Beograd on legal grounds, only data that meets the purposes of their processing in accordance with this Policy is subject to processing.

6.3 Confidentiality requirements are strictly observed with respect to all Data received by POV 9 d.o.o. Beograd. POV 9 d.o.o. Beograd does not disclose data to third parties, except for the cases established by this Policy and the requirements of applicable legislation, and will not distribute, sell, alienate and/or otherwise dispose of the received data, except for the purposes provided for in this Policy and in accordance with it, and use the data in any way-or in a way that does not comply with the requirements of the legislation of Serbia, for illegal purposes.

6.4 Cross-border data transmission on the territory of foreign states can be carried out by POV 9 d.o.o. Beograd for the purposes of fulfilling the this Privacy Policy. The User is notified and agrees that during the cross-border transfer of their data, the recipients of such data may be located both in foreign states that provide adequate protection of the rights of personal data subjects, and in foreign states that do not provide adequate protection of the rights of personal data. At the same time POV 9 d.o.o. Beograd will take all appropriate actions to ensure the confidentiality and security of any data transmitted to the territory of any foreign states.

6.5 POV 9 d.o.o. Beograd guarantees that only those actions are performed with respect to the received data that are necessary or desirable to achieve the above goals, including: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), blocking, deletion, destruction of data. Data processing is carried out both with the use of automation tools and without the use of such tools.

6.6 Access to the received data is limited. Organizational, legal and technical measures have been taken to protect Personal data from unlawful, unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of Personal data, as well as from other unlawful actions with respect to Personal data in accordance with the established requirements of legislation and authorized authorities.

6.7 POV 9 d.o.o. Beograd does not intentionally collect and process Data/Personal data of children/persons under the age of 18. In this connection POV 9 d.o.o. Beograd draws the attention of those under the age of 18 and urges them not to provide their data by registering and/or authorizing on the Website, as well as not to use other functionality of the Website providing for the provision of data. In any case responsibility for violations of the terms of this clause of the Policy by an individual under the age of 18 is assigned to their parents, adoptive parents, guardians, trustees or other legal representatives in accordance with the current legislation of Serbia.

6.8 By accepting the terms of this Policy, the User agrees to receiving emails and push notifications using Apps for devices, including advertising (marketing) and informational messages of any kind and content from POV 9 d.o.o. Beograd to the email address specified during registration and/or authorization (including authorization via social media).

7. User rights in data processing

7.1 The User has the right to receive information concerning the processing of their personal. This right must be exercised by the User by sending a corresponding request to the address of POV 9 d.o.o. Beograd in the ways provided for by this Policy. At the same time taking into account the peculiarities of processing the received User data by the Website, which in most cases do not allow unambiguously identifying a specific individual based on the received data, POV 9 d.o.o. Beograd reserves the right to request from the User proof of confirmation of his identity before providing the requested information.

7.2 The User has the right to demand clarification or destruction of his personal data if the personal data are incomplete, outdated, unreliable, illegally obtained or are not necessary for the stated purpose of processing. This right must be exercised by the User by sending a corresponding request to the address of POV 9 d.o.o. Beograd in the ways provided for by this Policy.

7.3 The User has the right at any time to send a request to POV 9 d.o.o. Beograd to refuse to receive advertising and/or marketing information and other information to the email address of the Support service, except for receiving push notifications and/or emails informing the User about the use of the Website, including cases of restoring access / password to the Account or other cases necessary to provide the User with access to the Website.

7.4 The User has the right at any time to revoke the consent to the processing of their Personal data provided by POV 9 d.o.o. Beograd by sending a written notification to the address of POV 9 d.o.o. Beograd: : Ljutice Bogdana 34, Belgrade 11 000, Republic of Serbia, marked "withdrawal of consent to the processing of personal data". The User's personal data will be deleted by POV 9 d.o.o. Beograd within 30 (thirty) calendar days from the date of receipt of this notification. Revocation of consent to the processing of personal data entails the deletion of the User's account from the Website, which may make it impossible to use the Website and access the Content. At the same time taking into account the peculiarities of processing the received User data by the Website, which in most cases do not allow unambiguously identifying a specific individual based on the received data, POV 9 d.o.o. Beograd reserves the right to request from the User proof of confirmation of his identity before providing the requested information. The User’s right provided for in this paragraph may be restricted in accordance with the requirements of current legislation. For example, such restrictions may provide for the obligation of POV 9 d.o.o. Beograd to save the User’s data requested for deletion for a period established by the current legislation.

8. Data Storage

8.1 All Data transmitted to POV 9 d.o.o. Beograd by users are stored with the requirements of the current legislation of the Serbia.

8.2 By transferring the data to POV 9 d.o.o. Beograd, the User agrees that POV 9 d.o.o. Beograd will store the Data for the entire period necessary to implement the purposes of collecting and processing Data by POV 9 d.o.o. Beograd in accordance with this Policy, or for a period established in accordance with the requirements of applicable legislation, for compliance with the requirements of applicable legislation, requests from competent state bodies, court decisions in force.

8.3 In case of achievement of the purposes of personal data processing, POV 9 d.o.o. Beograd undertakes to terminate the processing of personal data and destroy or depersonalize personal data within a period not exceeding 30 (thirty) calendar days from the date of achievement of the purpose of personal data processing or receipt of revocation of the user consent to the processing of personal data, unless otherwise provided by this Policy or the requirements of the applicable legislation.

8.4 The confidentiality regime with respect to Data is lifted in case of their depersonalization, as well as in other cases provided for by the legislation of Serbia.

9. Final provisions

9.1 All the Website users have access to this Policy. This Policy is available for review both on the Website.

9.2 Issues not regulated by the Policy are subject to resolution in accordance with the legislation of Serbia.

9.3 This Policy is written in English. Should there be any inconsistencies between the version of the Policy in English and the version of the Policy translated into another language, the provisions of the Policy in English will have priority and direct application.

9.4 In case of any questions, notifications, requests, suggestions regarding this Policy, as well as for the purpose of exercising their rights (unless the procedure for their implementation is set out separately in this Policy) the user can refer to POV 9 d.o.o. Beograd by sending the corresponding letter to the postal address: Ljutice Bogdana 34, Belgrade 11 000, Republic of Serbia.

9.5 If the User submits a claim, the User is obliged to provide documents that confirm the grounds for the claim, substantiation of the claim and contact details for communication.