Last updated 7/24/2019
Bulevar Oslobođenja 54
Personal data – any information relating to an identified or identifiable natural person (‘data subject’). Basically, any data that can identify or point in the direction of a living person.
Usage Data – is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Controller – can be the natural or legal person, public authority, agency or another body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Infostarters is a controller when handling data provided by our newsletter subscribers; data needed to communicate with our clients, and usage data meant to help us optimize the Website for our users.
Processor – can be a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller. Infostarters is a processor, for instance, when analyzing User/Client Data to provide our clients with the services they requested.
Processing – is any operation or set of operations which are performed on personal data or on sets of personal data, whether by automated means or manually.
Authorised Users – employees, agents, consultants or independent contractors of the client who are authorized by the client to use the Services and the documentation
The following section will define what kind of data we are likely to collect. We will also explain what we use that data for, and what is our legal basis for doing so.
Usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
Account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
Infostarters may process information contained in any inquiry you submit to us regarding our services (“inquiry data”). The inquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
We may process information contained in or relating to any communication that you send to us. Correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
Infostarters may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters. Notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website. Transaction data may include first and last names, your email address, billing contact information and credit card number. Transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests.
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
Personal data we handle in the roles of controller and processor is protected and monitored. Actions taken with the data are logged, as are the user accounts taking those actions. In case of data breaches, objections, data erasure requests, lawful basis disputes, etc. we need to be able to provide an accurate and consistent record of data interactions.
Before we collect any kind of personal data, send data collecting cookies your way, or make major changes in the way we handle your data, we will ask for your permission. This will be reflected in the design of our website, including different forms and text input fields, as well as sections triggering automatic data retrieval and storage (“privacy by design”).
You will, in plain terms, be informed about what we exactly need from you, why we need it, and what the risks and benefits of allowing us to collect your data are. Site’s architecture will ensure that you can never give out your data inadvertently, without being fully aware of what you are consenting to and without being able to review and remove your consent.
Your information collected through Infostarters Services may be stored and processed in the United States, Europe, or any other country in which Infostarters or its subsidiaries, affiliates or service providers maintain facilities. Infostarters may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Economic Area (EEA) or other regions with laws governing data collection and use, please note that we will generally not transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.
If such transfers to countries without an adequacy decision by the European Commission turned out to be necessary, Infostarters puts appropriate safeguards through contractual obligations.
We may disclose your personal data to the following persons:
Disclosure of information within Infostarters: We limit access to your personal data to employees who reasonably need to process such information as described under this policy. In this situation we:
Disclosure of information to particular third parties: We may disclose your personal data to the following third parties:
Disclosure of information in certain circumstances: We may also disclose your personal data:
Beyond this, we will not share your personal data with any other person without your consent.
You are legally responsible for all information, data, text, software or other materials uploaded, posted, stored and/or shared online in connection with your use of the Services (“Content”). The company is not responsible for your Content; you are solely responsible for any Content that may be lost or unrecoverable through your use of the Services. You are encouraged to backup your Content regularly and frequently.
You hereby grant Infostarters a limited license to use the Content you upload or otherwise make available to the Service for the purpose of enabling your use of the Service, and for the purpose of enabling the Service to provide you with its Product. By posting, uploading, displaying, transmitting, or otherwise distributing Content to the Site or Service, you are granting Company, its affiliates, officers, directors, employees, agents and representatives a worldwide, perpetual, royalty-free, non-exclusive license to host and use the Content in connection with the Service, including without limitation the right to copy, distribute, transmit, publicly display, publicly perform, reproduce, edit, and reformat your Content. You will not be compensated for the Company’s use of your Content. By uploading Content to the Site or Service you warrant and represent that, in accordance with Section 13.4., you own the rights to the Content or are otherwise authorized to post, display, perform, transmit, or otherwise distribute your Content.
Personal data that we process for any purpose shall be kept until such time as we receive a request for deletion from you.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree. Cookies contain information that is transferred to your device’s hard drive.
We use the following cookies:
Strictly necessary cookies. These are cookies required for the operation of our platform. They include, for example, session cookies which enable you to log into secure areas of our platform, or simply to browse our site as intended.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our platform when they are using it. This helps us to improve the way our platform works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our platform. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our platform.
Except for essential cookies, all cookies will expire after 1 year.
While some of the functionality cookies can be used without your expressed consent, like security and load-balancing cookies; there are those that we cannot send your way before first getting your consent. In our case, this includes Hotjar cookies, which you can choose to opt out of, if you wish, and still be able to use our platform.
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers for:
1) Monitoring and analyzing the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
Hotjar is used to track and record user behavior on our Website, and is meant to help us improve our service. You can view their GDPR compliance page here: https://www.hotjar.com/legal/compliance/gdpr-commitment
LinkedIn Insights Tag
2) Payments processing
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing - wire transfer and PayPal.
In order to ensure the correct use of information, we have put in place physical, electronic, and managerial procedures to safeguard and secure the information we collect in association with the Service. Please be aware, however, that no data transmission over the Internet or other networks can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security or integrity of any information you transmit to us or that you authorize us to collect on your behalf. You transmit information to us and authorize us to collect information on your behalf, at your own risk. Once we receive your information, we make reasonable efforts to protect it from unauthorized access, disclosure, alteration, or destruction. If you have any questions about security on our Site, you can contact us at firstname.lastname@example.org .
Despite us doing everything in our power to ensure the safety of your personal data, intrusions are always possible. In order to maximize the privacy of your data, and to minimize the impact of possible breaches, we are required to:
If we are the data controller, when Infostarters learns of a security systems breach, we will attempt to notify the data subject electronically within 72 hours so they can take appropriate protective steps. If we are the data processor, we will attempt to inform the controller of the breach, without undue delay. Infostarters may post a notice through the Service if a security breach occurs. If this happens, you will need a web browser enabling you to access the Service. Infostarters may also notify you via email in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
As a data subject, ie. someone whose personal data we are using, you have the following rights (some of which are relevant to us only when we are in the position of data controller):
Right to be informed
Refers to your right to be informed if we start collecting your data, why we are collecting it and where the data is coming from, in a timely and clear fashion. As consent or contract is the most common basis for our data collection, in most cases, where required, we will ask for your consent before starting to keep any kind of track of your data. Depending on the data we need and the type of our relationship with the data subject in question, we will ask for their consent through a site pop-up, an email, or another appropriate method.
Right of access
Should you send a request to access your data, held by us, we have one month to comply. You can make the request verbally, or in writing, and are to be granted access to your data without having to pay us a fee. You can make the request at email@example.com.
Right to rectification
If you feel that some of your personal data that we are storing is incorrect, you can make a verbal or written request to have us make the necessary corrections. We maintain a procedure in order to help you confirm that your Personal Information remains correct and up-to-date. We have one month to respond, but can also contest that the data is accurate and that there is no need for correction, should we determine there is grounds for such refusal to comply.
Right to erasure – right to be forgotten
If you want your data removed from our database, you have the right to demand it be erased. If your written or verbal request is valid, we will have one month to comply with it. You can ask for data to be erased if we obtained it on the grounds of your consent and you are no longer willing to provide it; if we no longer need it for whatever it was originally needed for, and in a number of other cases.
Infostarters will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods. You can make the request at firstname.lastname@example.org.
Right to restrict processing
Where personal information is subjected to restriction in this way we will only process it with your consent or for the establishment, exercise, or defense of legal claims. This right includes restricting the processing of your personal information to only include storage of your personal information (e.g. during the time when Infostarters assesses whether you are entitled to have personal information erased). You can make the request at email@example.com.
Right to data portability
If we are using your personal data, you have the right to expect us to be prepared to safely and promptly send that data to you, or, if technically feasible, to a third party of your choice, in a machine-readable format. This right only applies to us when we are in the position of a data controller. You can make the request at firstname.lastname@example.org.
Right to object
Where we are relying on legitimate interest to process personal information, you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or where we need to process the personal information for the establishment, exercise, or defense of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis. You can notify us of your objection at email@example.com.
Right not to be subject to automated decision-making
Mostly related to profiling and automated marketing campaigns. Data subjects have the right to demand to be exempt from such practices, while we are obliged to give them means of easily communicating their desire to be excluded.
Right to withdraw consent
Where you have provided us with your consent to process personal information, you have the right to withdraw such consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
You can do this by:
Infostarters site contains links to other websites. We are not responsible for the privacy practices or the content of such websites. We also make our blog and our social media accounts available to you. Please understand that any information that is disclosed and/or shared on these platforms becomes public information. We have no control over its use and you should exercise caution when deciding to disclose your Personal Information and any other information you consider private.
Our services are only available to persons over 16 years of age, so we are never in the position of the controller of personal data of a child.
If you believe we might have any information from or about a child under 16 years old, please contact us at firstname.lastname@example.org.
Infostarters reserves the right to make any and all necessary changes to this Policy at any time and for any reason. We will notify you of any changes and/or modifications to the Policy by updating the “Last Modified” date on this Policy, or when required, directly by asking for your consent. You are encouraged to periodically review this Policy to stay informed of updates. You shall be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Policy by your continued use of Infostarters services after the date such revised Policy is posted, except in cases where your explicit consent is required.
Infostarters hereby disclaims all warranties. The company is making the site available “as is” without warranty of any kind. You assume the risk of any and all damage or loss from the use of or inability to use, the site or the service. To the maximum extent permitted by law, the company expressly disclaims any and all warranties, express or implied, regarding the site, including, but not limited to, any implied warranties of merchantability, fitness for a particular purpose, or non infringement. The company does not warrant that the site or the service will meet your requirements or that the operation of the site or the service will be uninterrupted, timely, virus or error-free, or that data displayed by the services will be accurate or reliable.
Likewise, Infostarters’ liability to you is limited. To the maximum extent permitted by law, in no event shall the company, its affiliates or suppliers be liable for damages of any kind (including, but not limited to, special, incidental, or consequential damages, lost or compromised data, lost profits or revenue due to service interruption or computer failure, regardless of the foreseeability of those damages) arising out of or in connection with your use of the site or services of company. You hereby agree that company’s liability to you will not exceed any fees paid by you to the company for the service. This limitation shall apply regardless of whether the damages arise out of breach of contract or any other legal theory or form of action.
By using Infostarters and signing up as a Client, you agree to be legally bound by these Terms of Service, including those terms incorporated by reference. Please read the following carefully. If you do not accept these Terms of Service, you may not use our services. Infostarters may revise these terms at any time.
The Client will have the right to see the watermarked design for approval presented on our platform.
After the Client accepts the final design, payment is conducted before the delivery of the final project.
Once the payment is made, ownership (copyright and title) of the final artwork becomes the property of the Client. Normally, we reserve the right to use the final product or design elements from its development in our Portfolio and other pages on our website, but we would be ready to waive this right should you explicitly demand it. Regardless of our agreement regarding the final product, we retain the copyright to all concepts, comprehensives, or other preliminary materials which are not selected by the Client or are not included in the final delivery.
Infostarters reserves the right to terminate the service if the Client is unresponsive, uncooperative, or fails to comply with the stipulated Terms of Service in any way we find detrimental to the successful completion of the project.
Should you require any additional information, or wish to find out how any of our terms would apply to your particular case, feel free to contact us.