Personal data processing

GENERAL CONDITIONS FOR DATA PROCESSING OF OMNES GROUP

The protection of personal data integrity is our top priority. We want to ensure that you are aware of which personal data we collect and why, how we use the data, and what your choices and options are.

In order to provide you with application or service experience, which corresponds to your needs, it is necessary for Omnes Group to process your personal information. Your personal information helps us to understand your needs and provide you with the best support and advice. At the same time, we need your information in order to improve the quality of our services and supports, or to comply with any obligations arising from law or legal action.

In order to provide our customers with excellent experience and give an overview of everything Omnes Group offers, it is required to also share your personal data with data processors:

The principles for using data apply to Omnes Group and any person who uses the services or supports or e-environments of Omnes Group.

The conditions for data processing are valid on all websites of Omnes Group, including: omnesgroup.com and omnes.rs

On websites (for example, omnes.rs), due to their features, there may be special conditions in privacy policy or in the conditions for processing cookies, the compliance of which with the data processing policy is ensured by Omnes Group.

The following does not apply to the storage of data of legal persons and the processing of personal data on foreign websites referred to on the websites of Omnes Group, for the management of which Omnes Group is not liable.

If you have any questions, concerns or complaints with regard to personal data, please feel free to contact us by sending an email to office@omnesgroup.com.

1. Your information is securely stored in Omnes Group
   1. Omnes Group is committed to protecting your personal data. We consistently take appropriate technical and organisational measures to protect data against unauthorised access and to keep personal data secure. These measures include the protection of employees, information, IT infrastructure, the company’s internal and public networks, as well as office buildings and technical equipment.
   2. The employees of Omnes Group are subject to the rules on the confidentiality and protection of data. Data processors authorised by Omnes Group are obligated to ensure the compliance with the same rules with regard to their employees.
   3. However, you also need to use services, products, and online environment in a secure and careful manner, and ensure that the devices you use for them are secured. You are obligated to keep secret from others any paroles, passwords, user IDs or other identifiers required for your identification related to your device and the online environments of Omnes Group.
   4. You need to be aware and take into account the fact that Omnes Group cannot ensure the security of data and is not responsible if the data is not protected due to your activities. In this case, you are solely responsible for any possible consequences.
2. What kind of personal data do we collect?
   1. Personal data includes any information that can be linked to a person. The categories of data that Omnes Group mainly, but not exclusively, collects and processes are the following:
      1. Personal identification data, for example, name, personal identification code, date of birth, information about the identity document (for example, a copy of passport or ID card).
      2. Contact details, for example, address, telephone number, email address, communication language.
      3. Social media profile.
      4. Information about your relations with legal persons, for example, information submitted by you or obtained through public registers or third parties, for the purpose of making transactions on behalf of the corresponding legal person.
      5. Professional details, for example, your data about education or your professional career or professional correspondence.
      6. Data about reliability and due diligence, for example, information about payment behaviour or about any damage caused to Omnes Group or a third party.
      7. Data obtained and/or generated during the performance of the obligation arising from the law, for example, any information arising from the inquiries made by investigating authorities, notaries, tax authority, courts, and bailiffs.
      8. Data about your tax residency, for example, information about the country of residence, taxpayer identification number, citizenship.
      9. Communication data, for example, visual and/or audio recordings, which are collected when you visit any occasions, events, business trips or fairs organised by Omnes Group, or if you communicate with Omnes Group through email, messages and other communication mechanisms, for example, social media, or if you participate in feedback or satisfaction surveys or studies.
      10. Upon using the information systems of IP-address, for purposes of ensuring the security of information system and compliance with the terms of use of the service.
      11. Information related to services, for example, compliance or non-compliance with any contracts, performed transactions, submitted applications, inquiries, and complaints.
      12. Information about participation in games and campaigns, for example, prizes won in games and campaigns.
3. Why and when do we collect your personal data?
   1. The collection of data depends on the used service and specific information required to use such service. The reasons why we collect personal data may include (but not limited to) the following:
      1. Upon subscribing to a newsletter, your email address, name, and a list of newsletters you have subscribed to. All this to send you precisely the newsletters you are interested in. Omnes Group sends newsletters with your consent. An overview of newsletters and information about subscription options can be found here.
      2. On social media, your profile, provided that you have liked the Facebook page of Omnes Group. All this to provide you with news about the activities of Omnes Group through your newsfeed. Omnes Group also processes your social media profile if you use the social media profiles to create an account on omnesgroup.com
      3. In the recruitment process, your CV with the information included therein, other documents required in job advertisements, referees, data contained in the commercial register, and an extract from the criminal records database. All this to ensure that Omnes Group would employ an honest, impartial, as well as the best candidate. More information about the recruitment process is available in the privacy policy of Omnes Group (reference to the subpage here).
      4. If you contact us, including sending us an email (for example, media inquiry, request for information, request for explanation) or call us, requiring us to respond to you. We may publish summaries about inquiries by telephone in non-personalised form. Omnes Group does not record any telephone calls.
      5. Data, which we receive from third parties, such as public registers (for example, land register, tax board or commercial register), if this is required for the performance of contract or ensuring the performance of contract, such processing of data has been prescribed by law or your consent serves as the basis for data processing.
      6. Your visit details on the website of Omnes Group in order to provide you with the best user experience. Read more about the use of cookies here.
      7. In the process of applying for a vacancy, any information as provided for in legislation related to the corresponding support measure. Depending on the vacancy, these may include the CVs of the project team members of the applicants, agreements related to employment contract, etc. Processing of personal data as part of processing the applications takes place within the framework of carrying out a public law function and does not require your consent. Any information that is not provided for in legislation related to the support measure is requested from you based on your consent. Omnes Group uses the received personal data for better, more transparent, and faster processing of vacancies, as well as for better development of future support measures for statistical purposes and in non-personalised form.
      8. In a situation, where sharing is required by legislation or a legal act.
      9. In public procurements, to the extent that is required for carrying out the public procurement and awarding a public contract (including the registration of attendance at briefing days and the making of audio recordings). Depending on the procurement procedure, it may require the submission of the CVs of the team members of tenderers. In procurement procedure, the processing of personal data takes place for purpose of preparing the procurement contract and does not require your consent. If it is necessary due to the nature of the service, Omnes Group enters into a data processing contract with a successful tenderer within the meaning of Article 28 of the General Data Protection Regulation to ensure that the processing of your personal data would be secure. Information about the public procurements carried out by Omnes Group can be found here.
      10. In other contracts, in any parts where it is required to enter into and perform a contract. More information about the information used upon performing a contract is available in clause 4.
      11. Your email address to send you feedback or satisfaction surveys or invitations to a press trip, a business trip or a foreign visit or other event, and a notification thereof, provided that you have permitted to send these or if the sending of such is provided by law. We may process the data of the survey participants only for statistics in non-personalised form. Omnes Group may also use data collected as part of questionnaires and market surveys to improve the quality of its products, services or e-environments.
      12. In campaign games taking place on the websites of Omnes Group to announce the winner.
      13. Upon providing services, where it is necessary to map your needs, provide you with better service, create personal user experience, and develop our websites while creating better user experience. For example, we may process your personal data if you visit our websites, register as a visitor of an event, etc. on out websites, place orders, respond to a feedback survey, or if we make an offer to you with regard to our other services on our websites. Upon providing services, we process your personal data with your prior consent. Information about the services provided by Omnes Group can be found here .
      14. In marketing activities, which may accompany the marketing of briefing days, events, participation in fairs, visits, foreign visits, trade missions, and other activities of Omnes Group (hereinafter collectively as the “events”), where we register your attendance on a registration sheet or photograph or film you at some of the above-mentioned events. We record the events with the goal of informing you and our other customers about our activities through a newsletter or social media.
      15. Upon registering for the events organised by Omnes Group, published in the section of events at omnes.fourity.com
      16. Upon protecting the legitimate interest of Omnes Group to prevent, restrict, and investigate the misuse of the services and products of Omnes Group, to ensure their security, to detect unlawful use or any disturbances in their functioning, or to carry out internal training or to ensure the quality of these services and products.
      17. To prove, perform, divest, and protect legal requirements, which are based on the following: upon performing a contract or implementing the pre-contractual measures at your request or performing legal obligations or the legitimate interest of Omnes Group to perform legal requirements.
      18. To comply with obligations to perform international transactions through credit institutions, based on the following: upon performing a contract or implementing the pre-contractual measures at your request or performing legal obligations.
      19. Upon preserving the assets of Omnes Group if an employee leaves, and such preservation includes the employee’s email address, which is the property of the employer, and using it to solve work-related issues, if necessary. When an employee leaves Omnes Group, the latter closes the email address in way that it is impossible to send letters from there.
      20. Upon registering as a user of the information systems created by Omnes Group and using them (for example, the online environment of “My Account” for which the conditions of use can be found here)
   2. The register about the processing of personal data can be found here.
   3. To maintain and preserve customer relations, Omnes Group is using CRM business software.
   4. Omnes Group processes your data as little as possible. Your personal data will not be kept longer than necessary for processing. In any registers or on the websites (for example, the Public Procurement Register), the management of which is not the responsibility of Omnes Group, the latter is not responsible for the deadlines for the storage of personal data. The information about retention periods can be found here.
   5. Omnes Group does not sell, trade or lease your personal data to third persons.
   6. From the information we collect, we may prepare summaries in non-personalised way and share them with our partners.
   7. Omnes Group may combine data collected in various ways if such information has been collected for the same purpose.
4. Use of data to perform the contract and ensure the performance of the contract
   1. Omnes Group may use data based on legislation without your separate consent to perform the contract or to ensure the performance of contract at least in the following cases (including transferring data to data processors):
      1. To identify you or your representative;
      2. To provide you with services or to carry our any activities required for the sales of goods;
      3. To provide you with services and to eliminate any failures;
      4. To provide and develop the online environment, its services and functionalities, as well as high-quality personal user experience to you, and to send you information related to options for use and security of the online environment.;
      5. To calculate service fees related to the contract, to prepare notifications and invoices, and to send them to you;
      6. To send you notifications by post or email, and this does not assume the data to be used for marketing purposes;
      7. To document business and service activities and for business information exchange (including to be submitted to auditors upon auditing Omnes Group);
      8. To provide you with better service, including to measure the quality, performance or customer satisfaction of the online environment and the services, as well as to develop the services and business activities;
      9. To evaluate and prevent potential business risks or losses related to the provision of the service;
      10. To ensure the performance of contract;
      11. To protect any rights of Omnes Group, which have been violated or disputed, and to collect any debts (including to forward information related to contractual violation and/or debts by Omnes Group based on the contract to the persons providing collection service, lawyers, and other persons, who are authorised to process the corresponding data).
      12. To forward your credit status report to the credit information companies authorised by Omnes Group in case of breach of the contract
5. Disclosure and/or transfer of your data to third persons and the geographical region of processing
   1. Based on law and/or contracts, Omnes Group transfers and discloses your data:
      1. to data processors upon complying with any contractual obligations;
      2. to database administrators;
      3. to a new creditor upon assigning the right of claim;
      4. to law enforcement agencies and courts;
      5. to state authorities and institutions (for example, bailiff, notaries, supervisory agency);
      6. to auditors, legal and financial advisers;
      7. to debt collectors upon assigning the claims, to liquidators, rehabilitators, and trustees in bankruptcy;
      8. to persons who are related to national, European, and international payment systems;
      9. to third persons who protect the rights of Omnes Group if you have violated the contract;
      10. to data processors to process your data as part of direct marketing if you have given the corresponding consent.
   2. Upon making transactions in a foreign country or with foreign persons, customer data may also become available to the authorities of the corresponding country and data may be processed in accordance with the law of the corresponding country.
   3. In general, your data is processed within the European Union / European Economic Area (EU/EEA), however, in some cases, these are transferred to and processed in countries outside the EU/EEA.
   4. Transfer and processing of your data outside of the EU/EEA may take place, provided that there is a legal basis, for example, performance of a legal duty or your consent, and the relevant protection measures are applied. For example, the relevant protection measures are the following:
      1. there is a valid contract, which includes the standard contractual terms and conditions developed by the EU or approved code of conduct, certification, and the like, which complies with the General Data Protection Regulation (GDPR).
      2. in a country outside the EU/EEA, where the recipient is located, it is sufficient level of data protection according to the decision of the European Commission;
      3. the recipient has been certified based on the Privacy Shield Framework (applicable to recipients located in the United States of America).
   5. In case of an inquiry, you will receive more detailed information about the transfer of your data to the countries located outside the EU/EEA.
6. In case of a breach or change in the principles of the processing of personal data, and forwarding such information.
   1. If there is a breach related personal data that happens in Omnes Group and it poses a potential threat to your rights and freedoms, we will prepare the corresponding documents required in legislation. We will definitely take measures to immediately end the violation.
   2. If a violation results in a situation where you are likely to be at high risk with regard to your rights and freedoms, we will also inform you about it. The purpose of the notification is to enable you to take the necessary precautionary measures to mitigate the situation.
   3. If the use of your personal data is subject to change or any applicable legislation and rules (including the rules of Omnes Group for data processing) are updated, you can read about it from a document in the subheading “Personal data processing”
   4. Any changes to your data processing principles are communicated by Omnes Group through messages via email or the Facebook page of Omnes Group or the main pages of the websites of Omnes Group.
   5. If you have any questions, concerns or complaints with regard to personal data, please feel free to contact us by sending an email to office@omnesgroup.com.
   6. You can read more about your rights through the privacy policy of Omnes Group.